Neenah Menasha Sewerage Commission - Executive Summary |
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Neenah Menasha Sewerage Commission Risk Management Program Executive Summary The Facility The Neenah Menasha Sewerage Commission is a wastewater treatment facility located in the City of Menasha, Wisconsin, next to Little Lake Butte des Morts. The facility uses chlorine to disinfect the plant effluent prior to discharge. The facility's NPDES permit requires disinfection from May 1 through September 30 each year. The facility also uses chlorine to destroy undesirable organisms in the biological treatment process (filamentous organism reduction). The Neenah Menasha Sewerage Commission stores chlorine at the facility year round. The facility has stored on-site an average of 6000 pounds of chlorine. Handling of chlorine is limited to: 1) unloading cylinders from the delivery truck and placing the cylinders into the storage area 2) connecting full tanks to the feed system and disconnecting empty tanks. The facility has worked safely with chlorine for 30 years. The staff receives b oth on the job training and classroom training for chlorine handling. The Neenah Menasha Sewerage Commission is committed to the safe handling of chlorine for the protection of the employees, the public and the environment. Although the Commission is not yet required to comply with OSHA's 1910.119 Process Safety Management, the facility has been in compliance with this safety standard since 2/29/96. The facility will convert to sodium hypochlorite by the year 2000 thus eliminating the need for chlorine gas. Management System The purpose of the management program is to ensure that everyone who plays a part in the RMP understands their roles and that responsibilities are assigned for all program elements. Randall R. Much, General Manager has the overall responsibility for development, implementation and integration of the RMP. Jim Peichl has overall responsibility for the RMP in the absence of Randall R. Much. Other key plant personnel have been assigned responsibilities to match their expertise and knowledge of the subject. The program was designed to include the involvement of all plant personnel. RMP Organization: RMP Program Element Responsible Employee(s) Overall Responsibility -RMP Manager...Randall Much Alternate RMP Manager..Jim Peichl Process Safety InformationJim Peichl, Laurie Stenson Process Hazard AnalysisJim Peichl, Laurie Stenson, Safety Committee Operating Procedures..Terry Wingrove, Plant Operators Training...Jim Peichl, Marilyn West, Laurie Stenson Contractor Safety..Randall Much, Jim Peichl Prestartup Safety Reviews.Jim Peichl, Terry Wingrove Mechanical Integrity......Jim Peichl, Maintenance Staff Hot Work Permit.....Jim Peichl Management of Change....Randall Much, Jim Peichl Incident Investigation.....Safety Committee - Laurie Stenson Emergency Planning and Response.Randall Much, Laurie Stenson Compliance Sa fety Audits.....Safety Committee - Laurie Stenson RMP Updates (5 year and Changes)Jim Peichl, Laurie Stenson Worst-case Release Scenario and the Alternative Release Scenario The Neenah Menasha Sewerage Commission (NMSC) has analyzed the off-site impact of a release using the "EPA's RMP OFFSITE CONSEQUENCES ANALYSIS GUIDANCE." The worst-case release scenario for the NMSC would be a release of a 2000-pound cylinder outside of the storage room. This could only occur when the cylinders are being taken off the delivery truck. Personnel are trained in this procedure and the employees treat chlorine with respect, so it is unlikely that a release of this type would occur. Meteorological conditions for the worst-case scenario are defined by the EPA's Guidance Manual as atmospheric stability F (stable atmosphere), wind speed 3.4 mph, and ambient air temperature of 770 F, and 50% humidity. The scenario requires a ground level release and a toxic endpoint of 0.0087 mg/l. The off-s ite impact of this release would be 5.4 miles. The alternative scenario would be the release of the 2000-pound cylinder inside of the building. In the unlikely event of a chlorine release it is more probable that it would occur inside the storage area. The building would mitigate the release. Meteorological conditions for the alternative scenario are defined by the EPA's Guidance Manual as atmospheric stability D, wind speed 6.7 mph, ambient temperature 770 F, and humidity 50%. The scenario requires a ground level release and a toxic endpoint of 0.0087 mg/l. The off-site impact of this release would be 0.58 miles. Accidental Release Prevention Program The Neenah Menasha Sewerage Commission's (NMSC) prevention program follows the guidelines provided in OSHA's 1910.119 Process Safety Management Standard. The NMSC has several controls in place: Engineering Controls: Chlorine is stored in a room separate from other facility processes. The chlorine room is locked and posted with a "Danger Chlorine" and "Authorized Personnel Only" sign. The chlorine room has a leak detection system with an alarm. Administrative Controls: This facility is staffed 24-hours per day. This facility has written chlorine-handling procedures. When changing tanks, two employees are required for connecting and disconnecting the tanks. One operator attaches the connecting valves, while the other operator uses the ammonia bottle to check for leaks. Operators wear respiratory protection while changing tanks. Plant safety procedures in place include Lockout/Tagout, Hazard Communication, and Respiratory Protection. Plant personnel attend annual training sessions for all safety-related issues. The Mechanical Integrity Program includes regular testing and inspection of the equipment. Personal Protective Equipment: In the event of a chlorine leak the facility is equipped with SCBA, gloves, boots, and rain gear. This equipment is to be used for small connection leaks or emergency rescue of employees only. Any sizable rupture or leak will be handled by calling 911 and alerting the HAZ MAT Team. Plant personnel will contain the leak if possible by closing the doors of the storage area and turning off the exhaust fan. Five-year Accident History There have been no accidental releases with the chlorine system at the Neenah Menasha Sewerage Commission. Emergency Response Program The Neenah Menasha Sewerage Commission has an Emergency Action Plan as part of its Safety Manual. Included in this plan are procedures in the event of a chlorine emergency. Additionally, the NMSC coordinates an off-site plan for chlorine emergencies with the County LEPC, HAZ MAT, local fire departments and local police departments. The emergency response plan for a chlorine release is reviewed at least annually by all plant personnel. Planned Changes to Improve Safety The facility will convert to sodium hypochlorite by the year 2000 thus eliminating the need for chlorine gas. Until t hat time the facility will continue to implement the current safety and training program that has to date prevented any release of chlorine gas. |