Muskegon Heights Water Filtration Plant - Executive Summary |
|
Muskegon Heights WFP is a municipal drinking water treatment plant. Their facility is located at 2323 Seminole Road in Muskegon, Michigan. The following document contains information intended to analyze the impacts of an accidental release of an extremely hazardous substance and to highlight the steps the facility is taking to prevent a release from occurring. This document meets the requirements of the U.S. Environmental Protection Agency (EPA) Clean Air Act Risk Management Program rules listed in 40 CFR Part 68. The intent of the rule is to reduce the likelihood of a chemical release and the consequences of a release if one were to occur. The process uses chlorine which is a regulated substance under the Risk Management Program. Muskegon Heights WFP has a maximum inventory of 8,000 pounds of chlorine, which surpasses the EPA threshold of 2,500 pounds. The following requirements were used in the determination that the facility is Program 3: Subject to Occupational Health and Safety Association (OSHA) Process Safety Management (PSM) The worst-case release resulted in an offsite impact Because of the potential hazards when using chlorine, it is essential that steps be taken to minimize the risk of a catastrophic release. The prevention program for Muskegon Heights WFP complies with 40 CFR 68 Subpart D and includes process safety information(PSI), a process hazard analysis (PHA), and procedures for the following: operating, training, mechanical integrity, management of change, pre-startup safety review, compliance audit, incident investigation, employee participation, hot work permit and contractors. The purposes of the PSI are to compile and update written process information for use by employees, PHA teams, and auditors. The PHA identifies, evaluates, and controls the hazards and risks associated with processes using regulated substances. Operating procedures provide instruction for safe operation of each stage (initial and emergency s tartup; normal, temporary, and emergency operations; and emergency and normal shutdown). Training ensures that the operators and other personnel working on or near regulated processes are properly instructed in the hazards and response actions associated with the release of regulated substances. Mechanical Integrity requires the identification, inspection, and testing of the process equipment. Furthermore, mechanical integrity creates and implements written practices for maintaining the process equipment. Management of Change reviews the changes made to process chemicals, technology, equipment, and procedures. The Pre-Startup Review is to be performed in conjunction with the management of change. The review examines the safety of new and modified regulated processes. The Compliance Audit evaluates the owner's or operator's conformance with the requirements of Program 3. Incident Investigations review all occasions that resulted in, or had the possibility of resulting in a relea se of the regulated substance. Employee Participation guides the involvement of operators or other personnel in the creation and implementation of Program 3 provisions. Hot Work Permits are to be issued for all hot work carried out or near a regulated process. A Contractor review ensures that the performance of all outside contractors is evaluated in regard to their safety and adherence to established programs. In addition, the Contractor review provides notification to contractors regarding process hazards associated with the regulated substances. To predict the offsite impact in the event of an emergency, a hazard analysis was conducted according to the procedures outlined in the rule. The worst case release quantity for toxic gases is assumed to be a release of the largest container in the process during a period of 10 minutes. The maximum quantity of chlorine stored in any one container at the facility is 2,000 pounds. Therefore, the release rate used in the consequence mo deling was 200 pounds per minute for the entire 10-minute release period. No mitigation or administrative controls were considered. Due to the extensive preventative maintenance procedures, training, and emergency response procedures that have been implemented at Muskegon Heights WFP, it is highly unlikely that this scenario would occur. For Program 3 processes, the rule requires that at least one alternative release scenario be analyzed for each regulated toxic substance. The alternative release scenario must be more likely to occur than the worst case and must have an offsite impact whenever possible. Potential alternative release scenarios for Muskegon Heights WFP include valve leaks, gasket leaks, and pipe breaks. Because a valve break would result in the greatest quantity released and the greatest release rate, this was determined to be the alternative release scenario. Monitoring equipment at the facility will detect low levels of chlorine and alert staff of a possible lea k. In the event of a release inside the facility, prompt response and control measures would be implemented. However, for purposes of this analysis, the entire contents of one container (2,000 pounds) were assumed to be released over a one- hour period. The chlorine containers are stored in an enclosed room which would provide mitigation of a release should one occur. The RMP Offsite Consequence Analysis Guidance published by the EPA recommends applying a 55% mitigation factor for releases in enclosures. This factor was used in the alternative release scenario for Muskegon Heights WFP. The hazard analysis performed for the facility also includes a review of the five year accident history. During the past five years, Muskegon Heights WFP has not had an accidental release that met the criteria of 40 CFR 68.42(a). Muskegon Heights WFP has been actively involved in emergency response planning. They have worked closely with the Muskegon County Local Emergency Planning Committe e (LEPC) to develop standard operating procedures (SOPs) for offsite response. Muskegon Heights WFP is a Program 3 source and a non-responding facility. The Muskegon Heights WFP Emergency Response Plan outlines procedures for internal response to incidental releases and notification and coordination with the local emergency response organizations in the event of an incidental release which cannot be contained and will have offsite impacts. |