Lower Berkeley Wastewater Treatment Plant - Executive Summary |
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Berkeley County Water & Sanitation Authority Lower Berkeley WWTP Goose Creek, South Carolina Policy Statement The Berkeley County Water & Sanitation Authority operates the Lower Berkeley Wastewater Treatment Plant at 2111 Red Bank Road in Goose Creek, South Carolina. We are strongly committed to safety by maintaining comprehensive maintenance, prevention, and industrial safety programs that protect against any accidental release or spill which may result in on- or off-site consequences. In the unlikely event of a mishap, an emergency response plan has been developed in cooperation with the Berkeley County Disaster Preparedness Agency, which serves to ensure the safety and well being of the community and the environment. Our emergency response program is based upon the recommendations by The Chlorine Institute, Inc. within the "Emergency Response Plans for Chlorine Facilities." Facility Description Chlorine is stored on-site for use in the disinfection process for the trea tment of wastewater prior to final discharge. Six 2,000-pound pressurized chlorine cylinders are located within an enclosed building south of the treatment ponds for use in the treatment process. An additional six to eight 150-pound chlorine cylinders are stored on-site prior to transport to other facilities. The latest technology in process control systems are present in the chlorine storage area to minimize and prevent the impacts of any spillage, fire, explosion, or equipment failure. Within the dechlorination process, four 2000-pound storage cylinders supply gaseous sulfur dioxide, that when mixed with the treated wastewater, facilitates the removal of any residual chlorine following the chlorination process. An additional six to eight 150-pound cylinders are stored on-site prior to transport to other facilities. The latest technology in process control systems are present in the chlorine storage area to minimize and prevent the impacts of any spillage, fire, explo sion, or equipment failure. Accident History The Lower Berkeley Wastewater Treatment Plant has had an excellent record of preventing accidental release over the past 5 years. Due to our stringent release prevention policies, no accidental releases have occurred or were identified within the time period in question. Since the facility has been in operation, no deaths or injuries have resulted from the accidental release, explosion, or fire involving this regulated substance. Furthermore, no fish kills or other environmental impacts have resulted from an accident or spill incident at the Goose Creek, South Carolina facility. Off-site Consequence Analysis The Berkeley County has calculated a worst-case release scenario based on the EPA approved RMP*Comp modeling software. An altternative release scenario has been modeled using EPA's OCA Guidance Reference Tables and Equations. Details for each chosen scenario have been provided in the following paragraphs. Chlorine The wors t-case release scenario, as developed for the chlorination system, involves a catastrophic release of 2,000 pounds of chlorine from a single chlorine cylinder within the chlorine building. It has been assumed that the entire quantity of chlorine is released as a gas over a 10 minute time frame as a result of a tank rupture. Under worst-case weather conditions, the maximum distance of 3.0 miles corresponds to the toxic endpoint of 0.0087 mg/l. Industrial facilities, a U.S. Naval Weapons Station, military barracks, residential subdivisions, creeks, rivers, and the Berkeley Reservation would be affected by such a release. An alternative scenario may include the catastrophic release of chlorine gas during 3 m/s windspeeds, D Class atmospheric stability, and 77 degrees fahrenheit weather conditions. It has been assumed that a quantity of chlorine gas is released at a rate of 41.2 pounds per minute from the storage cylinders as a result of a pipe rupture within the chlorination buil ding. The facility's hazard response team would control the release by preventing flow through the piping within a 60 minute period. Under the alternative weather conditions, the maximum distance of 0.3 miles corresponds to a toxic endpoint of 0.0087 mg/l. Industrial facilities, a U.S. Naval Weapons Station, military barracks, and housing subdivisions would be affected by such a release. Environmental receptors exposed to chlorine concentrations above the 0.0087 mg/l level include creeks, rivers, and the Berkeley Reservation. Sulfur Dioxide The worst-case release scenario, as developed for the dechlorination system, involves a catastrophic release of 2,000 pounds of sulfur dioxide within the dechlorinination building. It has been assumed that the entire quantity of sulfur dioxide is released as a gas over a 10 minute time frame as a vapor cloud resulting from the rupturing of tanks. Under worst-case weather conditions, the maximum distance of 3.1 miles corresponds to the toxic endpoint of 0.0078 mg/l. Within this 3.1 mile radius, numerous public and environmental receptors including affected industrial facilities, a U.S. Naval Weapons Station, military barracks, residential subdivisions, creeks, rivers, and the Berkeley Reservation would be affected. The alternative release scenario has been modeled as the catastrophic release of sulfur dioxide gas during 3 m/s windspeeds, D Class atmospheric stability, and 77degrees fahrenheit weather conditions. It has been assumed that a quantity of sulfur dioxide gas is released at a rate of 31.3 lbs./min from the storage cylinders as a result of a pipe rupture within the dechlorination building. Under the Alternative weather conditions, the maximum distance of 0.3 miles corresponds to a toxic endpoint of 0.0078 mg/l. Residential subdivisions, industrial facilities, a U.S. Naval Weapons Station, military barracks, creeks, rivers, and the Berkeley Reservation would be affected by such a release. Accidental Releas e Prevention Program and Chemical-Specific Prevention Steps The Lower Berkeley WWTP has taken the necessary steps to comply with the accidental release prevention requirements as set forth in 40 CFR Part 68. The chlorination and dechlorination processes have been designed and constructed in accordance with The Chlorine Institute Standards, good engineering practices, and all applicable codes or standards. Furthermore, the Prevention Program at the Lower Berkeley WWTP has been developed in accordance with the standards established with 29 CFR 1910.119. The prevention program consists of the elements as follows: 1. Employee Participation Employees at the Lower Berkeley WWTP are provided access to all elements of this Risk Management Plan for review and input. Site management, whenever possible, involves employees in the development, revisions, review, and implementation of this plan. Employees, knowledgeable in the specified processes, are included in any task group or team for th eir invaluable experience and input for developing a successful program to ensure the well being of co-workers, the community, and the environment. 2. Process Safety Information The Lower Berkeley WWTP maintains a detailed written record of all safety information regarding the operation of each covered process. Information includes the chemical hazards, operating procedures, and equipment design parameters. 3. Process Hazard Analysis The checklist hazard analysis method is utilized at the Goose Creek, South Carolina facility to identify and prevent any activity that may result in a release of a regulated substance. A team of qualified personnel perform periodic reviews of operating procedures, equipment functions, and handling practices to identify potential hazards every three years, or in the event of any process or equipment change. Any findings related to the hazard review is addressed in a safe and timely manner. 4. Operating Procedures Written operating procedures addre ssing initial startup, normal operations, temporary operations, emergency shutdown, emergency operations have been developed to ensure the safe operation of the covered processes. 5. Training A comprehensive training program provides employees the proper education to safely maintain and operate the chlorination or dechlorination processes. New employees receive basic training in process operations and safety, followed by a supervised on-the-job training period. Refresher training is provided to all employees at least every three years or as needed. 6. Mechanical Integrity The Berkeley County utilizes maintenance employees to regularly inspect and document the condition and functioning of all equipment associated with the covered processes. Any inspections or maintenance operations are performed by qualified personnel with previous specialized training for accomplishing such tasks. All deficiencies or equipment were identified during maintenance inspections are corrected in a safe and timely manner. 7. Management of Change Prior to any modifications to equipment, procedures, raw materials, or processing, the Lower Berkeley WWTP shall ensure the process safety information, training requirements, the technical designs, and the operating procedures to ensure the safety of all employees, the community, and the environment. 8. Pre-Startup Review In the event that new equipment, materials, or processes are added, or existing processes are modified, the Berkeley County Water and Sanitation Authority shall review all design specifications, safety information, maintenance requirements, operating procedures, and emergency procedures prior to the introduction of a regulated substance. Any necessary training will be provided to employees to ensure safe operating conditions. 9. Contractors Contractors shall undergo a screening process prior to performing any work on or around the chlorination or dechlorination processes. The Operations Supervisor, at the Lower Berkeley WWTP, shall ensure all contractors are properly trained in the safe work practices and emergency response procedures at the facility. During or following any work, contractors will be evaluated for their performance in accomplishing their task, while complying with all said procedures at the wastewater treatment facility. 10. Hot Work Permits Written procedures have been developed to ensure that any work, conducted on or near the covered processes, with the potential to produce sparks does not result in fire or release involving the regulated substances. Proper evaluation of the area is required to ensure that adequate precautions are taken during any welding, brazing, or cutting operations. 11. Incident Investigation Any incident resulting in, or possibly resulting in, an accidental chlorine or sulfur dioxide release will be investigated by qualified personnel. Personnel identify any situation that may result in a release, recommend corrective action s, and document any such action. 12. Compliance Audits Compliance audits are performed on a regular basis to ensure compliance and implementation of the provisions within 40 CFR Part 68 and 29 CFR 1910.119. Audits are performed by a group of qualified employees at least every three years. All findings and recommendations shall be addressed in a safe and prompt fashion. Emergency Response The Emergency Response Plan has been developed in cooperation with the Berkeley County Disaster Preparedness Agency to ensure access to the necessary resources for response in the least amount of time. This cooperative approach includes the following: 1. Alert employees of the potential hazard and evacuate all employees from the area. 2. Dial 911 to alert local response agencies of the event. 3. Contact representatives at the U.S. Naval Weapons Station. 4. Supervisors or management will ensure all employees exit the facility in a safe manner. 5. The emergency response team shall evaluate th e release event and repair any damage when possible. 6. County resources will coordinate informing the public and protecting the community or environment when necessary. Provisions of the emergency response plan include the identification of adequate first aid, medical treatment, fire fighting, and security services within the surrounding community to ensure the well being of those affected in the event of a release. Planned changes to improve safety No changes have been planned for the Goose Creek, South Carolina facility. |