Turnpike Wastewater Reclamation Facility - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

EXECUTIVE SUMMARY 
 
INTRODUCTION 
 
The Turnpike Wastewater Reclamation Facility (Wastewater Reclamation Facility), owned and operated by the City of Leesburg is a sequencing batch reactor (SBR) wastewater treatment plant.  An integral component of the treatment plant is chlorine (Cl2) used for wastewater disinfection.  The Cl2 storage capacity of the facility is 14,000 pounds.  This inventory exceeds the 2,500-pound threshold for Cl2 set by EPA under the Risk Management Program (RMP) Rule codified at 40 CFR 68.  Pursuant to the requirements of the rule, the City of Leesburg has prepared this Risk Management Program (RMP) Plan. We are proud of our environmental, health, and safety efforts and programs and our record in these areas.  The following sections outline our RMP plan.    
 
OVERALL RESPONSIBILITY 
 
Our Director Water, Wastewater, Gas & Engineering has the overall responsibility for ensuring that our facility operates in a safe and reliable manner.  This responsibility includes overs 
eeing the implementation of the elements of our risk management program.  To ensure that our risk management program is appropriately developed and implemented, our Director Water, Wastewater, Gas & Engineering has assumed the role of RMP Coordinator.  The RMP Coordinator has the responsibility for the development, implementation, and integration of the EPA RMP elements.  In addition, the RMP Coordinator works closely with the Lead Operator/Operations Supervisor at the Wastewater Reclamation Facility to integrate the elements of OSHA's PSM program (where applicable) as required under Section 68.15 of the RMP rule.   
 
The RMP Coordinator serves as the chairman of the facility's RMP Steering Committee.  This committee comprises members with responsibilities for developing and managing specific elements of our risk management and process safety programs.  The members of this committee are assigned by the Director Water, Wastewater, Gas & Engineering.  Currently, the members of the RMP Ste 
ering Committee include the following:  
 
*  RMP Coordinator (Director Water, Wastewater, Gas & Engineering) 
*  Lead Operator/Operations Supervisor of the Wastewater Reclamation Facility 
*  Senior Operator of the Wastewater Reclamation Facility 
*  Purchasing Agent (City of Leesburg) 
 
The following sections identify the specific responsibilities for each aspect of our risk management and process safety management programs. 
 
HAZARD ASSESSMENTS 
 
The Director Water, Wastewater, Gas & Engineering has the responsibility for (1) ensuring that offsite consequence analyses for each regulated process are consistently performed and documented in accordance with Sections 68.20 through 68.39 and (2) selecting the scenarios that will be reported in the facility Risk Management Program Plan as required under Section 68.165.  The Director Water, Wastewater, Gas & Engineering also is responsible for ensuring that the accident history for each covered process is appropriately documented and maintaine 
d in accordance with Section 68.42 and 68.168 of the RMP rule. 
 
The rule requires the evaluation of a worst case scenario, though the likelihood of the occurrence of such a scenario may be extremely small.  The worst case scenario has been defined as a catastrophic release of one entire Cl2 tank containing 2,000 pounds.  The distance to the toxic endpoint as predicted by the EPA RMP Guidance for Wastewater Treatment Plant Reference Tables is 2.3 miles.  At this distance, residences, recreational areas, commercial/industrial areas, and a wildlife sanctuary appear to be vulnerable.  In addition to the worst case scenario, an alternative release scenario has been modeled employing more appropriate meteorological conditions and release assumptions.  In the alternative release scenario, 4.95 pounds of Cl2 per minute are assumed to be released as a result of a piping leak or valve failure.  A 15-minute release would be expected in such a scenario.  Based upon these assumptions, the distance  
to the endpoint as predicted by the RMP Guidance is 0.1 miles (528 feet).  At this distance, no residences, schools, recreational areas or environmental receptors appear to be vulnerable. 
 
FIVE-YEAR ACCIDENT HISTORY 
 
The Wastewater Reclamation Facility has had no reportable releases of Cl2.  As a state-of-the-art facility, this plant employs the most up-to-date industry-standard safety technology.  We have always taken a pro-active stance in the safety of our employees and the surrounding community and environment. 
 
PREVENTION PROGRAMS 
 
The RMP and PSM Coordinators have the responsibility for ensuring that the facility has an integrated, effective, and compliant prevention program that meets EPA RMP (Sections 68.65 through 68.87 of the RMP rule) and OSHA PSM requirements.   
 
PROCESS SAFETY INFORMATION 
 
The responsibility for process safety information (PSI) (Section 68.65 of the RMP rule) including the process chemical information, process technology information, and equipment informat 
ion is assigned to the Lead Operator/Operations Supervisor.  The Director Water, Wastewater, Gas & Engineering has the responsibility of ensuring that all of this information is readily accessible for use. 
 
PROCESS HAZARD ANALYSIS 
 
In accordance with Section 68.67 of the RMP rule, the Director Water, Wastewater, Gas & Engineering has the responsibility for ensuring that process hazard analyses (PHAs) are scheduled, conducted, and documented by the Lead Operator/Operations Supervisor.  The Director Water, Wastewater, Gas & Engineering also uses outside contractors/consultants to lead PHAs when appropriate.  The Lead Operator/Operations Supervisor is responsible for (1) ensuring that the information and personnel necessary to conduct PHAs are available according to the PHA implementation schedule and (2) resolving recommendations that are assigned to their respective areas. 
 
OPERATING PROCEDURES 
 
In accordance with Section 68.69 of the RMP rule, the Lead Operator/Operations Supervisor ha 
s the responsibility for ensuring that complete and accurate operating procedures are in place for all regulated processes.  The Lead Operator/Operations Supervisor works closely with the Director Water, Wastewater, Gas & Engineering to develop and maintain the facility's safe work practices. 
 
TRAINING 
 
In accordance with Section 68.71 of the RMP rule, the Lead Operator/Operations Supervisor has the responsibility for (1) ensuring that operations employees receive and understand training applicable to their specific jobs and the associated processes and (2) documenting the training.  The Director Water, Wastewater, Gas & Engineering has the responsibility for (1) ensuring that all facility employees receive and understand training in safe work practices applicable to their jobs and (2) documenting the training.   
 
MECHANICAL INTEGRITY 
 
In accordance with Section 68.73 of the RMP rule, the Lead Operator/Operations Supervisor has the responsibility for the overall mechanical integrity pr 
ogram, with specific emphasis on written procedures, maintenance training, the equipment and instrumentation inspection/test program and documentation, and equipment deficiency resolution.  The Wastewater Reclamation Facility also employs outside contractors and/or consultants to assist in the implementation and maintenance of the mechanical integrity program.  The Director Water, Wastewater, Gas & Engineering and the Purchasing Agent work with the Lead Operator/Operations Supervisor to define and maintain appropriate quality assurance procedures for all types of equipment acquisitions/installations/repairs. 
 
MANAGEMENT OF CHANGE 
 
In accordance with Section 68.75 of the RMP rule, the Director Water, Wastewater, Gas & Engineering has the responsibility for the overall management of change (MOC) program; however, the Lead Operator/Operations Supervisor has responsibility for ensuring that the overall MOC program is effectively implemented. 
 
PRE-STARTUP REVIEW 
 
In accordance with Section  
68.77 of the RMP rule, the Director Water, Wastewater, Gas & Engineering has the responsibility for the overall pre-startup review program, which is closely related to the MOC program. However, the Lead Operator/Operations Supervisor has the primary responsibility for ensuring that this program is effectively implemented before affected operations begin. 
 
COMPLIANCE AUDITS 
 
In accordance with Section 68.79 of the RMP rule, the Director Water, Wastewater, Gas & Engineering has the responsibility for ensuring that compliance audits regularly occur (and are documented) to verify that the prevention program is working and meets EPA/OSHA requirements.  The Lead Operator/Operations Supervisor has responsibility for resolving any identified deficiency at the Wastewater Reclamation Facility. 
 
INCIDENT INVESTIGATION 
 
In accordance with Section 68.81 of the RMP rule, the Director Water, Wastewater, Gas & Engineering has the responsibility for designing and managing the incident investigation pro 
gram, including tracking resolution of investigation findings and recommendations.  The Director Water, Wastewater, Gas & Engineering also has the responsibility of ensuring that only trained personnel lead our investigations.  The Lead Operator/Operations Supervisor each have responsibility for ensuring that all incidents in their areas are reported and investigated, and the investigations findings are resolved, documented, and communicated to affected personnel. 
 
EMPLOYEE PARTICIPATION 
 
In accordance with Section 68.83 of the RMP rule, the Director Water, Wastewater, Gas & Engineering working with Lead Operator/Operations Supervisor has the responsibility of involving employees in the planning and implementation of the facility's prevention program elements. 
 
HOT WORK PERMITS 
 
In accordance with Section 68.85 of the RMP rule, the Director Water, Wastewater, Gas & Engineering, working closely with the Lead Operator/Operations Supervisor, has the responsibility of developing and mainta 
ining the facility's hot work permit program. 
 
CONTRACTORS 
 
In accordance with Section 68.87 of the RMP rule, the Lead Operator/Operations Supervisor has the overall responsibility for the contractor program. 
 
EMERGENCY RESPONSE PROGRAM 
 
In accordance with Sections 68.90 and 68.95 of the RMP rule, the Director Water, Wastewater, Gas & Engineering is responsible for (1) designing, implementing, and maintaining the facility's emergency response plan, (2) ensuring that all associated training is conducted and documented as necessary, (3) coordinating the site emergency response plan with the community emergency response plan, and (4) responding to local emergency planners/responders when questions arise. 
 
RMPLAN PREPARATION AND SUBMISSION 
 
The Director Water, Wastewater, Gas & Engineering is responsible for preparing and submitting the Risk Management Program Plan for the facility as required under Sections 68.150 through 68.185 of the RMP rule. 
 
 
RMPLAN COMMUNICATION 
 
The Director Water 
, Wastewater, Gas & Engineering and Lead Operator/Operations Supervisor have the responsibility of providing Risk Management Program Plan information (other than the required EPA submission) to employees and the public as required under Section 68.210 of the RMP rule.
Click to return to beginning