Rolling Hills Water Treatment Plant - Executive Summary

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                         EXECUTIVE SUMMARY 
by the CITY OF FORT WORTH (CFW).  To comply with the requirements in 
40 CFR 68 Chemical Accident Prevention Provisions, the CITY OF FORT 
WORTH WATER DEPARTMENT (CFWWD) developed a Risk Management Program 
(RMProgram) for the RHWTP including Management System, Hazard 
Assessment, Accidental Release Prevention Program, and Emergency 
Response Plan.  The RMProgram main goal is to reduce the employee and 
public risk of injury, death or damage from accidental release of 
The CFW has the overall responsibility for implementing and 
integrating the ARPProgram into their organization.  In accordance 
with the Management System, the CFWWD Director is designated as the 
RMProgram Director, and the Assistant Water Director in charge of 
Production is the RMProgram Manager.  Other qualified individuals are 
assigned responsibility for implementing each indiv 
idual requirement 
set forth in the Accidental Release Prevention Program and/or 
Emergency Response Plan.  The RMProgram participants include the 
following positions: 
A.   RMProgram Director 
B.   RMProgram Manager 
C.   Hazard Assessment/Offsite Consequence Analysis Update Officer 
D.   Safety Information Officer 
E.   Hazard Review Update Officer 
F.   Operation Manager/Assistant Operation Manager 
G.   Training Supervisor 
H.   Maintenance Supervisor/Assistant Maintenance Supervisor 
I.   Compliance Audit Officer 
J.   Incident Investigation Officer 
K.   Emergency Planning and Response Officer 
L.   RMPlan Update Officer 
Management system detailed descriptions and procedures are provide in 
the Accidental Release Prevention Program to ensure every participant 
playing a role in the RMProgram understands their responsibilities. 
Regulated toxic chemicals and processes at the RHWTP are: 
A.   Storage, transfer and use of chlorine in the chlorination system 
B.   Storage, transfer and use of anhydrous ammonia in ammoniation 
Chlorine gas is stored as pressurized liquid in two (2) side-by-side 
tanks located outdoors.  Maximum liquid chlorine inventory in each 
tank is 48,000 lbs.   The maximum process quantity is 96,000 lbs., 
ignoring negligible quantities in the piping. 
Anhydrous ammonia gas is stored as a pressurized liquid in a single 
(1) tank located outdoors.  Maximum liquid ammonia inventory in each 
tank is 85% of the tank water volume of 20,000 gallons.  The ammonia 
volume is converted to a mass of 97,000 lbs. by assuming an ammonia 
density of 42.5 lb/ft3.  The maximum process quantity is 97,000 lbs., 
ignoring negligible quantities in the piping. 
The Hazard Assessment has been completed for the RHWTP.  Offsite 
consequence analysis modeling was performed based on the following 
principle elements: 
A.   Meteorological parameters for the dispersion modeling analysis 
    were determined using Nation 
al Weather Service data collected at 
    the Dallas/Fort Worth International Airport.  Highest daily 
    maximum temperature and average relative humidity over the last 
    three-year period were used for worst-case scenarios.  Typical 
    meteorological conditions based on the data over the last  
    three-year period were used for alternative release scenarios. 
B.   Total quantity in the single largest tank was used for chlorine 
    and ammonia worst-case scenarios.  A leak from a liquid line near 
    the outdoor storage tank was assumed for either chlorine or 
    ammonia alternative release scenario. 
C.   No mitigation measure was considered in worst-case scenarios.  
    The excess flow valve, however, was considered for either 
    chlorine or ammonia alternative release scenario. 
D.   Distances to toxic endpoints for chlorine and ammonia worst-case 
    scenarios were modeled using a dense gas dispersion model, 
E.   Distances to the toxic endpoints for c 
hlorine and ammonia 
    alternative scenarios involving vapor release were modeled using 
    the ALOHA model. 
F.   Distance to the toxic endpoint for the ammonia alternative 
    scenario involving two phase release were modeled using a dense 
    gas dispersion model, DEGADIS. 
G.   Offsite impact was evaluated with LANDVIEW III for each release 
The accidental release of chlorine from a storage tank is considered 
the worst-case scenario. A distance of 4.8 miles between the release 
source and the toxic endpoint was modeled in the offsite consequence 
analysis.  The alternative scenario impact distance is 1.2 miles for 
chlorine and 0.25 miles for ammonia. 
For the worst-case scenario, LANDVIEW III estimated a population of 
150,000 persons within the worst-case scenario impact radius of 4.8 
miles.  Populations are 6,900 and 0 persons for chlorine and ammonia 
alternative release scenarios, respectively. 
Public receptors within the worst-case scenario impact area include 
schools, residences, hospitals, correctional facilities, recreation 
areas and commercial, office, or industrial areas.  Public receptors 
within the alternate release scenario impact area are schools, 
residences, correctional facilities, recreation areas and commercial, 
office, or industrial areas.  No environmental receptors are within 
the impact area of the worst-case scenario. 
A comprehensive Accidental Release Prevention Program Manual was 
developed.  The main purpose of the manual is to provide operation and 
maintenance personnel detailed standard procedures to reduce employee 
and public risk to injury, death or property damage from accidental 
chemical releases.  The manual includes the following elements and 
complies with requirements set forth in 40 CFR 68 Chemical Accident 
Prevention Provisions. 
A.   Management 
B.   Safety Information 
C.   Hazard Review 
D.   Operating Procedures 
E.   Training 
F.   Maintenance 
G.   Compliance Audits 
H.   Incident Investigation 
Detailed procedures for the Accidental Release Prevention Program were 
developed and are undergoing implementation and integration into 
routine operation and maintenance practices at the RHWTP.  Historical 
and future significant efforts focus on the following areas: 
A.   Development of a safety information database essential for the 
    successful implementation of other procedures, including 
    operation, maintenance, training, compliance audits, incident 
    investigation, and emergency planning and response. 
B.   Implementation of corrective actions recommended during the most 
    recent hazard review completed on April 22, 1999.  This effort is 
    one of the most important steps for preventing a chemical release 
    or minimize its effects on plant personnel or the public. 
C.   Regular review and revision of operating procedures to address 
    the safely operating procedures for regulated process systems, 
    including all eight (8) element 
s set forth in the regulation.  
    When combined with the operator training program, current 
    operating procedures are essential in  ensuring safe operation of 
    systems and preventing accidental releases. 
D.   Regular review and revision of training programs to ensure plant 
    personnel working on or near regulated processes are adequately 
    trained and understand both inherent process hazards and 
    appropriate response actions to accidental chemical releases.  
    Employees who have received adequate classroom and/or on-the-job 
    training and are currently qualified to safely operate the 
    regulated systems have received certifications  in writing by the 
    RMProgram Manager.  A special training session will be provided 
    to plant personnel working on or near regulated processes as soon 
    as final revisions to operating procedures are completed. 
E.   Regular review and revision of the maintenance program to ensure 
    that current, accurate, and com 
plete procedures are provided for 
    process equipment in regulated processes.  Efforts were and are 
    continuously made for the preventative maintenance of equipment 
    per manufacturer's recommendations.  Effective maintenance 
    procedures are integral to preventing chemical releases that may 
    result from mechanical failure of improperly maintained 
No accidental releases of regulated chemicals from a regulated process 
at the RHWTP has occurred in the past five years resulting in any 
death, injury, or property damage on site, or known offsite impacts 
(i.e., deaths, injuries, evacuations, sheltering-in-place, or property 
damages, or environmental damages). 
CFWWD personnel do not respond to uncontrolled releases of chemicals 
from any regulated process at the RHWTP.  Plant employees are limited 
to responding only to incidental releases covered by maintenance 
procedures.  Appropriate procedu 
res have been developed and are in 
place that provide clear instructions on 1) how to determine if a leak 
is considered an incidental release, and 2) how to notify local 
emergency responders in the event of an uncontrolled release.  Current 
procedures were reviewed and revised to meet regulatory requirements, 
such as emergency notification, evacuation, training, documentation, 
availability, etc., under 29 CFR 1910.38(a).  Regulated processes at 
the RHWTP are not included in the community emergency response plan 
developed under 42 U.S.C. 11003.  The local emergency responder is 
the Emergency Management Office in association with the City of Fort 
Worth Fire Department.  Adequate safety information regarding 
regulated processes has been provided to the Emergency Management 
Office who has developed and implemented specific emergency response 
plans, provided suitable training, and conducted necessary drills in 
emergency response for regulated chemical releases from regulated 
processes.  Alt 
hough it will not be the responsibility of the plant 
employees to evacuate offsite areas, addresses and telephone numbers 
of major public receptors inside a one (1) mile radius are provided in 
the plan.  The CFWWD will work closely with the Emergency Management 
Office and document coordination activities and communications. 
To improve the safety of regulated facilities at the RHWTP, the 
following plant expansion, process modification and facility upgrade 
projects are under construction or are scheduled to begin soon: 
A.   Installation of additional warning signs 
B.   Installation of bollards around tanks to provide additional 
    vehicular protection 
C.   Implementation of modified leak detector testing and 
    documentation procedures 
D.   Implementation of revised operational, maintenance, and training 
E.   Implementation of revised contractor notification and monitoring 
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