MEMORIAL VILLAGES WATER AUTHORITY WWTP - Executive Summary |
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General Executive Summary for Memorial Villages Water Authority's Wastewater Treatment Facility 1. Accidential Release Prevention and Emergengy Response Policies: We at Memorial Villages Water Authority are strongly committed to employee, public and environmental safety. This commitment is inherent to a comprehensive accidental release prevention program in place 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. Unforeseeably, if such a release does occur, we are coordinated with Village Fire Department which provides highly trained emergency response personnel to control and mitigate the effects of the release. 2. Stationary Source and the Regulated Substances Handled: Our facility's primary activity is Wastewater Treatment. We have one regulated substance present at our facility . This substance is Chlorine. The regulated substance at our facility is involved in only one use. Chlorine is used for disinfection of treated wastwater. The maximum inventory of Chlorine at our facility is 6000 lbs. 3. The worst Case Release Scenario and the Alternative Release Scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario: To perform the required offsite consequence analysis for our facility, we have used the Environmental Protection Agency RMP Comp program which was downloaded directly from EPA's own web site. The following paragraphs provide details of the chosen scenarios. The worst case scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from our disinfection process. The scenario involves the release of a single vessel containing 2000 lbs of Chlorine in a gaseous form over 10 minutes. Under worst case weather conditions, namely Class F atmospheric stability and 1.5 m/s wind speed, the maximum distance of 1.3 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. One alternative release scenario has been submitted for each toxic substance present in Program 2 and Program 3 processes cumulatively. The alternative release scenario for Chlorine involves a release from our Chlorine Bay in the disinfecting process. The scenario involves the release of 10 lbs of Chlorine in a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L is 0.1 mile. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps: 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. The following sections briefly describes the elements of our release prevention program that are in place at our stationary source. Process Safety Information: Memorial Villages W ater Authority maintains a detailed record of written 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 process are identified and controlled efficiently. The studies are undertaken by qualified personnel in process operations and are revalidated at a regular interval of once a year. 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, Memorial Villages Water Authority maintains written operating procedures. These prcedures address various modes of operations such as initial startup, normal operation, temporary operations, emergency shutdown, emergency operations, normal shut down and startup after a turnaround. The information is regularly reviewed and is readily accessibl e to operators involved in the process. Training: Memorial Villages Water has a comprehensive training program in place to ensure that employees that are operating the disinfecting process are completely competent in the operating procedures associated with the process. New employees receive basic training in process operations followed by on the job supervision until they are deemed competent to work independently. Refresher training is provided at least every year and more frequently as needed. Mechanical Integrity: Memorial Villages Water Authority carries out maintenance checks on process equipment to ensure proper functions. Process equipment examined by these include among others; storage vessels, chlorinators, rotometers, piping system and EDS pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiancies identified by the m aintenance checks are corrected in a timely manner. Management of Change: Written procedures are in place at Memorial Villages Water Authority to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews: Pre-startup safety reviews related to new process and to modifications in established processes are conducted as a regular practice at Memorial Villages Water Authority. 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: Memorial Villages Water Authority conducts audits on a regular basis to determine whether the provisions are set out under the RMP rule are being implemented. These audits are ca rried 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. Incident Investigation: Memorial Villages Water Authority promptly investigates any incident that has resulted in, or could reasonably result in catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions necessary to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation: Memorial Villages Water Authority truly believes that process safety management and accident prevention is a team effort. Company employees are stronly 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, in particular, information resulting f rom process hazard analysis. Contractors: On occasion, our company 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. Memorial Villages Water Authority has a strict policy of informing the contractor of known potential hazards related to the contractor's work and the processes. Contractors are also informed of all procedures for emergency response should an accidental release of a regulated substance occur. 5. Five Year Accident History: Memorial Villages Water Authority has had an excellent record of preventing accidental releases over the last five years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan: Memorial Villages Water Authority carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all a spects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public. 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 within our processes that would require a modified emergency response. Villages Emergency Management Office is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated. 7. Planned Changes to Improve Safety: Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Increased training is one of the major steps we want to take to improve safety at our facility. This change is expected to be implemented by the end of this year. |