Lowell Regional Water Utility Treatment Plant - Executive Summary |
|
Risk Management Plan Executive Summary Lowell Regional Water Utility Water Treatment Plant Lowell, MA I. Executive Summary A. Accidental Release Prevention and Emergency Response Policies Lowell Regional Water Utility (LRWU) is committed to operating its water treatment plant in Lowell, Massachusetts in an environmentally responsible manner and to providing a safe workplace for its employees and the surrounding community. As part of this commitment to environmental stewardship and worker safety, LRWU has developed and implemented environmental and safety programs designed to reduce or eliminate the potential for accidental releases. LRWU has also developed and implemented a number of programs designed to ensure that if an accidental release occurs it will be handled in a manner that minimizes adverse impact to personnel, the surrounding community, the environment and the plant. LRWU views accident prevention, personnel protection, and environmental protection as continuous pr ocesses. Consequently, LRWU continuously strives to improve its accident prevention, environmental protection and emergency response programs. LRWU Risk Management Program complements this overall accident prevention and response program. LRWUs Risk Management Program (RMP) complies with the U.S. Environmental Protection Agencys ("EPAs") Chemical Accident Prevention rule found at 40 C.F.R. Part 68. This document is the RMP plan for the water treatment plant. LRWU has prepared a separate RMP Plan for the treatment plants intake station, which is located approximately = mile west of the plant. This RMP Plan provides the public with information about the treatment plants processes, accident prevention programs, and emergency response planning efforts. LRWUs compliance with EPAs RMP rule includes: 1. Completion of a hazard assessment in compliance with 40 C.F.R. Part 68, Subpart B, including the five-year accidental release history. LRWU has never experienced an RMP reporta ble release or accident at its water treatment plant. 2. Implementation of an accident prevention program. The plants RMP accident prevention program is coordinated with the plants Process Safety Management (PSM) program. Under the RMP rules, LRWUs water treatment plant is classified as a Level 2 facility, and must prepare an accident prevention program in compliance with RMPs Level 2 accident prevention program requirements. LRWU has elected to prepare a plan compliant with RMP requirements and also with more stringent and extensive Process Safety Management rules administered by the Occupational Safety and Health Administration "OSHA"; 3. Implementation of an emergency response program. As recommended in the RMP rule and by numerous federal response entities, the plant has developed an Integrated Contingency Plan designed to meet applicable state and federal accident prevention and emergency response planning requirements. Additional information regarding how LRWU addresse s each of these requirements is provided below and in the attached RMP plan. While the RMP program at LRWU helps ensure that the facility is maintained and operated in a safe and environmentally responsible manner, it is just one component of LRWUs comprehensive safety and environmental programs. Additional components that are beyond the scope of the RMP include, but are not limited to: regular employee/contractor safety training, periodic table-top safety and emergency response drills, acquisition and maintenance of emergency response and personnel protective equipment, development of safe work practices (confined space, lockout/tagout, hot work), implementation of safe work procedures, new project safety review procedures, preventive maintenance and regular inspections of all tanks and equipment that contain hazardous chemicals, chemical control and purchasing procedures, medical emergency response training, contractor certification, etc. The plant and all equipment are designed and operated to minimize the possibility of an accidental release. At a minimum, the plant and equipment meet government and industry design and construction standards. B. RMP Covered Stationary Source and Regulated Substance LRWU owns and operates its water treatment plant in Lowell, Massachusetts. The plant treats potable water from the intake station, which pumps the water directly from the Merrimack River, and distributes it to municipalities in the Lowell area. The only chemical present at the plant in sufficient quantities to be regulated by the chemical accident prevention rule is chlorine. Chlorine is used to disinfect water as it is pumped from the intake station. Chlorine is stored in 2,000 lb. tanks within the chlorinator room. The chlorinator room is equipped with chlorine detectors which sound an alarm in the event of an accidental release of chlorine. The total maximum amount of chlorine stored on-site is 16,000 lbs. (8 tanks). The maximum amount of chlorine u sed at any one time in the chlorination process is 8,000 lbs. C. Off-site Consequence Analysis As required by the RMP rule, LRWUs off-site consequence analysis included evaluation of a worst-case accidental release for all toxic chemicals (chlorine) and an alternative release for each covered chemical. A worst-case release is defined by EPA as "a release of the largest quantity of a regulated substance from a vessel or process line failure that results in the greatest distance to an endpoint defined in ' 68.22." 40 C.F.R. ' 68.3. EPA requires the worst-case accidental release to be modeled using highly conservative meteorological data designed to result in the maximum possible adverse impact. For example, EPA requires worst-case models to assume that the entire contents of the largest vessel are released instantaneously on a warm night with slow, steady wind. According to the Chlorine Institute, no 2,000 lb. chlorine tank has ever released its contents in ten minutes. The pro bability of such an event is extremely low. Using the EPA mandated criteria described above, the worst-case release at the plant (for purposes of RMP) would involve a complete failure of a 2,000 lb. chlorine tank, filled to maximum capacity. If such a release occurred, it would result in a vapor cloud that could impact persons outside of the plants property line. LRWU developed an alternative release of chlorine that focuses on more realistic release scenarios occurring during more common meteorological conditions. However, EPA requires modeling of a release which could impact off-site locations. After considering all criteria in the RMP rule, the Process Hazard Analysis performed on the chlorination process and all past releases, LRWU has chosen an alternative release scenario that involves a valve failure in the chlorinator room. This scenario is based on an actual release which occurred in 1996 at the LRWUs water intake station. Approximately 53 pounds of chlorine were relea sed during to the environment during this incident. The incident lasted approximately fifteen minutes. The chlorine leaked as a liquid or gas, and liquid vaporized into gas almost immediately. The chlorine gas was vented from the chlorinator room to the outside by exhaust fans. No such valve failure has ever occurred at the treatment plant, but, because this release had occurred at a similar facility with a similar process, it was selected as the type of release most likely to occur. D. Accident Release Prevention Program LRWU has developed an accidental release prevention program that is designed and implemented to drastically reduce the possibility of an accidental catastrophic release. The program complies with the requirements of OSHAs Process Safety Management rule found. at 29 C.F.R. Part 1910.119 and is analogous to, but more extensive than, RMP requirements found at 40 C.F.R. Part 68, Subpart D. While elements of this plan have been in place for years, the plan as a w hole was recently implemented. Even prior to the implementation of this plan no reportable releases had occurred at the treatment plant. The basic elements of LRWUs prevention program are described below: 1.0 Employee Participation. LRWU has developed and implements a written plan of action regarding employee participation in the safety and accident prevention process. The plan describes how employees are: (A) consulted and what input they will have in the development of process hazard analysis (PHA) and other PSM and RMP safety elements; and (B) given access to PSM and RMP information at the plant. 2.0 Process Safety Information. LRWU has compiled written process safety information which helped identify the hazards posed by chlorine, handling of materials, management, storage activities and the chlorination process in general. The compilation of process safety information provided the foundation for understanding the hazards involved in the chlorination process and was crucial to the development of a complete and thorough process hazard analysis (discussed below). The required process safety information includes information pertaining to the hazardous chemicals (e.g. chlorine), the technology of the process, and the process equipment. 29 C.F.R. ' 1910.119(d). The type of information pertaining to the technology of the process includes: (1) block flow diagrams; (2) process chemistry; (3) maximum intended inventory; (4) safe upper and lower limits for temperature, pressure, flow and composition; and (5) an evaluation of the consequences of deviations, including those affecting the safety and health of employees and the nearby public. The equipment information includes: (1) materials of construction; (2) piping and instrument diagrams (P&IDs); (3) electrical classification; (4) relief system design and design basis; (5) ventilation system design; (6) design codes and standards employed; and (7) material and energy balances for processes built a fter May 26, 1992. 3.0 Process Hazard Analyses. LRWU performed its most recent process hazard analysis (PHA) on the chlorination system in March 1999. The PHA is a key component of the process safety management system and LRWUs RMP accident prevention program. It provided a thorough, orderly, systematic approach for identifying, evaluating, and controlling hazards posed by the chlorination process. The PHA utilized the what-if/PHA methodology in accordance with 29 C.F.R. ' 1910.119(e) and 40 C.F.R. ' 68.67. The PHA addressed: (1) hazards of the process; (2) engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases (e.g., process monitoring and control instrumentation with alarms); (3) consequences of failure of engineering and administrative controls; (4) facility siting; (5) human factors (human error); and (6) a qualitative evaluation of a ran ge of the possible safety and health effects of failure of controls on the employees in the work place. 4.0 Operating Procedures. LRWU has developed and implements written operating procedures that provide clear instructions for safely conducting activities involved in the chlorination process. These procedures are consistent with the process safety information described in subtask 2, above, and cover: A. Initial startup; B. Normal operations; C. Temporary operations; D. Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner; E. Emergency Operations; F. Normal shutdown; G. Startup following a turnaround, or after an emergency shutdown; H. Consequences of deviation from operating limits; I. Steps required to correct or avoid deviation; J. Precautions necessary to prevent exposure, including engineering con trols, administrative controls, and personal protective equipment; K. Control measures to be taken if physical contact or airborne exposure occurs; L. Quality control for raw materials and control of hazardous chemical inventory levels; and M. Safety systems and their functions. LRWU has also developed and implements safe work practices that provide for the control of hazards during operations. For example, LRWU has programs that govern the following activities: lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into PSM and RMP covered portions of the plant by maintenance, contractor or other support personnel. 5. Training. LRWU provides employees, contractors and visitors with training that focuses on the special safety and health hazards posed by the plant operations, RMP and PSM covered processes, emergency operations, and safe work practices applicable to the employees job tasks. LRWU confirms that employees and contractors involved in operating a covered process have successfully completed the required training. LRWU documents that covered employees and contractors have received and understood the required training. Documentation, at a minimum, includes the identity of the employee or contract employee, the date of training, and the means used to verify that the employee understood the training. 6. Contractors. As part of LRWUs contractor selection process it obtains and evaluates information regarding contract employers safety performance and programs: (29 C.F.R. ' 1910.119(h). LRWU also: A. Informs contract employers of the known potential fire, explosion, or toxic release hazards related to the contractors work and the process; B. Explains to contract employers the applicable provisions of the facilitys integrated contingency plan (discussed below); and C. Develops and implements safe work practices to control the entrance, presence and exit of contract employers and contract employees i n covered process areas. 7.0 Pre-startup Safety Review. Prior to the introduction of highly hazardous chemicals to a new or existing RMP/PSM covered process, LRWU always confirms that the process is constructed and the equipment is designed in accordance with specifications, and that appropriate safety, operating, maintenance, and emergency procedures are in place to adequately protect the health and safety of employees and the nearby public. 8.0 Mechanical Integrity. LRWU has developed and implements written procedures to maintain the ongoing integrity of the process equipment listed below. LRWU also trains employees to maintain the following process equipment: A. Pressure vessels and storage tanks; B. Piping systems (including piping components such as valves); C. Relief and vent systems and devices; D. Emergency shutdown systems; E. Controls (including monitoring devices and sensors, alarms, and interlocks); and F. Pumps. 9.0 Hot Work Permit. LRWU implements a stringent ho t work permit program for all hot work operations (e.g., welding, soldering) conducted on or near any of the components involved in the chlorination process. 10.0 Management of Change. LRWU has established and implements written procedures to manage changes to process chemicals, technology, equipment, and procedures associated with the chlorination process; and, changes to facilities that affect the chlorination process. These procedures ensure that the following considerations are addressed prior to any change: A.0 The technical basis for the proposed change; B. Impact of change on safety and health; C. Modifications to operating procedures; D. Necessary time period for the change; and E. Authorization requirements for the proposed change. 11.0 Incident Investigation. LRWU investigates each incident which resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical in the workplace. An incident investigation team is established and co nsists of at least one person knowledgeable in the process involved, including a contract employee if the incident involved work of the contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident. 12.0 Emergency Planning and Response. LRWU has developed an integrated contingency plan that satisfies all applicable state and federal emergency response and prevention planning requirements (described under emergency response policies below). 13.0 Compliance Audits. LRWU will perform a compliance audit to evaluate the water treatment plants compliance with the PSM Standard and the RMP rule at least every three years to verify that the procedures and practices it has developed are adequate and being followed. A report of the RMP and PSM audit findings will be developed. 14.0 Trade Secrets. LRWU makes all necessary information available to those persons responsible for compiling process safety information and those assi sting in the development of the process hazard analysis. E. Five Year Accident History The water treatment plant has never experienced a release that requires reporting under the chemical accident prevention rule. F. Emergency Response Procedures and Policies LRWUs trained emergency response team provides initial response to all leaks and spills, with assistance provided on an as-needed basis by the Lowell Fire Department and other emergency responders. LRWUs emergency response team members have all been trained to OSHAs Incident Commander level. Emergency response procedures are described in detail in LWRUs integrated contingency plan. Employees have been trained on confined space entry procedures and the proper use of personal protection equipment (PPE). In the event of small fires, all plant employees are trained in the use of fire extinguishers. Personnel have also been trained to notify the plant manager in the event of more extensive accidental releases. The Operat ions Superintendent is responsible for assessment of releases, internal notification of releases, and determination of whether outside responders are needed. During an emergency, all non-emergency response team LRWU employees have been trained to evacuate to a predesignated muster point to assist outside response teams. In the event that an accidental release occurs that is beyond the capabilities of LRWUs emergency response team to control, the plant depends on the the Lowell Fire and Police Departments for outside support. The Lowell Fire Department operates under mutual aid agreements with surrounding and nearby towns to ensure that additional emergency response personnel and equipment are available to respond to an emergency release at the plant. In addition, LRWU has an agreement with an outside contractor, Jones Chemical, to provide emergency response services, if needed. LRWU has also adopted and implements an Integrated Contingency Plan that meets the regulatory requirem ents of the following federal and state response planning and prevention laws: 7 OSHA Emergency Response Plan (29 C.F.R. 1910.120(q)) 7 OSHA Process Safety Management emergency response requirements (29 C.F.R. ' 1910.119(n)) 7 Massachusetts Employee Right-to-Know Law (M.G.L. Ch. 111(f)) 7 EPA Risk Management Plan Emergency Response Program (40 C.F.R. ' 68.95) 7 EPA Oil Spill Prevention Control and Countermeasure Plan (40 C.F.R. ' 112.7) The ICP includes, among other things: 7 Procedures for notifying the public and the local emergency planning committee 7 Arrangements for first-aid procedures and emergency medical treatment procedures for exposure to chlorine 7 Emergency response and incident termination procedures 7 Procedures for using, inspecting and testing emergency response equipment 7 Employee training procedures 7 Procedures to amend the ICP plan G. Planned Changes LRWU intends to replace the gaseous chlorine system with a sodium hypochlorite system during the year 200 0. Once this replacement is completed chlorine gas will no longer be stored on site. |