Williams Water Treatment Plant - Executive Summary |
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File attached. WILLIAMS WATER TREATMENT PLANT AND RISK MANAGEMENT PLAN SUBMITTED June 21, 1999 EXECUTIVE SUMMARY 1. Corporate Prevention and Emergency Response Approach The Williams Water Treatment Plant (Williams Plant) is part of Water Utilities a division 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 Williams Plant is located at 1501 West Bella Vista Street in the north west corner of Lakeland, Florida. The plant consists of filtration, clarification, flouridation and purfication processes that treat drinking water for the City of Lakeland. The Wi lliams Plant adds chlorine to the filtered water as a purification 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. Six containers are always connected to the chlorination system, and up to ten are stored nearby. The total chlorine inventory in the process at any one time ranges from 12,0000 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 lb. 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 containe r 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, 0r 3 in order to determine the prevention program requirements. Since the worst case release from process 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 Williams facility is not one of the nine listed codes. This means that the Williams facility processes would be cla ssified 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 Williams 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 Williams 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 ha ve PSM listed processes. For RMP compliance purposes, this places the Williams Plant process in the Program 3 level. The Williams facility will use their PSM programs as the required Program 3 Prevention Program. The Williams Plant has a program in place to comply with the OSHA Process Safety Management Standard, 29 CFR 1919.119. The PSM Program was established in 1997 for the chlorine process. Although the programs are equivalent and have several common procedures, the programs must remain separate because the Facilities are part of separate City departments (see the Organization Chart attached). The PSM Programs of each facility receive full support of plant management and involvement of employees at all levels. 5. Accident History The Williams Plant has had no accidental releases of chlorine in the past five years. 6. Emergency Response Program As with the Prevention Program, the Williams 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 coordinated 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. |