Verona Pumping Station - Executive Summary |
City of Battle Creek-Verona Pumping Station RMP Executive Summary 1. Accidental Release Prevention and Emergency Response Policies We at the Verona Pumping Station (Water Treatment Plant) are strongly committed to employee, public and environmental safety. This is demonstrated, by an accidental release prevention program that covers such areas as design, installation, operating procedures, maintenance and employee training associated with the process at our facility. It is our policy, through the use of appropriate controls, to prevent the release of the regulated substance used in our operation. If such a release should occur, we are completely coordinated with the HAZMAT unit of the Battle Creek Fire Department. They would provide the highly trained emergency response personnel to control the effects of any release. The Source and Regulated Substance Handled The primary activity of the Verona Pumping Station is Municipal Water Supply and Treatment. We have 1 regulated substance at our facility. That substance is Chlorine. It is used in the treatment process for oxidation and disinfection. The maximum inventory at the Verona Pumping Station is 24,000 lbs. It is stored in 1 location in 2,000 lb. cylinders. 3. The Worst Case Release Scenario and the Alternative Release Scenario, including administrative controls and mitigation measures to limit the distance for each scenario. To evaluate the worst case scenario, we have used the AWWA Compliance Guidance and Model Risk Management Program for Water Treatment Plants. We have used the same reference book for the alternative scenario. The details are as follows. The worst case scenario submitted is CLW-2. This is for a program 3 toxic substance and involves a catastrophic release of Chlorine. The scenario involves a direct release of 2,000 lbs. of Chlorine in a gaseous form over 10 minutes. At Class F atmospheric stability and 1.5 m/s wind speed, a maximum distance of 2.63 miles is needed in an urban setting to reach a toxic endpoint of 0.0087 mg/L. The Alternative release scenario submitted is CLA-3 for a 1 ton Chlorine Container with gas feed. This scenario involves the release of Chlorine gas through a 5/16 diameter valve body opening due to tubing, connection or valve failure. It has a 317lb total release at a rate of 10.5 lb/min over a 60 minute duration. This scenario assumes a stability class D, relative humidity of 50%, temperature of 77 degrees F and wind speed of 3.0 m/s. This scenario has a distance to its toxic endpoint of 0.48 miles in an urban setting. Page 2 4. 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. The Chlorination process at our facility is subject to the OSHA PSM standard under 29 CFR 1910.119. The following sections briefly describe the elements of the program that is in place at t he Verona Pumping Station. Process Safety Information The Verona Pumping Station maintains a detailed record of safety information on the chemical hazards, operating parameters and equipment designs associated with the Chlorination process. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that the hazards associated with the Chlorination process are identified and controlled. We use the Check List" analysis method, conducted by a team of qualified personnel, to evaluate the process every 3 years or whenever there is a change to the process. Any problems are addressed in a timely manner. Operating Procedures The Verona Pumping Station maintains written operating procedures. These procedures cover the modes of operation such as start up, normal operations, emergency operations and shutdown procedures. These procedures are reviewed regularly and are available to anyone involved with the process. Training The Verona Pumping Station has a training program in place to ensure that employees operating the process are competent in the operating procedures associated with the process. Refresher training is provided at least every 3 years. Mechanical Integrity Verona Pumping Station carries out documented maintenance checks on all the chlorination equipment to ensure proper operation. Maintenance checks are performed by qualified personnel and factory trained service people. Any problems are corrected in a timely manner. Management of Change Written procedures are in place at the Verona Pumping Station to manage any change in the Chlorination process. This includes changes in equipment, technology or procedures. All employees involved with the maintenance or operation of the process are notified promptly of any changes and offered training on the changes. Page 3 Pre-start up Review Pre-start up, safety reviews are conducted on any new equipment or changes to existing equipment in the Chlorination process. These reviews are conducted to confirm that construction, operating and maintenance procedures are correct and understood by all employees involved in the process prior to the start up of any new equipment. Compliance Audits The Verona Pumping Station will conduct audits on a regular basis to determine if the provisions under the PSM rule are being carried out. These audits are to be done at least every 3 years. Any corrective actions required, as a result of these audits, will be promptly taken care of. Incident Investigation The Verona Pumping Station promptly investigates any incident that results in or could result in a chlorine release. These investigations are to identify the causes leading to the incident as well as any corrective actions necessary to prevent its recurrence. Employee Participation The staff, of the Verona Pumping Station, believes that process safety management and accident prevention are a team effort. Employees are encouraged to express their views on accident prevention and to recommen d improvements. Employees actively serve on the Process Safety Management Team. Contractors Sometimes we hire contractors to conduct maintenance and construction activities. These contractors are required to adhere to all safety regulations and policies. Verona Pumping Station has a strict policy of coordinating safety issues with contractors and employees on any potential hazards involved with the contractors work. Contractors are also informed of all emergency response procedures, should an accidental release occur. 5. Five year Accident History The Verona Pumping Station has an excellent record of preventing accidental releases over the years. In the past 5 years we have had no releases of chlorine that resulted in any deaths, injuries, damage on site or off site consequences. 6. Emergency Response Plan The Verona Pumping Station has a written emergency response plan to deal with the release of any hazardous materials. This plan requires the notification of the Battle Creek F ire Department. It relies on their HAZMAT team for all aspects of emergency response including first aid, medical treatment, evacuations, notification of local emergency agencies and the public. Page 4 To ensure proper operation, our emergency equipment is inspected and serviced according to the manufacturers recommendations. The Calhoun County LEPC is the Local Emergency Planning Committee. 7. Planned Changes to Improve Safety There are no current plans to change any of our operating equipment or procedures. We are constantly reviewing changes in our industry and new technologies for anything we can do to make the operation of our Chlorination Process safer. 8. Certification Statement The undersigned certifies that to the best of my knowledge, information and belief, formed after reasonable inquiry, the information is true, accurate and complete. David L. Rich Water Production Superintendent City of Battle Creek Date: 6/10/99 |