Carmel Wastewater Treatment Plant - Executive Summary |
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City of Carmel Wastewater Plant - Risk Management Submittal Executive Summary Chlorination Process Accident release and Emergency Response Procedures The City of Carmel Water/Wastewater Utility prides itself in having sound safety policies and procedures in place to protect the public, utility employees and the environment. This is first exhibited by upper managements commitment to safety in all aspects of utility operations, with a special emphasis on chemical safety at our wastewater treatment facility. We fully recognize the hazards certain chemicals present and are committed to providing the needed funds for up to date equipment and ongoing training. Overview of Facility The City of Carmels Wastewater Treatment Plant, located at 96th and Hazel Dell Road, provides wastewater treatment for the City of Carmel, Clay Waste Regional Sewer District, the City of Westfield, and Hamilton Western Utilities. The plant is rated to treat 12 million gallons per day with the current avera ge being 7.5 million gallons per day. As part of the treatment process we are required by our wastewater permit to disinfect the wastewater with chlorine prior to it being discharged into the West Fork of the White River. We are required to use chlorine from April 1 through October 31. Prior to discharging into the White River we must remove the large majority of the chlorine to prevent hurting the aquatic life in the river. This is done by feeding Sulfur Dioxide which removes the chlorine. The total amount of chlorine we store at the plant is 4000 pounds. The total amount of sulfur dioxide is also 4000 pounds. For our RMP submittal we are only required to submit a Risk Management Plan for chlorine given that the limit for sulfur dioxide is 5,000 pounds. However, our procedures for the safe handling and operations of sulfur dioxide are much the same as with chlorine. Worst Case Release Scenario This scenario represents a worst case release of chlorine from a 1-ton cylinder. Data f or this release analysis is described below. RMP*Comp was used to calculate the worst case scenario. Description: Catastrophic failure of a 1-ton cylinder of chlorine due to corrosion, impact, or construction defects. Amount Released: 2,000 pound total release 200 pounds per minute release rate 10 minute duration Release Location: Chlorine loading are, outside the chlorine room (No mitigation) Urban setting End Point Concentration: The maximum concentration below which nearly all individuals could be exposed for 1 hour without experiencing or developing serious health effects. Developed by the American Industrial Hygiene Association. Equal to 3 parts per million chlorine in the air. Distance to End Point (Calculated Radius): 1.3 miles (2.1 Kilometers) Receptor Data An endpoint circle with a radius of 1.30 miles includes a small portion of southeast Carmel, a small portion of western Fishers, and a small area in the northern portion of Marion County. The potentially affected p opulation within this circle is estimated to be 4,000 people. A release of this magnitude could require an evacuation of some residential areas dependent upon the wind direction. Within this area are industrial areas, some small offices, parks, and some residential areas. The major environmental receptor within the affected area is the West Fork of the White River. This river flows from northeast to southwest between the Citys of Carmel and the Town of Fishers, Indiana, and then south through the City of Indianapolis. Alternate Release Scenario This scenario represents an alternate case release of chlorine from a 1-ton cylinder. Data for this release analysis is described below. RMP*Comp was used to calculate the alternative case scenario. Description: Gas valve failure on a 1-ton cylinder of chlorine due to impact or other damage. Amount Released: 477 pound total release 7.95 pounds per minute release rate 60 minute duration Release Location: Inside the chlorine room; (Par tial mitigation) Released in an enclosed space with direct contact with the outside air Urban setting (Few buildings or obstructions) End Point Concentration: The maximum concentration below which nearly all individuals could be exposed for 1 hour without experiencing or developing serious health effects. Developed by the American Industrial Hygiene Association. Equal to 3 parts per million chlorine in the air. Distance to End Point (Calculated Radius): 0.1 miles (2 Kilometers) Receptor Data An endpoint circle with a radius of 0.1 miles includes a small section on the southeastern side of the City of Carmel, a small section of the southwest portion of the City of Fishers, and small portion of northern Marion County. The potentially affected population within this circle is estimated to be 100 people which is primarily employees of asphalt and stone companies. The residential population would be zero (0). The relatively low population within this endpoint circle is due to much of the area being industrial in nature, some undeveloped area, and local road ways. In the event of a chlorine release, additional concern should be given to motor vehicle and pedestrian traffic near the wastewater plant. The major environmental receptor within this affected area is the West Fork of the White River located just east of the plant. Accident Release Prevention Program - Chlorine The City of Carmel's Wastewater Treatment Plant falls under the guidelines of the OSHA process safety regulations for chlorine, and have been in place since May of 1997. The following is a description of how chlorine is handled to prevent accidental releases. CHLORINE OPERATIONS - Operating Procedures The purpose of this procedure is to ensure that the Carmel Wastewater Treatment Plant maintains up-to-date, accurate, written operating procedures that provide clear instructions for the process. Effective operating procedures, when combined with operator training, are instrumental in ensuring safe operation of the systems and preventing accidental releases. Written operating procedures for the chlorine system address the following operating phases: Initial Startup Cleaning and Testing Chemical Piping Injector Vacuum and Leak Test Gas Supply Check for Leaks Normal Operations Leaks Emergency Shutdown and Operations Normal Shutdown Changing Cylinders Temporary Operations Chlorine Detector Sensor Test Equipment Inspections The operating procedures are reviewed as often as necessary to assure that they reflect current practices. Responsibilities The Plant Superintendent has overall responsibility for implementing this procedure and ensuring operators and maintenance personnel have routine access to all operating procedures. Operating procedures are maintained in the Superintendent's office, the Maintenance office, and in the Emergency Cabinet marked Risk Management Document. The Plant Superintendent annually certifies that these operating procedures are current and a ccurate. Maintenance Purpose The purpose of a maintenance program is to maintain the on-going mechanical integrity of the process equipment. An effective maintenance program is critical to preventing accidental releases that may result from mechanical failure of improperly maintained equipment. Responsibilities The Plant Superintendent has overall responsibility for implementing the mechanical integrity program. The maintenance personnel assist the Plant Superintendent in implementing this procedure. Critical Equipment The critical equipment list is essential in maintaining the mechanical integrity of the program and process equipment. All critical equipment regarding the chlorine process is identified below. This list is important in ensuring a safe system operation. Chlorinators Vacuum Regulators Piping and valves Injectors Instrumentation Alarms Relief Vents Ventilation Leak Detectors Weigh Scales Hoist Requirements for Critical Equipment Inspection, testing, and maintenance procedures are developed to maintain the mechanical integrity of the equipment and to ensure safe and proper operation. Maintenance Documentation A record keeping system is developed to ensure that each procedure is documented and completed at the required frequency. Records are kept by maintenance personnel and include the following information: Date of maintenance (inspection, test, or other activity) Identification of individual performing the maintenance Identification of the equipment involved Identification of what maintenance was performed Result of maintenance performed Maintenance Training The owner or operator trains each employee involved in any maintenance practices by themselves or by other qualified individuals. The employee is trained in the hazards of the process, in how to avoid or correct unsafe conditions, and in the procedures applicable to the employee's job tasks. Any work that is contracted out must ensure that the contract maint enance employee is trained to perform the maintenance procedures. Consequences of Deviation Purpose The purpose of consequences of deviation is to provide information on the consequences of improper operation or maintenance of the chlorine system. Deviation from safe and proper operation of the equipment can lead to serious problems affecting the public and other environmental receptors. Chlorine gas is a respiratory irritant. Exposure to chlorine gas can lead to irritation of the mucous membranes, the respiratory system, and the skin. In extreme cases, suffocation and death can occur. Therefore, the following should always be done: Leaks must be repaired immediately. All chlorine gas must be removed from the equipment before any maintenance activity. Always wear Self-Contained Breathing Apparatus (SCBA) when there is a possibility of chlorine released to the atmosphere. Moisture must be excluded from any part of the equipment, which is normally exposed to dry chlorine on ly. Dry chlorine is non-corrosive, moist chlorine is extremely corrosive to common metals, such as brass or steel. Therefore, the following should always be done: Never apply water on a chlorine leak. When any connection is broken immediately plug the opening with a rubber stopper or equivalent to prevent entrance of moisture. Always clean and dry piping before initial startup or after a prolonged shutdown to ensure that any moisture is removed. Safety Information and Hazard Review Safety Information Purpose The purpose of this procedure is to provide safety information on the operation of the chlorine system and information on the safety equipment involved in the system. Responsibility The Plant Superintendent has overall responsibility for maintaining and implementing this procedure. The Plant Superintendent assigns additional qualified individuals as listed in the procedure to assist in compiling and maintaining the necessary information. The owner or operator update s the safety information if a major change occurs that makes the existing information inaccurate. Five Year Accident History The Carmel Wastewater Treatment Plant has had no chlorine releases in the last five years, or in the total lifetime of the plant, that have resulted in any off-site consequence. During the last five years we have had one very small leak, (less than a pound) that resulted in one employee having some eye and throat irritation. The employee was able to return to work the next day. Emergency Response Plan ( NOTE: The City of Carmel Wastewater Treatment Plant personnel do not respond to chlorine releases that result or are likely to result in an uncontrolled release. This does not include any efforts for incidental releases (minor leaks) that can be controlled at the time of release by employees in the immediate area, or by maintenance personnel. Purpose The purpose of this section is to formally outline procedures to be followed in an emergency situation inv olving an uncontrolled release of chlorine. This emergency action plan has been developed to ensure that in case of such an event, the personnel at the Carmel Wastewater Treatment Plant personnel respond safely and properly. Responsibility The RMP Program Manager has the overall responsibility for the safety of the employees at the Carmel Wastewater Treatment Plant. The evacuation of all employees from the Wastewater Treatment Plant is the first priority. The second priority is to inform the Carmel Fire Department of the situation. The safety of the public and control of the chlorine leak are the duty of the fire department. The City of Carmels Hazardous Materials Response Unit is responsible for control of the chlorine leak and evacuation of any affected residents. Chlorine Emergency Procedure Whenever there is imminent or actual chlorine emergency, the RMP Program Manager (or his designee, when he is offsite) must immediately: Notify everyone at the facility of the situatio n. Determine the area affected by the chlorine and the outdoor wind direction using wind direction signals on top of the control building. Telephone the fire department; DIAL 911. Give them all available information about the leak: What is leaking; Chlorine Whether the chlorine leak is liquid or gas Where the chlorine leak is located How the chlorine is leaking out When the leak started Outdoor wind direction Plant Evacuation Procedure This procedure is to be followed in the event of an emergency that would require the employees within the plant to evacuate. Primarily this would be in case of an imminent or actual risk of a chlorine release. The following procedure is followed if the RMP Program Manager (or his designee, when he is offsite) determines the need for a plant evacuation. The RMP Program Manager must immediately: Notify everyone at the facility of the situation. Based on the wind direction, determine the proper exit door to use for the evacuation to avoid chlori ne fumes. Choose the exit door that routes the employees to move upwind when they exit. Inform all employees of the appropriate assembly point as they exit. The assembly point is the area to gather during an evacuation so that all personnel can be accounted for. The area is dependent upon the wind direction and the exit door used. The assembly points are: Administrative building On the platform near the top of the diversion structure On the west side of the building near grit tank #3 In front of the pole barn on the north side of the plant property Telephone the fire department; DIAL 911. Give them all available information about the emergency. Move to the assembly point and account for all personnel. NOTE: If someone is missing do not reenter the building to search. Inform the fire department of the missing person when they arrive. Emergency Training The City of Carmel conducts annual awareness-level training for all personnel at the Wastewater Treatment Plant. The RMP Program Manager is responsible to ensure that the training is scheduled, conducted and documented. The training is to be of sufficient length to ensure that each employee is given a review of the following items: Emergency evacuation procedures, routes and safe assembly points. Emergency contact telephone numbers and notification procedure. The limits of incidental response; Minor leaks and the procedures for fixing them. The RMP Program Manager maintains the documentation of all training. Medical Treatment for Chlorine Exposure Exposure to high concentrations of chlorine can result in difficulty in breathing and, if prolonged, finally death through suffocation. Even low concentrations can result in minor eye and throat irritation if the exposure is long enough. Any exposure to chlorine should receive immediate medical attention. The following are steps to take while waiting for the proper medical attention: Severe exposure: Seek medical attention immediately Remove to a s afe area Place in a comfortable position If breathing stops start artificial respiration immediately If heart stops start CPR (by trained personnel) Clothing or skin contamination: Flush area with water under shower for at least 15 minutes While in shower remove affected clothing See a physician, do not attempt any medical treatment or to neutralize chlorine Eye contamination: Immediately flush eyes with tepid water Part eyelids and flush for at least 15 minutes See a physician, do not attempt any medical treatment or to neutralize chlorine Planned Changes to Improve Safety The implementation of the Risk Management Plan should only improve safety. It is our intent to implement evacuation drills on a semi-annual basis, and to conduct better evacuation/awareness training with new employees. This includes promoting proper fit testing for SCBA equipment and the corresponding training. In addition we have just recently installed new chlorine monitoring equipment and hoist equipment at t he Plant. |