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
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.
4. General Accidental Release Prevention Program and the Chemical-Specific Prevention
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
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
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
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.
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.
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
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.
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
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.
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.
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.
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.
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
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.
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