Cross Creek Water Reclamation Facility - Executive Summary |
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RISK MANAGEMENT PROGRAM FOR CROSS CREEK RECLAMATION FACILITY PLANT EXECUTIVE SUMMARY JUNE 1999 This Executive Summary for the Risk Management Program for the Cross Creek Water Reclamation Facility (CCWRF) conforms to 40 CFR Part 68 Section 112 R. Referenced documents, such as the PWC Comprehensive Emergency Management Plan, Emergency Action Plan, Spill Prevention, Containment and Countermeasures (SPCC) and Oil Pollution Act of 1990 (OPA 90) all plans are available for inspection by authorized individuals. Our Process will soon be operating with the use of non-RMP regulated chemicals. By the summer of 2000 both of our chemicals will be substituted with safer, less hazardous chemicals. Both of our "new" chemicals will better for the public. Prevention and Emergency Response Policies It is the policy of the CCWRF to prevent accidental releases through the use of preventive maintenance programs, testing, calibrations, routine maintenance, inspections, and replacement of equi pment as necessary and training personnel. A work order system is in place for employees to formally report deficiencies and track until rectified. CCWRF's overall policy is to provide a safe environment for all employees, contractors, visitors and neighbors. This extends to the design, training, and implementation of a program, which will result in saving lives and reducing property damage during an emergency. It is also CCWRF's policy to operate in an environmentally responsible manner consistent with environmental knowledge, policies, procedures and regulations that best serve the needs of employees, the community, and the company. Operations of the CCWRF are designed so as not to adversely affect the environment of the surrounding area during emergency situations or normal operating periods. Employees at the CCWRF attempt to prevent all emergencies from ever occurring. In emergency situations employees are to exit the facility, and notify the appropriate emergency response a gency for assistance. Preserving life is the prime consideration, so all procedures will be carried out in a manner to minimize risk to employees and emergency response personnel. Rescue and medical activities have priority over all other actions. It is the emergency response policy of the facility to immediately notify Cumberland County Emergency Management Agency CEMA, LEPC, and the SERC of any regulated substances in excess of the reportable qty. PWC Employees are only trained at the awareness levels within the HAZOP system. If possible, employees are allowed to eliminate the release source (i.e. closing valves, shutting down pumps, etc.) or contain the release. The CCWRF relies on the local HazMat team to respond to related emergencies. Description of the Facility The Cross Creek WRF is located on the eastern edge of the city limits on the Service road adjacent to US 301Business (Eastern Blvd). The site is situated on the western side of US 301 between the Cape Fear River and Big Cross Creek. Big Cross Creek is a large creek with substantial volume of moving water and is located adjacent to the SW side of the facility boundary. CCWRF is a water reclamation facility at which wastewater is collected in the City of Fayetteville's sewer system is treated prior to being discharged to the Cape Fear River. This plant is capable of treated up to 22 million gallons per day. Chemical Storage The CCWRF uses Chlorine and SO2 within its process. Both are RMP regulated chemicals that we store in an enclosed chemical storage area. This area is enclosed with brick walls equipped automatic ventilation fans to which provide secondary containment for these substances. These areas are also equipped with chemical sensors that alert our operations control center of releases. These alarms are periodically calibrated to insure the accuracy of their sensors. Chlorine is the primary disinfectant agent used in the treatment process. It is an oxidizer that i s also corrosive and toxic. On site are 8 Cl cylinder weighing 2000lbs each. Cl is kept in the gaseous state. Our process requires that two Cl cylinders be kept in the process at all times because of our process demands. Sulfur Dioxide is also used as a de-chlorinator, in the process to decrease the strength of the chlorinated water prior to it being returned to the river. Each SO2 cylinder weighs 2000lbs. and is kept in the gaseous state. Two-one ton SO2 cylinders are used in the process at all times; two are kept "on stand-by" and two kept in storage. Misc. Facility Information Cross-Creek facility employs approximately 27 people. They rely on the PWC medical staff as well as the local medical professional to assist with emergency and non-emergency incidents. Worst-Case Alternate Case Scenarios Both case scenarios were developed using the RMP COMP V 1.6 model. The model is listed in 40 CFR Part 51, Appendix W as an acceptable EPA Guideline Model. Worst-Case The followin g charts summarize the worst-case scenarios. Material Identification Chlorine Quantity 4000 pounds Process/Storage Conditions Gas Topography Rural Toxic Endpoint 1.3 Meteorological Conditions Wind 3.4 mph Administrative Limitation Yes Public and Environmental Receptors Yes Ambient Temperature 77F Release Duration 10 minutes Alternate Case Scenarios Both case scenarios were developed using the RMP COMP V 1.6 model. The model is listed in 40 CFR Part 51, Appendix W as an acceptable EPA Guideline Model. Alt-Case The following charts summarize the alt-case scenarios. Material Identification Chlorine Quantity 100 pounds Process/Storage Conditions Gas Topography Rural Toxic Endpoint .1 mile Meteorological Conditions Wind 3.4 mph Administrative Limitation Yes Public and Environmental Receptors Yes Ambient Temperature 77F Release Duration 10 minutes orst-Case Alternate Case Scenarios Both case scenarios were developed using the RMP COMP V 1.6 model. The model is listed in 40 CFR Par t 51, Appendix W as an acceptable EPA Guideline Model. Worst-Case The following charts summarize the worst-case scenarios. Material Identification SO2 Quantity 4000 pounds Process/Storage Conditions Gas Topography Rural Toxic Endpoint 1.3 Meteorological Conditions Wind 3.4 mph Administrative Limitation Yes Public and Environmental Receptors Yes Ambient Temperature 77F Release Duration 10 minutes Alternate Case Scenarios Both case scenarios were developed using the RMP COMP V 1.6 model. The model is listed in 40 CFR Part 51, Appendix W as an acceptable EPA Guideline Model. Alt-Case The following charts summarize the alt-case scenarios. Material Identification SO2 Quantity 100 pounds Process/Storage Conditions Gas Topography Rural Toxic Endpoint .1 mile Meteorological Conditions Wind 3.4 mph Administrative Limitation Yes Public and Environmental Receptors Yes Ambient Temperature 77F Release Duration 10 minutes General Accidental Release Prevention Program The CCWRF facility diligently attempts to comply with the various emergency related regulations. Additionally, the use of Safety and Operating Procedures provide a system to avert accidental releases by focusing on specific components of each shipment. The safety and operating procedures manual consists of safety procedures and operating procedures uniquely designed for specific job tasks. The manual is reviewed annually and revised as necessary to address any changes. Each and every inbound shipment receives a detailed pre-unloading inspection, inspection during unloading, and post unloading inspection by the loading technician. The chief technician for quality assurance performs a final inspection. Employees and contractors are trained regularly to insure proficiency in all phases of the operation. Five Year Accident History 1994 1995 1996 1997 1998 1999 None None None None None None In the case of an incident involving an accidental release of Cl, an incident investigation will take place. The Emergency Response Program The CCWRF follows the company-wide Comprehensive Emergency Management Plan (CEMP) designed to address prevention, preparation, response and recovery from a wide variety of potential emergencies, including accidental releases of any regulated substance at the facility. The facility, its employees and business operations are susceptible to emergencies such as natural disaster, severe weather, and man-made hazards. The CEMP, in conjunction with the Risk Management Program and other regulatory aids, help in managing potential emergency situations. The facility maintains an aggressive training program for all members of its emergency awareness teams. In addition to the initial training programs for all emergency response team members, annual refresher training is provided along with periodic drills and exercises. Emergency response equipment is maintained in prime condition and includes SCBA for protection during evacuations. During Emergencies the Lead Operations staff member will serve as the Incident Coordinator, until the area respondents take charge of the incident. Because of the nature of the location, CCWRF attempts to coordinate training programs with the local fire and rescue teams. Employee training is periodically provided, but at a minimum of annually. A windsock is placed near the chemical building and will be used to determine the wind direction and the fume flow of the ammonia release, in the event of a release. Incidental releases of chlorine may occur when the following operations are executed on the system: ? During the process of changing cylinders out for usage ? Minor leakage may occur when a valve packing nut is loosened a half turn to open or close the valve All other releases constitute an "abnormal release" and the response to them is handled in two levels of severity. Awareness/Minor Emergency Level 1) No off site resources needed. Major Emergency Level 1) Requires sounding of the emergency alarm and evacuating the site including the main office building. A full-scale response effort will be launched to protect employees and the community 2) Outside response teams will be called when authorized by the Incident Commander. These teams must have fully trained personnel at the Hazardous Materials Technicians level Periodic escorted visits of these teams to the pertinent building area will allow familiarity with the premises to promote effective response to emergencies A building plan showing the location of Cl will be filed with the City of Fayetteville's Fire Department The Risk Manager or his designate shall write a critique of each necessary emergency response action or drill. Planned Changes to Improve Safety The following items are planned changes to improve safety and reduce the likelihood an anhydrous ammonia release at CCWRF: ? SUBSTITUTE ALL RMP REGULATED CHEMICALS TO NON-RMP REGULATED CHEMICALS THIS PROJECT WILL BE COMPLETE BY THE SUMMER OF 2000!! Communicati ng Risk to the Community Community warning in the event of a significant Cl release is a critical concern. The LEPC has a plan for warning people of an emergency through the use of police vehicles broadcasting warnings over the speaker systems. Through the use of the CEMA notification system and our internal procedures, we feel confident that public notifications will be communicated in a timely expeditious manner. CCWRF will incorporate educating the public and surrounding community on RMP and the specific risks and non-risks posed by its facility through Water Week activities, the Safewatch Program, and tour of its facility. In addition, we routinely give public tours to explain our process and safety precautions. |