Cypress Creek Water Treatment Plant - Executive Summary
1. Accidental Release Prevention and Emergency Response Policies |
We at the City of Florence Utilities Water / Wastewater Department as owners and operators of the Cypress Creek Water Treatment Plant are committed to employee, public and environmental safety. This commitment is demonstrated by our accidental prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Unforeseeably, if such a release does occur, we are completely coordinated with the City of Florence Fire Department, which provides emergency response personnel to control and mitigate the effects of the release.
2. The Stationary Source and the Regulated Substance Handled
Our facility's primary activities encompass potable water treatment. We have one regulated substance present at our facility. This subst
ance is Chlorine. The Chlorine used at this facility is used for the purpose of disinfecting treated water for potable use by the City of Florence and Lauderdale County in Alabama.
The maximum inventory of Chlorine at this facility is 8000.00 pounds.
3. The Worst Case Release Scenario and the Alternative Release Scenario, including administrative controls and mitigation measures to limit distances for each reported scenario
To perform the required offsite consequence analysis for our facility, we have used the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenarios.
The worst case release scenario submitted for Program 2 toxic substances as a class involves a catastrophic release from the potable water chlorinating process. The scenario involves the release of 2000 pounds of chlorine in a gaseous form over 10 minutes. Passive mitigation controls such as enclosures are also t
aken into account to calculate the scenario. At Class F atmospheric stability and 1.5 m/sec. wind speed, the maximum distance of 0.90 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L.
The alternative release scenario of Chlorine involves a release from the Chlorine Storage Room in the potable water chlorinating process. The scenario involves the release of 1500 pounds of Chlorine in gaseous form over 10 minutes. Passive mitigation controls such as enclosures are taken into account to calculate the scenario. At Class D atmospheric stability and 3.0 m/sec. wind speed, the maximum distance of 0.20 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L.
4. The General Accidental Release Prevention Program and the Chemical Specific Prevention Steps
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The following sections briefly describe the elements of the rel
ease prevention program that is in place at our stationary source.
Process Safety Information
The Cypress Creek Water Treatment Plant maintains safety information that describes the chemical hazards, operating parameters, and equipment designs associated with the chlorinating process.
Process Hazard Review
Our facility conducts reviews to ensure that hazards associated with our process is identified and controlled efficiently. The reviews are undertaken by qualified personnel with the expertise in our process operation.
The Cypress Creek Water Treatment Plant has a training program in place to ensure that employees who are operating the process are competent in the operating procedures associated with this process. Refresher training is provided at least every 3 years and more frequently as needed.
The Cypress Creek Water Treatment Plant maintenance personnel perform maintenance checks on the process equipment to ensure proper operations. Process
equipment checked includes storage tanks, piping systems, relief and vent systems, emergency shutdown systems, and controls. Qualified personnel with previous training in maintenance practices carry out the maintenance operations. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.
The City of Florence Water / Wastewater Department truly believes that process safety and accident prevention is a team effort. Department employees are encouraged to express their views concerning accident prevention and to recommend improvements.
5. Five-year Accident History
The City of Florence Water / Wastewater Department has had an excellent record of preventing accidental releases over the last 5 years. There has been no accidental release from the Cypress Creek Water Treatment plant during this period.
6. Emergency Response Plan
Creek Water Treatment Plant has a written emergency response plan to deal with accidental releases of chlorine.
7. Planned Changes to Improve Safety
As a result of the implementation of the various elements of our accidental release prevention program, there are some steps that we want to take to improve safety at our facility. These changes include a more frequent evaluation of our process equipment and more frequent refresher training of the treatment plant personnel. Plans are currently being made to address these issues.