Ormond Beach Water Treatment Plant - Executive Summary |
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The City of Ormond Beach Public Works Department - Utilities Division has developed a Risk Management Program for control of catastrophic chlorine releases at its Water Treatment Plant (WTP) 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. USEPA's rule applies to any process that involves more than 2,500 pounds of chlorine. These programs apply to the use of chlorine for disinfection of water at the WWTP because the plant intends to store up to 8 tons of chlorine onsite. Pro gram 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, safe operating limits, and descriptions of the major process equipment are included in Section 3 of the program document. Process Hazard Review The Public Works Department - Utilities 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 c onsultant 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 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 chlorine is 0.0087 milligram per liter, or 3 parts per million. The worst case accident scenario assumes a 2,000 lb container releases in ten minutes. In the worst possible case, the EPA table yields a "distance to toxic endpoint" of 1.33 mile s 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 sites, and residences. An estimated 11,000 people live within 1.33 miles of the plant. The City also analyzed the potential impacts of more likely possible future chlorine 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 transfer line attached to a ton container operating in the vapor transfer mode. The valve on the chlorine ton container (which has a diameter of 5/16") would constrict the flow. The EPA method shows a chlorine 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 residences and an estimated 60 people living within 0.1 miles of the plant. To date there have been no releas es of chlorine from the water treatment plant. 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 Section 6 of the program document for chlorine, address startup, shutdown, inspections, temporary operation, emergency procedures, and troubleshooting. Maintenance SOPs appear in Section 7 of the program document, along with other safe work practices for handling chlorine and working in and around chlorine facilities. Contr actor Safety Program Pre-qualification requirements for all contractors working in or around the chlorine facility are included in Section 8 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 9 in the program document. Ormond Beach water treatment plant personnel have decided not to respond to major releases of chlorine at the WTP 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 eigh t HAZMAT members to a release, with over 30 more HAZMAT personnel available from nearby cities. Planned Changes to Improve Process Safety Chlorine vendor drivers will co-ordinate delivery to hours between 7 A.M. and 3 P.M., driver to page operator if no one is present when driver arrives. Operator must be present during delivery. Plant personnel to carry hand-held radios during chlorine deliveries. Operator is to inspect containers with hand-held chlorine meter. Receiving personnel to check container hydrostatic test 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 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' ammo nia solution should be purchased for leak testing. Enclose the chlorine facility in a building with heat if current system proves inadequate. Investigate alternative means of disinfection where "freezing" is not a problem. Vacuum regulators should be serviced at least once a year. Consider relocating chlorine facility to more central part of plant so chlorine could be vented to process. Install petcocks for a pressure vacuum gage on each header. Consider a vacuum/ pressure alarm. Modify the pipe-rack to provide better access and protection (knee wall). 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. Consider installing valves to isolate chlorinators. Hose clamps to be inspected monthly, replaced yearly. Chlo rinator O-rings to be replaced yearly. Install taps for pressure gages on supply lines, pump discharges, solution line after injector. Purchase spare gages. Train staff on how to isolate injector system and switch to backup. 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 alarm to be tied into auto-dialer. Have a second qualified review repairs before the system goes back into service. Post sign indicating sign-in location in highly visible location. Limit visits/ tours by untrained visitors to chlorine area. Post sign stating "city vehicles only" at location just beyond office. Verify that "Authorized Personnel Only" signs are in place at appropriate locations. Obtain escape units and store within reach of working areas. Install fire alarm and connect it to the auto-dialer. Move location where B-Kit is kept to under stairs of main operator building. Remove old, unused equipment and associated piping from chlorination system. Third-party contractors must be pre-qualified before performing work in sensitive areas. |