North Reservoir Filtration Plant - Executive Summary |
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Executive Summary The North Reservoir Filtration Plant (NRFP) is one of the facilities owned and operated by the City of Flagstaff. The NRFP has prepared a Risk Management Plan (RMP) in accordance with the EPA and OSHA regulatory requirements. A brief overview of the RMP and the associated policies at this facility is described below. Prevention and Response Policies The City takes an active role in preventing accidental releases by ensuring that its employees are properly trained in the safe operation of covered processes and the safe handling of treatment chemicals. The City has also established and maintains procedures for emergency notification and response. These are reviewed with employees on a periodic basis and revised to accommodate changes in staffing when they occur. To increase employee safety and awareness, the City: * maintains up-to-date safety information and operating procedures, * performs regular preventative maintenance, * provides periodic refresher training on safe handling of chemicals, and * conducts periodic safety drills. Facility Description and Regulated Substances North Reservoir Filtration Plant is an unmanned facility which utilizes surface water supplies to produce potable water through filtration and disinfection operations. City employees regularly inspect the facility to ensure proper operation of the chlorine facilities. The regulated substance handled at the NRFP is chlorine. The chlorine is stored in 150-lb cylinders, with a maximum of 30 cylinders (4,500 lbs) on site. Release Scenarios Worst-case and alternative release scenarios have been determined after careful review of the regulation and consideration of the storage vessel configuration at the facility. The EPA's software program RMP*Comp was used to model both release scenarios and determine the radius of impact. In the worst-case release scenario, the regulation clearly states the release quantity shall b e the contents of the single largest vessel of the covered process chemical, at ground level and under very stable atmospheric conditions. These conditions are most likely to result in a cloud of the released chemical remaining intact as it slowly moves along the ground. As required by regulation, the worst-case scenario for chlorine assumed the complete release of chlorine from a single cylinder (150 lbs), with no release mitigation measures taken. For the alternative release scenario for chlorine, the assumptions were that (a) a failure occurred in the cylinder safety device (fusible plug), and (b) the entire contents (150 lbs) were released over a 15-minute period before the leak could be repaired. No mitigation effects were considered, to provide the City with additional safety margin in protecting the public. Prevention Steps for Chlorine The prevention program fulfills the requirements of the OSHA Process Safety Management (PSM) rule and the EPA RMP rule, and inclu des: * formal and on-the-job training, * written operating procedures, and * a process equipment preventive maintenance program. Accident History There has been no release of the covered chemical in the past five years. Emergency Response Program North Reservoir Filtration Plant has established and maintains an emergency response program that is coordinated with local response agencies. The goals of the program are to protect responding personnel from the hazardous effects of a release and to minimize the effects of releases on the general public. The program is routinely reviewed and updated to reflect facility and regulatory changes. Planned Changes for Improved Safety Ideas for changes to improve safety are actively sought from employees. Employee meetings that focus on safety issues are held regularly at the facility. Employees are encouraged and trained to recognize hazards and present ideas to eliminate them or to minimize the potential con sequences of those hazards. During the development of this RMP document, a process hazard analysis of the chlorine system was conducted with key employees to fulfill the prevention program requirements. During these sessions, recommendations were made for the purpose of improving safety and preventing accidental chemical releases. Each recommendation will be or has been considered for implementation. In addition, the exercise provided all affected employees with a heightened awareness of safety issues related to the covered processes. |