Mt. Carmel Water Treatment Plant - Executive Summary
EXECUTIVE SUMMARY |
We have adopted this Program in order to implement 40 C.F.R. 68, the federal requirements regulating Risk Management of Highly Hazardous Chemicals.
This Program will help prevent the occurrence of, or minimize the consequences of, catastrophic releases by stating our policies and procedures for the management of process hazards in start-up, operation, inspection, maintenance and the other matters addressed in the federal standard.
Our Program calls for maximum employee participation and includes all elements of the employee participation provisions of the standard. We shall, as a minimum: (1) consult with employees and their representatives on the conduct and development of the process hazard review and other elements of the risk management plan, and (2) provide to our employees and their representatives access to the process hazard review and all other information required to be developed under that standard.
Accidental Release Prevention and Emergency Response
The City of Waco believes that preventative maintenance is the key to minimizing the potential for accidental releases. Standard Operating Procedures (SOPs) have been reviewed and revised to enable the employees to perform their work in a safe and efficient manner.
The City of Waco has taken steps to educate and inform the operators, supervisors, and maintenance crews in the appropriate response to an accidental release. The training includes classroom training and operating procedures on the proper response to emergency situations.
Stationary Source and Regulated Substances
The Mt. Carmel Water Treatment Plant utilizes chlorine and anhydrous ammonia for disinfection of the treated water. The maximum inventory and threshold quantities for these chemicals are shown below. All chlorine containers and the anhydrous ammonia are stored and utilized in separate areas. The chlorine is stored in a building, which will act as passive mitigation in the event of a release. Th
e anhydrous ammonia is stored outside in a tank.
Chemical Maximum Inventory (lb) Threshold Quantity (lb)
Chlorine 24,000 2,500
Anhydrous Ammonia 30,637 10,000
Offsite Consequence Analysis
The offsite consequence analysis includes a worst-case release scenario and an alternative release scenario as defined in 40 C.F.R. 68. RMP*Comp was used to determine endpoint distances for both scenarios. The model's input parameters are summarized in the table below.
RMP*Comp Input Parameters
Worst-Case Scenario Alternative Scenario
Windspeed (m/s) 1.5 3
Atmospheric Stability Class F
Temperature (0 F) 77 77
Humidity (%) 50 50
Height of Release (m) 0 1
Topography Urban Urban
End Points (mg/l) 0.0087 0.14
The results of the air dispersion model are summarized in the table below along with the estimated population within the impact area. The population data was estimated using the Block Uniform Density Group Method in Landview III, which uses the 1990 U. S. Census data to estimate population. The public and environmental recept
ors are listed in Section 8 of this plan.
RMP*Comp Output Results
Worst-Case Scenario Alternative Scenario
Chlorine Ammonia Chlorine Ammonia
Impact Radius (miles) 1.3 2 0.1 0.1
Estimated Population with Impact Area 3,100 11,000 56 56
Accidental Release Prevention Program
The City of Waco has implemented a General Accidental Release Prevention Program to minimize releases. This Program includes: safety information on the covered chemicals, hazard reviews, operating and maintenance procedures, training, compliance audits, incident investigations, and emerge
ncy response procedures.
Five-year Accident History
In the last 5 years, there have not been any accidental releases from the covered process that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage.
Planned Changes to Improve Safety
The City of Waco has implemented a Risk Management Plan (RMP) that meets or exceeds the requirements of 40 CFR 68. It is Waco's philosophy to continually improve the safe working conditions of its employees to minimize accidents and reduce the potential for either an on-site or off-site release. With this in mind, Waco is planning on incorporating many of the RMP elements into other areas of the process not covered under 40 CFR 68 to improve the overall safety of the plant.