Topeka Water Treatment Plant - Executive Summary

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City of Topeka, Kansas 
Water Treatment Plant 
Risk Management Plan Executive Summary 
 
 
1.0     Accidental Release Prevention and Emergency Response Policies 
 
At the City of Topeka, Kansas Water Treatment Plant, we are committed to operating and maintaining our facilities in a safe and responsible manner.  We use a combination of an accidental release prevention program and an emergency response planning program to help ensure the safety of our employees and the public, as well as protection of the environment.  This executive summary 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 EPA's risk management plan (RMP) 
          regulation. 
    *    A summary of results from our assessment of the potential offsite consequences from accidental 
          chemical releases. 
    *    An overview of our accidental release prevention program. 
 
  *    A five-year accident history for accidental release 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 employees, the public, and the environment. 
 
2.0     Stationary Source and Regulated Substances 
 
The City of Topeka's water supply and treatment facilities provide safe, reliable, and economical drinking water within the city limits and surrounding areas.  In our treatment process, we use the following chemical the EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: 
 
Toxics:  Chlorine 
 
Chlorine is used as a disinfectant to inactivate disease causing organisms and to maintain high quality potable water during distribution.  The maximum inventory of chlorine stored at the plant site is 220,0 
00 pounds. 
 
Flammables:  There are no RMP-regulated flammable chemicals used or stored at this facility. 
 
Our accidental release prevention program and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of chlorine. 
 
3.0     Key Offsite Consequence Analysis Scenarios 
 
EPA's RMP rule requires that we provide information about the worst-case release scenario and an alternate release scenario for our facility.  The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: 
 
Worst-case Release Scenario - Regulated Toxic Chemical:  Chlorine 
 
The worst-case release scenario for our facility would be the catastrophic failure on one full 55-ton tank railcar of chlorine.  The scenario is assumed to be a direct release over a 10-minute period, as required by the RMP regulation 
.  The release rate is 11,000 pounds per minute for a total release of 110,000 pounds.  The assumed meteorological conditions are 1.5 meters per second wind speed, atmospheric Stability Class F (very stable, calm evening conditions), and urban terrain.  Under these conditions,  the EPA  OCA Reference Table 11 predicts a distance of 9.9 miles to the toxic endpoint (0.0087 mg/L) of the release.  The population affected by this scenario is approximately 150,000, based on 1990 U.S. Census data. 
 
The public receptors within this distance include schools, residences, hospitals, prison/correctional facilities, public recreation areas, and major commercial, office, and industrial areas, and airports.  The environmental receptors within this distance include a National Historic Site, and Other (Kansas River, tributaries, Lake Shawnee, Lake Sherwood, Topeka Zoo, and farm fields). 
 
Alternate Release Scenario - Regulated Toxic Chemical:  Chlorine 
 
The alternate release scenario for our facility de 
scribes a situation that would be more likely to occur than the worst-case and which would affect areas off-site.  This scenario assumes the release of liquid chlorine through a severed unloading line protected by an excess flow valve.  The excess flow valve is designed to close when the rate of flow of liquid chlorine exceeds 7,000 pounds per hour.  The assumed leak duration is 60 minutes, for a total release of 7,000 pounds of chlorine.  The assumed meteorological conditions are 3.0 meters per second wind speed, atmospheric Stability Class D (neutral stability, overcast conditions), and urban terrain.  Under these conditions, the EPA  OCA Reference Table 24 predicts a distance of about 0.2 mile to the toxic endpoint (0.0087 mg/L) of the release.  The population affected by this scenario is approximately 30, based on 1990 U.S. Census data. 
 
The public receptors within this distance include commercial/industrial areas.  The environmental receptors within this distance include the Kansa 
s River. 
 
We are using this information to help ensure that our plant site and community emergency response plans address all reasonable contingency cases. 
 
Administrative controls that help prevent such releases from ever happening include proper training of all plant operators in the use of chlorine equipment.  At least two trained and certified operators are used whenever work is done in the chlorine evaporator room, when making connections to, and when disconnecting from the chlorine tank cars.  One operator acts as "safety observer", while the other(s) work on the equipment.  Each time a new tank car or container is connected for use, the operator performs a leak check of all connections to assure they are secure and properly installed. 
 
We also use specialized instrumentation that provides continuous chlorine leak monitoring of the area around each chlorine tank railcar, the evaporator building, and the chlorine feed room.  Even a small leak in any of these areas would activate a 
n alarm and alert the operators on duty at the plant. 
 
4.0     General Accidental Release Prevention Program and Chemical-Specific Prevention Steps 
 
We maintain a number of programs to help prevent accidental releases and ensure safe operation.  The prevention programs in place include: 
 
1.     Regular review of safety information such as Materials Safety Data Sheets (MSDS), daily 
        documentation of chlorine inventory, and regular updating of safety information to assure 
        accuracy and completeness. 
2.     Hazard review of the chlorination system using industry recommended checklists to assess 
        potential problems that could result in an accidental release, determine the safeguards needed 
        to control hazards or prevent equipment malfunction. 
3.     Written operating procedures that address initial startup, normal operations, temporary operations, 
        emergency shutdown, emergency operation, normal shutdown, startup following a normal or  
        emerg 
ency shutdown or a major change, consequences of deviations and steps required to correct 
        or avoid deviations, and routine equipment inspections. 
4.     Regular employee training to assure that each plant operator has the required knowledge, skills, 
       and abilities to safely carry out the duties and responsibilities assigned. 
5.     Written maintenance procedures and documentation to assure safe operation of critical equipment. 
       Operators routinely review these procedures prior to beginning maintenance procedures on the 
        chlorination equipment. 
6.     Compliance audits every 3 years to assure that the Topeka Water Treatment Plant facility and its 
       operators implement the risk management program and comply with the regulations. 
7.     Written plan for conducting an incident investigation, should even a minor release or near-miss 
        incident occur. 
 
These individual elements of our prevention program work together to prevent accidental chemical  
releases.  The City of Topeka Water Division and our employees are committed to the standard that these management systems set for the way we work, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. 
 
5.0      Five-Year Accident History 
 
We keep records for all significant accidental chemical releases that occur at our facility.  We have had no accidental releases involving chlorine during the past five years.  If an accidental release occurs, we are fully prepared and committed to conducting a formal incident investigation to identify and correct the root cause of the event. 
 
6.0     Emergency Response Program 
 
We maintain 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 the workers, the public, and the environment during  
emergency situations.  We maintain our own specially trained, on-site Hazardous Materials response team to assure a rapid response in the event of a chemical spill or leak.  Furthermore, we have coordinated our program with the LEPC, the community emergency response plan, and the City of Topeka Fire Department. 
 
7.0     Planned Changes to Improve Safety 
 
The following is a list of improvements that we are planning to implement at our facility to help prevent and/or better respond to accidental chemical releases: 
 
    1.     Implementation of a comprehensive Water Division training program. 
    2.     Installation of siren/horn audible alarms for alarm enhancement. 
    3.     Modernization and update of the chlorine leak detection system equipment.
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