Resort Water Reclamation Plant - Executive Summary

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    This Risk Management Plan was developed to address the hazards associated with the storage and use of chlorine gas at the West Hawaii Utilities Facilities.  It is the goal of the program to reduce the risk to employees and the public of injury or death from accidental releases of chemicals used at the facilities, in particular, chlorine gas. 
 
    The program covers the following areas in individual sections: 
         Management System 
         Employee Participation Plan 
         Process Safety Information 
         Process Hazard Analysis 
         Operating Procedures 
         Training 
         Contractor Safety 
         Pre-Startup Safety Review 
         Mechanical Integrity 
         Hot Work Permit 
         Management of Change 
         Incident Investigation 
         Emergency Planning and Response 
         Compliance Audits 
 
    Each of these areas addresses the aspects of controlling the risks associated with the safe handling of chlorine gas at the West Hawai 
i Faacilities. 
 
    The Management System designates the Utilities Manager as the person with overall responsibility for the program.  The various other responsibilities are shared between the water and wastewater field engineers. 
 
    The Employee Participation Plan designates which employees are to be included in reviewing and implementing the other sections of the plan.  It covers all of the remaining sections.  It includes all employees who may be impacted by the use of the chemicals. 
 
    The Process Safety Information includes procedures for reviewing the accuracy of all process diagrams and piping and instrumentation diagrams.  These are to be reviewed and updated by the Field Engineer - Wastewater with assistance from all operating personnel. 
 
    The Process Hazard Analysis section outlines the methods to be used to evaluate the hazards associated with the use of the chemicals in the processes covered by the program.  The processes covered at present include the chlorinati 
on system at the resort treatment facility and the chlorine storage area of the baseyard. 
 
    The Operating Procedures for these areas will be developed by the Field Engineer - Wastewater in conjunction with all of the operators which may be responsible for operation of the systems. 
 
    The Training section covers the need for proper training and outlines the steps to be taken to ensure that all employees working in or near the chlorination system of the resort facility or the storage area of the baseyard have the proper training before initially handling the chemical.  It also provides for the continuing training to maintain proficiency in responding to emergencies and safe handling practices. 
 
    The Contractor Safety section addresses the need to communicate the risks and hazards of the chemical processes to any contractors which may be working in or near the area of the chemical use. 
 
    The Prestartup Safety section addresses the need to perform a prestartup inspection bef 
ore beginning the operation of the chemical feed system, either as an initial startup or restart after repairs. 
 
    The Mechanical Integrity of the equipment and system is to be ensured by the procedures of the Mechanical Integrity section.  This outlines the steps that the Field Engineer - Wastewater and Maintenance Mechanic will follow to ensure that the equipment is always in proper working order and has been maintained as recommended by the manufacturer. 
 
    The Hot Work Permit section describes the need to monitor the hot work, which may be performed in the designated risk areas.  It details the methods to be followed to ensure no damage is done to the chemical system during hot work operations. 
 
    The Mangement of Change section details the procedures to be followed if any process changes or equipment changes are proposed.  It outlines the steps to be followed to have the changes reviewed and verified that they will not increase the risk of the system by altering the chara 
cteristics of the equipment. 
 
    Any accidental releases of chemical or injuries to employees or contractor personnel are to be investigated following the procedures outlined in the Incident Investigation section. 
 
    The Emergency Planning and Response section details the procedures for developing and implementing an emergency warning and evacuation plan for the sites.  It details the procedures for forming a response team and for reviewing and updating the plans. 
 
    The Compliance Safety Audit section covers the procedures to be used by the audit team to review all aspects of the program to ensure compliance with the requirements of the plan. 
 
    All of these sections together comprise the risk management plan for the West Hawaii Utilities. 
 
    The main chemical of concern for the utilities is chlorine gas, which is used as a disinfectant at the resort plant and at well sites for the water system.  The extra cylinders for the wells are stored at the baseyard. 
 
    In comp 
leting this plan the worst-case release investigated was for a one-ton cylinder losing all of its contents in 10 minutes at the resort plant.  This would affect an area with a radius of 3.0 miles around the plant.  The alternate release would be a reduced rate leak from a cylinder, most likely caused by the breaking off of a valve.  This release would have a duration of 23 minutes and affect an area with a radius of 0.4 mile from the plant. 
 
    Control and prevention measures which are part of this program include the inspection of all cylinders delivered to the facilities.  The routine servicing of all components of the metering system are also included. 
 
    The most likely time for an accidental release would be during cylinder changing operations.  To reduce this possiblity, all operators are required to wear a self contained breathing apparatus while changing cylinders.  This will allow them to make any  necessary repairs or adjustments to the system immediately without having  
to leave the area.  This will reduce the time of leakage and therefore the amount of any leak.  This will reduce possible harm to the attending employees. 
 
    There have been no significant releases from the system over the past five year period.  The above procedures have allowed the immediate repair of two leaking valves with only minimal releases of gas and no employee injuries. 
 
    The plant staff are constantly working to reduce the need for chlorine for disinfection.  It is hoped that in the future the volume needed can be reduced to allow the removal of the ton cylinders and use of 150 pound cylinders in their place.
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