Main Street Water Treatment Plant - Executive Summary |
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The Risk Management Program and Plan are developed by the City of Yuma, Office of Risk Management, and the City of Yuma Public Works Department, Water Treatment Plant in accordance with the U.S. E.P.A. Risk Management Program Rule (40 CFR 68) for stationary sources with over 2500 pounds of chlorine gas in the process (level 3). This program addresses storage, handling and transfer of chlorine gas to minimize the potential for a chlorine release in a municipal water treament facility located at 175 North Main Street, Yuma, Arizona 85364. The Plan was developed by employee participation and builds on the OSHA required Process Safety Management Plan, Emergency Response Plan, and Standard Operating Procedures; and includes the five year history and worst case and alternative case scenarios. Other participants in the RMP process include employees of the Yuma Fire Department, and members of the City of Yuma's Environmental Advisory Alliance . The City of Yuma is committed to the safety an d protection of human health and the environment while serving our community. In the history of the Yuma Main Street Water Treatment Plant, there has been no record of a chlorine emergency. To maintain the safety at our facilities and for our community, the Public Works Department has developed procedures, documentation, design and engineering controls, on-going training and program monitoring and evaluation. This Risk Management Plan contains information on the level 3 program, as described in EPA standard 40 CFR 68. The documentation consists of the required components for reporting. The steps taken to obtain the information include: performing a hazard assessment, developing or documenting existing programs for management of systems and change, prevention, emergency response, and worst and alternative case scensarios. Along with this executive summary, are a five year history of accidents, an off-site consequences analysis including worst case and alternative case scenarios, a checklist of dates for reviewing process safety information, process hazard anlyses, standard operating procedures, emergency action control plan, hot work, incident investigation, compliance audits, pre-startup reviews, and contractor information. The information obtained for developing this plan was used to develop a written Risk Management Program, and will be further used to implement procedures in the chlorination process to ensure the safety of human health and the environment. Dialogue with local public safety agencies will incorporate the findings of the Risk Management Plan. Plant modifications will be based on their impact on the safety of the chlorine process, system, subsystems, and equipment. The written program will be implemented through teaining and on-going employee participation in evaluation and implementation of the Risk Management Plan. The information will be readily available to employees and local emergency agencies in notebook form containing the elements of the OSHA Process Safety Management Plan, and the EPA Risk Management Plan. Some of the problem areas identified while developing our Process Safety Management Plan have been set on a time line for correction. A listing of these items includes the following. 150 pound chlorine cylinders stored on the loading dock, open to vandalism and weather mishaps. A Lack of maintenance procedures to preserve the upkeep of the chlroine process regularly. A lack of a fire alarm system in the control building. PVC piping exposed to sunlight. An unfavorable intake system. Lack of monitoring loading and unloading techniques. An MSDS file which was not regularly maintained. Lack of emergency situation drills with the loacl emergency response agencies. A lack of training for all contractors working on or near the chlorine process. Many of the items noted above have already been addressed and corrected, and there is a time line for addressing the rest. The written Risk Management Plan will be updated and revised as needed, and minimally - annually - to ensure that changes are managed, modifications and repairs are effective and efficient, and that employees are familiar with the procedures and safe operations of the facility. Records that support our Risk Management Plan will be kept for no less than five years, and will be available through the Office of Risk Management and the Public Works Department. The City of Yuma has chosen to establish an Emergency Action and Control Plan which involves the use of Hazmat trained fire fighters from the local fire department. Water treatment plant employees should know what type of evacuation is necessary and what their role is in carrying out the plan. In some cases, where the emergency is grave, total immediate evacuation of nonessential employees is necessary. In other emergencies, a partial evacuation of others may be necessary for continued plant operation. In some cases, only those employees in the immediate area of a fir e may be expected to evacuate or move to a safe area such as when a local application fire suppression system discharge employee alarm is sounded. Employees must be sure that they know what is expected of them in all such emergency situations which have been planned in order to provide assurance for their safety from fire or other emergency. The Emergency Action and Control Plan contains the information needed to implement this program. In most emergency cases at the plant (and involving the chlroine process) the Yuma Fire Department will be responsible for performing rescue and medical duties. The Fire Department and Hazmat Team are also capable of handling all major situations which may include fire, first aid, chemical spill or release. In April 1999, a chlorine safety drill was conducted utilizing employees and resources of the plant and Public Works Department, along with the Yuma Fire Department and Hazmat Teams. The results and findings of this exercise have led to changes in process and safety procedures for the plant and the fire department. Further annual drills are planned for the benefit of the plant, the fire department and community preparedness. Standard Operating Procedures for the chlorine process are outlined in the Process Safety Management notebook and are documented to provide a basic understanding and working knowledge of the chlorine system and the interdependence of the subsystems and equipment components essential to the system. SOPs are presented as a function of controls over the hazards associated with the chlorine process, engineering designs and the operation and maintenance of the systems and subsystems of the chlorination process. |