Mt. Vernon Water Treatment Plant - Executive Summary |
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EXECUTIVE SUMMARY INTRODUCTION Andrew and William McFadin were the first to carve homesteads in the Posey County wilderness in 1805. Travelers on the Ohio were glad to see the homesteads and were attracted to the bluffs "landing". In 1806, the struggling community was named McFadins Bluff. In 1816 a group of men gathered at the cabin of Andrew McFadin and renamed the now thriving community, "Mt. Vernon"; in honor of George Washington and his plantation on the Potomac River. Indiana was also admitted to statehood in 1816. As the community continued to grow and expand, a Water Treatment plant was constructed in 1886 on the high bluff overlooking the beautiful Ohio River. The plant remains, today, in its original location. THE PROCESS The City of Mt. Vernon Water Department accidental release prevention policy involves a unified approach that integrates technologies, procedures, and management practices. All applicable procedures of the U.S. Environmental Protection Agency ( EPA) Prevention Program are followed. The Water Department emergency response policy involves the preparation of response plans that are tailored to the facility and to the emergency response services available in the community, and is in compliance with the EPAs Emergency Response Program requirements. The Mt. Vernon Water Treatment Plant Chlorination Station has been installed to disinfect the flow in the Mt. Vernon Trunk Lines. This water serves Mt. Vernon and rural areas within 3 miles of the city. The chlorination station is located on College Avenue and Water Streets. The station includes a totally enclosed chlorination room, which contains liquid chlorine containers, a chlorinator, and various safety equipment; and an instrument room, which contains a flow recorder, various electrical panels, and additional safety equipment. The chlorine is used and dispensed from two one-ton containers. The facility is normally unmanned. Water treatment operators visit the facility each shift and respond to any trouble alarms that may occur. The facility is subject to the OSHA Process Safety Management regulation because Indiana is a "Program State". SCENARIOS The offsite consequence analysis includes consideration of two chlorine release scenarios, identified as "worst case scenario" and "alternative case scenario". The worst case scenario (WCS) as defined by EPA; which states that "the owner or operator shall assume that the ... maximum quantity in the largest vessel ... is released as a gas over 10 minutes," due to an unspecified failure. The alternative case scenario (ACS) is defined as "more likely to occur than the worst-case release scenario". Atmospheric dispersion modeling has been performed to determine the distance to the toxic endpoint for each scenario. The toxic endpoint used is specified by EPA at 3 ppm, which is the Emergency Response Planning Guideline Level 2 (ERPG-2) or (.0087 mg/liter). This is defined by the American Industrial Hygiene Asso ciation (AIHA) as the "maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ability to take protective action". Additionally, because the chlorine cylinders are unloaded, stored, and dispensed inside a fully enclosed block building; a credit of 55% of the total amount released has been incorporated. The resultant releases were plotted using NOAAs ALOHA toxic modeling program. WORST CASE SCENARIO The contents of one, one-ton cylinder (2000#) was considered released over a 10 minute period due to catastrophic cylinder failure of unknown consequence. This would create a release rate of 200# per minute. Taking a credit (55%) for passive mitigation of the block building; the actual release rate plotted would hence be 110# per minute. Using this information and the prescribed atmospheric c onditions of 1.5 meters per second wind speed at stability class F; the distance to the toxic endpoint is 2.5 miles. Actuation of the chlorine detector is an active mitigation measure considered, and even though in this worst case scenario it would not minimize the release size; it would allow for the Water Treatment plant operators to begin emergency response and notification measures at an earlier time; thus minimizing the risk to the public. It should be noted that it would be extremely difficult to have a release comparable to this worse case scenario because of all the safeguards in place. About the only two ways a release of this magnitude could occur would be if the safety release plug on the cylinder were to fail, or if the cylinder itself, were to fail. ALTERNATIVE CASE SCENARIO A rupture of a =" flexible plastic solution line feeding chlorine from the cylinder to the chlorinator was considered. The flow through this line is regulated at 200# per 24 hour period; or .139# per minute. Taking into consideration the passive mitigation of the block building; the actual release rate plotted would hence be .076# per minute. Using this information and the prescribed atmospheric conditions of 3.0 meters per second wind speed at stability class D, and plotting for a release that continues for 60 minutes; the distance to the toxic endpoint is 53 yards. Actuation of the chlorine detector is an active mitigation measure, and even though it was not considered in this scenario; it would definitely minimize the released amount since it would allow for executing the Emergency Response and notification plans at an earlier time; resulting in action being taken to stop the release within the first 60 minutes. ACCIDENT HISTORY There have been no accidental releases of chlorine at this facility in the past five years. PLANNED CHANGES TO IMPROVE SAFETY: Fourteen changes to improve safety (recommended actions) were identified in February 1999 during a HAZOP con ducted by local Emergency Planning officials, environmental experts from local industry and operating personnel from the Water Treatment Plant. These recommended actions have now been evaluated and implementation will be complete by August 1, 1999. These include: 7 Provide abrasion protection to chlorine tubing under floor channel-(complete) 7 Install low/high chlorine (residual in water) alarms in PLC-(complete) 7 Install low/high chlorine flow rate alarms in PLC-(complete) 7 Automate reporting of visual inspections on PLC-(complete) 7 Relocate emergency shutdown breaker to outside of room-(complete) 7 Install guards on roto-meters-(complete) 7 Investigate if system shutdown occurs on high chlorine alarm 7 Relocate safety shower to outside of chlorine room-(complete) 7 Relocate chlorine sensor to lowest point in room-(complete) 7 Improve audible volume on plant alarm-(complete) 7 Keep log of OJT for each operator-(started) 7 Obtain chlorine repair kit-(complete) 7 Need written h oist inspection procedures with recorded inspection reports -(complete) 7 Complete written operating procedures-(in progress) REVIEW AND UPDATE The Mt. Vernon Water Department plans to review and update the offsite consequence analysis at least once every five years. If changes in processes, quantities stored or handled, or any other aspect of the facility might reasonably be expected to increase or decrease the distance to the endpoint; the Water Department will complete a revised analysis within six months of the change and submit a revised risk management plan. The following procedures are being included in the Mt. Vernon Water Department General Operation and Maintenance Manual for Chlorination Stations; which is under development: 7 Initial startup 7 Normal operations 7 Emergency shutdown and operations 7 Normal shutdown 7 Startup following a normal or emergency shutdown or a major change that requires a hazard review 7 Consequences of deviations and steps required to c orrect or avoid deviations 7 Equipment inspections The Mt. Vernon Water Department will review these operating procedures annually and whenever a major change occurs and prior to startup of any changed process. TRAINING (68.54) Mt. Vernon Water Treatment Plant ensures that each employee presently operating the chlorination process, and each employee newly assigned to this process have been trained or tested competent in the operating procedures listed above that pertain to their duties. The water treatment plant employee training documentation files include a written certification for each employee assigned to operate the chlorination process that the employee has the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as provided in the operating procedures. Refresher training is provided annually to each employee operating the chlorination process to ensure that the employee understands and adheres to the current operating procedures of the process. The Mt. Vernon Water Department ensures that operators are trained in any updated or new processes prior to startup. These training records were not maintained prior to the inception of this plan; however, this is now being accomplished and will continue to be maintained by the Plant Superintendent. MAINTENANCE (68.56) The Mt. Vernon Water Department has prepared and implemented procedures to maintain the on-going mechanical integrity of the chlorination process equipment. A part of these procedures include an annual contract with Living Waters: a contract firm who provides maintenance of chlorine systems. As part of their annual contract, Living Waters checks and repairs the following: all chlorine handing lines, all fittings, valves, gaskets, and in-line appliances. They provide an annual report to the Mt. Vernon Water Department. The Mt. Vernon Water Department has trained each employee involved in maintaining the on-going mechanical integrity of the chlorination process. Some procedures or instructions were provided by chlorination process equipment vendors. . These training records were not maintained prior to the inception of this plan; however, this is now being accomplished and will continue to be maintained by the Plant Superintendent. . INCIDENT/ACCIDENT INVESTIGATIONS Any incident or accident will be immediately investigated. The Mt. Vernon Water Department will promptly address and resolve any investigation findings and recommendations. The findings will be reviewed with all affected personnel whose job tasks are affected by the findings. Resolutions and corrective actions will be documented. A written report of these incident/accidents, and their corrective actions will be maintained for at least 5 years. EMERGENCY RESPONSE PROGRAM (68.95) The facility has an emergency response plan, which was developed and coordinated with the Mt. Vernon Fire Department. This program includes an emergency response decision tree a nd a notification plan. Emergency response drills and drill evaluations are planned annually; after which, emergency operation and response procedures will be reviewed. The following elements are included in the plan: 7 procedures for emergency response after an accidental chlorine release 7 procedures for the use of emergency response equipment 7 training in relevant procedures for all employees 7 procedures to review and update, as appropriate, the emergency response plan to reflect changes and to insure that employees are informed of changes The facility Emergency Response Plan is attached as Appendix A. APPENDIX A EMERGENCY RESPONSE PLAN EMERGENCY ACTION PLAN ISSUED APRIL 1, 1999 for: Mt. Vernon IN. Water Works 29 CFR 1926.35 and 29 CFR 1910.38 EMERGENCIES COVERED UNDER THIS PLAN INCLUDE: Major emergencies- actual, natural, or vandal caused disasters; contracted employee deaths, three (3) or more employees are evacuated to a hospital. Accidental or Man-made Disasters - chemical spills, toxic gas release, explosions or fires. Natural Disasters - flooding, tornadoes, earthquakes, fires or winter storms. Vandalism - sabotage, riots, work stoppages and deliberate water contamination. Spill Response - A hazardous substance has been removed, contained, or neutralized. I. PURPOSE A. To provide for the safety of all city and contracted employees. B. This Emergency Action Plan is designed for Mt. Vernon IN. Water Works. C. Emergency - Any serious or unexpected situation that demands immediate action: D. Superintendents, their Supervisors and Contractor Safety Representatives. II. RESPONSIBILITIES A. All share the responsibilities of the implementation of the Emergency Action Plan . These include the following: 1. Designating an on site leader to serve as an EAP point of contact. 2. Reviewing the EAP with all jobsite employees, contractors and client/customer representatives. 3. Contacting and coordinating with Company Management in regards to interfacing with the media and governmental agencies; such as, IDEM and IOSHA. 4. Assessing the situation and taking appropriate action to minimize hazardous situations and exposures to all site employees and contracted personnel. 5. Posting the EAP where all personnel can see and read its provisions. 6. Directing all efforts in the area including evacuation of personnel and minimizing property loss. 7. Updating and amending the EAP as required by changes in work process or regulatory guidelines. 8. All contractors will comply with the provisions of the EAP as appropriate. They are also responsible for conveying this informat ion to their own employees. III. CONTACTS - All site employees and contractors must know exactly who to call in what order in the event of an emergency. Each contractor shall supplement this call list with their own. This includes the following: 911 Dispatch---Tell them who you are, what the emergency is, & what you need Superintendent--838-2565 (home)--463-1206 (pager) Mayors Office--838-5576 LEPC (Joe Straw)--838-1333 (office)--440-2363 (pager) A. Location of the primary and secondary evacuation route to be taken through the site. B. Each contractor shall have an Emergency Response Plan that shall use the primary route unless otherwise directed. The contractors Emergency Response Plan Leader shall identify individuals needed to act as guides along this route. C. Identification of the chain of command within the Emergency Response Plan 1. Site Evacuation - Evacuat ion procedures for the site will include the following: 2. Illustrated evacuation route, floor plans, site maps showing the Emergency Escape Routes along with safe refuge areas within and outside the site. 3. Each contractor is responsible for accounting procedures for all their personnel. 4. Dealing with the media IV. MEDIA SPOKESPERSON A. The company has designated the responsibility of a media spokesperson to the Mt. Vernon Water Works Plant Superintendent. NO ONE but the designated spokesperson is authorized to speak with news media. It is imperative that no other site employee become exposed to the potential liability that could arise from an interview regarding the emergency. V. EMERGENCY COMMUNICATION A. A hand held bull horn or portable horn will be used for emergency communication purposes at the site. The following signals will be used throughout the site. 1. Stop Work Order - one (1) blast of the horn /siren. - If you hear one blast while you are at the site stop work immediately and wait for further instruction from the Superintendent(s), your contractor safety representative or the on site supervisor. 2. Evacuation Order - two (2) blasts from the horn/siren. - If you hear two blasts while you are on the site go immediately to the safe evacuation area that is shown in this EAP and wait there for further instruction from the Superintendent(s) or Contractor Safety Representative. 3. All Clear Order - three (3) blasts from the horn/siren. - If you hear three blasts while you are on the site the emergency has been cleared and it is safe to return to work. 4. When total evacuation of the site is necessary, an alternate area where employees can report to, or which can act as a focal point for incoming and outgoing phone calls has been designated as City Hall Annex. The Super intendent(s) and the Contractor Safety Rep. shall inform police and/or emergency response team members the names of the individuals believed to be missing. VI. REQUIRED REPORTING IN AN EMERGENCY A. Management shall coordinate who shall contact the following agencies, in order; as necessary. 1. 911 -If the spill has the potential to affect anyone on or off site property. (Request they contact Mt. Vernon City Fire and Mt. Vernon Police.) 2. ALERT - If the spill causes, or has the potential to cause harm to any citizen. (Request 911 to contact) 3. LEPC -Local Emergency Planning Committee (838-1333) 4. IDEM -Office of Environmental Response - (888) 233-7745 5. NRC -The National Response Center (800) 424-8802 6. CHEMTREC (800) 424-9300 (for information & guidance for hazardous chemicals) VII. Spills or Releases of Hazardous Chemicals into surface water or to soil BEYOND the site boundary A. Report these spills to the Superintendent(s) immediately. B. The Water Dept will coordinate all communications to IDEM in regards to hazardous substances, leaks, or spills. C. IDEM requires a report to their office of Environmental Response at (888) 233-7745, within 2 hours IF the spill or release exceeds the Reportable Quantities listed below: RELEASE BEYOND SITE BOUNDARIES CHEMICAL REPORTABLE QUANTITY Chlorine-10 pounds Sodium Hydroxide-55 gallons Polyaluminum Chloride-55 gallons Gasoline-55 gallons Diesel Fuel-55 gallons Motor Oil-55 gallons VIII. Reportable quantities of chemical spills or releases to soil WITHIN the boundary. A. These releases or spills will be reported to the Superintendent(s) immediately. RELEASE WITHIN SITE BOUNDARIES CHEMICAL REPORTABLE QUANTITY Chlorine-any size Sodium Hydroxide-any size Polyaluminum Chloride-> 5 gallons Gasoline-> 1 gallon Diesel Fuel-> 1 gallon Motor Oil-> 1 gallon B. Immediate Actions - Refer to appropriate Material Safety Data Sheet (MSDS) 1. In the case of a Chlorine leak or release call 911 immediately. 2. Based on the type and volume of substance, contain the spill except chlorine 3. Perform appropriate spill response. 4. Call the people listed in VI. above. If necessary, contact the nearest downstream water users within 10 miles of the release or spill. 5. Notify affected property owners of spills or release OUTSIDE of boundaries. 6. If necessary, the Contractor Safety Rep. shall assist the Superintendent(s) to submit appropriate reports to IDEM and/or IOSHA IX. Contracted firms shall ensure that their employees are trained to understand the procedures in this EAP to include: A. How to respond to the alarm system. B. What the reporting procedures for personnel entail and who to report to. C. What must occur during a site shutdown. X. Based on the hazards at the site, contractors shall ensure their employees are trained in accordance with OSHA guidelines and with their internal safety programs, in the following areas and topics: A. Portable and/or fixed fire extinguishers. B. First Aid and Cardiopulmonary resuscitation (CPR). C. Evacuation procedures. D. Chemical spill control. E. Storage and use of flammable materials. F. Fire protection. G. Hazard Communication |