W. Carl Dicks Water Reclamation Facility - Executive Summary
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W. CARL DICKS WATER RECLAMATION FACILITY
RISK MANAGEMENT PLAN
SUBMITTED June 21, 1999
1. Corporate Prevention and Emergency Response Approach
The W. Carl Dicks water Reclamation (W. Carl Dicks Plant) is part of the Wastewater Operations Divisions of the City of Lakeland, Florida. The City of Lakeland requires each site to develop and maintain accident prevention programs and an emergency response plan appropriate to the site. Each site is also responsible for regulatory compliance issues that apply to the site. The City of Lakeland Office of Risk Management provides assistance in training for site employees and in budgeting and procurement of safety and training.
2. Description of Stationary Source
The W. Carl Dicks Plant is located at 1825 Glendale Street in the Southeast corner of Lakeland, Florida. The plant consists of disinfection, clarification, and aeration process that treat wastewater for the City of Lakeland.
The W. Ca
rl Dicks Plant adds chlorine to the treated wastewater as a disinfection agent. The chlorination process is located in a three-walled, covered building at the southeast corner of the property, where liquefied chlorine gas is stored in up to sixteen one-ton containers. Eight containers are always connected to the chlorination system, and up to eight are stored nearby. The total chlorine inventory in the process at any one time ranges from 16,0000 to 32,000 lbs. This exceeds the 2,500-lb. RMP threshold quantity.
3. Description of the Worst Case and Alternative Release
The Worst-Case release scenario is the rupture of a 2,000 lbs. container, releasing 2,000 lbs. of chlorine gas over a ten-minute period. Under worst case weather conditions, the chlorine gas could travel 7.4 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .0087 mg/L).
The Alternative Release Scenario is a leak at a rate of 74 lb./min. from
the container liquid supply valve due to failure of the fitting that attaches the valve to the container. Under normally expected weather conditions, taking into consideration the alarm system at the facility, the chlorine gas could travel .99 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .0087 mg/L).
4. Prevention Program
The RMP regulation requires classification of each process into a Program Level 1, 2, or 3 in order to determine the prevention program requirements. Since the worst case release from both processes would impact a public receptor, the processes cannot be classified as Program 1. Program 3 processes include those that are not Program 1, but are subject to OSHA's Process Safety Management Standard, 1010.119, or are part of an industry in on of a 9 SIC codes listed in the RMP regulation. The W. Carl Dicks facility is not one of the nine listed codes. This means that the W. Carl Dicks f
acility processes would be classified as Program 3 only if the are subject to the PSM Standard.
The OSHA Act states that states or political subdivisions of states are not employers and are therefore not subject of OSHA regulation. Since the W. Carl Dicks facility is city-owned, it may be considered a political subdivision of a state and therefore not technically subject to Process Safety Management; however, OSHA standard 1975.5, States and Political Subdivisions Therefore, lists public utilities as an example of the type of entity which "would normally not be considered a 'political subdivision of a state'." This means utilities, and therefore the W. Carl Dicks facility, are subject to the PSM Standard. Additionally, the Florida Department of Labor, Division of Safety, which governs state entities, adopts all OSHA Standards, including PSM, and enforces compliance with them. This reasoning has lead the City of Lakeland to consider its processes as subject to PSM and to implement a
PSM program at all facilities which have PSM listed processes. For RMP compliance purposes, this places the W. Carl Dicks processes in the Program 3 level. The W. Carl Dicks facility will use its PSM program as the required Program 3 Prevention Program.
The W. Carl Dicks Plant has a program in place to comply with the OSHA Process Safety Management Standard, 29 CFR 1919.119. The PSM Programs were established in 1997 for the chlorine process. The PSM Programs of each facility receive full support of plant management and involvement of employees at all levels.
5. Accident History
The W. Carl Dicks facility has had no accidental releases of chlorine in the past five years.
6. Emergency Response Program
The W. Carl Dicks Plant has an Emergency Response Program in place. The program complies with 29 CFR 1910.38. The site also has some internal emergency response capability and is developing a program to comply with paragraph (q) of 29 CFR 1919.120. The current plans have been co
ordinated with the Lakeland Fire Department and Hazardous Materials Response Team, and the District 7 Local Emergency Planning Committee. Notification is made locally by dialing 911, and by notifying Florida State Warning Point at (800) 320-0519 or (904) 413-9911.