Goose Creek Water Treatment Plant - Executive Summary

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Executive Summary 
Release prevention and emergency response policies 
The City of Fairfax (City) takes an active role in preventing accidental releases at it's water treatment facility by ensuring that its employees are properly trained in the safe operation and maintenance of processes subject to the Part 68 rule.  This training includes the safe handling of regulated substances under the rule. 
The City has also developed and maintained a risk management policy that contains general safety rules.  Though these rules do not specifically address the covered processes and their regulated substances, compliance with the general rules significantly reduces the potential for accidental releases of the regulated substances.  This facility complies with industry-standard practices for water treatment plants that use chlorine in bulk.  
As for emergency response, the City has established and maintains procedures for emergency notification and response.  These 
are reviewed with employees on a periodic basis and revised to accommodate changes in staffing when they occur.  In general, the City would deal only with incidental releases of a small amount of a regulated substance.  If the release is determined to be large or if the chemical is stored outside or has migrated outside from a release indoors, the City would immediately notify the Loudoun County Fire Department. 
City management understands its duty to provide a safe working environment at this facility and to take measures to prevent accidents that may have an effect on the surrounding community.  This understanding is reflected in procedures described and referenced in this document. 
Facility and regulated substance    
The Goose Creek WTP treats surface water from Goose Creek to provide drinking water to the community.  It does this through a series of physical and chemical treatment operations that include pretreatment neutralization, flocculation and sedimentation, filtration, and 
disinfection with chlorine. 
The treated water, now ready for use by the public, is transferred to a large reservoir and pumped into the distribution system.  The design capacity of the treatment plant is 18 million gallons per day.  
The regulated substance that is stored, handled, and used at this facility is chlorine. The chlorine is stored in one-ton containers with a maximum intended inventory of 14 containers on site.  The chlorine containers are stored inside the chlorine room and in the loading dock area. 
Worst-case and alternative release scenarios 
The worst-case release scenario for chlorine involves one of the one-ton containers used in the process.  Each can contain 2,000 pounds of chlorine.  The rule for worst-case release analysis assumes all of the contents are released in 10 minutes.  The scenario assumed a release of all the contents of the container outside of any enclosure, though the containers are normally stored inside of a building.  No mitigative measures were c 
The choice for alternative release was a severed header in the storage and feed room, allowing the contents of two connected and full containers to release into the chlorine room.  The chlorine is released into the room through a 3/8-inch diameter hole at 5.7 atmospheres, the pressure inside a full container.  The hole releases 61.9 pounds per minute, taking approximately 65 minutes to empty the two containers.  The mitigation measure of release in an enclosed space is used. 
For both analyses, the EPA's RMP*Comp was used, which is based on the formulae in EPA's Risk Management Program Guidance for Wastewater Treatment Plants.  
Accidental release prevention program 
The facility's prevention program for chlorine complies with EPA's 40 CFR part 68 rule for Program 3 processes.  To maintain this compliance, the City has in place many procedural and technological safeguards.  The procedural safeguards include an employee-training program and operating and maintenance procedures  
for those employees involved in operating the covered processes.  The technological safeguards include controls, sensors, alarms, and industry-standard systems.  All of these serve to prevent unintended releases of chlorine. 
Should the prevention program fail to prevent a release, the chlorine storage containers are kept inside of a building to mitigate the effects of a release.    
Five-year accident history 
[to be written based on information from the City] 
Emergency response program   
This facility has established and maintains an emergency action plan that is coordinated with local response agencies, such as the Loudoun County Fire Department.  The goals of the plan are to protect onsite employees from the hazardous effects of the releases and to minimize the effects of releases on the general public.  The program is routinely reviewed and updated to reflect personnel and regulatory changes.  It is also submitted to the Fire Department for review and comment. 
City employees handle 
incidental releases of chlorine and are trained and equipped to do so. 
Planned changes to improve safety 
Ideas for changes to improve safety are actively sought from employees.  Employee meetings that focus on safety issues are held regularly at this facility.  Employees are encouraged and trained to recognize hazards and present ideas to eliminate them or to minimize the potential consequences of those hazards. 
   During the development of the risk management plan, hazard reviews were conducted with key employees to meet the prevention program requirements.  During these sessions, recommendations were made for the purpose of improving safety and preventing accidental chemical releases.  Each recommendation has been or is being considered and evaluated for implementation.  This evaluation process will provide all affected employees with a heightened awareness of safety issues related to the covered processes. 
Prevention Program-Water Treatment Plant 
The chemical accident prevention  
program for the chlorine process includes procedures and safeguards that are in place and in use throughout the facility.  These were cited in the hazard review sessions and include: 
* Administrative controls, such as operating procedures, operator inspection rounds, maintenance procedures, employee training, experienced personnel, and reliable vendors; 
* Sensors and alarms for the presence of chlorine; and 
* Design safeguards such as relief devices and vacuum regulators. 
The prevention program contains the elements required for Program 3 processes, including safety information, hazard review, operating procedures, training, maintenance, compliance audits, incident investigations, hot work permits, and contractor management.
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