Little Falls Water Treatment Plant - Executive Summary
Accidental Release Prevention and Emergency Response Policies |
The Passaic Valley Water Commission (Commission) has documented their existing emergency response procedures in the Little Falls Water Treatment Plant's (WTP) Risk Management Plan (RMP) as part of a commitment to maintain a safe, reliable water treatment plant operation. The RMP describes all the procedures used at the plant to ensure the safe operation of the facility for its workers and for the surrounding communities. The RMP also contains on-site procedures and offsite agency coordination protocols to be followed in the event of a chlorine leak.
In addition, the Commission has implemented programs to periodically train all personnel involved in handling chlorine on safety and accident prevention. Moreover, all contractors working on the site are notified of the potential hazards of chlorine and are instructed to follow special safety procedures when they perform work on or around the prechlorination system. The Com
mission also maintains an employee participation program, a safety inspection program, and performs annual compliance audits.
Stationary Source and Substance Handled
The Little Falls WTP provides an average of 80 million gallons per day (mgd) of potable water to the cities of Passaic, Paterson and Clifton and to 22 other communities in northern New Jersey. The plant is operated 24 hours per day, 7 days a week and uses the prechlorination process to provide primary disinfection of the water that enters the WTP. The plant treats the water using conventional processes including chemical addition, flocculation, sedimentation, filtration and chlorine disinfection.
Offsite Consequences Analysis
The Little Falls WTP is an EPA rated Program 3 facility with one toxic gas; therefore, one worst-case release scenario and one alternative release scenario were assessed for the prechlorination facility. The USEPA Risk Management Program Guidance for Wastewater Treatment Plants (WWTPs) (USEPA 550
-8-98-010, October 1998) was used as a source to determine potential offsite consequences. This guidance specifically addresses the chemicals commonly found at wastewater treatment plants, such as chlorine, and since the chlorination process for water treatment plants is similar to the chlorination process for wastewater treatment plants, this guidance document is applicable to the Little Falls WTP prechlorination process.
The worst-case release scenario was determined in accordance with the requirements provided in 40 CFR 68.22 and 40 CFR 68.25 (b, c). For the Little Falls WTP, the worst-case scenario is a total release from one of the chlorine supply vessels (greatest amount stored on-site in a single vessel). It is assumed that a tanker truck ruptures and its entire contents escape to the atmosphere. Using the reference tables in the USEPA RMP Guidance for WWTPs, it was determined that this worst-case release has impacts that extend beyond the facility property. This event is
considered extremely unlikely to occur.
The alternative release scenario was determined in accordance with the requirements provided in 40 CFR 68.22 and 40 CFR 68.28. The alternative scenario was identified as a chlorine leak occurring when the piping between the tanker trucks and the Scale House is accidentally broken. The chlorine leak is assumed to be a two-phase release from a pipe carrying liquid chlorine from the tanker truck to the atmosphere. Using the reference tables in the USEPA RMP Guidance for WWTPs, it was determined that this release has impacts that extend beyond the facility property. This event is considered unlikely to occur.
General Accidental Release Prevention Program and Chemical Specific Prevention Steps
The Commission currently complies with the New Jersey Department of Environmental Protection's Toxic Catastrophe Prevention Act. The Little Falls WTP has a documented Prevention Program for the prechlorination facility that stipulates accident and releas
e prevention measures. The prevention measures include employee participation programs, process safety information and inspections, process hazard analyses, formalized operating procedures, staff training procedures, a contractor training/ information program, pre-startup reviews, mechanical integrity reviews, a hot work permit program, a management of change program and an incident investigation program. Compliance audits are also conducted annually to verify procedures and practices are adequate and are being followed, and in accordance with the criteria for design and operation.
Little Falls WTP employees who are involved in chlorine operations are trained in specific procedures regarding handling chlorine at the facility. The WTP is equipped with leak detection monitoring to decrease response time in the event of a chlorine leak. The Operator's Control Center is staffed 24 hours per day, 7 days a week and has a closed circuit television monitor which continuously monitors the
chlorine feed system.
Five Year Accident History
The Little Falls WTP has had no accidental releases of chlorine in the last five years that have resulted in on-site or offsite injuries or other impacts.
Emergency Response Program
PVWC maintains a written Emergency Response Plan that identifies the procedures to be implemented and the personnel to be involved in responding to chlorine release emergencies. This program includes formal protocols for notifying PVWC management, PVWC response personnel, local emergency response personnel and the New Jersey Department of Environmental Protection and identifies the specific equipment necessary for maintaining effective response capabilities.
The response team undergoes training in several areas including system maintenenace and operation, health and safety, emergency response, and regulations.
The Water Treatment Plant Repairers are charged with responding to chlorine leaks. Personnel are on-call 24-hours a day. The Supervisor, Water
Treatment Plant Repairers is responsible for the overall management and maintenance of the Emergency Response Plan and any drills, training and reporting required. A minimum of two drills are held per year.
Planned Changes to Improve Safety
Recommendations for safety improvements were identified in the annual safety review conducted in April 1999 and in the Process Hazard Analysis that was completed in May 1999. Additional recommendations may be made upon review of any accident and/or when the PHA is updated every five