Edwin Keith White Water Treatment Plant - Executive Summary |
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Risk Management Program Executive Summary Applicable Policies U.S. Environmental Protection Agency (EPA) Risk Management regulations (FR 61 [120], p 31668 issued June 20, 1996, requires facilities that have regulated substances above the listed threshold quantities to develop a formal Risk Management Program and to register and submit a Risk Management Plan. The regulation also apply to an estimated 7,200 public and private water and wastewater treatment facilities that use significant quantities of chlorine or ammonia. The rule was intended to lessen the number and severity of serious chemical accidents, such as the types that occurred in Bhopal, India (1984, 2,500 fatalities), and Pasadena, Texas (1989, 23 fatalities). The EPA regulation applies to facilities that manufacture; process, use, or otherwise handle regulated extremely hazardous substances in quantities that exceed specified thresholds (40 CFR Part 68 Subpart C). Purpose As a goal, the Frankfort Electric & Water Pl ant Board is dedicated to minimize or prevent damages to human health and the environment in the event of an unplanned sudden or non-sudden release of hazardous material within the perimeter of the Edwin Keith White Water Treatment Plant. Facility Description The Water Treatment Plant produces all the potable water for the City of Frankfort in Franklin County, and portions of Shelby, Scott, Anderson, and Woodford Counties. The plant is located on a 65 acre secured facility on Coffee Tree Road approximately 2 miles from downtown Frankfort. The major chemicals used in this process are chlorine, ammonia, 50% sodium hydroxide, hydrofluoslicic acid, ferric chloride, cationic polymer, powered activated carbon, zinc orthophosphate and potassium permanganate. The use of chlorine and/or anhydrous ammonia has been used in the process of treating drinking water for more than a century. Chlorine and ammonia are primarily used to disinfect the water to insure the water to be free of disease pro ducing organisms. Quantities of RMP Regulated Substances The following quantities of materials contained within the perimeter of this facility. * Chlorine 16,000 lb. * Anhydrous Ammonia 14,000 lb. Worst Case Release Scenario(s) Chlorine & Ammonia The following information provides worst-case distances to end points for the most common situations involved with chlorine and ammonia. All worst-case scenario results presented with this data assume Stability Class F, wind speed of 1.5 meter per second, a temperature of 77? F, and are applicable for any relative humidity. Chlorine Worse Case Chlorine: 1-Ton Container, catastrophic failure due to corrosion, impact, or construction defects. Amount Released and Duration of Release: 2,000-lb total release, 200 lb/min, and 10-minute duration. Distance to EndPoint: >6.2 miles Modeling used: Cameo/Marplot/Aloha Anhydrous Ammonia Worse Case Anhydrous Ammonia: Entire Contents of Bulk Storage Tank, catastrophic failure due to corros ion, impact, or construction defects. Amount Released and Duration of Release: 14,000-lb total release, 1400 lb/min, 10-minute duration. Distance to Endpoint: >1.1 miles Modeling used: Cameo/Marplot/Aloha Alternative Case Release Scenario(s) Chlorine & Ammonia Chlorine Several alternative release scenarios were modeled. However, the selected scenario involves a situation more appropriate to the process based on container, tubing, and pipe size. The most common incident involves connecting and disconnecting flexible tubing from the chlorine source. Worse Case Chlorine: 4-Ton Containers, catastrophic failure where as tubing ruptures, emptying 2-ton containers. System design would enable automatic switch over system to operate and release second bank of 2-ton containers Amount Released and Duration of Release: 8,000-lb total release, 1336 lb/min, 10-minute duration. Distance to EndPoint: >6.2 miles Modeling used: Cameo/Marplot/Aloha Anhydrous Ammonia The scenario chosen in th is process was as follows. While attempting to refill bulk storage tank with 1 inch ID hose, hose ruptures and driver is unable to close valve on bulk storage tank. Valve on supply tank has not yet been opened. Alternate Release Anhydrous Ammonia: Entire Contents of Bulk Storage Tank, 1 inch ID hose ruptures during fill, releasing entire contents of bulk storage tank. Amount Released and Duration of Release: 14,000-lb total release, 560 lb/min, 25-minute duration. Distance to EndPoint: >.65 mile Modeling used: Cameo/Marplot/Aloha Accidental Release Prevention The related Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) rules (29 CFR 1910.119), in effect since 1992, requires comprehensive management systems for the handling of highly hazardous chemicals. The Frankfort Plant Board has a comprehensive program to prevent accidental release of highly hazardous chemicals at its Edwin Keith White Water Treatment Plant. The prevention progra m ensures that proper safety information is in place, operating procedures are followed, chemical hazards are identified, employees and contractors are trained, and critical equipment is properly inspected and maintained. Our prevention program meets all aspects of the accidental release prevention program requirements of the EPA's Risk Management Program. The Risk Management Program should minimize the accidental releases of hazardous substances. Potential causes identified through the plan are as follows: * Adequate operating or emergency procedures for plant personnel. * Adequate training of operational and maintenance personnel. * Identification of premature equipment failure due to inadequate maintenance, inspection. * Equipment failure resulting from substandard materials. * Process or equipment changes that could prove to be unsafe because of effects on safety systems. Accident History This facility has not had a reportable release of a regulated substance. Emergency Respon se The Treatment Plant has personnel on-site 16.5 hours/day, (0600 - 2330), 7 days/week the entire year. The Operator in responsible charge will be aware of the primary and alternate emergency coordinators in the emergency plan, as well as, all emergency procedures. The primary and alternate emergency coordinators are thoroughly familiar with all aspects of the facility emergency plan, all operations and activities at the facility, the location and characteristics of hazardous material, the location of all records within the facility and the facility layout. The Frankfort Plant Board is committed to operating safe and environmentally sound utility facilities throughout our service area. Protection of our neighbors and employees is the highest priority. This on going commitment to employee safety is demonstrated through resources invested for safe design, operation, and maintenance of our facilities. The Edwin Keith White facility is included in the community response plan of the loc al fire department. The plant has participated and will continue to participate with these intites in mock emergency response drills at the plant in order to facilitate any future response needs. Employees at the WTP are trained in the hazards of the chemicals. Employees have also been briefed on the physical characteristics (odor, color, etc) of the chemicals to aid in their recognition skills. If an employee discovers a leak or release of any size, they are instructed to notify a facility supervisor. If a supervisor is unavailable, the employee will contact the Risk Manager, or their alternate. Planned Improvements The Frankfort Electric & Water Plant Board continuously strives to reduce risk by review of available literature involving process control. As technology improves new mitigation or control equipment will be added to minimize risk factors. |