Town of Farmville Wastewater Treatment Plant - Executive Summary

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Hydro Management Services 
Farmville, North Carolina 
Wastewater Treatment Plant 
 
RMP Executive Summary 
 
Hydro Management Services  has implemented a comprehensive program to safely manage chlorine at the Farmville Wastewater Treatment Plant located in Farmville, North Carolina. There have been no chlorine incidents in the most recent five-year period nor in the 20-year history of the plant. 
 
To comply with the EPA Risk Management Program (RMP), the initial step was to develop a prevention program as required by the RMP and by the OSHA Process Safety Management (PSM) regulation. This prevention program was initiated at the Plant using a consulting organization. An RMP/PSM Compliance Manual was developed for the site.  
 
Key items included in the manual were: 
 
-Written site specific procedures for Employee Involvement, Management of Change, Incident Investigation, Pre-Startup Reviews and Self Audits; 
 
-Chlorine safety information as required by the regulations; 
 
-Standard Operating Procedu 
res for chlorine management; and 
 
-Chlorine system maintenance procedures. 
 
The following additional steps were implemented to complete the prevention program: 
 
-Training on PSM and its key components including Management of Change, Mechanical Integrity  and Incident Investigation. 
 
-Conducting  Process Hazards Analyses for the three chlorine processes; 
 
-Developing an initial Emergency Response Plan; and 
 
-Training in support of the certification of operators. 
 
The plant superintendent and company safety officer are meeting several times per year to review and update procedures and to maintain compliance with all aspects of the PSM/ RMP regulations. 
 
In addition to RMP/PSM compliance, the plant has implemented a number of programs to improve the safe handling of chlorine and other chemicals. 
 
-In 1998, a full vacuum chlorine delivery system was installed inside a dedicated chemical storage building. The vacuum process has proven to greatly reduce leaks by reducing the amount 
of equipment that is exposed to pressurized chlorine.  
 
-The new chemical storage building serves to contain and reduce the impact of any chlorine release. 
 
-Plant inventories are being reduced from five (5) full cylinders to two (2) full cylinders of chlorine at the site. 
 
The site's Emergency Response Plans (ERP) have been significantly upgraded. In 1999, the ERP was revised to include offsite response and communication. The County LEPC and other local response organizations have been incorporated into the ERP. The services of a Regional Hazmat Team to provide hazardous materials response has been obtained. Where necessary, communication plans have been developed to residences that may be impacted by a release. Chlorine Response Drills are being routinely conducted. 
 
To further understand chlorine risks, a consulting firm was contracted to conduct "Offsite Consequence" Modeling Analysis, as required by EPA's Risk Management Program. Both a "Worst Case" and an "Alternative Case" chlo 
rine release scenarios were studied for the site. 
 
The "Worst Case" modeling showed the potential impact of a full, 2000 pound cylinder of chlorine released in 10 minutes. This resulting chlorine plume extended 0.9 miles. For the "Alternative Case," a more typical possible release of 180 pounds, three pounds/minute for 60 minutes, was modeled. The modeling indicated that a plume extending 0.1 miles would result. 
 
The modeling showed that the risk of chlorine exposure is low due to the favorable location of the plant. The  Wastewater Treatment Plant is located 2.3 east southeast of the Town or Farmville at 2884 Chinquapin Road. The site is surrounded by a pond, a creek, dense forestation and swampland.  Since chlorine is a heavier-than-air, reactive gas, the surrounding terrain would act to contain and dissipate any chlorine release. Thus, a chlorine release should result in no public exposure to minimum public exposure. 
 
In addition to Process Safety Management, the organization has an 
active safety program. Hydro Management Services  has an active Safety Committee. The committee meets monthly and its duties include reviewing new safety procedures, accident investigations, safety surveys and safety communications. 
 
At  the Wastewater Plant, there are monthly safety meetings to review an OSHA subject or discuss a safety issue. Routine training is conducted for topics such as: 
 
- Hazard Communications 
 
-Personal Protective Equipment 
 
-Lockout/Tagged 
 
-Confined Space 
 
As a result of our programs, the plant  has had an excellent safety record over the past three years. As mentioned earlier, there have been no reportable chlorine releases from the plant.  The plant has worked extensively to upgrade its safety program.                                                                                                                                                                                                                                                                   
                                                                Report by: 
 
Gary Stainback                                                               
Director of Operations 
Hydro Management Services, Inc.
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