City of Reidsville Wastewater Treatment Plant - Executive Summary |
|
Hydro Management Services Reidsville, North Carolina Wastewater Treatment Plant RMP Executive Summary Hydro Management Services has implemented a comprehensive program to safely manage chlorine at the Reidsville Wastewater Treatment Plant located in Reidsville, North Carolina. There have been no chlorine incidents in the most recent five-year period. 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) regulations. 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 are: -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 Procedures for chlorine management; and -C hlorine system maintenance procedures. Additional steps have been 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 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 icals. -A full vacuum chlorine delivery system is being planned for the wastewater plant. The vacuum process greatly reduces leaks by reducing the amount of equipment that is exposed to pressurized chlorine. - Plant inventories are being controlled to maintain only four chlorine cylinders on 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 private 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 Managemen t Program. Both a "Worst Case" and an "Alternative Case" chlorine 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 1.3 miles south of the center of the Town of Reidsville at 407 Broad Street. The location of the plant is very favorable to controlling any chlorine release. The facility is situated in a low-lying area directly adjacent to Little Troublesome Creek. The creek is about 35 feet down gradient from the plant. Since chlorine is a heavier-than-air gas, it will tend to flow down hill toward the water, where the chlorine would be consumed by the surrounding trees, vegetation and surface waters. 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 Treatment 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/Tag-out -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. |