City of Oxford Wastewater Treatment Plant - Executive Summary |
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Hydro Management Services Oxford, North Carolina Wastewater Treatment Plant RMP Executive Summary Hydro Management Services has implemented a comprehensive program to safely manage chlorine at the Oxford Wastewater Treatment Plant located in Oxford, North Carolina. There have been no chlorine incidents in the most recent five-year period nor in the 20-year history of the plant. To comply with the EPA Risk Management Program (RMP), the initial step was to develop a prevention program as required by the RMP and by the OSHA Process Safety Management (PSM) regulation. This prevention program was initiated at the Plant using a consulting organization. An RMP/PSM Compliance Manual was developed for the site. Key items included in the manual are: -Written site specific procedures for Employee Involvement, Management of Change, Incident Investigation, Pre-Startup Reviews and Self Audits; -Chlorine safety information as required by the regulations; -Standard Operating Procedures for c hlorine management; and -Chlorine system maintenance procedures. The following additional steps have been implemented to complete the prevention program: -Training on PSM and its key components including Management of Change, Mechanical Integrity and Incident Investigation; -Conducting Process Hazards Analyses for the three chlorine processes; -Developing an initial Emergency Response Plan; and -Training in support of the certification of operators. The plant superintendent and company safety officer are meeting several times per year to review and update procedures and to maintain compliance with all aspects of the PSM/ RMP regulations. In addition to RMP/PSM compliance, the plant has implemented a number of programs to improve the safe handling of chlorine and other chemicals. -In 1996, a full vacuum chlorine delivery system was installed. The vacuum process has proven to greatly reduce leaks by reducing the amount of equipment that is exposed to pressurized chlorin e. -Plant inventories are being reduced from five (5) full cylinders to three (3) full cylinders of chlorine at the site. The site's Emergency Response Plans (ERP) have been significantly upgraded. In 1999, the ERP was revised to include offsite response and communication. The County LEPC and other local response organizations have been incorporated into the ERP. The services of a Regional Hazmat Team to provide hazardous materials response has been obtained. Where necessary, communication plans have been developed to residences that may be impacted by a release. Chlorine Response Drills are being routinely conducted. To further understand chlorine risks, a consulting firm was contracted to conduct "Offsite Consequence" Modeling Analysis, as required by EPA's Risk Management Program. Both a "Worst Case" and an "Alternative Case" chlorine release scenarios were studied for the site. The "Worst Case" modeling showed the potential impact of a full, 2000 pound cylinder of chlorine rel eased in 10 minutes. This resulting chlorine plume extended 1.3 miles. For the "Alternative Case," a more typical possible release of 180 pounds, three pounds/minute for 60 minutes, was modeled. The modeling indicated that a plume extending 0.1 miles would result. The modeling showed that the risk of chlorine exposure is low due to the favorable location of the plant. The Wastewater Treatment Plant is located approximately 1.6 miles south of the City of Oxford at 1649 New Commerce Drive. The site is located in a low-lying area, on a slight hill that slopes downward to the west to Fishing Creek. An unnamed, intermittent tributary to Fishing Creek is located about 100 feet north of the plant. Also, the plant is surrounded by heavy vegetation. Since chlorine is a heavier-than-air, reactive gas, the surrounding terrain would act to contain and dissipate any chlorine release. Thus, a chlorine release should result in no public exposure to minimum public exposure. In addition to Process Safety Management, the organization has an active safety program. Hydro Management Services has an active Safety Committee. The committee meets monthly and its duties include reviewing new safety procedures, accident investigations, safety surveys and safety communications. At the Wastewater Plant, there are monthly safety meetings to review an OSHA subject or discuss a safety issue. Routine training is conducted for topics such as: - Hazard Communications -Personal Protective Equipment -Lockout/Tagged -Confined Space As a result of our programs, the plant has had an excellent safety record over the past three years. As mentioned earlier, there have been no reportable chlorine releases from the plant. The plant has worked extensively to upgrade its safety program. Report by: Gary Stainback Director of Operations Hydro Management Services, Inc. |