City of Poway Lester J. Berglund - Water Treatment - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES |
City of Poway, Lester J. Berglund - Water Treatment Plant has an emergency response plan in effect. The Emergency Response Plan (Plan) is detailed in the Emergency Planning and Response section of this PSM/RMP document. This Plan was designed to meet the following objectives:
1.)To save lives.
2.)To minimize and avoid injuries.
3.)To protect the environment.
4.)To minimize property damage.
City of Poway, Lester J. Berglund - Water Treatment Plant maintains a safety committee whose members are the designated emergency coordinators for the facility. The Plan provides the response organization and notification procedures, evacuation routes, chlorine health hazards, and mitigation procedures which will be implemented to respond effectively to emergency situations that may arise at the facility. This Plan is reviewed and updated at least once per year. This Plan will be reviewed and updated to ensure compliance with the P
SM and RMP regulations, and to ensure that the plan is kept current.
STATIONARY SOURCE AND REGULATED SUBSTANCE
The facility has been in operation since 1973 but the water treatment system was modified in 1997. The process is located at 14521 Lake Poway Road, Poway, CA 92064. The chlorine system for City of Poway, Lester J. Berglund - Water Treatment Plant consists of chlorine one-ton containers which are the storage vessels. Chlorine gas is pulled from the one ton containers to the chlorinators through the vacuum regulator. The chlorinators are equipped with water at the injectors and the resulting chlorine solution is distributed through rotameters to other water processes at the facility. Below provides a list of the chlorine equipment.
Chlorine One-Ton Containers (9) in the Storage Area
150 pound cylinders (5) (Stored in the Storage Area)
Vacuum Regulators (4) in the Storage Area
Chlorinators (4) in the Chlorinator Room (Chemical Building)
Injectors (4) in the Chlorinator Ro
om (Chemical Building)
Injectors (2) in the Ammonia Building
Scrubber Sytem, Located at the south end of the facility.
The maximum quantity of chlorine that can be stored on site is 18,750 pounds.
HAZARD ASSESSMENT SUMMARY
Worst Case Release Result Summary
Scenario Description: Release of the maximum quantity of chlorine that can be stored in a vessel - 2,000 pounds in 10 minutes. The most pessimistic meteorological conditions were used: 1.5 meters/second wind speed, and F stability in an urban area. The EPA's RMP Guidance for Wastewater Treatment Plants was used to determine the distance to the toxic endpoint of 3 ppm. This scenario reaches off-site and may affect population receptors. One environmental receptor was affected by this potential scenario.
Alternative Release Result Summary
Scenario Description: A release of chlorine gas from 1/4 inch diameter leak. The release rate of chlorine due to the pressure of the tank is 3.4 pounds per minute. Active mitigation measure
of the scrubber was considered. The scrubber was designed to neutralize 1 ton of chlorine in the case of a release at an efficiency of 98%. Therefore, the release rate to the atmosphere was calculated to be 0.068 pounds per minute. This rate does not result in an off site consequence therefore, the release rate was rounded up to match the lowest rate found in the EPA's RMP Guidance for Wastewater Treatment Plants (1 pound per minute) to determine the toxic endpoint of 3 ppm. The meteorological conditions used were 3 meters per second wind speed, and D stability for an urban area. Because this release rate was rounded to 1 lb./min. the scenario distance reaches off-site and may affect population receptors. No environmental receptors were affected by this potential scenario.
ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS
City of Poway, Lester J. Berglund - Water Treatment Plant has a Process Safety Management program in place to manage the handling o
f chlorine. In addition, common industry standards, policies, and procedures are utilized to ensure safe practices are being performed. This includes common practices outlined by the Chlorine Institute. In addition to the Management Programs, there is a scrubber system tied to a chlorine sensor that is activated if the concentration of chlorine exceeds 3 ppm. Visual and audible alarms are activated to alert personnel of the release. Procedures are in place for operators to respond to a release.
FIVE YEAR ACCIDENT HISTORY
There has been no reportable release of chlorine at the facility within the last five years.
EMERGENCY RESPONSE PROGRAM
If a release of chlorine were to occur, the City of Poway, Lester J. Berglund - Water Treatment Plant's response plan is to call 911 in order to reach the Fire Department's HAZMAT team. Employees will evacuate the facility to a point that is upwind of the hazard. Evacuation drills are performed annually. The last evacuation drill was per
formed on May 12, 1999. The emergency response plan provides the response organization and notification procedures, and mitigation procedures which will be implemented to respond effectively to emergency situations that may arise at the facility. This plan was reviewed and updated to ensure compliance with the PSM and RMP regulations. It is reviewed annually to ensure that the plan is kept current.
PLANNED CHANGES TO IMPROVE SAFETY
The Process Hazard Analysis (PHA) provided the mitigation measures outlined below to improve safety at the City of Poway, Lester J. Berglund - Water Treatment Plant. The PHA was comprised of one session that included a HAZOP, What-If Walkthrough, and Checklists. The City of Poway, Lester J. Berglund - Water Treatment Plant would like to note that these recommendations will be complete by December 31, 1999.
R01 Verify concentration setpoint of chlorine scrubber.
R02 Ensure that chlorine sensors are calibrated and maintenanced per manufacturer's sp
R03 Install a digital readout of the internal chlorine concentration on the exterior of the chlorine building. The Water Treatment Plant would like to note that this recommendation is complete by the installation of a readout on the computer screen in the main control room. This is tied into the SCADA system for the plant. An on-duty operator is more likely to see the computer screen readout than the readout on the exterior of the building.
R04 Decide upon and implement a plan to deal with a chlorine leak in the chlorination room.
R05 Maintain chains at two different heights around the 150 pound chlorine containers in the chlorine storage room.
R06 Investigate and implement the seismic requirements for the one-ton chlorine containers. The Water Treatment Plant would like to note that this recommendation is in progress.
R07 Tag the two valves on the liquid chlorine header to the evaporators to remain closed.
R08 Implement a valve numbering system and tag the im
portant valves. Also, label chlorine piping to show contents and flow direction. The Water Treatment Plant would like to note that this recommendation has been completed.
R09 Include the operating procedures and training information for the City of Poway - Community Swim Center in the Water Treatment Plant operations manual. The Water Treatment Plant would like to note that this recommendation is in progress.
R10 Post floor plans that clearly indicate emergency escape routes and assembly locations for all employees at the Water Treatment Plant. The Water Treatment Plant would like to note that this recommendation is in progress.
R11 Establish a procedure to regularly hold emergency evacuation drills for the entire Water Treatment Plant facility. The Water Treatment Plant would like to note that this recommendation is an on-going procedure and the last evacuation drill was performed on 5/12/99.