Douglas H. Allen Water Reclamation Facility - Executive Summary
EXECUTIVE SUMMARY |
The Douglas H. Allen Water Reclamation Facility (Water Reclamation Facility) owned and operated by the City of Bartow is a sequencing batch reactor (SBR) wastewater treatment plant. An integral component of the treatment plant is chlorine (Cl2) used for wastewater disinfection. The Cl2 storage capacity of the facility is 14,000 pounds. This inventory exceeds the 2,500-pound threshold for Cl2 set by EPA under the Risk Management Program (RMP) Rule codified at 40 CFR 68. Pursuant to the requirements of the rule, the City of Bartow has prepared this Risk Management Program (RMP) Plan. We are proud of our environmental, health, and safety efforts and programs and our record in these areas. The following sections outline our RMP plan.
Our Water/Wastewater Director has the overall responsibility for ensuring that our facility operates in a safe and reliable manner. This responsibility includes overseeing the implementation of
the elements of our risk management program. To ensure that our risk management program is appropriately developed and implemented, our Water/Wastewater Director has assumed the role of RMP Coordinator. The RMP Coordinator has the responsibility for the development, implementation, and integration of the EPA RMP elements. In addition, the RMP Coordinator works closely with the Wastewater Supervisor at the Water Reclamation Facility to integrate the elements of OSHA's PSM program (where applicable) as required under Section 68.15 of the RMP rule.
The RMP Coordinator serves as the chairman of the facility's RMP Steering Committee. This committee comprises members with responsibilities for developing and managing specific elements of our risk management and process safety programs. The members of this committee are assigned by the Water/Wastewater Director. Currently, the members of the RMP Steering Committee include the following:
* RMP Coordinator (Water/Wastewater Directo
* Wastewater Supervisor of the Water Reclamation Facility
* Senior Operator of the Water Reclamation Facility
* Purchasing Agent (City of Bartow)
The following sections identify the specific responsibilities for each aspect of our risk management and process safety management programs.
The Water/Wastewater Director has the responsibility for (1) ensuring that offsite consequence analyses for each regulated process are consistently performed and documented in accordance with Sections 68.20 through 68.39 and (2) selecting the scenarios that will be reported in the facility Risk Management Program Plan as required under Section 68.165. The Water/Wastewater Director also is responsible for ensuring that the accident history for each covered process is appropriately documented and maintained in accordance with Section 68.42 and 68.168 of the RMP rule.
The rule requires the evaluation of a worst case scenario, even though the likelihood of the occurrence of s
uch a scenario may be extremely small. The worst case scenario has been defined as a catastrophic release of one entire Cl2 tank containing 2,000 pounds. The distance to the toxic endpoint as predicted by the EPA RMP Guidance for Wastewater Treatment Plant Reference Tables is 3.0 miles. In addition to the worst case scenario, an alternative release scenario has been modeled employing more appropriate meteorological conditions and release assumptions. In the alternative release scenario, 9 pounds of Cl2 per minute are assumed to be released as a result of a valve failure. A 15-minute release would be expected in such a scenario. Based upon these assumptions, the distance to the endpoint as predicted by the RMP Guidance is 0.33 miles (1,760 feet). At these distances, residences, schools, and recreational areas would be impacted.
FIVE-YEAR ACCIDENT HISTORY
The Water Reclamation Facility has had no reportable releases of Cl2 since the commencement of operations at the facility in
1994. We have always taken a pro-active stance in the safety of our employees and the surrounding community and environment.
The RMP Coordinator has the responsibility for ensuring that the facility has an integrated, effective, and compliant prevention program that meets EPA RMP (Sections 68.65 through 68.87 of the RMP rule) and OSHA PSM requirements (where applicable).
PROCESS SAFETY INFORMATION
The responsibility for process safety information (PSI) (Section 68.65 of the RMP rule) including the process chemical information, process technology information, and equipment information is assigned to the Wastewater Supervisor. The Water/Wastewater Director has the responsibility of ensuring that all of this information is readily accessible for use.
PROCESS HAZARD ANALYSIS
In accordance with Section 68.67 of the RMP rule, the Water/Wastewater Director has the responsibility for ensuring that process hazard analyses (PHAs) are scheduled, conducted, and docume
nted by the Wastewater Supervisor. The Water/Wastewater Director may also use outside contractors/consultants to lead PHAs when appropriate. The Wastewater Supervisor is responsible for (1) ensuring that the information and personnel necessary to conduct PHAs are available according to the PHA implementation schedule and (2) resolving recommendations that are assigned to their respective areas.
In accordance with Section 68.69 of the RMP rule, the Wastewater Supervisor has the responsibility for ensuring that complete and accurate operating procedures are in place for all regulated processes. The Wastewater Supervisor works closely with the Water/Wastewater Director to develop and maintain the facility's safe work practices.
In accordance with Section 68.71 of the RMP rule, the Wastewater Supervisor has the responsibility for (1) ensuring that operations employees receive and understand training applicable to their specific jobs and the associated p
rocesses and (2) documenting the training. The Water/Wastewater Director has the responsibility for (1) ensuring that all facility employees receive and understand training in safe work practices applicable to their jobs and (2) documenting the training.
In accordance with Section 68.73 of the RMP rule, the Wastewater Supervisor has the responsibility for the overall mechanical integrity program, with specific emphasis on written procedures, maintenance training, the equipment and instrumentation inspection/test program and documentation, and equipment deficiency resolution. The Water Reclamation Facility also employs outside contractors and/or consultants to assist in the implementation and maintenance of the mechanical integrity program. The Water/Wastewater Director and the Purchasing Agent work with the Wastewater Supervisor to define and maintain appropriate quality assurance procedures for all types of equipment acquisitions/installations/repairs.
AGEMENT OF CHANGE
In accordance with Section 68.75 of the RMP rule, the Water/Wastewater Director has the responsibility for the overall management of change (MOC) program; however, the Wastewater Supervisor has responsibility for ensuring that the overall MOC program is effectively implemented.
In accordance with Section 68.77 of the RMP rule, the Water/Wastewater Director has the responsibility for the overall pre-startup review program, which is closely related to the MOC program. However, the Wastewater Supervisor has the primary responsibility for ensuring that this program is effectively implemented before affected operations begin.
In accordance with Section 68.79 of the RMP rule, the Water/Wastewater Director has the responsibility for ensuring that compliance audits regularly occur (and are documented) to verify that the prevention program is working and meets EPA/OSHA requirements. The Wastewater Supervisor has responsibility for res
olving any identified deficiency at the Water Reclamation Facility.
In accordance with Section 68.81 of the RMP rule, the Water/Wastewater Director has the responsibility for designing and managing the incident investigation program, including tracking resolution of investigation findings and recommendations. The Water/Wastewater Director also has the responsibility of ensuring that only trained personnel lead our investigations. The Wastewater Supervisor has responsibility for ensuring that all incidents are reported and investigated, and the investigation's findings are resolved, documented, and communicated to affected personnel.
In accordance with Section 68.83 of the RMP rule, the Water/Wastewater Director, working with the Wastewater Supervisor, has the responsibility of involving employees in the planning and implementation of the facility's prevention program elements.
HOT WORK PERMITS
In accordance with Section 68.85 of the
RMP rule, the Water/Wastewater Director, working closely with the Wastewater Supervisor, has the responsibility of developing and maintaining the facility's hot work permit program.
In accordance with Section 68.87 of the RMP rule, the Wastewater Supervisor has the overall responsibility for the contractor program.
EMERGENCY RESPONSE PROGRAM
In accordance with Sections 68.90 and 68.95 of the RMP rule, the Water/Wastewater Director is responsible for (1) designing, implementing, and maintaining the facility's emergency response plan, (2) ensuring that all associated training is conducted and documented as necessary, (3) coordinating the site emergency response plan with the community emergency response plan, and (4) responding to local emergency planners/responders when questions arise.
RMPLAN PREPARATION AND SUBMISSION
The Water/Wastewater Director is responsible for preparing and submitting the Risk Management Program Plan for the facility as required under Section
s 68.150 through 68.185 of the RMP rule.
The Water/Wastewater Director and Wastewater Supervisor have the responsibility of providing Risk Management Program Plan information (other than the required EPA submission) to employees and the public as required under Section 68.210 of the RMP rule.