Coral Springs Improvement District WTP/ WWTF - Executive Summary

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Executive Summary 
The Coral Springs Improvement District (CSID) was created by Special Act of the Florida Legislature in 1970.  Among its powers is the authority to own, operate, and maintain water treatment and transmission facilities and wastewater treatment facilities to serve development within the District. 
The CSID owns and operates a water treatment plant and wastewater treatment facility, both located at 10300 NW 11th Manor, Coral Springs.  The CSID utility site is approximately 26.35 acres and is centrally located in the community.   Both the water and wastewater treatment facilities use chlorine gas in their processes.  The water plant for disinfection and the wastewater facility for odor control.  The chlorination systems are separate from one another. 
The CSID WTP has a dedicated chemical building on-site.  Chlorine gas is stored on the site in eight one-ton containers.  The CSID WWTF also has a dedicated chlorine area, where one ton container is stored and used.  The maxi 
mum chlorine inventory at the site is 18,000 lbs (16,000 lbs-WTP; 2,000 lbs-WWTF).  The following characteristics of the CSID utility site subject it to Rule 40 CFR Part 68, which requires development and implementation of a Risk Management Program (RMP): 
q The facility is a stationary source; and 
q The facility handles, uses, and stores a toxic substance regulated by 40 CFR 68.130 (e.g. chlorine gas); and 
q The handling, use, and storage of chlorine meet the definition of a "process;" and 
q The chlorine is present in quantities above the threshold quantities established by the Rule (e.g. 2,500 lbs for chlorine).  
The CSID WTP is considered by the regulation to be a Program Level 3.  This is the highest level program and requires the most extensive risk management plan.  The criteria for Program Level three follow: 
q Public receptors are within the distance to the endpoint for a worst-case scenario release; and 
q The process is subject to the OSHA PSM standard since the chemical use, c 
hlorine is included in Appendix A of 29 CFR 1910.119 and the quantity stored and handled exceeds the threshold quantity for chlorine of 1,500 lbs; 
The Level 3 Risk Management Program is basically comprised of three sections: Hazard Assessment; Prevention Program; and Emergency Response Plan.   
The Hazard Assessment for a toxic gas involves modeling the consequences of at least two release scenarios, the worst-case and an alternative case.  The worst case scenario involves the largest container of the regulated substance being released into the environment over the period of ten minutes.  The Environmental Protection Agency's (EPA) air model RMP Comp* Version 1.06 was used to simulate the worst case scenario.  The model uses input data to generate the estimated distance from the point of release to the toxic endpoint.  The toxic endpoint is defined for chlorine gas as the point where the concentration of chlorine gas in the air is 0.0087 mg/L.  For the worst case scenario, the release r 
ate was 110 lbs/minute and the distance to the toxic endpoint was 0.9 miles (distance from the chemical building).   
The alternative case release scenario is one that is more likely to occur than the worst-case and has off-site consequences (e.g. the distance to the toxic endpoint is further than the distance to the site boundary).  In the alternative release case, the RMP Comp* model allows the user to enter more site specific data, including consideration of active mitigation devices (these were not allowed for the worst case scenario).  Two alternative case release scenarios were considered for the CSID WTP, both resulted in the distance to the toxic endpoint of 0.1 miles (528 feet) or less.  
The second section of the Risk Management Program is the Prevention Program.  This section is the heart of the RMP and account for a large portion of the document's thickness.  The Prevention Program includes detailed information and discussion regarding the management system at the facility; f 
ive-year accident history; process safety information review; process hazard analysis; procedures for operation, training, maintenance, management of change, compliance audit, incident investigation, employee participation, and hot work; and contractor selection.  The Prevention Program provides documented guidance to facility staff regarding day to day operation regarding chlorine storage, handling, and use.  The Prevention Program is intended to educate staff and thereby reduce the probability of release due to improper operations, inadequate maintenance, ignorance of the hazards, or lack of safety awareness.   
The CSID water and wastewater systems have employed chlorine gas as a disinfectant and odor control agent since 1972.  There have been no uncontrolled releases in chlorine gas which caused injury or death to on-site or off-site persons.  The chlorination systems which use chlorine gas at the facility are vacuum operated.  The system employs active mitigation devices which incl 
ude vacuum induced gas withdrawal, fail-close valves (vacuum regulator), secondary check valves, isolation valves, sensors (high/low vacuum, chlorine gas detector) which are connected to an alarm system, pressure relief valves, ventilation systems, and automatic container switchover system (via vacuum regulator).  These active mitigation devices have attributed to the successful and safe operation of the system since startup.  The existing system is capable of continuing to provide safe utilization of chlorine gas as a disinfectant.   Improvements to the facility will include continued maintenance of the existing system and investigation into new technologies as they are developed. 
The third component of the Risk Management Program is the Emergency Response Plan.  The emergency response plan documents the activities to be performed in the event of an uncontrolled release of chlorine gas into the environment.  The plan provides detailed how-to information regarding movement, notificatio 
n, personnel accountability, site control, release remediation, first aid, personal protective equipment, and coordination with professional emergency responders.  The facility staff is primarily responsible for protection of on-site persons and notification of outside organizations which will takes steps to provide protection for off-site persons.  The City of Coral Springs Emergency Response Coordinator and the Broward County Emergency Management Division will coordinate off-site activities and release remediation once contacted by the 9-1-1 dispatcher.
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