CIty of Jacksonville Beach Water Plant No. 1 - Executive Summary |
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CITY OF JACKSONVILLE BEACH WATER TREATMENT PLANT NUMBER ONE EXECUTIVE SUMMARY The City of Jacksonville Beach Water Treatment Plant Number One (Facility) is a water supply facility (NAICS Code 22131) for the city of Jacksonville Beach, using one regulated substance, chlorine (CAS Number 7782-50-5), in the chlorination process. The chlorination process consists of the use of chlorine from one-ton cylinders to treat potable water in a standard chlorine disinfection system. The hazard assessment was performed on the chlorination process using the United States Environmental Protection Agency (USEPA) RMP*CompTM Model. The worst-case release scenario was assumed to be the release of a one ton cylinder over a 10 minute period. The alternative release scenario selected for the Facility was a failure scenario developed during the process hazard review and analysis. In this scenario, a 0.25-inch diameter orifice is formed in a one-ton cylinder as the re sult of a poor bond between the lead alloy and the fusible plug retainer. The Facility has the capability of responding to and stopping the leak within 30 minutes of detection. For both scenarios, the off-site consequence analysis indicated that off-site receptors could be potentially impacted by the release of chlorine. Although off-site areas would be impacted, the Facility believes that safety procedures and mitigation measures will reduce the potential for off-site consequences and subsequent risks to the surrounding community. The Facility's safety devices include chlorine leak detectors, alarms, and an automatic system shut-off feature triggered by a loss in system vacuum. In order to fulfill the requirements of the Risk Management Program (RMP), the Facility has developed an accidental release prevention program and emergency action plan for the Facility. The accidental release prevention program satisfies the requirements for the USEPA RMP and the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) program. The prevention program ensures that the Facility is operated under safe conditions and that any risk of an accidental release of chlorine is minimized. The program has been written to reduce the potential of an accidental release due to human error, or equipment failure at the Facility. In order to help prevent the release of chlorine due to human error, the Facility's prevention program ensures that operating procedures are current and reviewed annually. Training also plays a vital part in the Facility's program. Employees and contractors working near or on the chlorination process are required to be trained in the chlorination process and the hazards of chlorine. To prevent equipment failure that could result in a release, the program ensures that equipment inspections, tests, and preventive maintenance are performed in accordance with accepted engineering practices, manufacturer's recommendations, and p lanned maintenance schedules. All chlorine cylinders are examined upon delivery and are rejected if there are any signs of damage. In addition, equipment pertaining to the chlorine process is visually inspected daily. The potential for a chlorine release is greatly reduced in the chlorination process due to the use of a vacuum system from the point of chlorine withdrawal to its point of application. In the event that there is a failure in chlorination equipment, the system will automatically shut down (i.e. failsafe). All existing and proposed future chlorination equipment have been designed according to applicable standards and codes. The Facility maintains records and documentation on equipment inspection and tests. Precautions are taken to ensure that new equipment and processes are inspected and tested, that all changes on the process are authorized, and employees are informed of changes. The Facility performed a Process Hazard Analysis (PHA) to address the hazards in the chlorination process and to evaluate and control where the potential for a chlorine release exists. Employees were involved in determining hazards of the process and subsequent consequences. The chlorination process was found to be operating safely and no changes were recommended. Active employee participation will ensure the success of the RMP at the Facility. Employees have been assigned various tasks to ensure that all elements of the RMP are implemented. The Facility has developed management forms to assist employees in recording and documenting the various elements of the RMP. At the time of the submittal of this Risk Management Plan, there have been no accidental releases of chlorine at the Facility in the past five years. However, in the event that there is an accidental release of chlorine, an Emergency Action Plan has been written in compliance with 29 CFR 1910.38. The Facility is also included in the community emergency response plan. Employees at the Facility d o not respond to accidental releases of chlorine, but coordinate with outside responders. Therefore, an Emergency Response Program is not required for the Facility. In the event that a chlorine release occurs, all employees are required to evacuate the process area and report the incident. The emergency action plan consists of evacuation procedures, facility emergency numbers, and coordination with the City of Jacksonville Beach Fire Department. The plan also addresses notification procedures to the public and the local emergency response agency. |