Fairfield Suisun Sewer District WWTP - Executive Summary |
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1. Accidental Release Prevention and Emergency Response Policies Chemicals are widely used in industry, in the home, and in the environment. They are transported on roads, water, and railways. We at Fairfield-Suisun Sewer District (FSSD) and our Contract Operator (the primary contractor responsible for all plant maintenance and operations in the facility) use chemicals, too. For example, we use chlorine and sulfur dioxide to disinfect our water to provide safe water discharges to the environment or for landscaping or irrigation uses. Storing large qualities of chlorine and sulfur dioxide can be a hazard. We take our safety obligations in storing and using chlorine and sulfur dioxide very seriously. The following document describes what could happen if there were to be an accident, the steps we take everyday to ensure a safely operating plant, and what to do in event of an emergency. Please feel free to contact Gerald McMackin at (707) 429-3233 or Larry Bahr at (707) 429-8930 if you hav e any questions. FSSD and the Contract Operator's basic commitment to responsible stewardship of the environment, protection of the community, protection of employee health, and assurance of product safety extends to the processes covered by the new EPA Risk Management Plan (RMP) requirements. We have developed management systems in compliance with various applicable regulations to prevent the release of regulated substances especially in locations that may cause detrimental effects to employees, the community, or the environment. This is accomplished through a systematic evaluation of process design, process technology, operational procedures, maintenance activities, non-routine procedures, emergency preparedness, training, and several other factors. We plan to meet or exceed regulatory requirements. In the attempt to accomplish this goal, the management systems have been developed in such a way that the hazards are identified, understood, and controlled to prevent accidents. Chlorine and sulfur dioxide are regulated under the RMP requirements. We have developed programs to comply with the U.S. Environmental Protection Agency's (EPA's) Risk Management Program, under Section 112 (r) of the Clean Air Act (CAA) Amendments of 1990, 40 Code of Federal Regulations (CFR) Part 68 and the California Accidental Release Prevention (CalARP) Program under California Code of Regulations (CCF) Title 19, Division 2, Chapter 4.5. 2. The Stationary Source and the Regulated Substances Handled The primary purpose of our facility is the disinfection of wastewater to provide safe water discharges to the environment. To meet this requirement, we store chlorine in quantities up to 23 one-ton cylinders. Typically, three chlorine cylinders are connected to a common manifold and liquid is piped from the two cylinders through a chlorine gas evaporator, to the chlorinators and on to chlorine injectors where it is injected into plant process water. We store sulfur dioxide in quantities up to 1 2 one-ton cylinders. Typically, two sulfur dioxide cylinders are manifolded and liquid is piped from the two cylinders through a sulfur dioxide gas evaporator, to the sulfunators and on to the injectors where sulfur dioxide is injected into plant process water. 3. The Worst-Case Release Scenarios and the Alternative Release Scenarios We developed worst-case and alternative case release scenarios for chlorine to determine the effects an accidental chemical release would have on the public. The development of the worst-case scenario is directed by EPA regulation. Namely, the quantity of a substance released is equal to the greatest amount held in a single vessel or pipeline. The alternative case release scenario developed is considered to be a more likely release scenario. However, the alternative case release scenario is still considered unlikely to occur. As part of its release prevention program, discussed in detail in the next section, FSSD and the Contract Operator are constantly mo nitoring, reviewing, and upgrading standard operating procedures and equipment. In addition to these administrative controls, FSSD and the Contract Operator have the systems enclosed in a building and have automatic release mitigation systems, including a scrubber system in place. For worst-case and alternative case release scenarios, the USEPA's RMP*Comp model was used to determine the distance to the toxic endpoint. Worst-Case and Alternative Case Release Scenario Worst-Case Scenario The largest vessel of chlorine on-site contains 2,000 pounds. For the worst-case scenario, the entire contents of this tank are released in 10 minutes. This scenario was modeled using a building enclosure as passive mitigation, reducing the release rate to 110 lb/min. The distance to the toxic endpoint was determined to be 2.2 miles. The largest vessel of sulfur dioxide on-site contains 2,000 pounds. For the worst-case scenario, the entire contents of this tank are released in 10 minutes. This scenari o was modeled using a building enclosure as passive mitigation, reducing the release rate to 110 lb/min. The distance to the toxic endpoint was determined to be 2.1 miles. Alternative Case Scenario For chlorine, a release scenario considered by FSSD and the Contract Operator to be more likely to occur than the worst-case scenario would be a pressure regulator failure and leak to the atmosphere. This scenario was modeled using a building enclosure as passive mitigation and a scrubber system as active mitigation. The automatic scrubber system is expected to remove 95% of the chlorine gas released. Under this scenario, 2.37 pounds per minute of gaseous chlorine would be released for 60 minutes. The distance to the toxic endpoint for this scenario was calculated at 0.1 miles. For sulfur dioxide, a release scenario considered by FSSD and the Contract Operator to be more likely to occur than the worst-case scenario would assume liquid is released from a 5/16-inch pigtail. This scenario w as modeled using a building enclosure as passive mitigation and a scrubber system as active mitigation. The automatic scrubber system is expected to remove 95% of the sulfur dioxide gas released. Under this scenario, 7.95 pounds per minute of gaseous sulfur dioxide would be released over 60 minutes. The distance to the toxic endpoint for this scenario was calculated at 0.2 miles. 4. The General Accidental Release Prevention Program and Chemical-specific Prevention Steps. Our facility complies with EPA's Accidental Release Prevention Rule and with all applicable state codes and regulations. The Prevention Program consists of 12 elements, which will help us minimize releases of regulated substances. A description of each of the elements is given below: Employee Participation We have involved employees in the development and implementation of the elements of the Process Safety Management and the Prevention Program. We encourage employees to participate with the understanding that their pa rticipation is a key factor to the success of any program. We are committed to maintaining a safe workplace, and as a result all employees are responsible for adhering to the Process Safety Management and Risk Management Plan (PSM/RMP) regulations. We are committed to the following: 7 Including employees in Process Hazard Analyses 7 Consulting employees on the development of PSM/RMP regulation elements 7 Providing employees with access to the information developed through the PSM and RMP rules 7 A description of the Employee Participation Program is provided in the RMP/PSM Document Process Safety Information We provide our personnel with the necessary information about the process equipment to conduct their jobs in a safe manner. A complete compilation of Process Safety Information (PSI) is made available to those involved in operating and maintaining the chlorine and sulfur dioxide process. The PSI includes the following: 7 Hazards from chemicals used or produced by the process 7 Info rmation pertaining to the technology of the process 7 Information pertaining to the equipment in the process A chapter containing the PSI for chlorine and sulfur dioxide is provided in the RMP/PSM Document. The RMP Coordinator is responsible for ensuring the PSI remains up to date. Process Hazard Analysis We provide appropriate resources to make the working environment around chlorine and sulfur dioxide safe. To assist in assuring safety, hazards are identified through a Process Hazard Analyses performed on the chlorine and sulfur dioxide processes. We have performed Process Hazard Analyses (PHA) on the chlorine and sulfur dioxide processes. We will update the hazard analyses at least every five years to assure that the PHA remains applicable to any process improvements and changes. The level of detail in the PHA is intended to be appropriate to the complexity of the process. The findings, which require changes, will be submitted in the RMP. A copy of each PHA is available in the Cen tral files. The RMP Coordinator is responsible for scheduling the PHAs and notifying the supervisor of maintenance, engineering, and operations of the area. The supervisors are responsible for ensuring appropriate representatives participate in the PHA. The ongoing recordkeeping requirements for process hazard analysis are: 7 Documentation that shows the recommendations from the PHA are resolved in a timely manner. 7 Documentation that shows what actions are to be taken as a result of the PHA; a written schedule of when these actions are to be completed; communication of these actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions. 7 Document that all PHA's are updated at least every 5 years. Standard Operating Procedures We provide appropriate resources to insure personnel have the knowledge necessary to make the working environment at the facility safe. To assist in assuring the safety of employees, the surrounding community, and the environment, operating procedures have been completed for the chlorine and sulfur dioxide processes. In conjunction with operating personnel, we have developed and implemented written operating procedures, available in the operating manuals, which provide clear instructions for safely conducting activities involved in the chlorine and sulfur dioxide processes. Employees who work in or maintain the process utilize the procedures. The procedures address all operational phases, and are reviewed at least annually to ensure they remain up to date. Copies of the Standard Operating Procedures (SOP) are available in the control rooms. The RMP Coordinator is responsible for notifying the supervisor of the process area the date by which the SOP needs to be re-certified. The supervisor of the process is responsible for ensuring the manual is reviewed and certified annually. The ongoing recordkeeping requirements for the standard operating procedure s are: 7 Proof of certification annually that the standard operating procedures are current and accurate. Training We provide the appropriate resources to ensure adequate training of personnel involved in operating the regulated processes and to ensure that the jobs can be performed safely. The training program includes initial training, refresher training, and training documentation. Employees currently involved in operating a regulated process and employees being transferred into a regulated process will be trained in an overview of the process and in the standard operating procedures. This initial training will also include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks. Refresher training will be provided a minimum of once every three years to employees involved in operating a regulated process to assure that the employee understands and adheres to the current standard opera ting procedures of the process. We will verify that each employee involved in operating a regulated process has received and understood the required training. A record will be prepared that contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training. The training programs and documentation are available in the RMP Central files. The area supervisors are responsible for ensuring employees in their area are appropriately trained. The ongoing recordkeeping requirements for training are: 7 A written record that contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training. Contractors We periodically use contractors to perform work in and around processes that involve regulated substances. To ensure safety, we developed a Contractor Program to inform and manage contract employees working in or near the chlorine and sulfur dioxide processes. The Contr actor Program has been developed to establish a screening process so that we hire and use contractors who have a commitment to safe work practices. The contractor program includes all activities that have the potential for affecting process safety, including the performance of maintenance or repair, turnaround, equipment installation, renovation, demolition, or specialty work on or adjacent to the chlorine and sulfur dioxide processes. A facility wide Contractor Program is available in the RMP Central files or through both FSSD and the Contract Operator's Purchasing. Pre-Startup Safety Review We will ensure a new, or significantly modified, facility in a regulated process is as safe as possible before starting the system. To assist in assuring safety, a Pre-Startup Safety Review is performed before chlorine or sulfur dioxide is introduced to the system. The Pre-Startup Safety Review verifies the following information: 7 Training is complete 7 SOPs are complete 7 Construction/equipment is in accordance with the design specifications 7 A PHA has been complete, if it is a new facility Records of the Pre-Startup Safety Review and procedures are available in the RMP Central Files. The supervisor of the area/ construction project leader is responsible for ensuring a Pre-Startup Safety Review is performed. Mechanical Integrity We provide appropriate resources to ensure that the equipment used to process, store, or handle chlorine and sulfur dioxide is designed, constructed, installed, and maintained to minimize the risk of releases of the regulated substances into the workplace or community. To accomplish this goal, a Mechanical Integrity Program has been implemented to ensure the continued integrity of the processes. The Mechanical Integrity Program has been implemented for the systems that could potentially result in the release of chlorine or sulfur dioxide. The program utilizes increased maintenance training, and preventive maintenance in conjunction with regular insp ections and tests, to ensure equipment is in satisfactory condition. A summary of the Mechanical Integrity Program is found in the RMP Central Files with more details located in the maintenance shop. The ongoing record-keeping requirements for the mechanical integrity testing program are: 7 Documentation showing each inspection and test that has been performed on process equipment. The documentation will identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test. Hot-work/Safe Work The objective of our Hot-work Permit is to consistently control non-routine work conducted in the process areas. The Hot Work Permit System is specifically concerned with the permitting of hot work operations associated with welding and cutting on or near chlorine and s ulfur dioxide process areas. The permits will document compliance with the fire prevention and protection requirements. Additional safe work practices such as lockout/tagout, confined space entry, and control over entrance have also been implemented to increase facility safety. The ongoing recordkeeping requirements for the hot work/safe work programs are: 7 Copies of the hot work permit showing: that the fire prevention and protection requirements in 29 CFR 1910.252(a) have been implemented prior to beginning the hot work operations; the date(s) authorized for hot work; and the object on which hot work is to be performed. The permit will be kept on file until completion of the hot work operations. Management of Change We manage all changes to the chlorine and sulfur dioxide processes to ensure the process is operated and maintained as safely as possible. To assist in accomplishing this goal, a Management of Change Program has been implemented. Management of Change examines any type o f change that is planned for the process, and the basis of the change. The Management of Change Program is designed to evaluate, approve and administer changes to the chlorine and sulfur dioxide processes to assure any changes implemented enhance the operation and safety of the system. A description and procedures for the Management of Change Program can be found in the RMP Central Files. The RMP Coordinator is responsible for ensuring all MOC forms are complete. The ongoing recordkeeping requirements for management of change are: 7 Copy of the written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and, changes to stationary sources that affect a covered process. Incident Investigation It is our policy to investigate any incident, which occurs in the chlorine or sulfur dioxide process that could have or did result in a catastrophic release of a hazardous chemical in the workplace. The Incident Investigation policy, procedures, and records of the Incident Investigations are available in the RMP Central Files. Compliance Audits Compliance audits are utilized to evaluate the effectiveness of the PSM/RMP programs that have been implemented. The compliance audit is intended to identify any deficiencies or weaknesses in our policies, programs, or procedures, and take action to correct the deficiencies. A compliance audit is performed at least every three years to verify that the systems required by the PSM and RMP Regulations are in place and have been implemented. The regulations require that the previous two compliance audits be kept on file. This documentation and the Compliance Audit procedures are available in the RMP Central Files. The ongoing recordkeeping requirements for compliance audits are: 7 Proof of certification that compliance with the provisions of the prevention program has been evaluated at least every three years to verify that the procedures and practices developed under t he standard are adequate and are being followed. 5. Summary of Recordkeeping Requirements for the Prevention Program The following is a summary of our ongoing recordkeeping for the prevention program. Process Hazard Analysis 7 Documentation that shows the recommendations from the PHA are resolved in a timely manner. 7 Documentation that shows what actions are to be taken as a result of the PHA; a written schedule of when these actions are to be completed; communication of these actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions. Document that all PHA's are updated at least every five years. Standard Operating Procedures 7 Proof of certification annually that the standard operating procedures are current and accurate. Training 7 A written record that contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training. Mec hanical Integrity 7 Documentation showing each inspection and test that has been performed on process equipment. The documentation will identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test. Hot Work/ Safe Work Copies of the hot work permit showing: that the fire prevention and protection requirements in 29 CFR 1910.252(a) have been implemented prior to beginning the hot work operations; the date(s) authorized for hot work; and the object on which hot work is to be performed. The permit will be kept on file until completion of the hot work operations. Management of Change Copy of the written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and, changes to stationary sources that affect a covered process. Compliance Audits 7 Proof of certification that compliance with the provisions of the prevention program have been evaluated at least every 3 years to verify that the procedures and practices developed under the standard are adequate and are being followed. 6. The 5-Year Accident History During the past 5 years since June 21, 1994, our facility has had no reportable accidents. 7. The Emergency Response Program We have developed and implemented an emergency response program for the purpose of protecting public health and the environment. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, the emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within the covered processes that would require a modified emergency response. The emergency response plan, which is maintained at the facility, contains the following elements: 7 Procedures for informing the public and local emergency response agencies about accidental releases. 7 Documentation of proper first aid and emergency medical treatment necessary to treat accidental human exposures. 7 Procedures and measures for emergency response after an accidental release of a regulated substance. 7 Procedures for the use of emergency response equipment and for its inspection, testing, and maintenance. 7 Training for all employees in relevant procedures. 7 Procedures to review and update, as appropriate, the emergency response plan to reflect changes at the stationary source and ensure that employees are informed of changes. 7 A written plan that complies with other Federal contingency plan regulations or is consistent with the approach in the National Response Team's Integra ted Contingency Plan Guidance ("One Plan"). 7 The emergency response plan will be coordinated with the community emergency response plan developed under 42 U.S.C. 11003. Upon request of the local emergency planning committee or emergency response officials, promptly provide to the local emergency response officials the information necessary for developing and implementing the community emergency response plan. 7 Training with local emergency response agencies and local emergency care providers. 8. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release program. The PHAs was conducted in April 1999 under the RMP and CalARP program requirements. Based on these reviews, seven additional changes were identified to improve the safety of the chlorination system. It is expected that the recommended actions be evaluated and implemented by December 1999. The implementation of these recommendation s will further improve the safety of the covered processes. |