Quindaro Water Treatment Plant - Executive Summary |
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The name of the attached executive summary is RMP Executive Summary EXECUTIVE SUMMARY The Kansas City, Kansas Board of Public Utilities (BPU) is required to comply with regulations addressing the safe storage, handling, and use of specific hazardous chemicals exceeding threshold quantities listed in Table 1 of 40 Code of Federal Regulations (CFR) Part 68.130. As part of compliance BPU is required to prepare, submit, and implement a Risk Management Plan (RMP) pursuant to 40 CFR 68, Subpart G, for the Quindaro Water Treatment Plant (QWTP). The QWTP is located on the south bank of the Missouri River in an urban area of Kansas City, Kansas. The facility is adjacent to industrial and residential areas to the east and south, respectively. In compliance with the RMP rule, the following Executive Summary has been prepared pursuant to 40 CFR 68.155. Accidental Release Prevention and Emergency Response Policies (40 CFR 68.155(a)) BPU takes an active role in preventing accidental rel eases at the QWTP by ensuring that its employees are properly trained in the safe operation and maintenance of processes subject to the Part 68 RMP rule. This training includes the safe handling of regulated substances under the rule. BPU has also developed and maintained a risk management policy that contains general safety rules. Though these rules do not specifically address the covered processes and their regulated substances, compliance with the general rules significantly reduces the potential for accidental releases of the regulated substances. This facility complies with standard industry practices for water treatment plants that use bulk quantities of chlorine and aqueous ammonia. BPU has also established procedures for emergency response and actively maintain procedures for emergency notification and action. These procedures are reviewed with employees on a periodic basis and revised to accommodate changes in staffing when they occur. In general, BPU plant employees would only manage small quantity releases of regulated substances. If the release is determined to be large or if the chemical is stored outside or has migrated outside from an indoor release, BPU would immediately notifiy the fire department. BPU management understands its duty to provide a safe working environment at this facility and to take measures to prevent accidents that may have an effect on the surrounding community. This understanding is reflected in procedures described and referenced in this RMP. Stationary Source and Regulated Substances (40 CFR 68.155(b)) The BPU QWTP is a drinking water processing plant that treats raw water from underground wells in the Missouri River flood plain and provides drinking water to the community. Treatment is accomplished through a series of physical and chemical treatment operations that include rapid mix flocculation, sedimentation, filtration, and chlorine disinfection. The treated water, now ready for public use, is transfer red to a large reservoir and pumped into the distribution system. The two regulated substances stored, handled, and used at the facility are chlorine and 29% aqueous ammonia. Chlorine is stored in one-ton cylinders with an average inventory of 17 cylinders onsite at one time. All chlorine cylinders are stored inside the chlorine building east of the water treatment laboratory. Aqueous ammonia is stored in two 6,000-gallon aboveground storage tanks (ASTs) located south of the chlorine building in a diked area. Each tank contains 48,000 pounds of solution. Worst-Case and Alternative Release Scenarios (40 CFR 68.155(c)) Worst-case and alternative release scenarios for the QWTP were determined using United States Environmental Protection Agency (USEPA) RMP Offsite Consequence Analysis Guidance, April 1999, and Risk Management Program Guidance for Wastewater Treatment Plants, October 1998. Worst-Case Release Scenarios The worst-case release scenario for chlorine consists o f a 100 % release of one of the one-ton cylinders. Each cylinder can contain 2,000 pounds of chlorine. The rule for worst-case release analysis assumes that all of the contents are released in a 10-minute time span. The scenario assumed a release of all the contents of the cylinder during unloading and thus outside of any enclosure, though the cylinders are always stored inside the chlorine building. No passive mitigation measures were considered in this worst-case release scenario. The worst-case release scenario for 29% aqueous ammonia consists of an instantaneous 100% release of a full 6,000-gallon AST into a secondary containment structure in a 10-minute time span. This would equate to 48,000 pounds of solution. Because the AST is located in an adequately sized diked area, this secondary containment structure would capture the entire contents of the full tank and the contained solution would evaporate over a period of time assumed to be one hour. Alternative Release Scenarios The alternative release scenarios for chlorine and 29% aqueous ammonia are based on results of the hazard review conducted as part of this RMP development, experience at other similar facilities, and industry experience. The alternative release scenario for chlorine has been designated as broken or disengaged flexible tubing from the cylinder to the header. The release would occur inside the chlorine building. The conservative assumption was made that the chlorine scrubber system does not work as intended, but that the enclosure of the building acts as passive mitigation. The actual release of chlorine gas from the tubing would be 15 pounds per minute. When the enclosure factor of 0.55 was used, the release rate to the atmosphere was calculated at 8.3 pounds per minute for 10 minutes, or for a total of 83 pounds. The alternative release scenario for 29% aqueous ammonia consists of a release resulting from a fill hose rupture between the tanker truck and AST out side the containment area. It was assumed that the auto shutoff valve failed but that the release was manually stopped after two minutes. The total amount of solution released onto the ground would be 1,850 pounds. Through pooling and evaporation, the rate of gas release to the atmosphere would be 46 pounds per minute until the solution has completely evaporated. General Accidental Release Prevention Program and Chemical Specific Steps (40 CFR 68.155(d)) The BPU QWTP prevention program for both chlorine and 29% aqueous ammonia complies with USEPA's 40 CFR 68 rule for Program 2 processes. To maintain this compliance, BPU has implemented many procedural and technological safeguards. These procedural safeguards include an employee-training program and operating and maintenance procedures for those employees involved in operating the covered processes. The technological safeguards include controls, sensors, alarms, and industry-standard systems. All of these serve to preven t unintended releases of chlorine and 29% aqueous ammonia. Should the prevention program fail to prevent a release, the facility is equipped with engineering controls designed to minimize the effect of the release on the surrounding community. For chlorine, the storage cylinders are kept inside the chlorine building to mitigate the effects of a release. The facility is also equipped with a scrubber system capable of neutralizing one ton of chlorine, the amount stored in the largest single container onsite. The scrubber system is maintained on a regular basis to ensure proper operation if needed during a chlorine release. The 29% aqueous ammonia ASTs are surrounded by a concrete secondary containment structure so that a release will not migrate from the tank. As with chlorine, the equipment in the ammonia process is operated and maintained by personnel properly trained in the hazards of the chemical and the process. Five Year Accident History (40 CFR 68.155(e)) There have b een no chemical releases at the facility in the past five years. Emergency Response Program (40 CFR 68.155(f)) The facility has an established emergency response plan that is coordinated with local response agencies such as the fire department and local HAZMAT team. The goals of the plan are to protect onsite employees from the hazardous effects of a potential release and to minimize the effects of potential releases on the general public. The program is routinely reviewed and updated to reflect personnel and regulatory changes. It is also submitted to the fire department for review and comment. Planned Changes to Improve Safety (40 CFR 68.155(g)) Ideas for changes to improve safety at the facility are actively sought from employees and employee meetings that focus on safety issues are held regularly. Employees are encouraged and trained to recognize hazards and present ideas to eliminate them or to minimize the potential consequences of those hazards. Hazard reviews have been conducted with key employees to meet prevention program requirements. During those sessions, recommendations were made for the purpose of improving safety and preventing accidental chemical releases. Each recommendation has been considered and evaluated for implementation. This evaluation process has provided all affected employees with a heightened awareness of safety issues related to the covered processes. BPU Quindaro Water Treatment Plant ES-1 Risk Management Plan March 2001 Revision No. 2 |