City of Richmond Wastewater Treatment Plant - Executive Summary
The accidental release prevention and emergency response policy: |
The policy of the City of Richmond is to manage hazardous chemicals in such a way as to prevent chemical releases and establish emergency response procedures to minimize the consequences of an accidental release of hazardous chemicals at the Wastewater Treatment Plant. The goal of this policy is to reduce the risk to Plant employees and to protect the public and the environment.
The stationary source and regulated substances handled:
The process at the wastewater treatment plant subject to the RMP regulations is the chlorination/dechlorination system, which manages greater than threshold quantities of chlorine and sulfur dioxide.
The worst-case release scenario(s) and the alternative release scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario:
Based on EPA criteria, the worst-case release scenario at the Wastewater Treatment
Plant is the catastrophic failure of the sulfur dioxide rail car used to store sulfur dioxide. This is extremely unlikely since the rail car steel tank is nearly two-inches thick along with the additional safeguards described in the Prevention Program.
The worst of the several alternative release scenarios considered for chlorine is the catastrophic failure of a one-inch liquid pipe or valve (e.g., 1-in. pressure relief valve on rail car). In order for the reported toxic end point distance to be achieve, the excess flow valves on the chlorine rail car would also have to fail. There are numerous mechanical and procedural safeguards at the Plant designed to prevent this from occurring, however, for emergency response planning purposes they were not considered in the alternative release scenario.
The worst of the several alternative release scenarios considered for sulfur dioxide is the catastrophic failure of a one-inch liquid pipe or valve. In order for the repo
rted toxic end point distance to be achieve, the excess flow valves on the sulfur dioxide rail car would also have to fail. There are numerous mechanical and procedural safeguards at the Plant designed to prevent this from occurring, however, for emergency response planning purposes they were not considered in the alternative release scenario.
The general accidental release prevention program and chemical-specific prevention steps:
The accidental release prevention program at the Wastewater Treatment Plant is focused on the safe management of chlorine and sulfur dioxide used in the chlorination/dechlorination system. The first step in the prevention program at the Plant was the establishment of a management system to assign overall responsibility and responsibility for the individual program elements. Additional steps include: ensuring process safety information on the disinfection system is accurate, complete and up-to-date; ensuring the system is designed and modified saf
ely by periodically conducting process hazard analyses; ensuring the system is operated and maintained in a safe manner by developing, maintaining and implementing Standard Operating and Preventive Maintenance Procedures; ensuring Plant employee are adequately trained and tested in the RMP program elements; ensuring new equipment and modifications to the disinfection system are designed, constructed, operated and maintained by following Management of Change, Pre-startup Review and Hot Work Permit Procedures; ensuring contractors are qualified, and oriented to the site hazards; and conducting periodic Compliance Audits and Incident Investigations including resolution of recommendations made during these investigations/reviews.
The five-year accident history:
During the previous five years, no accidents have occurred at the Wastewater Treatment Plant.
The emergency response program:
The Wastewater Treatment Plant is included in the City of Richmond Local Emergency P
lanning Committee (LEPC) emergency response plan. In addition, the Plant has in place an emergency action plan than includes procedures to be followed in the event of an accidental release of chlorine or sulfur dioxide. The procedures cover the following: evacuation plan; recognizing emergencies; emergency action procedures; coordinating personnel; first aid procedures; notifying the public and local emergency response agencies; emergency response contacts; emergency response equipment; reportable release quantities and documenting releases; emergency alarm system; emergency responders; training and drills; and pre-emergency coordination with the LEPC.