Fountain Hills Wastewater Treatment Plant - Executive Summary |
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Executive Summary The Fountain Hills Wastewater Treatment Plant (FHWWTP) is owned and operated by the Fountain Hills Sanitary District (FHSD). The FHWWTP has prepared a Risk Management Plan (RMP) in accordance with the EPA and OSHA regulatory requirements. A brief overview of the RMP and the associated policies at the FHWWTP is described below. Prevention and Response Policies The FHSD takes an active role in preventing accidental releases by ensuring that its employees are properly trained in the safe operation of covered processes and the safe handling of treatment chemicals. The FHSD has also 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. To increase employee safety and awareness, the FHSD: * maintains up-to-date safety information and operating procedures, * performs regular preventative maintenance, * provides periodic refresher training on safe handling of chemicals, and * conducts monthly safety drills. Facility Description and Regulated Substances The FHWWTP disinfects wastewater from residential and business sources through a series of physical and chemical treatment operations that include grit removal, sedimentation, aeration, clarification, and disinfection. The regulated substance handled at the FHWWTP is chlorine. Release Scenarios Worst-case and alternative release scenarios have been determined after careful review of the regulation and consideration of the storage vessel configuration at the facility. The EPA's software program RMP*Comp was used to model both release scenarios and determine the radius of impact. In the worst-case release scenario, the regulation clearly states the release quantity shall be the contents of the single largest vessel of the covered process chemical. Therefore, the scenario assumed a complete release of chlo rine from one 150-lb cylinder outside the chlorine storage building. Per the regulation, no active mitigation measures could be considered. In addition, no passive mitigation measures were considered. For the alternative release scenario, the assumptions were that (a) a failure occurred in the manifold feed line, (b) 750 lbs of chlorine were released over a 30 minute period, and (c) the release occurred in the chlorine storage building. The passive mitigation effect of the chlorine storage building reduces the amount of chlorine released to the atmosphere by 55% (from 750 to 410 lbs). Prevention Steps for Chlorine The prevention program fulfills the requirements of the OSHA Process Safety Management (PSM) rule and the EPA RMP rule, and includes: * formal and on-the-job training, * written operating procedures, and * a process equipment preventive maintenance program. Accident History There has been no release of the covered chemical in the past five years. Emergency Response Program This facility has established and maintains an emergency action plan (EAP) that is coordinated with local response agencies. The goals of the EAP are to protect on-site employees from the hazardous effects of a release and to minimize the effects of releases on the general public. The program is routinely reviewed and updated to reflect personnel and regulatory changes. Planned Changes for Improve Safety Ideas for changes to improve safety are actively sought from employees. Employee meetings that focus on safety issues are held regularly at the 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 this RMP document, a process hazard analysis of the chlorine system was conducted with key employees to fulfill the prevention program requirements. During these sessions, recommendations were mad e for the purpose of improving safety and preventing accidental chemical releases. Each recommendation will be or has been considered for implementation. Though not all recommendations may be implemented, the exercise provided all affected employees with a heightened awareness of safety issues related to the covered process. |