East Tennessee Mechanical Contractors (ETMC) WTP - Executive Summary |
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EXECUTIVE SUMMARY (640 CFR 68.155) Prevention and Response Policies Excerpts from ETMC Company Policy It is the policy of East Tennessee Mechanical Contractors (ETMC) to provide a safe and healthful work environment for all employees and strive to minimize the risk of work-related injuries and illnesses and the resulting human and economic loss. This can only be done by the establishment of sound loss control procedures and by management and employees working together toward the prevention of accidents. The philosophy that prevention of accidents and efficiency in operations are inseparable, will guide plans and actions. It is our intention that this statement of policy be our basis for assuring an efficient, safe and healthful workplace for our employees. Our primary objective is to systematically integrate safety considerations into management and work practices at all levels within the company, so that our mission is accomplished while protecting the public, worker, and the envi ronment. Advise employees of and protect employees from generally recognized workplace hazards. Promote the health and well being of employees and help them develop an awareness of sound health and safety practices. Assure to the greatest extent possible that each employee is physically and mentally fit and properly trained to perform each assigned task safely. Integrate health, safety and human factors information into design, construction, installation, modification, use, maintenance and service procedure, condition or practice. Comply with all applicable Federal, State, and local laws, regulations, contractual standards/requirements and company practices related to employee health and safety in the work environment. Evaluate on continuing basis compliance set forth in applicable Federal, State and local laws and regulations, including appropriate Department of Energy (DOE) Orders and consensus standards. Conduct a thorough hazard analysis of facilities under our control on a continuous basis to assure that safety vulnerabilities are identified. Develop and maintain a safety and health plan commensurate with identified hazards. Support and contribute to the development of reasonable, cost-effective occupational safety and health policies. Source and Process Description Water System Description The water system is comprised of three subsystems that include the raw water supply system, the water treatment system, and the treated water distribution system. The system provides water for potability, cooling, process, and fire protection needs and is vital to the continuous on-line reliability of the Y-12 and X-10 facilities. Any interruption in continuous water service will have an immediate harmful impact on plant operations. The water system is also important to public health and the economic stability of the City of Oak Ridge (OR). The city receives potable water from the DOE/OR water plant for use by domestic, commercial, and industrial consumers. Raw Water System The raw water supply system starts with raw water from Melton Hill Lake (Clinch River). The River Intake/Pump Station on Pump House Road is located on the southern edge of the City of Oak Ridge, Anderson County, Tennessee. An emergency pump station consisting of two 7,000-gpm pumps is available for pumping water from an inlet cove near the original intake structure. Alternate power source (diesel/generator set) is installed to provide a backup power source. The raw water storage tank and booster pump station along Scarboro Road has a capacity of 1.5 MG. Raw water is pumped from the River Intake/Pump Station to the raw water booster storage tank and then to the booster pump station through two parallel mains. Water Treatment System The Water Treatment Plant is located on Pine Ridge, north of the Y-12 complex, approximately 1/2 of a mile northwest from the intersection of Scarboro and Bear Creek roads. The water plant's current maximum daily production capacity is 28 mill ion gallons daily (MGD). Average pumping of treated water is approximately 13 MGD. Water treatment includes chemical mixing using potassium permanganate and polymers, coagulation, flocculation, sedimentation, filtration, and disinfection with chlorine. Zinc phosphate is fed as a corrosion inhibitor and fluoride is fed for dental hygiene into the clearwell. Treated water is stored on the plant site in reservoirs with 3 MG and 4 MG capacities . Chlorine, a regulated substance, is used for disinfection purposes in the production of potable water. The approximate daily usage of chlorine is 170 to 350 pounds. Approximately four (4), one-ton containers are stored at the Water Treatment Plant, and two (2), one-ton containers are stored at the River Intake/Pump Station. Two containers are on line at all times. The Water Treatment Plant uses an average of one container per week, and the River Intake/Pump Station uses approximately one container every 12 days; annual chlorine usage is approxima tely 85,000 pounds. Major Hazards Chlorine is highly toxic, and gas leaks can pose a health hazard to employees and the public and may possibly interrupt water treatment. Chlorine is an irritant to the eyes, mucous membranes, and skin. Overexposure can cause an irritation in the throat and lungs. Chlorine is about 2.5 times heavier than air. Gaseous chlorine will channel, pool, and pancake in low leveled areas, and it has a high affinity for water. Chlorine is a yellow-greenish gas with a characteristic penetrating and irritating odor. The range of reported odor thresholds for chlorine is 0.03 to 3.5 ppm; however, because of the fatigue of the olfactory glands, the odor does not always serve as an adequate warning of exposure. Chlorine is a nonflammable gas, but it does support combustion due to its oxidational properties. Chlorine gas will react with moisture in the atmosphere to form an acidic and irritating cloud or plume. Chlorine emits toxic fumes as hydrogen chloride gas und er fire conditions. Hazard Control Failure The worst case chlorine release scenario for two, interconnected, one-ton containers involves catastrophic failure due to corrosion, impact, or construction defects. This scenario was modeled on two, one-ton containers as a direct release over a 10-minute period. The result assumes Stability Class F, a wind speed of 1 meter per second, a temperature of 780 F, and 80% relative humidity. The topography is urban. The distance to the toxic endpoint is 6.91 miles. Within this radius, schools, residences, hospitals, public recreational areas, and commercial, office, and industrial areas exist. This area includes DOE National Environmental Research Park (NERP) reference and natural areas. Reference areas have representative or unique plant communities. Natural areas have rare plant habitats or unique plant communities. The population within the 6.91-mile radius is 40,000. Passive mitigation is that each one-ton container is approximately an inch t hick in diameter and is locked inside a concrete building. The alternate chlorine release scenario for a one-ton container involves tubing failure, a bad connection, or valve failure resulting in the release of gas through the 5/16-inch-diameter valve body opening. This scenario was modeled as a release from a horizontal, cylindrical tank with the release occurring through a short pipe or valve in the top of the tank. The chlorine escapes only as a gas. The total release is 317 pounds over a 60-minute duration period. The result assumes Stability Class D, a wind speed of 3.0 meters per second, a temperature of 900 F, and 80% relative humidity. The topography is urban. The distance to the toxic endpoint is .45 miles. Within this radius, residences, public recreational areas, and commercial, office, and industrial areas exist. This area includes DOE National Environmental Research Park (NERP) reference and natural areas. The population within the radius is 6,500. Passive mitigation is that each one-ton container is approximately an inch thick in diameter and is locked inside a concrete building. Active mitigation includes scrubbers (neutralization), alarms, and emergency shutdown systems, as well as chlorine spill kits. The scrubbing system uses a 25% solution of sodium hydroxide to remove and absorb chlorine fumes from the atmosphere. Accidental Chemical Release Prevention ETMC's operation is critical to DOE's Y-12 Plant, Oak Ridge National Laboratories (ORNL), and the City of Oak Ridge. Therefore, we must ensure that we are well-equipped and prepared to handle any potentially hazardous situation. We engineer safety into our facilities. All of ETMC's hazardous materials accumulation areas are designed with safeguards to prevent a release of hazardous materials in case of an equipment or mechanical failure. ETMC complies with 29 CFR 1910.119, Process Safety Management, which is a systematic approach to evaluating the entire process from design to use. Using this approach, the process design, process technology, operational and maintenance activities and procedures, non-routine activities and procedures, emergency preparedness plans and procedures, training programs, and any other elements which impact the process are all considered in the evaluation. Relevant Environmental Safety and Health (ES&H) Manual chapters define the operating procedures for safe chemical usage at ETMC. Policies and procedures are written and implemented in accordance with local, State, and Federal rules and regulations. ETMC has a special work permit checklist/request form which is used for each task performed. If chemicals are used in performance of the task, the ES&H Department performs a hazard analysis to ensure positive control measures are implemented. Purchasing of chemicals is limited to the minimum quantity required to accomplish the required task, i.e., chlorine is limited to six, one-ton containers on site at any time. Buying chemicals in bulk quantities is prohibited. ETMC Department Supervisors are charged with the responsibility of maintaining the Material Safety Data Sheet (MSDS), chemical inventories, and hazard communication written program (HAZCOM) located at the department's Right-to-Know station. ETMC ensures workers are informed of chemical hazards in the workplace by complying with OSHA Standard 29 CFR 1910.1200. The HAZCOM program makes use of MSDSs labels and training. Employees receive orientation, and formal and specific training for the job they are to perform. HAZCOM refresher training is conducted annually. Chemical handlers receive OSHA-required training such as HAZCOM, HAZWOPER, and fire safety, as well as chemical-specific hazards involved in the work task. Chlorine handling presents the highest risk associated with chemicals at ETMC. The chlorine feed room and storage area is locked, and only authorized personnel are allowed into this area. The area is checked a minimum of three times, once per shift, in a 24 -hour period during routine inspections. Chlorine is fed into the water through a "closed" system to prevent personnel contact. Operators are required to use a self-contained breathing apparatus (SCBA) while changing containers. Training is consistent with the requirements in 29 CFR 1910.120(f), Hazardous Waste Operations and Emergency Response. Public access is blocked when changing containers to minimize risk. The Emergency Response Support Organization is notified before container change or container delivery. Each activity is appropriately monitored until concluded. When a container is empty, the valve is closed for a few minutes before the feed line is disconnected in order to evacuate the feed line before switching to the second container. A chlorine detector (Chloralert) monitors the atmosphere in the chlorine feed room where the chlorine containers are in use. After any activation of the scrubbing system, and not later than 30 days, the operator checks the sodium hydroxide co ncentration. If the concentration falls below 10%, the solution is replaced. Emergency Response ETMC has a trained Emergency Response Team to provide support at each facility. The team is trained in accordance with OSHA Standard 29 CFR 1910.120(q), HAZMAT Technician. Should a mishap occur involving chlorine, a Memorandum of Understanding (MOU) is in effect with Lockheed-Martin Energy Systems (LMES) to provide ambulance and Hazardous Material Response for the Water Treatment Plant. The City of Oak Ridge Fire Department is provided a detailed hazards inventory and a mutual aid agreement is in effect. Joint drills with the Oak Ridge Fire Department, LMES, and ETMC Personnel are scheduled to ensure effective response coordination. ETMC's Water System Emergency Response Plan complies with the rule of the Tennessee Department of Environment and Conservation (TDEC), Chapter 1200-5-17(7), that states, "All community water systems shall prepare an emergency operations plan in order to safe guard the water supply and alert the public of unsafe drinking water in the event of natural or man-made disasters." Emergency Response Organization (ERO) ETMC supports the Y- 12 Emergency Response Organization (ERO) as defined in the LMES Y40- 139 procedure, "Y- 12 Emergency Response Organization," and the ETMC Building/Facility Emergency Plan. Emergency Categorization Facility-specific event classification criteria (i.e., emergency action levels-EALs) are developed for the spectrum of potential operational emergencies identified by the facility's Hazards Assessment process. EALs are the link between the severity of an emergency situation, as reflected in the event classification system, and the facility-specific indicators of the event. Complete and accurate Hazards Assessments and EALs are essential for effective decision-making during an emergency. Communications Reliable communication systems provide the Y-12 Plant with the means to notify Federal, State, and local response ag encies, warn the public, and provide direction and control of the ERO. The Oak Ridge Emergency Operations Center (OREOC) and the Y- 12 Technical Support Center (TSC) have both secure and nonsecure capabilities for connectivity with the DOE-Headquarters Emergency Operations Center and the State Emergency Operations Center. Public Information ETMC is a participant in the Y-12 Public Information Program that provides the framework to ensure timely and accurate information to the media and general public in the event of an emergency. At the report of an emergency, LMES and DOE make the decision about activation level of the emergency public information system. ETMC personnel are NOT authorized to provide information of any type directly to the public or media without approval of the DOE. Emergency Facilities and Equipment Emergency facilities and equipment are maintained adequately to support the ERO. Equipment includes information management and communication systems that are capable of ensuring that all required notifications of emergency events and all necessary exchanges of information are made. Emergency alarm systems are installed to provide for effective emergency response and emergency protective actions that may be required. Public address systems are located throughout the Oak Ridge reservation and are tested several times daily. The public at large is notified of an emergency by numerous sirens placed throughout Oak Ridge and by television and radio announcements. Plans and procedures are available to request personnel from federal and state agencies and from local governments. Training The Emergency Management Training and Drill Programs will ensure that personnel are prepared to respond, manage, mitigate, and recover from emergencies associated with ETMC operations. The training program, includes both classroom instruction and hands-on experience. Both initial and refresher training is required for qualification of all personnel (primary and alternate) c omprising the ERO. Training for general employee response is included in both the General Employee Training and the Building/Facility Emergency Plan Program. Emergency-related training includes emergency awareness, warning and alarms, evacuation, and accountability. Annual drills are conducted to familiarize employees with protective action implementation. Addressing Hazards Integrated Safety Management Plan Over the past several years, the DOE has directed contractors and subcontractors to develop and implement a number of systems designed to achieve an acceptable level of safety throughout DOE operations. In compliance with the Secretary of Energy's goal of Integrated Safety Management System (ISMS) and DOE Implementation Plan 95-2, ETMC has developed an Integrated Safety Management Plan (ISMP), which describes the methodology for implementing the ISMS. Simply stated, this plan provides the format for integrating Environmental, Safety and Health requirements into all ETMC activit ies at the DOE Oak Ridge facilities. Our objective is to systematically integrate safety considerations into management and work practices at all levels within our company, so that our company's mission and safety objectives outlined in our company policy, are accomplished while protecting the public, the worker, and the environment. Simply stated, we will do work safely. We use the five core safety management functions established in DOE Policy (DOE P) 450.4 Safety Management System Policy to provide the necessary structure for any hazardous work activity. We apply these functions as a continuous cycle. The five core safety management functions are: 1. define the scope of work 2. identify and analyze hazards associated with the work 3. develop and implement hazard controls 4. perform work within controls 5. provide feedback on adequacy of controls and continuous improvement in defining and planning work ETMC provides input through a variety of self-assessment, continuous improvemen t, and review activities based on our contract. The second source of input is from inspection, assessment, and surveillance activities from line and independent oversight programs. Five-Year Accident History No accidental releases of chlorine have occurred in the last five years at either the River Intake/Pump Station or the Water Treatment Plant. ETMC, in cooperation with LMES, has completed a project-wide Hazards Assessment and determined that existing safety programs provide adequate safeguards for personnel, the environment, and property in chemical usage. Also, an assessment was made of ETMC based on DOE Order 5480.19, Conduct of Operations. This assessment revealed no areas of chemical vulnerability requiring other actions beyond current practices. Based strictly on requirements of regulations, orders, and standards, ETMC has programs, which are "beyond compliance." |