City of Palatka Wastewater Plant - Executive Summary |
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We at the City of Palatka Wastewater Plant are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. We have 1 regulated substance present at our facility, chlorine gas. Chlorine gas is used in the final stage of potable water treatment process. At this time the maximum inventory of chlorine gas at our facility is 10,000 pounds. To perform the required offsite consequence analysis for our facility, we have used RMP* Comp a program provided by the EPA. 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 rele ase from chlorine. The scenario involves the release of 2,000 pounds of chlorine in a gaseous form over 10 minutes. At Class F atmospheric stability and 3.4 mph (1.5 m/s) wind speed, the maximum distance of 1.3 miles (2.1 kilometers) is obtained corresponding to a toxic endpoint of 0.0087 mg/L. The alternative release scenario for chlorine involves a release from one chlorine cylinder in the chlorine process. The scenario involves the release of 2,000 lb. of chlorine in a gaseous form over 3.5 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 0.4 miles. Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with all relevant standards, including: Technical Bulletin - Design Criteria for Mechanical, Electrical, and Fluid Systems and Component Reliability - Supplemen t to Federal Guidelines for Design, Operation and Maintenance of Wastewater Treatment Facilities, 1974 Edition;Recommended Standards for Wastewater Facilities (Ten State Standards), 1990 Edition; and all relevant Florida Department of Environmental Protection standards. Our facility is also subject to EPCRA Section 302 notification requirements. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information The City of Palatka Wastewater Plant maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is "What - If". The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered process, the City of Palatka Wastewater Plant maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency 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. Training The City of Palatka Wastewater Plant has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least once every year and more frequently as needed. Mechanical Integrity The City of Palatka Wastewater Plant carries out highly documented maintenance checks 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 with previous training in maintenance practices. 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. Management of Change Written procedures are in place at the City of Palatka Wastewater 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. Pre-start up Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at the City of Palatka Wastewater 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. Compliance Audits The City of Palatka Wastewater Plant conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation The City of Palatka Wastewater Plant promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as an y corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation The City of Palatka Wastewater Plant truly believes that process safety management and accident prevention is a team effort. All employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our 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 in particular. Contractors On occasion, the City of Palatka Wastewater 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 City of Palatka Wastewater Plant has a strict policy of informing the contractors of known potential hazards related the contractor's work and the process. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. The City of Palatka Wastewater Plant has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. The City of Palatka Wastewater Plant is included in the community 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. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that wo uld require a modified emergency response. |