Ormond Beach Wastewater Treatment Plant - Executive Summary

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The City of Ormond Beach Public Works Department - Utilities Division has developed the Risk Management Program for control of catastrophic chlorine and/or sulfur dioxide releases at its Wastewater Treatment Plant (WWTP) in Ormond Beach, Florida. This program continues Ormond Beach's commitment to the protection of its neighbors and its employees and the control of the potential for hazardous releases.  To date, no such release has occurred at the plant. 
 
Regulatory Applicability 
OSHA's Process Safety Management standard (29 CFR 1910.119, as cited by the Florida Department of Community Affairs), and USEPA's Chemical Accident Prevention rule (40 CFR 68) require a risk management program.  The OSHA standard applies to any process that involves more than 1,500 pounds of chlorine or more than 1,000 pounds of sulfur dioxide.  USEPA's rule applies to any process that involves more than 2,500 pounds of chlorine, or more than 5,000 pounds of sulfur dioxide. These programs apply to the use of c 
hlorine for disinfection of water at the WWTP, because the plant intends to store up to 8 tons of chlorine onsite, and for the use of sulfur dioxide for de-chlorination because the plant intends to store up to 2 tons onsite..  
 
Program Summary 
The program supplements the procedures described in other City documents such as general administrative guidelines and safety and health manuals.  The program addresses Ormond Beach's program management procedures, process safety information, hazard review, operating procedures, employee training, safe work practices, contractor safety, and emergency response.  Each topic has its own section in the program document, with management elements of the program contained in Section 2 of the program document.  Process safety information describing the hazards and physical properties of chlorine and sulfur dioxide, safe operating limits, and descriptions of the major process equipment are included in Section 3 of the program document. 
 
Process Hazard Rev 
iew 
The Division conducted a hazard review for each regulated process.  The hazard review team consisted of plant management, process operation and maintenance personnel, an outside process design engineer, and a consultant knowledgeable in the hazard review process itself.  The hazard review team used a "what-if checklist" technique, which is shown in Section 4 of the program document with its results included.  The Division's analysis of chlorine and sulfur dioxide release potential (for the worst case and alternate case scenarios) appears in Section 4 of the program document. 
 
The City analyzed the potential impacts of possible future chlorine releases in accord with the guidance that USEPA set in its Risk Management Program Guidance For POTWs.   The analysis determines the distance at which the plume would dilute to a concentration at which people would suffer no serious permanent harm, but would voluntarily go to the hospital for evaluation.  The "toxic endpoint," for both chlorin 
eis 0.0087 milligram per liter, or 3 parts per million and is 0.0078 milligrams per liter, or 3 parts per million.  For the worst case scenario, it is assumed that a ton container will completely empty in ten minutes. Although highly unlikely, this is the worst possible case for the plant.  In the worst possible case, the EPA table yields a "distance to toxic endpoint" of 1.33 miles for the type of landscape (urban) in which the plant is located.  Within the 1.33 mile radius of the plant, there are schools, a hospital, recreation areas, commercial/office sits, and residences.  An estimated 9,600 people live within a 1.33 mile radius of the plant. 
 
The City also analyzed the potential impacts of more likely possible future chlorine or sulfur dioxide releases in accord with the guidance that USEPA set in its Risk Management Program Guidance For POTWS.   The City evaluated a release involving a break in a chlorine or sulfur dioxide transfer line attached to a ton container operating in th 
e vapor transfer mode.   The valve on the chlorine/SO2 ton container (which has a diameter of 5/16") would constrict the flow.  The EPA method shows a chlorine/SO2 release rate of 15 pounds per minute and a "distance to toxic endpoint" of 528 feet for the type of landscape (urban) in which the plant is located.  There are no offsite consequences for the alternative release scenario. 
 
To date there has only been one minor release at the plant (involving chlorine) which affected one employee and had no offsite consequences.  Additional training procedures were implemented immediately to prevent such an accident from reocurring. 
 
Training  
Ormond Beach has implemented a training program with guidelines for conducting regular, structured plant training for Ormond Beach employees.  Training record forms document the required training.  The training records for all personnel associated with the covered processes appear in the training file kept at the plant.  The training program appears in  
Section 5 of the program document. 
 
Operating Procedures 
Ormond Beach has adopted standard operating procedures (SOPs) that provide system descriptions, specifications, and operating procedures for the chlorine systems.  The procedures, presented in Section 6 of the program document for sulfur dioxide and Section 7of the program document for chlorine, address startup, shutdown, inspections, temporary operation, emergency procedures, and troubleshooting.  Maintenance SOPs appear in Section 8 of the program documenet, along with other safe work practices for handling chlorine and working in and around chlorine facilities. 
 
Contractor Safety Program 
Pre-qualification requirements for all contractors working in or around the chlorine and sulfur dioxide facilities are included in Section 9 of the program document.  In addition, this section presents guidelines that contractors must follow to conduct work in a safe manner. 
 
Emergency Response Program 
An Emergency Response Procedure documents 
the measures Ormond Beach will take to control process upsets and chlorine releases.  The Emergency Response Procedure appears in Section 10 in the program document.  Ormond Beach wastewater treatment plant personnel have decided not to respond to major releases of chlorine at the  WWTP with its own personnel.  The procedure focuses, instead, on keeping employees away from dangerous areas, while the mechanical equipment and emergency services control the chemical release. The Ormond Beach  HAZMAT team (mainly Fire Department personnel) will be contacted to be first responders to any major release.  The Ormond Beach fire department can respond up to eight HAZMAT members to a release, with over 30 more HAZMAT personnel available from nearby cities. 
 
 
Planned Changes to Imporve Process Safety 
Plant personnel to carry hand-held radios during chlorine/SO2 deliveries.  Operator is to inspect containers with hand-held chlorine/SO2 meter.  Receiving personnel to check container hydrostatic te 
st date upon delivery. 
 
Vendors should only send trucks with booms to plant, all trucks are to be well maintained. 
 
As part of bid specs, require vendor to certify quality of chlorine/sulfur dioxide to AWWA specs. 
 
Proper number of "F" wrenches should be purchased. 
 
Vendor will be requested to deliver containers in proper alignment. 
 
Chlorine Institute approved wrenches should be purchased for each on-line container. 
 
A spare regulator should be purchased. 
 
26 deg.  Baume' ammonia solution should be purchased for leak testing. 
 
Enclose the chlorine facility in a building with heat if current system provides inadequate heat.  Investigate alternative means of disinfection where "freezing" is not a problem. 
 
Vacuum regulators should be serviced at least once a year. 
 
Install pressure vacuum gage on each header. 
 
The flexible tubing should be frequently inspected, and replaced at least yearly. 
 
Gas lines should be replaced every five (5) years, and solution lines every ten (10)  
years. 
 
Mount an additional display from Cl2 sensor at operator control room.  Add additional Cl2 sensors at each end of chlorine building. 
 
Chlorinator O-rings to be replaced yearly. 
 
Install  pressure gages on supply lines, pump discharges, solution line after injector.  Purchase spare   gages. 
 
Install emergency lights in chlorine area. 
 
Install usage alarm on eyewash station. 
 
Install additional eyewash station at a location to be determined. 
 
Document sensor testing at least monthly. 
 
Chlorine/SO2 alarm to be tied into auto-dialer. 
 
Have a second qualified person review repairs and pre-startup before the system goes back into service. 
 
Third-party contractors must be pre-qualified before performing work in sensitive areas.
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