Belmont Water Treatment Plant - Executive Summary

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Executive Summary 
Chemicals are widely used in industry, in the home, and in the environment.  They are transported on roads, waterways, and railways.  We at the Belmont Water Treatment Plant (Belmont WTP) use chemicals too.  For example, we use chlorine to disinfect our water to provide safe drinking water for human consumption.  Storing large quantities of chlorine can be a hazard.  We take our safety obligations in storing and using chlorine as seriously as we do providing the public safe, disinfected drinking water.  The following document describes what could happen if there were to be an accident, the steps we take everyday to ensure a safely operating plant, and what to do in event of an emergency.   
Accidental Release Prevention and  Emergency Response Policies 
The Philadelphia Water Department (PWD) and Belmont WTP accidental release prevention policy involves a unified approach that integrates proven technology, trains staff on operation and maintenance practi 
ces, and uses tested management system practices.  All applicable procedures of the U.S. Environmental Protection Agency (EPA) Prevention Program are adhered to, including key elements such as training, systems management, and emergency response procedures.   
This document complies with the U.S. Environmental Protection Agency's (EPA's) Risk Management Program, under Section 112 (r) of the Clean Air Act (CAA) Amendments of 1990, 40 Code of Federal Regulations (CFR) Part 68. The Belmont WTP has a chlorination system that uses chlorine gas fed from ton cylinders. This document summarizes our existing health and safety programs, our internal management response team, policies, procedures, and on-going actions that are designed to prevent or minimize impacts of accidental releases of chlorine to the environment. The Belmont WTP has prepared a detailed and comprehensive emergency response plan to handle any potential accidental releases that is designed to safeguard both on- and off-site pe 
ople. To date, we have had an excellent record in preventing accidents from occurring. 
General Facility and Regulated Substances Information 
The Belmont WTP, operating since 1966, is located at 4300 Ford Road in the City of Philadelphia. The plant is located on property between the Ford Road and Belmont Avenue in Philadelphia.  Surface water taken from the Schuylkill River is treated and disinfected at the Belmont WTP to EPA standards and sent to the public for human consumption. This water treatment process includes preliminary screening, coagulation and sedimentation, filtration, and chlorination before final distribution to the public. The Belmont WTP produces up to 86 million gallons per day (MGD) of potable water, with an average flow of 46 MGD. 
The facility currently stores chlorine, which is a regulated toxic substance under 40 CFR Part 68 - RMP. The Plant's chlorine storage exceeds the listed threshold quantity of 2,500 pounds in the RMP Regulations.  
Liquid chlorine is brought 
to the plant via delivery trucks that drop off the ton containers at the chlorine loading/unloading area. Chlorine leak detector monitors continuously check for leaks in the bulk storage areas and in the chlorination rooms. Other indicators include chlorine feed and evaporator alarms. These alarms are annunciated at the central and local control panels at the plant in the main control room. In the case of a leak, the storage area has an audible alarm and red flashing warning light on top of the building.  In addition, an evaporator shut-off and pressure reducing valve is designed to close if low evaporator gas temperature is detected; thus preventing liquid chlorine from reaching the gas piping system.  These valves also reduce pressure and allow for quicker liquefaction to occur.  All process related, factory-set pressure relief valves are set to protect the integrity of the equipment. 
The ton cylinder usage area and the chlorination rooms are enclosed in a building.  Both buildings  
are equipped with an automatic chlorine scrubber system that activates when the chlorine leak detector detects 2 ppm of either chlorine in the room. Room air is vented to a scrubber that neutralizes the gases.  Emergency showers and eye wash stations are provided at each building.  The main control building has Self-Contained Breathing Apparatus (SCBAs) available.    
The Belmont WTP is controlled at State Road by a gate that is only open during normal working hours.  Visitors and contractors must check-in at the administration building and be approved by Belmont WTP staff prior to entry into the facility.  The plant is manned 24-hours a day, year round, and alarms notify staff of any problems or situations that require follow-up investigations at all times.       
Offsite Consequence Analysis Results 
The offsite consequence analysis includes consideration of two release scenarios, identified as "worst case" and "alternative" release scenarios. The worst case scenario assumes that the en 
tire content of the largest single container of chlorine is released, regardless of how improbable that may be.  In addition, only "passive" mitigation methods, such as buildings or dikes (for liquids) can be considered.  Passive mitigation, as defined, requires no mechanical, electrical, or human input. The regulations require that the worst case scenario assume atmospheric conditions that are conservative and result in large impact areas. 
An alternative release scenario is also required.   
The worst case release scenario for chlorine is focused on the ton cylinders that store chlorine liquid. The scenario used for Belmont WTP is the rupture of one chlorine cylinder with a maximum capacity of 2000 lbs, resulting in a release of 2,000 pounds of chlorine over a 10-minute duration. There are chlorine cylinders stored outdoors at times, so no building mitigation factor can be applied at Belmont WTP. The release rate for this scenario is 200 pounds per minute (lbs/min).     
The cylinder r 
upture resulting in a chlorine release could be caused by catastrophic events, such as an earthquake or a fire. In practice this type of total release of a ton cylinder would be unlikely and never occur during the lifetime of the plant. The results of the dispersion modeling analysis for this worst case release scenario indicate that this scenario has an offsite impact. 
The alternative release reflects a type of release that is more likely to occur, as compared to the worst case scenario.  Unlike the worst case scenario, the alternative release scenario may consider "active" mitigation, such as automatic shutoff valves and scrubbers.  Active mitigation is defined as requiring mechanical, electrical, or human input.  Lastly, the alternative release scenario assumes more realistic regional and seasonal meteorology. 
Based on the process hazard analysis performed for the chlorine system, several alternative release scenarios were selected.  Unlike the worst case release scenario, active co 
ntrols can be applied to minimize the leak or impacts.  Active controls consist of mechanical, electrical, or human input.  The scenario used for chlorine was a failure of the fusible plugs on the ton cylinder with mitigation provided by the storage building. Under this scenario, the amount of chlorine released was calculated to be 74.6 lbs/min. The results of the dispersion modeling analysis for the worst alternative release scenario indicate that this scenario has a slight offsite impact.  
Five-year Accident History Summary 
No chlorine releases that could have caused safety or health hazards to any individuals at on-site or off-site locations (no deaths, injuries, property or environmental damage, evacuations, or sheltering in place) occurred at Belmont WTP during the last five years.  
Summary of the Accidental Release Prevention Program and Chemical-specific Prevention Steps  
Belmont WTP is in compliance with Federal Risk Management Planning (RMP) requirements.  Chemical-specific pr 
evention steps include availability of self-contained escape breathing apparatus, worn by the operators during connection and disconnection of the chlorine supply, awareness of the hazardous and toxic properties of chlorine, and the presence of chlorine detectors and alarms. 
Belmont WTP's accidental release prevention program is based on the following key elements: 
* Detailed management system and clear levels of responsibilities and team member roles 
* Comprehensive safety process information that is readily available to staff, emergency responders,  and contractors 
* Comprehensive preventive maintenance program 
* Completion of a process hazard analysis of equipment and procedures with operation and maintenance staff participation and review. 
* Use of state-of-the-art process and safety equipment 
* Use of accurate and effective operating procedures, written with operations and maintenance staff participation 
* High level of training of operators and maintenance staff 
* Implementation  
of an incident investigation, inspection, and auditing program using qualified staff. 
Safety Information 
Comprehensive chemical data have been assembled to include regulatory reporting and action thresholds, health hazard, and chemical exposure limitations, as well as detailed physical properties of each regulated substance.  This information was compiled from numerous sources and is intended to be a one-stop source for the reader seeking data about these substances.  This information includes chlorine background information, material safety data sheets (MSDS), and chlorine reaction chemistry. 
Equipment safety information was meticulously compiled on the chlorine process.  Specifications for the process are collected in one place for easy reference.  Details such as maximum intended inventory; safe upper and lower temperatures; safe upper and lower pressures; and codes and standards used to design, build, and operate the processes are on file at the facility. 
We also have procedures i 
n place that is triggered to update safety information if there is a major change that makes existing information inaccurate. 
Hazard Analysis  
In 1998, a detailed hazard analysis (HA) was conducted with plant staff, engineering, and administrative staff for the regulated process.  The team consisted of process operating and maintenance experts and process design engineers.  The HA technique used was the "What-If" scenario and process checklist procedure, per acceptable approach guidance from EPA. The HA was lead by knowledgeable persons on the type of process being reviewed.  This review will be updated again within a five-year period, or whenever there is major change in the process.  A list of actions to resolve any found significant hazard review findings was prepared, and staff is currently working to resolve this action item list.  Staff will document completion of any action item. 
Operating Procedures 
Belmont WTP maintains up-to-date, accurate, written operating procedures that g 
ive clear instructions for the chlorine process. Belmont WTP ensures effective operating practices by combining them with operating and maintenance training programs.  Standard operating procedures (SOPs) provide system descriptions, specifications, equipment inspection requirements, and operating procedures for the chlorine system.  Procedures include startup, shutdown, and normal, alternate, and emergency operation.  Also included are maintenance and troubleshooting procedures, including consequences of deviation and the steps to avoid and correct deviations.  Belmont WTP will update procedures whenever a change occurs that alters the steps needed to operate safely.  Operating procedures will be developed and in place prior to any new process equipment coming on line or a changed process starting back up. 
Operations and  Maintenance Training Program 
Each Belmont WTP employee presently involved in operating or maintaining the chlorine process is trained in an overview of the process a 
nd detailed, applicable operating and maintenance procedures.  In fact, Belmont WTP helps their employees understand, through training, the nature and cause of problems arising from operations involving chlorine on site, and to increase their employees awareness with respect to their hazards. Belmont WTP's training program includes both initial and refresher training that covers 1) a general overview of the processes, 2) the properties and hazards of the substances in the process, and 3) a detailed review of the process operating procedures and safe work practices.  Oral reviews and written self-evaluations are used to verify that an employee understands the training material before the process work can be resumed.  
Training documentation includes: date of most recent review or revision to the training program, type of training required, and the type of competency testing used to ensure staff understands the training.   
Maintenance Program 
Belmont WTP maintains the mechanical integrity 
of process equipment to help prevent equipment failures that could endanger workers, the public, or the environment.  Belmont WTP believes that this program is the primary line of defense against a release, and addresses equipment testing and inspection, preventative maintenance schedules, and personnel training. Belmont WTP's maintenance program includes the following: 
* Written procedures for maintaining mechanical integrity through inspection and testing of process equipment, based on instructions of equipment vendors, industry codes, and prior operating experience 
* Implementation of the written procedures by performing inspections and tests on process equipment at specified intervals 
* Training of maintenance personnel in procedures for safe work practices, such as lockout/tagout, line or equipment opening, and avoidance and correction of unsafe conditions 
Internal Compliance Audits 
Internal compliance audits are conducted every three years to verify compliance with the programs  
and procedures contained in the RMP.  Belmont WTP and PWD assembles an audit team that includes personnel knowledgeable in the Risk Management Program rule and in the process, and this team evaluates whether the prevention program satisfies the requirements of the Risk Management Program rule and whether the prevention program is sufficient to help ensure safe operation of the process.  The results of the audit are documented, recommendations are resolved, and appropriate enhancements to the prevention program are implemented. 
Incident Investigation 
Belmont WTP investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public, or the environment so that similar accidents can be prevented.  Belmont WTP trains employees to identify and report any incident that requires investigation.  An investigation team is assembled and the investigation is initiated within 48 hours of the incident.  The results of the investigation are documented, recommendat 
ions are resolved, and appropriate process enhancements are implemented.  Information found during the investigation is reviewed by affected staff, added or used to revise operating and maintenance procedures, and passed on to the training unit for their inclusion in existing training programs, if warranted, to prevent a future event. 
Emergency Response Program Summary 
Belmont WTP has established a written emergency response program that is followed by the employees to help safely respond to accidental releases of hazardous substances.  This program has been coordinated with the City of Philadelphia Fire Department HAZMAT Unit, which is a member of the Local Emergency Response Planning Committee (LEPC).  This program includes an emergency response notification plan.  Emergency response drills and drill evaluations are conducted at a minimum frequency of every 12 months; emergency operation and response procedures are also reviewed at that time. 
Planned Changes to Improve Safety 
A few m 
inor changes to improve safety (recommended actions) were identified for the chlorine process in 1998 during the hazard review process.  These recommended actions have been evaluated and will be implemented as required.  It is expected that the recommended actions will be evaluated and implemented by December 1999.  The implementation of these recommendations will further improve the safety of the covered processes.  
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