Delta Mills Plants 2 & 3 - Executive Summary |
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Delta Mills Marketing Company Wallace, South Carolina Executive Summary The Delta Mills Marketing Company has implemented a comprehensive program to safely manage chlorine at its Water Treatment Plant supporting Plant # 2 and #3 in Wallace, South. There have been no chlorine incidents in the most recent five-year history period nor in the history of the plant. In 1996, a Process Safety Management (PSM) program was initiated at the Water Treatment Plant with the assistance of a consulting organization. A PSM Implementation Manual has been edited to be site specific. The Manual was issued to the plant. With these steps, approximately 50% of PSM requirements were met. Key items included in the manual are: -Written site specific procedures for Employee Involvement, Management of Change, Incident Investigation, Pre-Startup Reviews and Self Audits; and -Chlorine safety information as required by the regulations. Next, these additional steps have been implemented to complete the PSM program: -Training on PSM and its key components including Management of Change, Mechanical Integrity and Incident Investigation; -Conducting Process Hazards Analyses for the three chlorine processes; -Developing Standard Operating Procedures for Chlorine Management; -Developing an initial Emergency Response Plan; and -Training in support of the certification of operators. The Utilities Manager, Safety Officer and several plant operators meet annually to review and update procedures and to maintain compliance with all aspects of the PSM regulation. In addition to PSM compliance, the plants have implemented or are considering implementing a number of programs to improve the safe handling of chlorine and other chemicals: -The chlorine delivery system at the plant was upgraded to a full vacuum process in 1996. This process has been proven to greatly reduce leaks by reducing the amount of equipment that is exposed to pressurized chlorine. -Storage of all chlorine cylin ders inside a secure building was initiated in 1990. This building will act to contain and control and chlorine release and it improves site security. -The replacement of chlorine with an alternate disinfectant (e.g., sodium hypochlorite) or replacing the one (1) ton chlorine cylinders with 150 cylinders will be considered once the plants have switched to city supplied water by July 1999. The site's Emergency Response Plan (ERP) has been significantly upgraded. In 1996, the ERP was revised to include offsite response and communication. The County LEPC and other local response organizations have been incorporated into the ERP. Where necessary, communication plans have been developed to notify businesses or residences that may be impacted by a release. Chlorine Response Drills have been routinely conducted since 1997. The last drill was conducted on May 18, 1999. To further understand chlorine risks, a consulting firm was contracted to conduct "Offsite Consequence" Modeling Analysis, as required by EPA's Risk Management Program. Both a "Worst Case" and an "Alternative Case" chlorine release scenarios were studied for each site. The "Worst Case" modeling showed the potential impact of a full, 2000 pound cylinder of chlorine released in 10 minutes. This resulting chlorine plume extended 2.2 miles. For the "Alternative Case", a more typical possible release of 180 pounds, 3 pounds/minute for 60 minutes, was modeled. The modeling indicated that a plume extending 0.1 miles would result. The results showed that the risk of chlorine exposure varies depending on direction of the wind and extent of the chlorine plume. The Water Treatment Plant is located on the southwest side and down gradient of Plants #2 and #3. From the Water Treatment Plant the land slopes down to the Great Pee Dee river which is 0.75 miles to the southwest. The City of Cheraw is across from the Great Pee Dee River. The Great Pee River is also due west from the site. The Town of Wallace is northeast of the site on Highway US 9 North. Highway US 1 North is northwest of the site. At the junction of Highways 1 and 9, there are located several small business and several residences. The land east and southeast of the site is low swampland. Thus, with no wind or wind from the north, northeast or northwest, any chlorine release will fall to the Great Pee Dee River. The release will be contained by the river's banks until dissipated. A wind from the west or southwest will carry any release into Plants #2 and #3 and possible into the Town of Wallace. A south or southeast wind will carry any release across the Highways 1 and 9 junction and into the open farm area beyond. In addition to Process Safety Management, the Delta Mills Marketing Company organization has an active Safety Program and an active Safety Committee. There is a Utility representative on the Safety Committee. The Safety Committee meets monthly. Its duties include reviewing new safety procedures, accident investigations, safety surveys and safety communications. The Safety Manager for the Delta Mills Marketing Company also takes an active role in supporting the Utilities Safety Program. Within the Utilities Department, there are monthly safety meetings to review an OSHA subject or discuss a safety issue. Routine training is conducted for topics such as: - Hazard Communications - Personal Protective Equipment - Lockout/Tagout - Confined Space As a result of our programs, the plants have had an excellent safety record with no recordable injuries over the past three years. As mentioned earlier, there have no reportable chlorine releases from the plants in the last five years nor in the history of the plant. We plan to continue our emphasis on safety to maintain and improve our safety performance. Report by: Jimmy Lampley Environmental Manager |