University of Florida Water Reclamaion Facility - Executive Summary |
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Executive Summary General Policy The purpose of this document is to inform interested persons, including the public, that the University of Florida Water Reclamation Facility (UF WRF) is complying with the Environmental Protection Agency (EPA) Accidental Release Prevention Requirements and Risk Management Programs under the Clean Air Act Section 112(r)(7). This regulation is published in Title 40 of the Code of Federal Regulations (CFR) Part 68. We have one regulated substance, chlorine, that is above the threshold quantity as specified in Section 68.130 of 40 CFR Part 68, and therefore we must comply with the RMP program. This program provides our facility with an integrated approach to identifying and managing the hazards posed by chlorine. Under this program, our facility has assessed and continues to assess hazards to determine how accidental releases can impact the public health and environment. Like the majority of municipal wastewater treatment plants in the United States , gaseous chlorine is used at the UF WRF facility to destroy pathogenic organisms in the treated wastewater before its reuse. The same properties that make chlorine valuable as a disinfectant also make it necessary to observe certain safety precautions in handling chlorine as a safeguard to our workers, our community and the environment. The UF Physical Plant Division's commitment at the UF WRF facility is to store, handle and use chlorine in a manner that achieves the needed benefits of disinfection while minimizing both onsite and offsite risks. This is accomplished by designing a safe process, maintaining the process in optimum working condition, operating safely through documented procedures, and ensuring that operators are properly trained in the procedures. The UF WRF also has detectors and emergency scrubber to inactivate chlorine and prevent a release from the storage building. Our commitment to safety is demonstrated in the fact that over the UF WRF's operating history, no chlorine accidents have occurred that resulted in employee injury or offsite consequences. As part of our risk management program, our facility has completed a registration, which includes the regulated substance for the covered process at our facility. The registration has been submitted to the proper authorities and is attached to this written plan. The University has also registered the process with the Department of Community Affairs, the lead agency for RMP Program 3 enforcement in Florida. Management System The management system at our facility oversees the implementation of the RMP elements in order to manage the risk of a chemical release at our facility. We have assigned the Plant Manager as the person with the overall responsibility for the development, implementation, and integration of the RMP elements. The Plant Manager requires adherence to the risk prevention program and addresses the organizational, human and resource needs of the program. The Plant M anager also arranges for periodic compliance audits, updates to process hazard analyses, and updates to process safety information to keep the program current. The Plant Manager delegates the day-to-day responsibility of the various program components according to job type. For example, the management of change program is primarily the responsibility of maintenance employees who might change out process equipment, while plant operators are responsible for ensuring that the process operating procedures and training are revised to reflect such change in equipment. Hazard Assessment Our written hazard assessment program evaluates the impact of significant accidental releases on the public health and environment and develops a history of such releases. Our hazard assessment includes: Offsite Consequence Parameters. The off-site consequence parameters are those factors that define the offsite significance of the worst-case and alternative scenarios. For toxic substances, the most significant parameters are the endpoint specified in the regulation for each toxic substance, the release rate for each scenario, and the meteorological data that determines the distance that a release will travel before it reaches the designated endpoint. For chlorine, the endpoint is defined as a concentration of 0.0087 milligrams per liter, which has been determined by a national consensus health group as a concentration below which serious adverse effects are not expected. The release rate for the worst-case scenario is specified by rule as a chlorine cylinder being released over a 10-minute period, while the release rate in the alternative (more realistic) scenario is based on the release from a lead washer leak over a 30-minute period. The EPA default meteorological conditions were used for the worst-case and alternative scenarios to arrive at a distance to endpoint, which is the radius of the circle of impact used to identify potential human and environmental recepto rs. Worst-Case Release Scenario. The following summarizes the worst-case scenarios of a substance release at our facility: - Release of 2,000 pounds of chlorine (entire cylinder) over a I0-min period. - Release occurs to open air. - The wind speed is 1.5 meters per second, and the atmospheric stability class if "F", which is very stable and therefore able to carry a gas release the greatest distance. - The distance to the chlorine endpoint of 0.0087 mg/L is estimated by RMP*Comp to be 0.9 miles from the release. Alternative Release Scenario. The following summarizes the alternative release scenarios of a substance release at our facility: - Release of chlorine gas around a lead washer used to seat the yoke to the cylinder. - Gas detection and alarm, and Gainesville Fire Department response leading to the leak being fixed, is conservatively estimated to occur within 30 minutes from the time the release occurs. - The wind speed is 3.0 meters per second, and the atmospheric stability class is "D" which is moderately stable atmosphere that provides some chlorine gas dispersion. - The distance to the chlorine endpoint of 0.0087 mg/L is estimated by RMP*Comp to be less than 0. I mile from the release. Analysis Review and Updates. The consequence analysis will be updated whenever there is a change in the chlorine process, or changes in chemical quantities handled or stored. The analysis will be updated as necessary to reflect any new insight gained from periodic compliance audits (every 3 years) and updates to the process hazard analysis (every 5 years). Off-site Consequence analysis Documentation. The documentation for the UF WRF hazard assessment is contained in the report entitled Hazard Assessment For The University of Florida Reclamation Facility kept on file with the Plant Manager, the Physical Plant Division/Operation Engineering and the Environmental Health and Safety Division . Five-year Accident History. There have been no serious accidents involving chlorine at UF WRF in the 5 years prior to this RMP Plan. Prevention Program Our Program 3 prevention program ensures that the elements of the risk management program are integrated and implemented on an ongoing basis, and that there is accountability and responsibility for the overall program and for each element of the program. The following paragraphs provide a brief summary of each element and its function in the overall risk prevention program at University of Florida WRF: Process Safety Information. Prior to conducting any process hazard analyses, our facility compiles written process safety information regarding process chemicals, process technology, and process equipment. The purpose of compiling this written material is to enable our Facility and the employees involved in the operating processes at our facility, to identify and understand the potential hazards of processes that involve highly hazardous chemicals. Process Hazard Analysis. Our facility has developed a thorough, orderly, and systematic approach for identifying, evaluating, and controlling processes that involve highly hazardous chemicals. A team with expertise and knowledge specific to the process being evaluated performs the analysis. In addition, at least one team member is knowledgeable of the specific process, hazard analysis methodology being used. We have performed an initial process hazard analysis (hazard evaluation) at our facility; the analysis is appropriate to the complexity of the process. Operating Procedures. The standard operating procedures at our facility provide clear instructions for properly conducting all activities associated with a covered process. We have developed and implemented written operating procedures that provide clear instructions to safely conduct activities that are involved in each process. Each operating procedure addresses: Training. The employ ee's training program at our facility help our employees understand the nature and the causes of problems that may arise from process operations; our program helps prevent incidents arising from process operations. The intent of our training program is to increase employee awareness of process hazards that are associated with a particular process. We train each employee who is involved in operating a process, and each employee who will be involved in a newly assigned process, with an overview and the proper operating procedures of the process. Mechanical Integrity. At our facility, we ensure that all equipment used to process, store, or handle highly hazardous chemicals is designed, constructed, installed, and maintained in order to minimize the risk of chemical release. We have also established and implemented written procedures to maintain the on-going mechanical integrity of our process equipment. In addition, we ensure that the frequency of our mechanical inspe ctions is consistent with applicable manufacturer's recommendations and that each test and/or inspection is thoroughly documented. Pre-Startup Review. The pre-startup safety reviews conducted at our facility confirm that, prior to the introduction of highly hazardous chemicals into a process, all construction and equipment is in accordance with design specifications. We also ensure that the training of each employee involved in operating a process is complete, and that all safety, operating, maintenance, and emergency procedures are in place and are deemed to be adequate. Compliance Audits. Our compliance audits evaluate the effectiveness of our compliance with the risk management program, identify any deficiencies in the program, and ensure that corrective actions are implemented in a timely manner. We conduct our audits at least every 3years and retain the two most recent compliance audit reports. Our audits are conducted by at least one person who is knowledgeable of the process and we ensure that a report of any findings of the audit is developed and all deficiencies are corrected. Incident Investigation. Our incident investigation program is established to examine any incident that either resulted in, or could have resulted in, a catastrophic release of a highly hazardous chemical at our facility. Our investigation will be initiated within 48 hours following the incident, and all written reports will be retained for at least five years. The written report that is prepared at the conclusion of the investigation includes the following types of information: Employee Participation. In order to create an awareness of the aspects of the risk management plan, our facility involves our employees in the planning process. We have developed a written action plan, which explains how we involve our employees, as well as contractor employees, in the plan. We consult with our employees and their representatives on the conduct and developme nt of the elements of the risk management plan, and the overall content of the plan. We also provide our employees and their representatives access to process hazard analysis and other related information developed under the risk management plan. Emergency Response Program Our emergency planning and response program addresses the actions that our employees are to take in the event of an unwanted release of a highly hazardous chemical at our facility. We have established an emergency action plan, which provides procedures for planning and responding to a release of a highly hazardous chemical. UF WRF operators are provided with annual safety training that includes a review of the emergency response plan. The emergency response plan covers all aspects of emergency response, including escape procedures and routes, procedures for post-evacuation employee accounting, notification procedures, rescue and medical duties, and response procedures for spills or leaks. If an uncontrolled leak were to occur that is beyond the training and resources of the onsite response team, the Gainesville Fire/Rescue HAZMAT Response Team will be called in immediately for assistance. |