Winter Park Estates Waste Water Treatment Facility - Executive Summary |
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EXECUTIVE SUMMARY RMP EXECUTIVE SUMMARY FROM RMP*SUBMIT FILE FOR SUBMISSION TO THE EPA 1. Corporate Prevention and Emergency Response Approach The Winter Park Estates Water Treatment Plan is owned by the City of Winter Park. The facility has developed and maintains accident prevention programs and an emergency response plan to prevent and mitigate the effects of hazardous chemical releases. 2. Description of Stationary Source The Winter Park Estates Waste Water Treatment Plant is located adjacent to a residential area at 1655 Bongart Road, in Winter Park, Orange County, Florida. Winter Park uses chlorine as a disinfectant for sewage treatment process. Liquefied chlorine gas is stored in up to four one-ton containers at the chlorination process building. Two one-ton containers are always connected to the process, while up to two additional containers are stored adjacent to the connected containers. The total chlorine inventory in the process at any one time is 8,000 lbs. This is greater than the 2,500 lb. RMP threshold quantity for chlorine. This process is not enclosed in a building, but sheltered with a three-sided building or shed with a roof. 3. Description of the Worst-Case and Alternative Release Scenarios The Worst-Case release scenario is the rupture of a one-ton container from the chlorination process, releasing 2,000 lbs. of chlorine gas over a 10-minute period. Under worst-case weather conditions, the chlorine gas could travel 1.3 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .0087 mg/L), using the WWTP Guidance look-up tables. The Alternative Release scenario is characterized by a release of liquid chlorine due to a failure of the liquid supply valve connection from worker/human error, external impact, or corrosion. For the chlorination (Chlorine) process, the release rate was determined to be 251 lbs/min. Under normal expected weather conditions, the chlorinati on process chlorine gas could travel 0.3 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .0087 mg/L), using the WWTP Guidance Method. 4. Prevention Program For the Chlorination process, this facility exceeds the chlorine threshold quantity for the OSHA Process Safety Management (PSM) Standard, 1910.119. For RMP compliance purposes, this places the Winter Park Estates Chlorination process in the Program 3 level. The Winter Park Estates facility will address all elements for the Prevention Program 3 as required by the RMP rule. Winter Park has a program in place to comply with the OSHA Process Safety Management Standard, 29 CFR 1910.119. The PSM Program was created in 1999. The PSM Program includes written operating procedures for the chlorination process. These procedures cover all phases of operation and include information on worker protection. These procedures will be used to train all operators and m echanics who work on the chlorination and dechlorination processes to ensure consistency of operation and minimize human error. The PSM Program also includes a preventative maintenance plan which requires all chlorination equipment to be periodically inspected and serviced. This will ensure that the equipment remains in good operation condition and will minimize the probability of accidents due to faulty equipment. Safe work practices, such as Lockout/Tagout and Hot Work Permit, have long been required by the City of Winter Park. These will be reviewed and updated to ensure that all non-routine work can be performed safely. Other components of the Prevention Program include the collection and review of all equipment information and the development of updated Piping & Instrumentation Diagrams (P&IDs). These actions will ensure that the equipment meets all chlorination and wastewater industry standards and that accurate equipment information will be available when needed. Other PS M procedures, including Management of Change, Pre-Startup Safety Review, Compliance Audits, and Incident Investigation will also be incorporated into this program to ensure continued safe operation and prompt correction of deficiencies. The PSM Program receives full support of plant management and involvement of employees at all levels. 5. Accident History The Winter Park Estates facility has had no accidental releases of chlorine in the past five years. 6. Emergency Response Program The Winter Park Estates WWTP has an Emergency Response Plan in place. The program complies with 29 CFR 1910.38. The site also has some internal emergency response capability and has a procedure for addressing small releases of chlorine. The current plan has been coordinated with the Winter Park and Orange County Fire Department and the Regional Local Emergency Planning Committee. Notification is made locally by dialing 911 and by notifying the Florida State Warning Point . |