Camden Water L.L.C. - Morris-Delair WaterTreatment - Executive Summary

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Executive Summary 
 
For nearly five years, the City of Camden implemented a successful accidental release prevention program for the Morris-Delair Water Treatment Plant.  As operator, Camden Water LLC has improved upon this successful program to achieve an even greater level of process safety and risk management at the water treatment plant. 
 
All process safety information is clearly documented in a central location where operators and contractors working on or near the covered process are encouraged to access and review information found therein.   
 
Process Hazard analyses are conducted on a five-year schedule by a process hazard analysis team.  The team is composed of a team leader/process engineer, maintenance specialist, plant superintendent and a process operator.  Vulnerable processes or procedures are identified and recommendations to eliminate the vulnerability to the extent possible are identified.   
 
The water treatment superintendent using the process safety information in co 
operation with the process operator writes the operating procedures used when working on or around the chlorine processes.  The water treatment superintendent and a process operator verify all existing operating procedures for correctness once a year.  Operating procedures are available at the plant. 
 
Training is formulated and tracked by the plant superintendent according to a training schedule developed to respond to the development needs of the employees.  The plant superintendent keeps the training materials on file.  Written tests, oral exams and demonstration assure understanding of the training.  The Group Health & Safety Officer also tracks training for the site. 
 
The Mechanical Integrity program assures the continued integrity of process equipment.  The program consists of equipment lists, preventative maintenance procedures and a time dependent maintenance schedule.  Equipment is replaced prior to the expected useful life of the equipment or if excessive wear that indicates d 
egradation of its effectiveness is evident. The Responsible Manager assures the Mechanical Integrity program. 
 
The Management of Change program ensures that system changes are properly reviewed against original design specifications and can be accomplished safely.  It ensures any changes made to the processes will not increase the risk of an accident occurring on the process.  It is composed of a written program with elements delegated to appropriate members of the management team.  The Responsible Manager quality assures the Management of Change and keeps all completed Management of Change forms on file.  
 
There is a written pre-startup safety review program that ensures that prior to startup of any changes made to the processes, which require a change in the process safety information, are reviewed to ensure that the process is ready to operate safely.  The pre-startup safety review program is quality assured by the Responsible Manager.  Progress is documented in the Management of Ch 
ange files. 
 
Compliance audits assure that the program remains compliant in all respects.  The audits are led and conducted once a year by the Responsible Manager in cooperation with the delegated personnel implementing the program elements.  Deficiencies are noted and scheduled for system improvements by the delegated program implementers.  The Water Manager with the Project Engineer monitor scheduled completion dates. 
 
The Incident investigation program reduces the risk of incidents that come close to causing an accident.  The program follows corporate policy for fact determination, root cause system analysis, and recommendation implementation.  The Water Manager, together with the Group Health & Safety Officer, monitors system update schedules developed through the compliance audit and incident investigation. 
 
Employee participation is incorporated in each element program description. 
 
The Contractor Program follows Camden Water LLC contractor policy.  The Purchasing Manager impleme 
nts the program. 
 
At most, thirty thousand pounds of chlorine are inventoried in potable water treatment at the Morris-Delair Water Treatment Plant. 
 
The Worst Case toxic release scenario of chlorine involves the unlikely event of a single cylinder releasing its entire contents within 10 minutes.  This scenario would result in a vapor cloud migrating off site. 
 
The Alternate Case toxic release scenario of chlorine involves the release of a vapor cloud within the feed room from the unlikely event of a one inch puncture in one of the ton cylinders.  This scenario would result in a vapor cloud that does not migrate off site.  The chlorine feed room is used as passive mitigation. 
 
Release prevention and chemical specific prevention used are manual shutoff, alarms and procedures, emergency power, rupture disks, and excess flow devices.  Firewalls are used for mitigation systems.  The process areas are monitored by leak detection systems indicated by an audible alarm.  The maintenance progra 
m conducts equipment reliability reviews to assure operation of the prevention devices.  
 
There have been no accidents resulting in off-site releases.  Minor releases have occurred on two occasions, which have been rapidly controlled on-site. 
 
The company's emergency response program for chlorine release was updated in June of 1999.  The plan defines the response organization, coordination with local emergency response committee, equipment, response procedures, training, notification procedures, and drills.  The plan is updated periodically according to the need identified by the periodic drills.
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