64th Street Reservior - Executive Summary |
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Executive Summary The 64th Street Reservoir is one of the many facilities owned and operated by the City of Phoenix. 64th Street Reservoir has prepared a Risk Management Plan (RMP) in accordance with the EPA and OSHA regulatory requirements. A brief overview of the RMP and the associated policies at 64th Street Reservoir is described below. Prevention and Response Policies The City takes an active role in preventing accidental releases by ensuring that its employees are properly trained in the safe operation of covered processes and the safe handling of treatment chemicals. The City has also established and maintains procedures for emergency notification and response. These are reviewed with employees on a periodic basis and revised to accommodate changes in staffing when they occur. To increase employee safety and awareness, the City: 7 maintains up-to-date safety information and operating procedures, 7 performs regular preventative maintenance, 7 provides periodic ref resher training on safe handling of chemicals, and 7 conducts quarterly safety drills. Facility Description and Regulated Substances 64th Street Reservoir is an unmanned facility which stores potable water for delivery to the distribution system; it has facilities for maintaining chlorine residual at the appropriate levels. City employees regularly inspect the facility to ensure proper operation of the chlorine facilities. The regulated substance handled at 64th Street Reservoir is chlorine. The chlorine is stored in 1-ton containers, with a maximum of 2 containers (4,000 lbs) on site. Release Scenarios Worst-case and alternative release scenarios have been determined after careful review of the regulation and consideration of the storage vessel configuration at the facility. The EPA's software program RMP*Comp was used to model both release scenarios and determine the radius of impact. In the worst-case release scenario, the regulation clearly states the rel ease quantity shall be the contents of the single largest vessel of the covered process chemical. Therefore, the scenario assumed a complete release of chlorine from one 1-ton container (2,000 lbs). Per the regulation, no active mitigation measures, such as a scrubber, could be considered. In addition, no passive mitigation measures were considered, to provide the City with additional safety margin in protecting the public health. For the alternative release scenario, the assumptions were that (a) a failure occurred in the feed line, (b) 600 lbs of chlorine were released over a 30-minute period, (c) the release occurred in the chlorine storage building, and (d) the scrubber did not work. The passive mitigation effect of the chlorine storage building reduces the amount of chlorine released to the atmosphere by 55% (from 570 lbs to 310 lbs). Prevention Steps for Chlorine The prevention program fulfills the requirements of the OSHA Process Safety Management (PSM) rule and t he EPA RMP rule, and includes: 7 formal and on-the-job training, 7 written operating procedures, and 7 a process equipment preventive maintenance program. The primary means of mitigating an accidental chlorine release at 64th Street Reservoir is the installation of a chemical scrubber for the chlorine building. The scrubber is maintained on a regular basis to ensure proper operation if needed during a chlorine release. Accident History There has been no accidental release of the covered chemical in the past five years. Emergency Response Program This facility has established and maintains an emergency response program that is coordinated with local response agencies. The goals of the program are to protect responding employees from the hazardous effects of the releases and to minimize the effects of releases on the general public. The program is routinely reviewed and updated to reflect personnel and regulatory changes. Planned Changes for Improved Safety Id eas for changes to improve safety are actively sought from employees. Employee meetings that focus on safety issues are held regularly at the facility. Employees are encouraged and trained to recognize hazards and present ideas to eliminate them or to minimize the potential consequences of those hazards. During the development of this RMP document, a process hazard analysis of the chlorine system was conducted with key employees to fulfill the prevention program requirements. During these sessions, recommendations were made for the purpose of improving safety and preventing accidental chemical releases. Each recommendation will be or has been considered for implementation. Though not all recommendations may be implemented, the exercise provided all affected employees with a heightened awareness of safety issues related to the covered processes. |