John Kubala Water Treatment Plant - Executive Summary
Facility Description |
The John Kubala Water Treatment Plant is located in Arlington, Texas at 7001 US Hwy 287. The facility is owned and operated by the City of Arlington. This facility is a conventional water treatment plant and uses chlorine and anhydrous ammonia as part of the treatment process. Currently, a maximum of 85,000 pounds of chlorine and 13,200 pounds of anhydrous ammonia are maintained on the site. No other toxic or flammable substances, as listed in 40 CFR 68, are stored or utilized at the facility.
The anhydrous ammonia and chlorine are stored in bulk storage tanks located within separate completely enclosed areas at the facility. All anhydrous ammonia and chlorine feed systems are likewise located within the building. This protects these processes, helping to minimize the chance that an accidental release will occur. The building itself would mitigate a release, should one occur, by containing both gas and liquid.
Other safeguards at the facility include the
air scrubbers for both the chlorine and ammonia storage areas. The chlorine scrubber would neutralize chlorine using sodium hydroxide. The anhydrous ammonia scrubber uses water.
The City of Arlington is fully committed to safety at the water treatment plant. Arlington Water Utilities has long emphasized the importance of safety in storing and using regulated toxic substances and has used the 40 CFR 68 requirements as an opportunity to further refine its safety program. This opportunity has also been used to strengthen emergency response procedures between the water treatment plant and the City of Arlington Fire Department. The Fire Department is capable of responding to accidental releases of chlorine or anhydrous ammonia, should a release occur. Arlington Water Utilities is committed to a process of continual improvement in its risk management program at the John Kubala Water Treatment Plant.
Five Year Accident History
The commitment to managing r
isks associated with chlorine and anhydrous ammonia is demonstrated by the excellent track record at the John Kubala Water Treatment Plant with respect to these substances. The water treatment plan has not experienced an accident related to chlorine or anhydrous ammonia within the past five years.
Offsite Consequence Analysis
Chlorine was established as having the largest radius of impact, and was thus used for the worst-case scenario. Public receptors do exist within this radius. As required by the risk management regulations, the offsite consequence analysis also required development of alternative-release scenarios for both chlorine and anhydrous ammonia. Realistic potential alternatives were modeled, with consideration toward actual conditions at the site. The resulting radii of impact are therefore useful tools for emergency response teams in planning for and responding to emergency situations.
Prevention Program Description
The prevention program represents the core of th
e day-to-day means by which accidental releases of regulated substances into the air will be minimized. This component will be used primarily by plant personnel responsible for the operation and maintenance of regulated processes at the facility. The prevention program will also become a useful tool in ongoing training of plant personnel.
The Program 2 Prevention Program includes seven primary components:
7 Safety Information: Up-to-date safety information has been compiled relating to regulated substances, processes, and equipment. Safety information will also be updated any time a major change occurs that would make the safety information inaccurate.
7 Hazard Review: Regulated processes at the facility have been reviewed to identify potential hazards. The results have been documented in a hazard review report. Problems identified by the hazard review are being resolved in a timely manner.
7 Operating Procedures: Written operating procedures have been prepared providing ins
tructions for safely conducting activities associated with regulated processes. These procedures will also be updated should a major change in the handling or storage of regulated substances occur.
7 Training: Plant personnel responsible for operating regulated processes receive training in the processes. Periodic refresher training is required.
7 Maintenance: Procedures have been implemented to ensure that the mechanical integrity of the process equipment is maintained. Ongoing training of personnel responsible for maintenance is also required. Inspection and testing of regulated process equipment is a requirement as well.
7 Compliance Audits: The prevention program will be audited at least once every three years to evaluate compliance with the risk management rules. The results of the audit will be documented, and deficiencies corrected.
7 Incident Investigation: Should an incident involving a release, or near release, of a regulated substance occur, it will be investigate
d promptly. The findings of any such incident investigation will be used to improve the safety of the process.
Emergency Response Program
The City of Arlington has determined that the staff assigned to the John Kubala Water Treatment Plant will assume a non-responder status with respect to accidental releases of chlorine or anhydrous ammonia. The Fire Department will instead be the appropriate local emergency response agency in such cases. The Arlington Fire Department has the necessary training to respond to chlorine and anhydrous ammonia leaks. Arlington Water Utilities has coordinated with the Fire Department to ensure that the facility is included in the community emergency response plan regarding response to a potential release.
Even though the John Kubala plant will be a non-responding facility, its employees still have a significant role in the event of a release of chlorine or anhydrous ammonia. Should a release occur or be suspected when employees are at the facility,
employees responsible for working with chlorine and anhydrous ammonia will follow procedures for assessing the situation and attempting to safely stop the release by "valving off" the gas supply before a leak becomes a significant problem. Facility personnel will receive ongoing training in identification of potential releases, and in how to determine when emergency response personnel should be involved.
Arlington Water Utilities will continue to work closely with the Fire Department to ensure that emergency response, should it become necessary, is efficiently and safely carried out. Coordination may include:
7 periodic meetings between operators and Fire Department emergency responders to discuss emergency response measures
7 periodic inspections of the facility by Fire Department emergency responders to ensure their familiarity with routes to the facility, ingress and egress routes at the facility, and layout of the chlorine and anhydrous ammonia process areas
7 periodic practi
ce drills utilizing both Water Utilities and Fire Department personnel.
Employees responsible for working with chlorine and anhydrous ammonia will receive periodic training, as detailed in the Procedures Manual of the RMProgram.
Arlington Water Utilities will continue to improve its risk management program for the water treatment plant by responding to the recommended changes outlined in the Hazard Review, by ongoing training of personnel, and by continued coordination with emergency response officials. As the water treatment plant grows to meet the growing demands of the City, future plant expansions will consider further improvements in the treatment process to manage risks associated with these regulated substances.