Pequannock WTP Pre-Treatment Building - Executive Summary |
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The Pequannock Water Treatment Plant is located on Route 23 in West Milford, New Jersey. The Pequannock Water Treatment Plant is owned by the City of Newark and operated by the Newark Watershed Conservation and Development Corporation (NWCDC). The chlorine system, used for disinfection, is the plant's only process that is subject to the EPA RMP Part 68 and NJAC 7:31 Toxic Catasprohe Prevention Act (TCPA) Regulations. The chlorine process is located at the Pre-Treatment Building which is separate from the Treatment Plant. Chlorine is stored in steel one-ton containers in the Chlorine Storage Room, within the Pre-Treatment Plant Building, which is of sound masonry construction. The City of Newark has maintained an "approved" Risk Management Plan Program under the New Jersey Toxic Catastrophe Prevention Act (TCPA) for the chlorine process since approximately 1988. The current City of Newark/NWCDC Program includes a complete chlorine safety program including extensive operator trainin g, emergency response training, standard operating procedures, and chlorine safety equipment. The chlorine process utilizes state-of-the-art design for all piping and equipment, including all necessary chlorine monitors, alarms and controls. Emergency response procedures include an on-site emergency response team, as well as off-site response from local emergency response agencies. Annual emergency response drills are conducted, which include on-site and off-site responders. The City of Newark/NWCDC written Risk Management Program includes all necessary Prevention Program elements, meeting the requirements of EPA and OSHA Process Safety Management. The Prevention Program includes elements such as safety information, standard operating procedures, operator training, preventive maintenance, hot works permits and other safety progams to ensure that the chlorine process meets the highest possible safety standards. There have been no reportable catastrophic or near catastrophic chlori ne accidents at the Pequanncok Water Treatment Plant to date. As required by the EPA Rule, the worst-case release scenario for the chlorine process is the release of the entire contents of a full one-ton container of chlorine (2000 lbs.) within 10 minutes. According to Exhibit 4-4 in the EPA RMP Guidance for Wastewater Treatment Plants, the downwind distance to the toxic endpoint (concentration of 3 ppm) for this scenario is 1.3 miles for the area surrounding the Pre-Treatment Building. The worst-case scenario is considered to be an unlikely release scenario. The alternative release scenario for the chlorine process was determined to be an indoor liquid chlorine release due to the rupture of a 1" diameter header pipe. The alternative release scenario represents a more realistic potential release event than the worst-case scenario. According to Exhibit 4-12 in the EPA RMP Guidance for Wastewater Treatment Plants, the downwind distance to the toxic endpoint (concentration of 3 ppm) for this scenario is 0.4 miles for the area surrounding the Pre-Treatment Building. The installation of remote operated valve acuators for the chlorine ton containers is currently being implemented by the City. The remote operated valve actuators will allow the chlorine container to be immediately closed from a remote location (i.e. the Treatment Plant, lobby of the Pre-Treatment Building) in the event of a significant chlorine release. New chlorine detectors are also being provided for the chlorine process as a risk reduction measure. |