Lake Worth Water Treatment Plant - Executive Summary
RISK MANAGEMENT PLAN |
LAKE WORTH WATER PLANT
1. Corporate Prevention and Emergency Response Approach
The City of Lake Worth Water Treatment Plant (Lake Worth) is owned by the City of Lake Worth Utilities. The facility has developed and maintains accident prevention programs and an emergency response plan to prevent and mitigate the effects of hazardous chemical releases.
2. Description of Stationary Source
The Lake Worth WTP is a Water Treament facility located on at 301 College Street, west of downtown Lake Worth, Palm Beach County, Florida. Lake Worth adds chlorine in their chlorination process in order to disinfect the City's water supply.
Liquefied chlorine gas is stored in up to eighteen one-ton containers at the Chlorination process. Four one-ton containers are always connected to the process with two on standby, while up to twelve additional containers are stored adjacent to the connected containers. The total chlorine inventory in the process a
t any one time is 36,000 lbs. This is greater than the 2,500 lb. RMP threshold quantity for chlorine. This process is not in an enclosed in a building.
3. Description of the Worst Case and Alternative Release Scenarios
The Worst Case release scenario is the rupture of a one- ton container from the Chlorination process, releasing 2,000 lbs. of Chlorine gas over a ten minute period. Under worst case weather conditions, the chlorine gas could travel 1.30 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .0087 mg/L), using the WWTP Guidance lookup tables.
The Alternative-Case Release Scenario is characterized by a two- phase release due the failure of the liquid supply valve connection from worker/human error, external impact, or corrosion. For the chlorination (Chlorine) process, the release rate was determined to be 1,387 lbs/min. Under normally expected weather conditions, the chlorination processes chlori
ne gas could travel 0.6 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .0087 mg/L), using the WWTP Guidance.
4. Prevention Program
For the Chlorination process, this facility exceeds the chlorine threshold quantity for the OSHA Process Safety Management (PSM) Standard, 1910.119, and is therefore subject to the PSM requirements. For RMP compliance purposes, this places the Lake Worth Chlorination process in the Program 3 level. The Lake Worth facility will use its PSM program as the required Program 3 Prevention Program.
The Lake Worth Water Treatment Plant has a program in place to comply with the OSHA Process Safety Management Standard, 29 CFR 1910.119. To ensure that all requirements of the RMP regulation were met, the PSM Program was reviewed and updated in 1999. The PSM Program includes written operating procedures for the chlorination processes. These procedures cover all phases of operation and in
clude information on worker protection. These procedures will be used to train all operators and mechanics who work on the chlorination processes to ensure consistency of operation and minimize human error. The PSM Program also includes a preventative maintenance plan which requires all chlorination equipment to be periodically inspected and serviced. This will ensure that the equipment remains in good operating condition and will minimize the probability of accidents due to faulty equipment. Safe work practices, such as Lockout/Tagout and Hot Work Permit, have long been required by the Lake Worth Treatment Operations Department. These were reviewed and updated to ensure that all non-routine work can be performed safely. Other components of the Prevention Program include the collection and review of all equipment information and the development of updated Piping & Instrumentation Diagrams (P&IDs). These actions will ensure that the equipment meets all chlorination industry stand
ards and that accurate equipment information will be available when needed. The staff also performed a Process Hazard Analysis of the process. Other PSM procedures, including Management of Change, Pre-Startup Safety Review, Compliance Audits, and Incident Investigation have also been incorporated into this program to ensure continued safe operation and prompt correction of deficiencies. The PSM Program receives full support of plant management and involvement of employees at all levels.
5. Accident History
The Lake Worth Water Treatment facility has had no accidental releases of chlorine in the past five years.
6. Emergency Response Program
The Lake Worth has an Emergency Response Plan in place. The program complies with 29 CFR 1910.38. The site also has some internal emergency response capability and has a procedure to address small releases of chlorine. The current plan has been coordinated with the Lake Worth Fire Department and Palm Beach County Hazardous Materials Respo
nse Team, and the Regional Local Emergency Planning Committee. Notification is made locally by dialing 911, and by notifying Florida State Warning Point at (800) 320-0519.