Wastewater Treatment Plant - Executive Summary |
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Executive Summary for the Battle Creek Wastewater Treatment Plant 1. Accidental Release Prevention and Emergency Response Policies We at the Battle Creek Wastewater Treatment Plant are strongly committed to employee, public and environmental safety. This commitment is inherent to a comprehensive accidental release prevention program in place that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Unforeseeably, if such a release does occur, we are completely coordinated with Battle Creek Fire Department (HAZMAT) which provides highly trained emergency response personnel to control and mitigate the effects of the release. The HAZMAT team also coordinates their response with the Calhoun County LEPC and state, local, and federal emergency response agencies. 2. The Stationary So urce and the Regulated Substances Handled Our facility's primary activities encompass municipal wastewater (sewage) treatment. We have 1 regulated substance present at our facility. This substance is Chlorine. The regulated substance at our facility is involved in several uses. Chlorine is used for disinfection and process control. Chlorine is used in two buildings within the facility, the Opertions Building and the Chlorine Building. Chlorine is present within two rooms in each building. All Chlorine locations are interconnected by a piping system. Together these four locations and the piping comprise our one and only Chlorination process. The maximum inventory of Chlorine at our facility is 96000.00 lb. at two locations, in 2000 lb. containers. 3. The Worst Case Release Scenario and the Alternative Release Scenario (including administrative controls and mitigation measures to limit the distances for each reported scenario) To evaluate the worst case scenari o, we have used the look-up tables and equations provided by the EPA in the EPA Risk Management Program Guidance for Wastewater Treatment Plants. For alternative release scenario analyses, we have employed the look-up tables and equations provided by the EPA in the EPA Risk Management Program Guidance for Wastewater Treatment Plants. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 3 toxic substances involves a catastrophic release from the Chlorination process. The scenario involves the release of 2000 lb. of Chlorine in a liquid form over 10 minutes. No mitigation is taken into account to calculate the scenario. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 1.3 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. The alternative release scenario for Chlorine involves a release from the Chlorination process. The scenario involves the release of 2000 lb. of Chlorine in a gaseous form over 133.3 minutes. Passive mitigation controls such as enclosures are taken into account to calculate the scenario. Under Class D atmospheric stability, with 3.0 m/s windspeed, the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 0.10 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The Chlorination process at our facility is subject to the OSHA PSM standard under 29 CFR 1910.119. We also have an air operating permit pending (Michigan ID - B6307) under Title V of the Clean Air Act. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information The Wastewater Treatment Plant maintains a detailed record of safety informa tion that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is the "what-if" method. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of three (3) years. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, the Wastewater Treatment Plant maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround . The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Wastewater Treatment Plant has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every three (3) years and more frequently as needed. Mechanical Integrity The Wastewater Treatment Plant carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls, pumps, leak detectors, and ventilation systems. Maintenance operations are carried out by qualified personnel or contractors with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed . Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at the Wastewater Treatment Plant to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as needed at the Wastewater Treatment Plant. These reviews are conducted in conjunction with management of change procedures to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits The Wastewater Treatment Plant conducts audits on a regular basis t o determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every three (3) years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation The Wastewater Treatment Plant promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of five (5) years. Employee Participation The Wastewater Treatment Plant truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all i nformation created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. Company employees actively serve on the Process Safety Management team. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Specification require that contractors adhere to all federal, state, and local safety regulations and company policies. The Wastewater Treatment Plant has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes, and of coordinating safety issues with contractors and Wastewater Treatment Plant employees. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. Contractor safety performance is reviewed at the time of contract acceptance, annually thereafter, and at all construction progress meetings. 5. Five-year Accident History The Wastewater Treatment Plant has had an excellent record of preventing accidental releases over the last five years. Due to our stringent policies and procedures, there have been no reportable accidental releases in the last five years 6. Emergency Response Plan The Wastewater Treatment Plant carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan covers all aspects of emergency response including isolation, evacuations, and notification of a qualified and staffed local emergency response provider. The facility's emergency response plan is incorporated in the City's overall emergency plan. This plan extensively details large scale evacuations, notification of the public and other agencies, and clean-up procedures. Our plans are periodically reviewed and updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. T he Battle Creek Fire Department (HAZMAT) emergency response team is the responding agency for uncontrolled releases of hazardous substances at our facility. Their emergency response program includes extensive training and procedures for incident command, controlling releases, mitigation, evacuation, first-aid and medical care, and wide scale reponse notification and coordination. The Calhoun County LEPC is the Local Emergency Planning Committee (LEPC) which has been notified of our highly hazardous materials as required, and with which our emergency plan provisions have been coordinated. 7. Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Additional mitigation devices, excess flow valves, reduction of inventories, and revised procedures are some of the steps which have already been taken to improve Chlorine safety at our facility. Additional leak sensors a nd annunciators are expected to be installed to further improve or safety and response. These changes are expected to be implemented by 10/01/1999. 8. Certification Statement The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. Name: Lawrence L. DeLong Signature: Title: Wastewater Treatment Superintendent Date signed: June 14, 1999 |