Newark Water Treatment Plant - Executive Summary

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'68.155(a) Accidental Release and Emergency Response Policies 
The Newark Water Treatment Plant has documented emergency response procedures in place, as documented in the facility's Emergency Action Plan.  This plan has been endorsed by the City staff responsible for the operation and maintenance of the Newark WTP.  The City of Newark WTP has procedures in place, including both onsite activities and coordination with offsite responders, that must be followed in the event of a chlorine leak.  All personnel involved in handling chlorine are trained with regard to chlorine safety and accident prevention. 
'68.155(b) Stationary Source and Substance Handled 
The stationary source subject to 40 CFR Part 68 is the City of Newark WTP Chlorination Facility.  The Newark WTP has a design capacity of 15 million gallons per day (MGD) and treats surface water to drinking water standards.  Facilities are provided for the handling and utilization of chlorine in one-ton containers.  The chlorination  
building houses the active containers and all process equipment and has an outside covered Storage/Unloading area. 
The chlorine ton containers are stored in the outdoor covered Storage/Unloading area.  Provisions are made to house nine (9) one-ton containers of chlorine.  A monorail and hoist assembly is provided for the handling and transfer of the one-ton containers to the storage facilities from flat-bed delivery trucks or from storage to the scale assemblies for process use.  Inside the chlorination building, two separate header assemblies are provided to maintain a supply of chlorine gas for any of the three chlorinators.  Each header assembly can accommodate two one-ton containers.  Two one-ton containers are in operation at a time, with the other two containers on standby.  As the manifolded containers are exhausted, containers are moved from storage to the scales and the empty containers are placed on the storage trunnions until the next shipment of chlorine is received.  Chlo 
rine gas is fed under pressure from the containers through the manifold adjacent to the scales to the  vacuum regulator.  From the vacuum regulator, chlorine is fed under a vacuum to the chlorinators.  Three vacuum chlorinators and three water injectors are provided for solution chlorine feed at various process locations.  Vacuum chlorine feed reduces the likelihood of a release into the environment. 
Two chlorine leak detector are installed in the Chlorination Room to alert the plant staff quickly in the event of a chlorine leak.  One chlorine leak detector is located next to the chlorinators and the other chlorine leak detector is located next to the active containers.  An audible alarm automatically sounds inside and outside of the building when chlorine levels reach 1 ppm.   
'68.155(c) Offsite Consequence Analysis 
As a Program 3 Process with one toxic gas, one worst-case release scenario and one alternative release scenario will be assessed for the Chlorination Facility.  The Cit 
y of Newark WTP has chosen to use the US EPA Risk Management Program Guidance for Wastewater Treatment Plants (40 CFR Part 68), US EPA 550-B-98-010, October 1998, (WWTP Guidance), as a source to determine off-site consequences.  This guidance specifically addresses the chemicals commonly found at WWTPs.  The chlorination process for WTPs is similar to the chlorination process at WWTPs.  Therefore, this guidance document is applicable to the Newark Water Treatment Plant's chlorination process. 
The worst-case release scenario was determined in accordance with the requirements provided in 40 CFR 68.22 and 40 CFR 68.25(b,c).  For the Newark WTP facility the worst-case scenario is a total release from one of the one-ton containers of chlorine (greatest amount held in a single vessel) over 10 minutes.  This results in offsite impacts. The facility is also required to complete at least one alternative release scenario that reaches an endpoint offsite.  The alternative release scenario was ev 
aluated in accordance with the guidelines provided in 40 CFR 68.22 and 40 CFR 68.28.  The most likely release scenario is identified based on the results of the Process Hazard Analysis (PHA).  The alternative release scenario for chlorine that results in offsite impacts is a vapor release through a 3/16 inch opening in a leaking flexible tubing line, valve connection, process piping or equipment.   
'68.155(d) Accidental Release Prevention Program 
The Newark WTP facility has a documented Prevention Program for the chlorination facility that documents release prevention measures.  These prevention measures include elements such as Employee Participation, Process Safety Information, Process Hazard Analysis, Operating Procedures, Training, Contractors, Pre-startup Review, Mechanical Integrity, Hot Work Permits, Management of Change, Incident Investigation, and Compliance Audits.   
Newark WTP is equipped with leak detection monitoring to decrease response time in the event of a chlorine  
leak. Two chlorine leak detector are installed in the Chlorination Room.  One chlorine leak detector is located next to the chlorinators and the other chlorine leak detector is located next to the active containers.  An audible alarm automatically sounds inside and outside of the building when chlorine levels reach 1 ppm.  Also, Newark WTP employees who are involved in chlorine operations are trained in specific procedures regarding handling and storage of chlorine at the facility. 
'68.155(e) Five-Year Accident History 
The Newark WTP facility has had no accidental releases of chlorine in the last five years that have resulted in on-site injuries or off-site injuries or other impacts.  
'68.155(f) Emergency Response Program 
The City of Newark WTP is a non-responding facility, as defined by OSHA and USEPA (29 CFR 1910.120 and 40 CFR part 311).  Therefore the City of Newark WTP has developed an Emergency Action Plan to ensure employee safety instead of an Emergency Response Program, as 
allowed by 40 CFR 68.90(b). The Newark WTP facility Emergency Action Plan outlines actions required to respond to a chlorine emergency and has coordinated this plan with the City Fire Department.  City Fire Department personnel are the designated first responders in the event of a chlorine emergency.  Newark WTP employees are not designated responders to a chlorine release.  As specified in 40 CFR 68.90, Newark WTP's Emergency Action Plan meets the exception listed in 40 CFR 68.90(b) and therefore, the facility is not required to have the Emergency Response Program of 40 CFR 68.95. 
'68.155(g) Safety Improvements 
Recommendations for safety improvements were identified in the Process Hazard Analysis (PHA) which was completed per OSHA 29 CFR 1910.119(e) in January of 1999.  Recommended improvements were identified in three main categories: Standard Operating Procedures, Maintenance, and Training.  According to the Process Safety Management Plan, any safety improvements will be investig 
ated concerning their impacts on other systems and/or procedures prior to implementation.  Additional recommendations may be made upon review of any accidents and/or when the PHA is updated every five years.
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