City of Wheeling - Water Treatment Plant - Executive Summary |
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Wheeling Water Treatment Facility Risk Management Plan Executive Summary Regulations contained in 40 CFR 68 require facilities which store hazardous chemicals in excess of a certain threshold amounts to develop and submit to the USEPA a Risk Management Plan (RMP). The regulated chemicals and the threshold amounts are listed in the regulations and a variety of guidance documents. The Water Treatment Plant (WTP) of the City of Wheeling qualified for inclusion in the RMP due to the presence of chlorine stored on-site. The threshold amount for chlorine is 2,500 lbs. Those facilities with 2,500 lbs. or more are subject to RMP regulations. The maximum amount of chlorine present at the facility is 16,000 lbs. (8 - 1 ton cylinders can be stored at one time). RMP regulations require the owner to determine which program level that the facility falls under. There are three levels. Program 1 is for facilities where a worst case release would not have an effect on any off-site public or en vironmental receptors. The WTP did not qualify for this program level. Program levels 2 and 3 are for facilities where a worst case release would have an effect on any off-site public or environmental receptors. Program 3 facilities are those that have either a specific SIC Code (a list of the codes that indicate a Program 3 industry are included in 40 CFR 68) or are subject to OSHA Process Safety Management Regulations. The WTP was not included by SIC codes and is not subject to OSHA regulations and therefore qualified as a Program 2 facility. A worst case release scenario was conducted as required by the RMP. The scenario dictates that the largest single vessel or container be released to the atmosphere over a 10 minute period. Air dispersion modeling was conducted using Areal Locations of Hazardous Atmospheres (ALOHA) to determine the distance to the toxic endpoint. The model indicated that the distance to the toxic endpoint was 0.76 miles. The effected population was estim ated to be 3,700 people. Public receptors were identified as schools, residences, hospitals, recreation areas, major commercial areas, office buildings, industrial areas, churches and shopping areas. There were no environmental receptors identified by the model. The regulations also require that the facility model an air release of a more likely release scenario. After inspection of the treatment plant, a scenario which consisted of a leak at the valve mounted on the chlorine cylinder selected as more likely. There are vacuum regulators mounted directly on to the feed valves of the chlorine cylinder. The valve failure scenario was the only likely release identified. Specifically, Valve Failure - scenario CLA-3 (5/16" hole at valve body) From Model RMPlan for the Water Industry Table 5-5 pg. 5-22, AWWARF, Nov. 1998 was used. Air dispersion modeling was conducted using Areal Locations of Hazardous Atmospheres (ALOHA) to determine the distance to the toxic endpoint for this scena rio. The model indicated that the distance to the toxic endpoint was 0.12 miles. The effected population was estimated to be 550 people. Public receptors were identified as a school and recreation areas. There were no environmental receptors identified by the model. The WTP has an active release prevention program in place. Elements of the prevention program include automatic leak sensors with local and remote alarms. There are notification procedures in place with detailed instructions for employees to call 911 whenever an uncontrollable release of chlorine occurs. WTP employees are trained annually in the properties and safe handling of chlorine. Employees are also trained in the use of safety equipment including SCBAs and leak repair kits. RMP required prevention program elements also include a management system to be developed. Safety information such as, Material Safety Data Sheets for chlorine, maximum intended inventory of regulated substances, safe upper and lower tem peratures, pressures, flows and compositions of equipment used to store and handle the regulated substance, equipment specifications and codes and standards used to design, build and operate the process was compiled. The above will be updated if a major change occurs that makes the information inaccurate. The facility will conduct a hazards review of the regulated process at least every five years or whenever a major change to the system occurs. Use of a checklist and 'what if' questionnaire facilitate the completion of the hazard review. Operating and maintenance manuals are available for personnel to use for reference purposes. These manuals detail the proper and safe procedures for handling the regulated chemical as well as maintenance procedures and frequencies. The operators log amounts of chemical used and operating adjustments made to the process. Maintenance personnel log maintenance procedures performed on the process equipment. All current employees have received traini ng in the properties of the regulated chemical and the safe and proper operation of equipment used to store and handle the substance. New employees are trained as above before they are permitted to operate or maintain the chlorine system. Annual training updates are conducted. All training activities are to be recorded on training logs. At least every three years, the facility conducts a compliance audit to ensure that the facility is adhering to all the elements of the RMP. A compliance audit checklist is used to conduct the compliance audit. Whenever an incident which resulted in, or could reasonably have resulted in a catastrophic release occurs the owner conducts an incident investigation. The owner promptly addresses and resolves the investigation findings and recommendations. Resolutions and corrective actions are documented. The findings of the investigation are reviewed with all affected personnel whose job tasks are affected by the findings. Investigation summaries will be retained for five years. The facility has had no accidental releases of chlorine which have resulted in on-site deaths, injuries or significant property damage or known offsite deaths, injuries, property damage, environmental damage, evacuations or sheltering in place in the last five years. The WTP is included in the community's Emergency Response Plan. The Water Treatment Facility does respond to incidental releases of chlorine that can be controlled at the time of release by employees in the immediate release area. This does not constitute a response under OSHA's HAZWOPER Standard (29 CFR 1910.120) which was adopted by EPA for use in the Risk Management Plan Regulations. For releases where concentrations of the regulated chemical in the work area exceed relevant work place standards, such as OSHA Permissible Exposure Limit (1 ppm, Short Term Exposure Limit) or where the leak is clearly progressing so that a hazard is imminent, the release can no longer be considered inciden tal and emergency responders will be alerted. The community's Emergency Response Plan has evacuation, shelter in place and vehicular traffic detour contingencies in place if a release of toxic material occurs. The Emergency Response Plan also has procedures in place to notify the city Fire Department as well as Chemtrec (1-800-424-9300) in the event of a chlorine release. The program is activated by 911 when they receive notice of a chlorine leak from the WTP. Chemtrec is designated as first responders for chlorine releases. The Fire Department and Water Pollution Control Facility employees will provide support services to Chemtrec during release events. The WTP has recently upgraded its chlorine facilities and anticipates no major changes to the chlorine storage or handling system in the near future. Any changes that do occur will result in an update of this RMP. |