Moorhead Water Plant - Executive Summary
EXECUTIVE SUMMARY |
This executive summary is a brief overview of the RMP and the associated policies at the Moorhead Water Treatment Plant, owned and operated by the City of Moorhead Public Service. It contains the information called for in Section 68.155 of the rule.
RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES
The accidental release prevention policies are represented in Sections 2 through 13. The emergency response policy is represented in Sections 14. Moorhead Public Service takes an active role in preventing accidental releases at this facility by ensuring that its employees are properly trained in the safe operation and maintenance of processes subject to the Part 68 rule. They are also trained in the safe handling of all chemicals that are regulated substances under the rule.
In addition to ensure the adequate training of its employees, Moorhead Public Service works to prevent accidents by providing and revising as needed written procedures for operating its covered
processes under the rule. Although these procedures in and of themselves should prevent accidental releases, Moorhead Public Service maintains and follows a policy of compliance audits, the goals of which are to determine if existing procedures are adequate and, if they are, to ensure that they are followed.
Moorhead Public Service has also developed and maintained a risk management policy that contains general safety rules. The general safety rules fall under Minnesota's Chapter 182 Occupational Safety and Health Act. The safety and health program is required to meet Minnesota's Workplace Accident and Incident Reduction (AWAIR) Law. This program covers topics such as personal protection equipment, hazard communications, confined space, respiratory protection, excavation and trenching, lock-out/tag-out, and bloodborne disease exposure control. Although these general rules do not specifically address the covered processes and their regulated substances, compliance with the general
rules will significantly reduce the potential for accidental release of these substances. These manuals for this program are available to all Moorhead Public Service employees in the control room of the Moorhead Water Treatment Plant.
As for emergency response, Moorhead Public Service has established and maintained procedures for emergency notification and response. These are reviewed with employees on a periodic basis and revised to accommodate changes in staffing when they occur. Moorhead Public Service's response to a release is to notify the Moorhead Fire Department. The City of Moorhead Fire Department and the City of Fargo, North Dakota Fire Department jointly operate and maintain a common HAZMAT team.
Moorhead Public Service management understands its duty to provide a safe working environment at this facility and to take measures to prevent accidents that may have an effect on the surrounding community. This understanding is reflected in procedures described and refer
enced in this document.
STATIONARY SOURCE AND REGULATED SUBSTANCES
The Moorhead WTP treats surface water from the Red Rivers and ground water from several aquifers to provide drinking water to the community. It does this through a series of physical and chemical treatment operations that include:
>Secondary disinfection with chloramines
The treated water, now ready for use by the public, is transferred to a large reservoir and pumped into the distribution system. The design capacity of the treatment plants is 16 million gallons per day.
The regulated substance stored, handled, and used at this facility is chlorine. The chlorine is stored in one-ton containers with a maximum intended inventory of 4 containers on site. All of the containers are stored inside of a building.
Worst-case and alternative release scenarios have been determined after careful review of the regulation and consideration of the sto
rage vessel configurations at the WTP. No active mitigation measures or devices, such as scrubbers, could be considered for analysis of worst-case releases.
For this worst-case release scenario, the regulation specifies the release conditions and meteorological conditions at the time of the release. When these conditions were modeled, using the Areal Locations of Hazardous Atmospheres (ALOHA) program, the results were as follows:
Chlorine worst-case release scenario
>Quantity released = 2,000 pounds
>Release duration = 10 minutes
>Release rate = 220 pounds per minute
>Distance to endpoint = 2.3 miles
For the alternative release scenario, described in detail in Appendix 5 of this document, the following results were obtained:
Chlorine alternative release scenario
>Quantity released = 317 pounds
>Release duration = 60 minutes
>Release rate = 10.6 pounds per minute
>Distance to end point = 0.40 mile
These scenarios are described in greater detail in Section 4.0, P
rocess Hazard Analysis.
RELEASE PREVENTION PROGRAM FOR COVERED CHEMICALS
The prevention program and chemical-specific prevention steps are described in detail in Section 2 through Section 13 of this document. In accordance with the Part 68 rule, the prevention program contains the following sections:
>Process safety information
>Process hazard analysis
>Prestartup safety review
>Hot work permits
>Management of change
The prevention program elements that are most critical in preventing accidental releases in this facility include employee training, both formal and on-the-job; written operating procedures for all to use who operate or maintain the covered processes; and a process equipment preventive maintenance program.
Should the prevention program fail to prevent a release, the WTP is equipped with engineeri
ng controls designed to minimize the effect of the release of the surrounding community. The chlorine containers are kept inside of a building to mitigate the effects of the release. But more important, the plant has installed a scrubber capable of neutralizing one ton of chlorine, the amount stored in the largest single container onsite. The scrubber is maintained on a regular basis to ensure proper operation if needed during a chlorine release. Our WTP also has a 500 kW generator for back-up power for the chlorine scrubber.
FIVE-YEAR ACCIDENT HISTORY
There have been no accidental releases of regulated substances from this facility during the past five years.
EMERGENCY RESPONSE PROGRAM
This facility has established and maintains an emergency response program that is coordinated with local response agencies, such as the Moorhead Fire Department, which is part of the local HAZMAT team along with the City of Fargo, North Dakota. The program is described in detail in Section 14 o
f this document. The goals of the program are to protect onsite employees from the hazardous effects of the releases and to minimize the effects of releases on the general public. The program is routinely reviewed and updated to reflect personnel and regulatory changes. It is also submitted to the Fire Department for review and comment.
PLANNED CHANGES TO IMPROVED SAFETY
Ideas for changes to improve safety are actively sought from employees. Employee meetings that focus on safety issues are held regularly at this facility. Employees are encouraged and trained to recognize hazards and present ideas to eliminate them or to minimize the potential consequences of those hazards.
During the development of this RMP document, hazard reviews were conducted with key employees to meet the prevention program requirements. During these sessions, recommendations were made for the purpose of improving safety and preventing accidental chemical releases. Each recommendation has been or will b
e considered and evaluated for implementation. The recommendation for the installation of an auto tank valve shutdown system will be install during 1999. The hazard review process provided all affected employees with a heightened awareness of safety issues related to the covered process.