Town of Southern Pines Water Treatment Plant - Executive Summary |
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Hydro Management Services Southern Pines, North Carolina Water Treatment Plant RMP Executive Summary Hydro Management Services has implemented a comprehensive program to safely manage chlorine at its Southern Pines Water Treatment Plant located in Southern Pines, North Carolina. There have been no chlorine incidents in the most recent five year history period. To comply with the EPA's 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) regulations. 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 chlorine managem ent; and - Chlorine system maintenance procedures. Additional steps have been implemented to complete the PSM program: -Training on PSM/RMP 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 PSM/RMP compliance, the plant has implemented or is implementing a number of programs to improve the safe handling of chlorine and other chemicals. -The chlorine delivery system at the plant is being upgraded to a full vacuum process. This process has proven to reduce leaks by reducing the amount of equipment that is exposed to pressurized chlorine. - Plant inventories are controlled to maintain only three chlorine cylinders on 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. Where necessary, communication plans have been developed to notify businesses or residences that may be impacted by a release. Chlorine Response Drills are 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 each site. The "Worst Case" modeling showed the potential impact of a full, 2000 pound cylinder of chlorine released in 10 minutes. This resulting chlorine plume extended 0.90 miles. For the "Alternative Case, a more typical pos sible 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 Water Treatment Plant is located approximately 8.25 miles southwest of downtown Southern Pines, just outside the southwest corner of the Town of Pinebluff. The Water Treatment Plant is located in a relatively level, flat area typical of the Sandhills region of the Carolina Coastal Plain. The topographic gradient in the vicinity of the site slopes very slightly downward toward the east. Vegetation in the area of a chlorine release tends to react with the gas, absorbing it and mitigating the effects of the release. The site is located in a heavily vegetated area on the west side of U.S. Highway 1. Thus, a chlorine release should result in minimum public exposure. In addition to Process Safety Management, the organization has an act ive 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 Water Treatment 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 with no recordable injuries over the past three years. As mentioned earlier, there have been no reportable chlorine releases from the plants in the last five years. The plant has worked extensively to upgrade its safety program. Report by: Gary Stainback Director of Operations Hydro Management Services, Inc. |