Chandler Water Treatment Plant - Executive Summary

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1. Accidental Release Prevention and Emergency Response Policies 
 
The Chandler Water Treatment Plant is committed to employee, public and environmental safety. A comprehensive accidental release prevention program is incorporated and adopted in the Chandler Water Treatment Plant Process Safety Management Plan and the Hazardous Materials Management Plan (HMMP).  This program covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at the facility. It is policy to implement appropriate controls to prevent possible releases of regulated substances. Unforeseeably, if such a release does occur, highly trained emergency response personnel are at hand to control and mitigate the effects of the release.  In the Process Safety Management Plan, the safety consultant has calculated that the scrubber is capable of scrubbing 10,039 pounds of Chlorine.  The Chlorine scrubber exhaust system can provide one complete air exchange  
of the Chlorine Storage room every 5 1/2 minutes.  The Chandler Fire Department provides emergency response expertise to the site.  The plant receives two fire inspections from the Fire Department annually one must be completed after the HMMP permit is issued.  A complete HMMP is submitted to the Fire Department annually for compliance. The HMMP is reviewed by the Fire Department, a fire inspection is completed and the HMMP permit is issued.  
 
2. Regulated Substances Handled 
 
The Chandler Water Treatment Plant's primary activities encompass TREATMENT OF PUBLIC WATER UTILITY SYSTEM.  Chlorine is the only regulated substance present at the facility.  The maximum inventory of Chlorine at the facility is 12 one-ton containers (24,000 lb).  Four one-ton containers are manifolded together for the water treatment processing.  Additionally, eight one-ton containers are stored in the water treatment process area.  All containers are enclosed in the chlorine room, which is protected by the scrub 
bing system described above.  
 
3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario. 
 
To evaluate the worst case and alternative scenarios, RMP*Comp (TM) was used. The following paragraphs provide details of the chosen scenarios. 
 
The worst case release scenario submitted for Program 3 toxic substances as a class involves a catastrophic release from a Chlorine cylinder.  The scenario involves the release of 2000 lb. of Chlorine in a gaseous form over 10 minutes. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 1.3 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. 
 
The alternative release scenario for Chlorine involves a release from one-ton cylinder on the loading dock.  If a Chlorine leak did occur, which is highly unlikely, it would be during loading and unloading of the cylinders at the dock area.  The  
scenario involves the release of 65 lb. of Chlorine in a gaseous form over 60 minutes.  If a leak occurs procedures are in place to immediately move the leaking Chlorine cylinder into the scrubber room.  Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 0.1 miles. 
 
4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps 
 
The facility has taken all the necessary steps to comply with the accidental release prevention requirement set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with Uniform Building Code, Uniform Fire Code, and NFPA Standards. The process at the facility is subject to the OSHA PSM standard under 29 CFR 1910.119. The facility is also subject to EPCRA Section 302 notification requirements. The following sections briefly describe the elements of the release prevention program in place at the facility, which are fully described in t 
he PSMP. 
 
4.1 Process Safety Information 
 
The Chandler Water Treatment Plant maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. 
 
4.2 Process Hazard Analysis 
 
The facility conducts comprehensive a process hazards analysis to ensure that hazards associated with the processes are identified and controlled efficiently.  The analysis is undertaken by a team of qualified personnel with expertise in process operations and is revalidated at a regular interval of three years. Any findings related to the process hazard analysis are addressed in a timely manner. 
 
4.3 Operating Procedures 
 
For the purposes of safely conducting activities within covered processes, the Chandler Water Treatment Plant maintains an Operations and Maintenance Manual. The O&M Manual includes procedures addressing various modes of operation such as initial startup, normal operations, temporary operations, emergenc 
y shutdown, emergency operations, normal shutdown and startup after a turnaround.  The information is regularly reviewed and is readily accessible to operators involved in the processes. 
 
4.4 Training 
 
The Chandler Water Treatment Plant has a comprehensive training program in place to ensure employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least annually and more frequently as needed. 
 
4.5 Mechanical Integrity 
 
The Chandler Water Treatment Plant carries out computerized maintenance schedules on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Qualified personnel carry out maintenance operations.  Furthermore, these personnel are offered specialized training as needed.  Any equipment deficiencies identified  
by the maintenance checks are corrected in a safe and timely manner. 
 
4.6 Management of Change 
 
Written procedures are in place at the Chandler Water Treatment Plant to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. 
 
4.7 Pre-startup Reviews 
 
Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at the Chandler Water Treatment Plant.  These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. 
 
4.8 Compliance Audits 
 
The Chandler Water Treatment Plant conducts audits in accordance with the PSMP to determine whether the provisions set out under the RMP rule 
are being implemented. These audits are carried out at least every three years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. 
 
4.9 Incident Investigation 
 
The Chandler Water Treatment Plant promptly investigates any incident in accordance with the PSMP that has resulted in, or could result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. 
 
4.10 Employee Participation 
 
The Chandler Water Treatment Plant truly believes that process safety management and accident prevention is a team effort. Employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, employees have access to all information created as part of the facility's implementation of  
the RMP rule, including information resulting from process hazard analyses.  All is enacted in accordance with the PSMP. 
 
4.11 Contractors 
 
On occasion, the Chandler Water Treatment Plant hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out.  The Chandler Water Treatment Plant has a strict policy in accordance with the PSMP of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 
 
5. Five-year Accident History 
 
The Chandler Water Treatment Plant has had an excellent record of preventing accidental releases over the last 5 years. Due to stringent release prevention policies, there has been no accidental release during this period. 
 
6. Emergency Response Plan 
 
The Chandl 
er Water Treatment Plant HMMP carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. 
 
The plan is promptly updated to reflect any pertinent changes taking place within the facility processes that would require a modified emergency response. 
 
7. Planned Changes to Improve Safety 
 
The Chandler Water Treatment Plant has designated an individual to evaluate additional or alternative process controls and mitigation systems to improve plant safety.
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