City of Flagler Beach Water Treatment Plant - Executive Summary |
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EXECUTIVE SUMMARY 1. Accidental Release Prevention and Emergency Response Policies The City of Flagler Beach Lime Softening Water Treatment Plant (WTP) is required to provide disinfection to the finished water prior to discharge for public consumption. Chlorine gas is used to achieve the level of disinfection required under state and federal regulations. Chlorine is considered a toxic substance by the United States Environmental Protection Agency (USEPA) and because quantities above the 2,500 pound threshold limit are stored on-site, a Risk Management Program (RMP) is required. The same properties that make chlorine valuable as a disinfectant in drinking water also make it necessary to observe certain safety precautions in handling chlorine to prevent unnecessary human exposure, to reduce the threat to on-site personnel, and to reduce the threat to nearby members of the community. It is the policy of The City of Flagler Beach to adhere to all applicable federal and state rules a nd regulations. Safety depends on the manner in which chlorine is handled, the safety devices inherent in the design of the facilities, safe handling procedures of the operators, and the training of personnel. The City of Flagler Beach Lime Softening WTP's emergency response plan includes procedures for notification of the City of Flagler Beach Fire Department and through a mutual aid agreement throughout Flagler County, the Palm Coast Fire Department Hazmat Team. 2. The Stationary Source and Regulated Substances Handled The primary purpose of City of Flagler Beach Lime Softening WTP is to provide a clean, safe, palatable drinking water that meets all the Federal requirements of the Safe Drinking Water Act in addition to all applicable state and local regulations. The chlorine is received via truck from P.B.&S. Chemical. Access to the WTP is restricted to authorized facility employees, management personnel, and other authorized personnel. Chlorine is the only substance at this f acility regulated under 40 CFR Part 68, Chemical Accident Prevention Provisions. The maximum inventory of chlorine stored at this facility is 6,000 pounds. 3. The Worst-Case Release Scenario and the Alternative Release Scenario, Including Administrative Controls and Mitigation Measures to Limit the Distances for Each Reported Scenario. Worst-Case Scenario - Catastrophic failure of a 1-ton chlorine container due to corrosion, impact, or structural defects. It is assumed that all 2,000 pounds of the chlorine is released as vapor, which is heavier than air, in 10-minutes at a release rate of 200 pounds per minute. The distance to the endpoint of 0.0087 mg/L was determined to be 1.3 miles using to the EPA model RMP*Comp. The affected area would include two schools, the Flagler County Airport, and residential areas with a population of 145 persons. There would be no environmental receptors for this scenario. Alternative Release Scenario - Tubing failure, bad connection, or valve fa ilure resulting in the release of chlorine gas through the 5/16-inch diameter valve body opening. It is assumed that a 317 pound total release of chlorine gas occurs with a maximum average sustained release rate of 10.5 pounds per minute for a 60 minute duration. The distance to endpoint of 0.0087 mg/L was determined to be 0.1 miles using the EPA model RMP*Comp. There would be no public or environmental receptors for this scenario. Prior to acceptance of the 1-ton chlorine containers, each container is inspected for visual defects that may cause an accidental release. The chlorination system operates under vacuum pressure and is inspected daily. 4. The General Accidental Release Prevention Program and the Specific Prevention Steps. This facility complies with EPA's Accidental Release Prevention Rule and with all applicable state codes and regulations. This facility was designed and is operated in accordance with recommendations from the American Water Works Association and fed eral and state codes and regulations. 5. Five-Year Accident History There have not been any accidental releases of chlorine in the last five years. 6. The Emergency Response Program The City of Flagler Beach Lime Softening WTP's emergency response plan includes procedures for notification of the City of Flagler Beach Fire Department and through a mutual aid agreement throughout Flagler County, the Palm Coast Fire Department Hazmat Team. 7. Planned Changes to Improve Safety This facility uses lime softening along with chlorination to provide clean, palatable, and disinfected potable water. The changes that have occurred since the Process Hazards Analysis (PHA) meeting held on May 5, 1999 include the development of a standard operating procedure (SOP) for daily and emergency chlorine handling. In addition, all WTP personnel along with Flagler Beach Fire Department personnel received chlorine handling and safety training from P.B.&S. Chemical in May of 1999. |