West Virginia - American Water Company Mercer/Sum - Executive Summary |
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WEST VIRGINIA-AMERCIAN WATER COMPANY MERCER/SUMMERS WATER TREATMENT PLANT Risk Management Plan Executive Summary Accidental Release Prevention and Emergency Response Policies West Virginia-American Water Company's Mercer/Summers Water Treatment Plant is committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees, contractors, and the public, as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: A description of our facility and use of substances regulated by the Environmental Protection Agency's (EPA's) risk management program (RMP) regulation A summary of results from our assessment of the potential off-site consequences from acciden tal chemical releases An overview of our accidental release prevention program A 5-year accident history for accidental releases of chemicals regulated by EPA's RMP rule An overview of our emergency response program An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our associates, contractors, the public, and the environment Mercer/Summers Water Treatment Plant Regulated Substances The Mercer/Summers Water Treatment Plant is a water treatment facility that takes raw water from the New River in Hinton, West Virginia, and treats the water with chlorine and other chemicals to make potable (drinking) quality water for public distribution and consumption. Sewage treatment is not a part of plant operations. The plant handles one RMP-regulated toxic substance above the EPA threshold quantity, which is chlorine. No regulated flammable substances are present at the treatment plant Chlorine is delivere d to our plant and stored in 1-ton ("ton") containers and is fed to the process from one of the containers at a time. The container storage room can hold up to 6 ton containers. One container is connected to the same feed piping manifold. An alternate supply arrangement consists of one additional ton containers connected to a parallel, but normally isolated, feed piping manifold. Chlorine is stored as a liquefied gas under pressure, fed as a gas to the chlorinators, and injected as a vapor at the outlet of the into the water stream. The chlorine process is classified as a Program Level 3 process, and we implement a complete accident prevention program. Offsite Consequence Analysis We performed an off-site consequence analysis to estimate the potential for an accidental release of chlorine from our facility as a regulated toxic substance that could affect the public or the environment. The off-site consequence analysis consisted of evaluating both a worst-case scenario (WCS) and an al ternative release scenario (ARS) following identification of the appropriate ARS. We do not expect a worst-case release scenario to ever occur. An ARS represents a release that might occur during the lifetime of a facility similar to our water treatment plant. ARS's can be used to help the Summers (local) Emergency Planning Committee (SEPC) improve and prepare an effective community emergency response plan. We have submitted release scenario analyses to EPA and have shared that information with SEPC and other organizations involved in emergency response activities. It is also available to local residents, schools, hospitals, and businesses. For these events, we have emergency mitigation systems that should help reduce the consequences of the events if they occur. In all cases, if such events occur, we would activate our emergency response plan to respond to the event notify local authorities, and take appropriate actions to protect our employees, contractors, and people in the communi ty. The paragraphs below briefly describe the scenarios we have included in our risk management plan (RMPlan), including information about the key administrative controls and mitigation measures we have put in place to limit the exposure distances for each scenario. Worst-case Release Scenario for Chlorine The worst case scenario at our water treatment facility involves a failure of a ton container holding approximately 2000 lbs of liquefied chlorine gas under pressure, resulting in a release with vaporization of the entire contents of the container. In this scenario, the chlorine is released as a vaporizing liquid inside a completely enclosed chlorine storage room in our water treatment building. The containment provided by the building mitigates the release. Such building confinement reduces the release rate of chlorine vapor directly to the outdoors. Since this facility is located in a semi-populated area, the toxic cloud formed by the evaporating chlorine would reach off-site end points and nearby public receptors. A sump is provided to collect and contain portions of a liquid release that do not immediately vaporize. In reality, the sump could serve to reduce the vaporization rate of chlorine to the storage room air, and likewise reduce the rate at which chlorine gas is released from the room directly to the outside air. However, because we based our analysis on a very conservative approach, we did not take credit for the sump as a form of mitigation in reducing the endpoint distance reached off-site. Numerous administrative controls are in place to prevent a release of this type and should one occur, to provide for effective emergency response. Controls include container design, storage, operation, maintenance and inspection; container repair and emergency response equipment; and personnel training conducted in accordance with regulatory requirements, chlorine industry standards and practices, and our company's corporate policies and procedures, which are strictly enforced at the water treatment plant. Alternative Release Scenario for Chlorine Our alternative release scenario for chlorine involves a chlorine release of approximately 317 lbs through a broken flexible connection ("pigtail") between the chlorine container and a supply manifold in the piping to our chlorine feed system. A break in a pigtail connecting the container to the piping will permit the connected container to vent the contents through the open ends of the severed pigtail. Credit is taken in accordance with EPA's simplified approach for the partial containment of chlorine vapor by the room/building enclosure, which mitigates the release, and also by conservatively figuring the vacuum feed system to fail at a point during a leak. The building confinement reduces the release rate of chlorine vapor directly to the outdoors. Since this facility is located in a semi-populated area, the toxic cloud formed by the evaporating chlorine would reach off-site end points and n earby public receptors. As in the WCS, we have taken a very conservative approach to determining the ARS endpoint distance off-site. In determining the ARS endpoint distance we have, in this case, taken credit for active mitigation provided by engineered safeguards that include chlorine monitors/detectors that automatically activate an alarm in the control room and the vacuum feed system. The chlorine leak detection system is calibrated to initiate alarms at very low concentrations of chlorine (i.e., lower than industry recommended settings). Some of our additional engineering safeguards are outlined in the following section of this summary and include isolation valves. Isolation valves are provided in the downstream chlorine feed system to isolate downstream chlorine source from the pigtail leak. As stated in the description of the WCS, numerous administrative controls are in place to prevent a release of this type and to provide effective emergency response should one occur. We ar e using this information to help us ensure that our site/facility emergency response plan and the community emergency response plan address all reasonable contingency cases. Accidental Release Prevention Program and Chemical-specific Prevention Steps for Chlorine We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our RMP-regulated chlorine process is also subject to the Occupational Safety and Health Administration's (OSHA's) process safety management (PSM) standard. We have extended the PSM program at this facility, where necessary, to satisfy EPA's Program Level 3 accident prevention program requirements. Our PSM Program and RMP Level 3 Prevention Program are designed to comply with OSHA and EPA requirements. Additionally, we adhere to chlorine industry(i.e.., Chlorine Institute) and American Water Works Association guidance and recommended practices for PSM and RMP programs, including facility and chlorine system design and safety p ractices. Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, contractors, the public, and the environment by our use of chlorine in treating drinking-quality water. We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. Our systematic, proactive management systems address each of the key features of successful prevention programs including: Process safety information Process hazard analysis Operating procedures Training Mechanical integrity Management of change Pre-startup review Compliance audits Incident investigation Employee participation Hot work permit Contractors As part of our prevention efforts, the following is a list of key safeguards and chlorine-specific accidental release prevention steps that we have implemented at our site: A new, state-of-the-art chlorine feed system Instrumentation and control systems with an emergency power supply designed in accordance with current industry (recognized and generally accepted good engineering) practices Corrosion-resistant equipment components and piping systems Protective devices to prevent the formation of excessive pressure in chlorine equipment Isolation valves to permit isolation of different parts of the process Chlorine monitors/detectors with alarm notification to a constantly attended control room and to other key facility locations A liquid chlorine spill collection and containment system consisting of floor sumps Chlorine rooms designed to help contain a chlorine release, and building construction materials that will not support fire development, fire spread, and fire damage to equipment Strict administrative controls prohibiting the entry and use of combustible materials in chlorine handling/use areas to prevent and control fire spread that may pressurize equi pment Cross-trained operations and maintenance personnel that are equally trained in emergency response actions for chlorine releases to the OSHA (29 CFR1910.120) EPA HAZWOPER responder level These individual elements of our prevention program work together and in tandem with the chlorine release prevention steps to prevent accidental chemical releases. Our company, our employees, and contractors are committed to the standard that these management systems set for the way we do business, and we have specific, internal management accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. Five-year Accident History We keep records for all significant accidental chemical releases that occur at our facility. During the past 5 years we have not had any releases involving chlorine from the RMP-covered process that had any reportable on-site or off-site effects. Our facility has instituted procedures that require formal investigation of in cidents involving chemical releases, regardless of chemical identity or listing by the EPA RMP rule. For each incident, we conduct formal incident investigations to identify and correct the root causes of the events. Emergency Response Program The West Virginia-American Water Company's Mercer/Summers Water Treatment Plant maintains an integrated contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, contractors, the public, and the environment during emergency situations. The program consists of procedures for responding to a chlorine release. The procedures address all aspects of emergency response, including (1) proper first aid and emergency medical treatment for human exposures, (2) facility evacuation plans and accounting for facility personnel after an evacuation, (3) notification of local emergency resp onse agencies and the public if a release occurs, and (4) post-incident follow-up requirements. Procedures are in place governing the establishment of the plant's Emergency Operation Center where management personnel can direct and control emergency operations on an as-needed basis. In addition, we have procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures to perform their specific emergency response duties. The emergency response program is updated when necessary based on modifications made to plant facilities or to the chlorine storage and feed process, or when improvement benefits are recognized. Affected personnel are informed about, and trained on, the changes, The overall emergency response program for the plant is coordinated with the local emergency planning committee (LEPC) having jurisdiction in Summers County - and with emergency management officials. We have around-the-clock communications capability with appropriate emergency response organizations (e.g.., contracted chlorine emergency response [HAZMAT] teams, local fire department, police department). This provides a means for notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. Additionally, we conduct periodic walk-around orientation tours of the plant facilities with key representatives of local emergency response organizations. During such tours we discuss and review the source of chlorine at our site, the hazards of a chlorine release, release mitigation features and emergency response actions involving the chlorine system. Thus, our emergency response plan is fully coordinated with the community emergency response plan. Planned Changes to Improve Safety At the West Virginia-American Water Company Mercer/Summers Water Treatment Plant we constantly strive to improve the safety of our operations through periodic safety reviews, our incident investigation program, and a program for soliciting safety suggestions from our facility workers. We resolve all findings from our reviews of proposed changes to facilities, equipment, and operations and from analyses of process hazards. Some findings of this type can result in modifications to the process. the prevention program, or administrative controls. The following is a list of improvements that we are planning to implement at the facility during the next 5 years to help prevent and/or better respond to accidental chemical releases: An engineering review of the leak-tightness of each chlorine room to more precisely determine the building (containment) mitigation factor, possibly resulting in reduced endpoint distances for WCS and ARS releases of chlorine An assessment of the effectiveness of each element of the Level 3 Prevention Program to ensure that the program will achieve its objectives and to strive for continuous program improvement |