Water Treatment Facility - North - Executive Summary |
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Facility Name: City of Louisville, Colorado Water Treatment Plant 1955 North Washington Street Louisville, Colorado 82007 This document summarizes the Risk Management Program (RMP) developed and implemented at the City of Louisville, Colorado Water Treatment Plant located at 1955 North Washington (North Plant) in Louisville, Colorado. In compliance with applicable Environmental Protection Agency (EPA) RMP requirements, the City of Louisville RMP document demonstrates compliance with the following components of a RMP: 7 A hazard assessment program that identifies and analyzes the potential on-site and off-site impacts of worst-case and alternate accidental release scenarios of regulated substances, and includes documentation of five-year accident histories involving regulated substances (Hazard Assessment). 7 An overall system to manage the development and implementation of a risk management program (Management System). 7 A prevention program that covers operating proc edures, maintenance, training, management of change, process safety information, and other similar information involving regulated substances (Accident Prevention). 7 An emergency action plan to mitigate any accidental releases that occur ( Emergency Action Plan). The plan is submitted in accordance with regulations cited at 40 CFR 68.155 through 68.185 for the on-site disinfection processes covered by RMP regulations. The primary activity at the water treatment plant is the treatment of wastewater for the City of Pueblo, Colorado. Regulated chemicals used, stored, or handled on-site in amounts greater than the threshold quantities of the RMP rule are described below: CHEMICAL: Chlorine PROCESS: Disinfection LOCATION: North Plant STORAGE VESSEL(S) and QUANTITY (LBS): One 1-ton cylinder stored inside on standby One 1-ton cylinder stored inside in service RMP PROGRAM: 2 A hazard assessment was performed for chlorine for the North and South City of Louisville Water Treatme nt Plants. Both worst case and alternate case scenarios were modeled for both urban and rural settings. Modeling was performed using the software program RMP*Comp version 1.06. RMP*Comp was developed by the Hazardous Materials Response and Assessment Division of NOAA, and the Chemical Emergency Prevention and Preparedness Office of the EPA. A map showing the radius of concern for both the worse case and alternate case scenarios is provided for each plant. The smaller radius shown represents the alternate case scenario. Maps were created using MARPLOT software which also posts locations of various receptors that are located with the radius of concern. LANDVIEW software was then used to generate census data for the areas within each radius of concern. The worst case scenario is based on a catastrophic failure of the chlorine holding tank due to corrosion, impacts, or structural failure. The entire 2,000 pound tank capacity is assumed to disperse at a rate of 200 pounds per min ute for a period of 10 minutes. Worst case distance to toxic endpoint for 2,000 pound chlorine release = 1.3 miles The modeled distance to the toxic endpoint for chlorine under the worst case scenario is as follows: Alternate case distance to toxic endpoint for 92 pound chlorine release = 0.1 miles Sid Copeland, Superintendent at the City of Louisville Water Treatment Plants (North and South Plants) is a qualified individual with overall responsibility for overseeing the implementation of the RMP. He has the authority to commit resources required to implement the Risk Management Program. The City of Louisville Water Treatment Plant has developed a RMP accident prevention program (including HAZOP studies for chlorine) from the existing maintenance program and is in compliance with the RMP requirements for Program 2. The City of Louisville Water Treatment Plant is a "non-responding facility" and emergency responses permissible by City of Louisville Water Treatment Facilities personnel are responses to incidental releases of hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area, or by maintenance personnel as well as responses to releases of hazardous substances where there is no potential safety or health hazard (i.e. fire, explosion, or chemical exposure). There have been no reportable accidents involving chlorine at the water treatment plant within the past 5-years. The City of Louisville Water Treatment Plants Risk Management Program will be revised as necessary to ensure compliance with applicable RMP regulations and to improve safety. |