Riverside Water Treatment Plant - Executive Summary |
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Executive Summary The United States Environmental Protection Agency (EPA) requires that facilities having regulated substances above listed threshold quantities must develop a formal Risk Management Program (RMProgram) and register and submit a Risk Management Plan (RMPlan). These new regulations also apply to an estimated 7,200 public and private drinking water and wastewater treatment facilities that use significant quantities of chlorine or ammonia. This rule was formulated to decrease the number and severity of serious chemical accidents, such as the tragedies that have occurred in Bhopal, India (1984, 2500 fatalities), and Pasadena, Texas (1989, 23 fatalities). The EPA regulation applies to facilities that manufacture, process, use, store, or otherwise handle regulated extremely hazardous substances in quantities that exceed specified thresholds (40 CFR Part 68 Subpart C). The Greater Johnstown Water Authority's Riverside Water Treatment Plant operates under the follo wing objectives: to provide sufficient water of safe, sanitary quality, and to provide an attractive water, which is free from objectionable turbidity, color, taste and odor. In order to achieve these objectives, the implementation of Chlorine treatment is a necessity. Due to the large volume of customers served by the Riverside Water Treatment Plant (over 62,000 persons), subsequently large volumes of Chlorine must be available on-site for the effective treatment process. In compliance with the EPA's Risk Management Rule, Greater Johnstown Water Authority, Laurel Management Company and Gibson-Thomas Engineering Co., Inc. have developed a Risk Management Plan that will not only aid in preventing avoidable accidents, but also better inform the public as to the many steps and precautions involved in the process of water treatment and distribution, and the necessary conduct to follow in the event of a chemical accident at the Riverside Water Treatment Plant. The Riverside Water Tre atment Plant is located at 242 Neil Street in Johnstown, Pennsylvania. The Plant is owned by the Greater Johnstown Water Authority and operated by the Laurel Management Company of Johnstown. The Authority supplies domestic, commercial and industrial water to the Greater Johnstown Area. Chlorine is the only regulated chemical stored on-site at the Riverside Water Treatment Plant. Approximately 8,000 lbs. of chlorine are stored in four (4) 2,000 lbs. vessels. As part of the RMP compliance, a worst-case scenario predicated on the release of chlorine gas has been modeled utilizing the EPA's OCA Guidance Reference Tables or Equations. The worst-case release quantity has been determined to be 2,000 lbs. (1 vessel), at a release rate of 200 lbs./minute for a 10-minute duration. In this highly unlikely scenario, the affected area would be a 2.63 mile radius from the center of the treatment facility. In this situation, approximately 790 persons living within the radius would be subj ect to the affects of the chlorine gas. Not only does this 2.63 mile radius encompass almost 800 individuals, but also schools, churches, recreation areas and a hospital. Because the likelihood of such an occurence taking place is so minute, a more realistic alternative release scenario has also been formulated using the EPA's OCA Guidance Reference Tables or Equations. This alternative release scenario is modeled after an occurrence that is more likely to occur than the total release of a 2,000 lbs. vessel. In this alternative situation, chlorine gas would be released during a transfer hose failure during the connection process of a full tank. According to the model, approximately 317 lbs. of chlorine gas would be released at a rate of 10.5 lbs./minute over a one-hour duration. The outcome of this type of release is much less severe than that of the worst-case scenario results. The affected area is shown to be a radius of only 0.48 miles, affecting only 140 persons and no s chools, churches, parks or hospitals. Flammable chemical modeling was not required for this RMP because the Riverside Water Treatment Plant does not house flammable chemicals in quantities exceeding EPA threshold requirements. As part of the Risk Management Plan compliance, each facility is required to update their individual plan every five (5) years. Section 6 of the plan is reserved for any reportable accident or chemical spill that has occurred in the last five years. This Five Year Accident History portion of the current plan is vacant because no accidents or spills have occurred within the last five years. The main goal of the Level 2 Prevention Program (Section 8) is to reduce the risk to employees and the public of injury or death from the accidental release of chemicals. The requirements of the Level 2 Prevention Program are detailed in 40 CFR 68.48 through 68.60 and include safety information, hazard review, operating procedures, training, maintenance, compliance a udits and incident investigations. |