Ash Street Facility - Executive Summary

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1. EXECUTIVE SUMMARY  68.155 
The Town of Orange Park operates its Water and Wastewater Treatment Plant at the Ash Street Facility in Orange Park, Florida. 
1.1. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES     (a) 
The Town of Orange Park Ash Street Facility accidental release prevention policy involves a unified approach that integrates technologies, procedures and management practices.  Our prevention program complies with all applicable procedures of the U.S. Environmental Protection Agency (EPA) Risk Management Program (RMP) 40 CFR-68, Prevention Program. 
1.1.1. MANAGEMENT SYSTEM  (A)(1) 
The Town of Orange Park has a management system in place, which oversees the implementation and on-going use of the RMP elements.  This program, along with other Town of Orange Park policies, eliminates and/or reduces the likelihood of a hazardous chemical release at the plant. 
1.1.2. PREVENTION PROGRAM LEVEL 3  (A)(2) 
The Town of Orange Park maintains policies, procedures and syst 
ems as part of their prevention program.  The program addresses each of the EPA Program Level 3 listed 12 elements, plus RMP elements needed to implement the program, and the like elements in place in the plants' OSHA PSM program.  These are maintained by the Town of Orange Park's Public Works Director, at the Ash Street Faciltiy.. 
1.2. THE TOWN OF ORANGE PARK STATIONARY SOURCE AND REGULATED SUBSTANCE HANDLED AT ASH STREET FACILITY (B) 
The Town of Orange Park Plant employs 12 full-time employees engaged in water and wastewater treatment plant and field operations.  Only 6 employees including the Public Works Director and Utilities Superintendent are permitted in the chlorine building. Chlorine is used as part of the manufacturing process. 
1.2.1. SITE DESCRIPTION  (B)(1) 
The site is owned and operated by the Town of Orange Park.  The site is located at 700 Ash Street, Orange Park, Clay County, Florida.  The 13-acre site is boarded by the CSX railway tracks on the west and Loring Avenue 
on the south. 
The Facility includes a chlorine storage and distribution system contained in a frame building (chlorine building) and some chlorinators inside a block building (water treatment plant chlorine room). The boundaries of the chlorine system subject to the RMP regulation include the chlorine building and water treatment plant chlorine room including the associated vent and exhaust systems. 
1.2.2. REGULATED SUBSTANCE  (b)(2) 
Chlorine is the only regulated substance on site, which exceeds the EPA 40 CFR-68 rule threshold quantity.  The Town of Orange Park chlorine process was installed as part of the process of purifying water for public consumption and disinfecting the treated effluent wastewater before discharge to receiving waters.  The chlorine is received, stored and distributed to two process control systems.  
Chlorine is an EPA-and OSHA-listed toxic chemical.  It is an irritant and it is corrosive.  Chlorine is a halogen with the formula Cl2.  It is a chlorinating or 
oxidizing agent that is not flammable.  It has a 1 ppm OSHA ceiling Permissible Exposure Limit (PEL) and a NFPA health rating of 4, severe; with immediate and delayed health hazards.  Chlorine is not a carcinogen. 
1.3. WORST AND ALTERNATIVE CASE RELEASE SCENARIOS  (c) 
Two offsite consequence analyses were conducted which include two chlorine release scenarios.  The first is a "worst case release".  The second is a more probable "alternative release scenario".  The first scenario is defined by EPA, which states that "the < shall assume that the < maximum quantity in the largest vessel < is released as a gas over 10 minutes" due to an unspecified failure.  The alternative scenario is defined as "more likely to occur than the worst-case scenario". 
Atmospheric dispersion modeling was performed to determine the distance traveled by the chlorine released before its concentration decreases to the "toxic endpoint."  The EPA selected endpoint for chlorine is 0.0087 mg/l, which equals 3 ppm. Th 
e 3 ppm endpoint is the Emergency Response Planning Guideline Level 2 (ERPG-2).  This is defined by the American Industrial Hygiene Association (AIHA) as the "maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ability to take protective action." The residential population within a circle with a radius corresponding to the toxic endpoint distance was defined, "to estimate the population potentially affected." 
1.3.1. WORST CASE   (c)(1) 
Atmospheric dispersion modeling for the worst case scenario was performed using the EPA assumptions.  Results demonstrate a distance of 1.30 miles to the toxic endpoint.  The residential population that could potentially be affected by the release is estimated at 12,475 people. 
 
1.3.2. ALTERNATIVE CASE   (c)(2) 
The alternative release scenario involves the f 
ailure of the yoke assembly regulator of the pressure system connected to one of the one ton containers. This failure is equal to creating a 1/16 inch diameter hole in either the yoke assembly, the drip tube, a pipe, or even the container. Modeling using the EPA wastewater guidance demonstrated the rate of chlorine release is 20.0 lbs./min.  The toxic endpoint distance determined is 0.10 miles.  The number of public receptor that would be impacted by this release is estimated at 70 people. 
1.4. ACCIDENTAL RELEASE PREVENTION PROGRAM  (d) 
The Town of Orange Park accidental release prevention program is based on OSHA's PSM program and EPA's RMP Level 3 prevention program.  The PSM program has been in place and effectively used.  It is part of the plants operating culture.  There are two parts to the program.  The first is the general overall site program.  The second is the chlorine-specific actions within the site program.  This is coordinated with the Town of Orange Park, Florida, Fire  
Department. 
1.4.1. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM   (d)(1) 
Facility-wide, many elements of the prevention program are used for all operations. The overview of these generally written programs are listed below: 
7 The Town of Orange Park has detailed process safety information on each of its operations.  
7 The Public Works Department acts as the document control system (DCM), and is integral to the management of change for all operations on site.   
7 Training is the backbone of employee knowledge, job operations and is ongoing in each area.  Employee training in operations and maintenance emphasizes awareness of the hazardous and toxic properties of all chemicals used.  
7 Maintenance and preventive maintenance are used for all operations making mechanical integrity a part of each piece of equipment.  
7 Incident investigations of accidents and near-miss incidents ensure we learn from each event as well as correct the causes of the incident.  
7 Employees participate in all  
aspects of the plant as listed below under emergency response.  
7 Safe work practices are used throughout the facility including: 1) Hot Work Permits, 2) Lock Out Tag Out, 3) Site Security, and 4) Breaking Into Chemical lines.  
7 Contractors must meet The Town of Orange Park's high safety and technical standards as part of selection and ongoing evaluations. Plus, The Town of Orange Park demands training of contractors to our standards.  
1.4.2. CHLORINE-SPECIFIC RESPONSE PROGRAM  (d)(2) 
1.4.2.1. Chlorine-Specific Policies and Procedures 
Chemical-specific prevention features of the facility include: the policies and procedures listed above and those of the chlorine specific program.  These include: 
7 Specific procedures for the operation of the chlorine building.  
7 Completion of a Pre-startup Safety Review prior to start up of the modified chlorine system.  
7 Specific emergency response procedures for chlorine releases as outlined below under emergency response.  
7 Specific training in 
the properties, hazards, handling requirements, and leak repair for chlorine.  
7 Finally, the details of both facility and equipment design are key to the safe operations of the chlorine system.  
1.4.2.2. Facility Design 
The facility and support equipment of the chlorine storage and control building meet and exceed design codes standards and good engineering practices. The buildings are equipped with either natural or fan driven vent make-up.  The vent at the water treatment plant chlorine room is constantly working, thus keeping fresh air inside the room.  The chlorine building where the one ton cylinders are kept, is open on one side. 
1.4.2.3. Equipment Design 
The chlorine high pressure piping system is made of chlorine compatible steel for high pressure systems or tubes and rated to 500 psig for the high pressure system and over 100 psig for the low pressure system. The maximum pressure of the chlorine in the high pressure system is only 150 psig giving a 3 to 1 safety factor. Thes 
e materials in the high pressure system are chlorine compatible.  The materials in the low pressure or vacuum system are all chlorine compatible (not corroded by chlorine). There is a chlorine monitor, which detects the presence of chlorine in the storage building.  The alarm and light alert employees of a potential chlorine leak. 
1.5. FIVE-YEAR ACCIDENT HISTORY  (e) 
The Town of Orange Park has had no accidental releases of chlorine in the past five years per EPA 40 CFR 67.42 (a). 
1.6. EMERGENCY RESPONSE PROGRAM  (f) 
Emergency response procedures are contained in the Town of Orange Park Contingency Plan (Emergency Response Plan).  The plan includes an emergency response "decision tree" and a notification plan.  Emergency response drills and drill evaluations are being planned to be conducted on an annual basis by the operating department.  Emergency operation and response procedures are also reviewed at that time. 
The emergency response program (contingency plan) is coordinated (review 
ed by) with the Town of Orange Park Fire Department, which coordinates with Local Clay County Emergency Response Planning Committee (LEPC) and the Clay County HazMat Team, Green Cove Springs, Florida.  Copies of the program are given to the fire department in Orange Park, and the LEPC. Besides the specific emergency response program, key elements of the prevention programs are incorporated in the operating culture of the Town of Orange Park plant. 
The Contingency Plan procedures detail the actions and responses to chlorine spills (releases).  The plan includes training of all chlorine-area operators. The primary response team includes the Town of Orange Park fire and rescue, plus the County HazMat Team.  All of these responds to severe chlorine leak situations.  Actions include catastrophic, severe, and moderate leaks.  A Chlorine "B" Kit is maintained by the Towns fire department to aid in stopping leaks.  Public notification is facilitated through the County Sheriff Department. 
1.6.1 
. PERSONNEL  (f)(1) 
Personnel are the key resource of the Town of Orange Park's prevention program. Our employees make up the operators and emergency response teams.  The Town of Orange Park fosters a high level of involvement in every aspect of the chlorine system operations including participation in: 
7 Chlorine PSM/RMP safety teams,  
7 Development of the operation procedures,  
7 Hazard evaluations, and  
7 On-going training of the operators and other involved staff. 
1.7. CHANGES TO IMPROVE SAFETY  (g) 
Changes to improve safety (recommended actions) were identified during the hazard analysis conducted on June 2, 1999, of the PSM program to meet requirements of the Risk Management Prevention Program.  These recommended actions have now been evaluated and implemented as required.  An Audit was conducted on April 21st 1999, to review the site and PSM program.  The key safety action items were completed by June 9th 1999. Other recommendations are to be completed by July 1999.  
The Town o 
f Orange Park continually reviews implemented and potential safety improvements for all of its operations.  Currently, the Town of Orange Park management team and chlorine safety team is reviewing potential upgrades to the existing design of the chlorine operations to make the system even safer in the event of a release of chlorine.                                                                                                                                                               (THE PREVENTION PROGRAM HAS BEEN INCLUDED AS A PART OF THE EXECUTIVE SUMMARY DUE TO TECHNICAL DIFICULTIES THAT THE EPA RMP CENTER HAD WITH OUR PREVOIUSLY (2 TIMES) SUBMITTED DISKETTE)                                                                                                                                                           3. PREVENTION PROGRAM 3, SUBPART D 
The Chlorine System is subject to comply with Prevention Program 3.  This is based on the worst-case release scenario analysis results 
and the Chlorine System being subject to OSHA's PSM rule, 29 CFR 1910-119.  The Town of Orange Park accidental release prevention policy involves a unified approach that integrates technologies, procedures, and management practices, and it is in compliance with all applicable EPA Prevention Program requirements.  The plan also includes the prevention steps taken beyond this regulatory requirement.  The Town of Orange Park's Document Management System (DMS) contains in it the key OSHA document, which details the operation of the prevention program. 
The general Town of Orange Park accidental release prevention program is based on OSHA PSM program and EPA RMP Level 3 prevention program (described above in section 1.1.2).  The facility has an emergency response program, which is coordinated (reviewed by) with the Town of Orange Park Fire Department, which is a member of Local Emergency Response Planning Committee (LEPC).  This program includes an emergency response decision tree and a not 
ification plan.  Emergency operation and response procedures are reviewed in the plan.  To ensure the public safety evacuation during a major release is begun at a minimum of 1.3 mile radius from the source.  Plus the incident commander is advised to evacuate up to 4 mile radius based on the circumstances of the catastrophic release.  This is three times the distance recommended by the EPA Guidance.  Besides the specific emergency response program, key elements of the prevention programs are incorporated in the operating culture of the Town of Orange Park plant by the following key elements: 
7 High level of involvement in every aspect of the chlorine system operations including participation in :   
* chlorine PSM/RMP safety teams,  
* development of the operation procedures,  
* hazard evaluations, and  
* on-going training of the operators and other involved staff. 
7 Preventive maintenance and mechanical integrity programs ensure the safe operation of the equipment and systems. 
7 Use of  
state-of-the-art process and safety equipment that meets and/or exceeds industry and regulatory standards. 
7 Use of accurate and effective operating procedures written with the participation of the operators.  These documents are all controlled by the Town of Orange Park DMS document control system. 
7 Management of all changes to the procedures, equipment and chemicals used by the Town of Orange Park on the site.  Again, the DMS document control system is key to the high quality of the operation and its products. 
7 Performance of a hazard review of equipment, facility, and procedures. 
7 Implementation of an auditing and inspection program. 
Chemical-specific prevention features of the facility include: 1).  the  chlorine building ventilation system, 2). chlorine detectors,  3).  the availability of self-contained breathing apparatus (SCBA) worn by the operators during connection and disconnection of the chlorine supply,  4).  employee training in operations and maintenance with emphasis 
on awareness of the hazardous and toxic properties of chlorine,  5).  Participation of the Town of Orange Park Fire Chief and Clay County HazMat team in site safety evaluations. 
The Town of Orange Park has in use policies, procedures and systems as part of their prevention program.  The program addresses each of the EPA Program level 3 listed 12 elements, plus RMP elements needed to implement the program, and the like elements in place in the plants' OSHA PSM program.  These are maintained in the Town of Orange Park DMS document control system under the Key Document listed below: 
Element Title    EPA 68 #    OSHA 1910-119 # 
7 Management System    15    (a&e) 
7 Process safety information    65    ( d ) 
7 Process hazard analysis    67    ( e ) 
7 Operating procedures    69    ( f ) 
7 Training    71    ( g ) 
7 Mechanical integrity    73    ( j ) 
7 Management of change    75    ( l ) 
7 Pre-startup review    77    ( i ) 
7 Compliance audits    79    ( o ) 
7 Incident investigation    81    ( m ) 
7 Employee participation    83    ( c ) 
7 Hot work permit    85    ( k ) 
7 
Contractors    87    ( h ) 
7 Emergency Response    95    (n) 
7 Trade Secrets    N/A    ( q ) 
The Town of Orange Park is in compliance with the OSHA PSM elements, which are like the RMP elements (above).  The program is tailored to the Town of Orange Park facility and to the emergency response services available in the Town of Orange Park, Florida community.  Finally, the plant is in compliance with the EPA Emergency Response Program requirements. 
3.1. MANAGEMENT SYSTEM  68.15 
The Town of Orange Park has a management system to oversee the implementation and ongoing use of the RMP elements.  This program along with other the Town of Orange Park policies is intended to eliminate and/or reduce the potential for a hazardous chemical release at the Town of Orange Park, FL plant. The Town of Orange Park Manager is responsible for and leads the Management Team.  The organization and lines of responsibility are defined in the organization included in the RMP Report.  All responsible staff related to the RMP an 
d PSM programs are listed. Key RMP managers that report to Town Manager include the Public Works Director and the Public Safety Director.  The Public Works Director has the overall responsibility for implementation of the RMP program. Respective responsibilities are defined in the Town of Orange Park Contingency Plan (Emergency Response Plan), and the Applicability P&P, plus the Employee Participation P&P. 
 
3.2. SAFETY INFORMATION  (68.65) 
Safety information is provided below as follows: This information was used in performing the hazard analysis as part of the PSM program.  It is also listed below. 
3.2.1. MATERIAL SAFETY DATA SHEET (MSDS) 
The chlorine MSDS is provided by the vendor supplying chlorine to the Town of Orange Park.  It is in compliance with 29 CFR 1910.1200 (g). The chlorine MSDS is included in Appendix 7.3. Chlorine is an EPA-listed, toxic chemical.  It is also an OSHA-listed, toxic chemical.  It is an irritant and it is corrosive.  Chlorine is a halogen with the formu 
la Cl2.  It is a chlorinating or oxidizing agent that is not flammable (it supports combustion).  It has a 1 ppm OSHA ceiling Permissible Exposure Limit (PEL) and a NFPA health rating of 4, severe; with immediate and delayed health hazards.  Chlorine is not a carcinogen.  It is reactive with water and other chemicals when inadvertently mixed.  It is corrosive and is chemically stable. 
3.2.2. PROCESS TECHNOLOGY 
3.2.2.1. The Town of Orange Park maintains detailed accurate information on the technology of the chlorine process. 
The Town of Orange Park chlorine process was installed as part of the process of treating water to make it suitable for public consumption and to treat the wastewater effluent before it is discharged to the receiving waters.  The chlorine is received, stored and distributed by two process control systems.  One system feeds the wastewater water treatment plants, while the other feeds the water treatment plant.  The wastewater system is located in the main chlorine bu 
ilding which is also the storage and receiving area.  The water system is located in the chlorine room of the water treatment plant. Two individual chlorine cylinders on individual weigh stations are used one at a time. The two cylinders are connected to the distribution systems.  The system then feeds to:  
7 Three chlorinators for the wastewater system, one for each plant and, 
7 Four chlorinators for the water treatment plant, one for each high service pump and one to the aerator. 
These chlorinators inject chlorine into the plant water.  This water absorbs the chlorine, which reacts to hydro and hyper chloric acid that the chlorine gas is taken from the containers. The chlorinators for the wastewater treatment plants are automatically proportioned to the flow at the plants.  The chlorinators at the water treatment plant are manually adjusted as required to obtain required residual downstream of the distribution system. Chlorine gas is feed through a combination of P.V.C and special pa 
raflex piping from the chlorine cylinders to the chlorinators and then to the injectors.  The chlorine gas piping for the wastewater plant injectors is located inside the main chlorine building.  However, the chlorine gas piping for the water treatment plant injectors extends from the main chlorine building to the water treatment plant chlorine room.  Hence the RMP boundary consists of both the main chlorine building and the water treatment plant building. 
3.2.2.2. A block flow diagram shows the major components and flow of the system. 
3.2.2.3. First, chlorine evaporates in the storage cylinders and remains as gas in the system. The chlorine undergoes no chemical reaction as it leaves the container.  The vacuum regulator check unit attached to the one-ton container is a vacuum activated unit.  Thus if there is no vacuum, the valves do not open.  This is a safe system, which reduces the possibility of a chlorine release.  Next the chlorine leaving the regulator is under vacuum pressure  
(less than one atmosphere) and its flow rate is controlled.  Chlorine gas finally is drawn into the injector where is mixes and devolves/ionizes and reacts with the water.  The chlorine ionizes and forms acids which complex with impurities.  A 1 to 3 ppm residual of free chlorine ions is required in drinking water to ensure the highest quality potable water.  The Town of Orange Park following industry guidelines and takes great care to prevent unwanted reaction with chlorine and other substances, especially water.  (Note: moisture even in the air reacts with chlorine to form acid, which causes corrosion). 
3.2.2.4. The maximum intended inventory for chlorine is 10,000 lbs. It is stored in five DOT-approved one-ton cylinders.  A maximum of two containers are connected to the two chlorine distribution systems at one time.  Only one of these is in service.  When the in service container is empty, The automatic switchover unit switches and begins to draw chlorine form the stand by container 
.  The operator manually shuts the valve off, of the empty container after the automatic switchover has occurred. The empty container is then replaced with a full one.  The containers are separately piped up to the switchover device without interconnections between the containers. 
3.2.2.5. The safe upper and lower units.  The chlorine containers and feed yoke regulator assembly pressure varies from several to 140 psig depending on the temperature and amount of chlorine in a container.  The DOT-approved containers have a pressure rating of 500 psig. The chlorine gas at container pressure is drawn from the container through the regulator, through the controller by the vacuum created by the injector.  The entire system down stream of the regulator is under vacuum.  Thus if a leak in the piping occurs, air is drawn into the system preventing a chlorine release.  The chlorine system operating temperature is ambient.  The chlorinator system for the wastewater system precisely controls the fl 
ow rate to the wastewater plant feed systems.  The flow rate is monitored on the control panel and process unit for each of these systems. The feed rate for the chlorinators at the water treatment plant are manually controlled.  Also the chlorine content of the finished water and wastewater is manually monitored.  If the chlorine level varies outside the upper or lower the operator changes the feed rate at the chlorinators.  
3.2.2.6. The Town of Orange Park used the HazOp for the chlorine system to evaluate the consequence of deviation from design.  This information is also included in the operating procedure and throughout maintenance and design consideration. 
3.2.3. EQUIPMENT AND DESIGN SPECIFICATIONS  
The chlorine process is designed in compliance with the Chlorine Institute's guidelines as well as recognized and generally accepted good engineering practices.  The design and operation of the chlorine system and its support equipment adheres to or exceeds the guidelines of the Chlor 
ine Institute. These are presented in the Technical Data Sheets included in the Process Safety Information maintained by the plant. 
3.2.3.1. The chlorine system materials of construction meet or exceed industry requirements.  The DOT containers are steel and all interconnecting high pressure piping is steel which is corrosion resistance and pressure rating for high pressure chlorine systems. The vacuum system is made of PVC pipe and filters, plus flex tubing which are compatible with chlorine. 
3.2.3.2. The system piping and instrument drawing are detailed.  They are developed and checked for accuracy prior to construction.  Finally, they are maintained current by staff review. 
3.2.3.3. System and facility design.  The specially designed chlorination system utilities and building were designed in conformance with the following Codes and Standards: This code is listed on the "Facility Design Standard Table". 
3.2.3.4. Process Safety Information Updating.  The Town of Orange Park updates t 
his safety information if a change occurs that makes the information inaccurate.  The information is corrected.  This is accomplished by employee involvement, audits of the procedures, etc. All of this is controlled by the Management of Change Procedures and the DMS document control system in place. 
Facility Design Standards Table 
Equipment    Code/Standard    abbreviation  
Electrical     National Electrical Code    (NEC) 
Piping    American Society Of Mechanical Engineers/American National Standards Institute, Chlorine Institute    (ASME/ANSI) 
Structures    Uniform Building Code-American Institute of Steel Construction    (UBC) (AISC) 
Ventilation    American Society of Heating, Refrigeration and Air Conditioning Engineers     (ASHRAE) 
Concrete    American Society for Testing Materials     (ASTM) 
Other General    General Uniform Fire Code     (UFC) 
 
3.2.3.5. The system material and energy balance for this process demonstrates chlorine evaporation and flow through the system. 
3.2.3.6. Safety Systems: The Town of Orange Park's d 
esign includes many safety systems.  The building, in which the system is situated, is designed to secure the system or control entry to the building. The Town of Orange Park maintains eyewashes and safety showers near the chlorine area.  Finally, chlorine detectors and alarm systems are used to sample the air in the chlorine room.  An alarm warning is sounded locally within the facility if the level exceeds 1 ppm. 
3.3. HAZARD REVIEW  (68.67)     
A review of the hazards associated with the chlorine facility process and procedures was performed on 6/2/99 using the HAZOP procedure.  (It is included in the RMP Technical Document)  Other applicable items from other sections are referenced below.  The analysis was conducted by a team of experts in both operations engineering and safety. The following required items were identified: 
3.3.1. The hazards associated with chlorine and the chlorine process (MSDS Appended to this report). 
3.3.2. Possibility of equipment malfunctions or human errors th 
at could cause an accidental release (Located in the PSM/RMP Prevention Program Document). 
3.3.3. The safeguards used or needed to control the hazards or prevent equipment malfunction or human error. Process Safety Information and Operating Procedures.  (PSM/ RMP Prevention Program). 
3.3.4. Steps used or needed to detect or monitor releases of Emergency Response and Operating Procedure of the PSM/RMP Prevention Program Document. 
3.3.5. All equipment was inspected during the hazard review.  It was determined that the chlorine facility was designed, built, and operated in accordance with all applicable codes and industrial guidelines (See the HazOp Report). 
3.3.6. The results of the hazard review were documented and are detailed in each HazOp report.  (Included in the PSM/RMP Technical Document). 
3.3.7. The hazard review is updated at least once every five years.  Also, The Town of Orange Park uses a strict Management of Change Procedure. Thus, a Hazards Operability Study is conducted wh 
enever a major change in the process safety information occurs.  All issues identified in the review are resolved before the startup of the changed process occurs. Finally, all documents are updated and the affected employees and contractors are trained in the modified procedures.  The Town of Orange Park documents the HazOp findings in its report.  These findings are resolved and results documented in a timely manner.  These HazOp studies are conducted prior to modification and/or at least every five years. All documents related to the HazOp are maintained in the DMS document system and Technology for the life of this process. 
3.4. OPERATING PROCEDURES (68.96) 
The Town of Orange Park has prepared written procedures that provide clear instructions for steps to safely conducting activities associated with the chlorine process.  The Operating Procedures are consistent with the applicable safety information.  The following are parts of the operating procedures included in The Town of Ora 
nge Park's DMS document system for the Operation and Maintenance of Chlorine systems:  
3.4.1. Steps for each phase of operation 
3.4.1.1. Initial startup; 
3.4.1.2. Normal operations; 
3.4.1.3. Emergency shutdown; 
3.4.1.4. Emergency operations; 
3.4.1.5. Normal shutdown; 
3.4.1.6. Startup following a normal shutdown; 
3.4.1.7. Startup following a emergency shutdown or a major change that requires a hazard review; 
3.4.1.8. Temporary operations; 
3.4.1.9. Consequences of deviations and steps required to correct or avoid deviations; and 
3.4.1.10. Equipment inspections, testing and calibration. 
The Town of Orange Park updates these operating procedures on an ongoing basis as necessary.  At a minimum once per year these are reviewed and accuracy certified.  This is covered in detail in the Management of Change section below.  
3.4.2. Operating Limits 
Within the operating procedures are the operating limits of the chlorine process.  Details are listed, plus steps to avoid or correct deviations. 
 
 
3.4.3. Safety and Health Considerations 
The Town of Orange Park procedures includes safety and health information excerpts from the MSDS of chlorine.  Also included are: precautions to prevent exposure, control measures if contacted by chlorine including safety showers and respiratory protections. 
The building is designed for a maximum of five containers.  Operating procedures reflects the purchase and inventory control requirements.   
3.4.4. All maintenance and operation of safety systems are listed in the operating procedures.  It includes alarms, vent controls, etc. 
3.4.5. The operating procedures are both reviewed and written by operators of the system.  These procedures are kept in the operator's laboratory office and maintained by the DMS document system. 
3.4.6. The Town of Orange Park has in place, safe work procedures for the control of hazards.  Those in place that apply to the chlorine system include: lockout/tag-out, confined space entry, opening equipment and piping, cont 
rol of entry into the facility as well as the chlorine area. The above applies to the Town of Orange Park staff and contractors. 
3.5. TRAINING (68.71) 
3.5.1. INITIAL TRAINING 
The Town of Orange Park ensures that each employee presently operating or monitoring the chlorine process, and each employee newly-assigned to this process have been properly trained or tested competent in the operating procedures listed above that pertain to their duties.  The Town of Orange Park employee training documentation files include written certification for each employee assigned to operate or monitor the chlorine process. This ensures that the employee has the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as provided in the operating and maintenance procedures. 
3.5.2. REFRESHER TRAINING 
Refresher training for PSM and RMP is provided every three years or as a needed.  Many safety critical areas are retrained on an annual basis.  This training is provided 
to each employee operating or monitoring the chlorine process to ensure that the employee understands and adheres to the current operating procedures of the process.  This frequency of refresher training was determined by the Town of Orange Park, in consultation with the employees operating the process.  It meets or exceeds by three times more frequent then the minimum EPA and OSHA requirements. 
The Town of Orange Park ensures that operators are trained for any updated on new procedures prior to startup of a modified system.  The Town of Orange Park training program is further discussed in the PSM/RMP Prevention Program Document. 
3.6. MECHANICAL INTEGRITY/MAINTENANCE  (68.73) 
3.6.1. APPLICATION 
The entire chlorine system included in both the RMP and PSM programs are subject to the Town of Orange Park's Mechanical Integrity Program.  The items included are depicted in the P&ID for the chlorine process as well as the utilities that support the chlorine system.  These items are tabulat 
ed on the equipment lists and include: 
3.6.1.1. Pressure vessels and storage tanks; (containers) 
3.6.1.2. Piping systems (including piping components such as valves); 
3.6.1.3. Relief and vent systems and devices; 
3.6.1.4. Controls (including monitoring devices and sensors, alarms, and interlocks), and  
3.6.1.5. All equipment identified in the HazOp as critical to the chlorine system. 
3.6.2. WRITTEN PROCEDURES 
The Town of Orange Park has prepared and implemented written procedures to maintain the on-going mechanical integrity of the chlorine process equipment. Some procedures or instructions were provided by chlorination process equipment vendors.  All the Town of Orange Park procedures are maintained in the DCM document control system.   
3.6.3. TRAINING 
The Town of Orange Park has trained each operator involved in maintaining the on-going mechanical integrity of the chlorine process.  To ensure that the employee can perform the job tasks in a safe manner, each employee (operator) was 
trained in the hazards of the process, in how to avoid or correct unsafe conditions, and in the procedures applicable to the employee's job tasks. 
The Town of Orange Park does use outside maintenance contractors, as needed, for annual as well as other chlorine system maintenance. The safety performance of contractors are evaluated when selecting contractors to work in or around the chlorine system.  The Town of Orange Park also verifies that any such contractors are trained to safely perform the required maintenance procedures  (Refer to the Contractors Section below).   
3.6.4. INSPECTION AND TESTING  
The Town of Orange Park performs inspections, calibrations, and tests on chlorine process and safety equipment.  Inspection and testing procedures follow manufacturer specifications and/or recognized and generally accepted good engineering practices.  The frequency of inspections of process equipment is consistent with the applicable manufacturers' recommendations, industry standards o 
r codes, good engineering practices, and prior operating experience.  The frequency of maintenance procedures and inspections, tests, and calibrations are further described in the PSM/ RMP Mechanical Integrity Document. 
3.6.5. EQUIPMENT DEFICIENCIES 
Equipment deficiencies are corrected immediately or as soon as practical. The Town of Orange Park adheres to strict equipment specifications when correcting or repairing deficiencies.  Deficient equipment, which would present a significant hazard, is shut down until the deficiency is corrected. 
3.6.6. QUALITY ASSURANCE 
3.6.6.1. In the construction of new plants and or equipment, the Town of Orange Park assures via inspection and shake down, check out, that equipment as fabricated is suitable for the process application for which they are used. 
3.6.6.2. The Town of Orange Park ensures appropriate checks and inspections are performed to assure that equipment is installed properly and consistent with design specifications and the manufacturer 
's instructions. 
3.6.6.3. The Town of Orange Park assures that maintenance materials, spare parts and equipment are suitable for the process application for which they are used. 
3.7. MANAGEMENT OF CHANGE  (68.75) 
3.7.1. WRITTEN PROCEDURES 
The Town of Orange Park develops and implements written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and, changes to stationary sources that affect the chlorine process. 
The procedures address the following considerations prior to any change: 
3.7.1.1. The technical basis for the proposed change; 
3.7.1.2. Impact of change on safety and health; 
3.7.1.3. Modifications to operating procedures; 
3.7.1.4. Necessary time period for the change; and, 
3.7.1.5. Authorization requirements for the proposed change. 
3.7.2. EMPLOYEE INVOLVEMENT 
Employees involved in operating a process, and maintenance or contract employees whose job tasks are affected by a change in the process are in 
formed of, and trained in, the change prior to start-up of the process or affected part of the process. 
3.7.3. PROCESS SAFETY INFORMATION 
If a change covered by this paragraph results in a change in the process safety information required, it is updated accordingly. 
3.7.4. OPERATING PROCEDURES 
If a change covered by this paragraph results in a change in the operating procedures or practices required, such procedures or practices are updated accordingly. 
3.8. PRE-STARTUP REVIEW (68.77) 
3.8.1. APPLICATION 
The Town of Orange Park performs a pre-startup safety review for new and modified covered processes.  The Town of Orange Park uses a detailed review procedure checklist tailored to either a new or modified unit. 
3.8.2. REQUIREMENTS CONFIRMATION 
The review conducted before chlorine enters the process will include at a minimum, the following items. 
3.8.2.1. Construction and equipment is per design specifications. 
3.8.2.2. Safety, operation, maintenance and emergency procedures are in  
place and adequate. 
3.8.2.3. For a new or modified process the hazard analysis is performed, the recommendations are resolved and implemented before start up. 
3.8.2.4. For a modified process, the management of change procedures have been followed. 
3.8.2.5. Employee training is completed by each person involved in the operation(s). 
3.9. AUDITS (68.79)  
3.9.1. APPLICATION 
The Town of Orange Park has conducted an audit of compliance per OSHA PSM requirements at least every three years.  The Town of Orange Park will continue these audits which also comply with the RMP's Program Prevention Level 3 requirements.  To date, The Town of Orange Park has conducted one audit.  The audit evaluated and verified that the procedures and practices developed are adequate, current, and are being followed.  Auditing and inspecting procedures are also discussed in the PSM Documents. 
3.9.2. CERTIFICATION 
The Town of Orange Park management certifies that they have evaluated their compliance with the provisi 
ons of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed. 
3.9.3. AUDIT PROTOCOL 
The compliance audit is conducted by at least one person knowledgeable in the process.  Plus, the audit follows the PSM and EPA prevention program elements to ensure each area is documented to be in compliance.  
The Town of Orange Park prepares a written report of the audit findings.  The last report was conducted April 21, 1999. 
3.9.4. FINDINGS AND RESPONSE 
The Town of Orange Park promptly determines and documents an appropriate response to each of the findings of the compliance audit. 
3.9.5. FINDINGS RESOLUTION 
The Town of Orange Park documents that deficiencies have been corrected. Training is recorded in the employee's records.   
3.9.6. RECORDS RETENTION 
The Town of Orange Park plans to retain the two most recent compliance audit reports in the future.  Presently, the Town retains the audit conducted o 
n April 21, 1999. 
3.10. INCIDENT INVESTIGATION  (68.81) 
The Town of Orange Park investigates each incident, which resulted in, or could reasonably have resulted in a catastrophic release. 
3.10.1. TIMING 
The incident investigation is started as soon as possible but no later than 48 hours following the incident.  
3.10.2. TEAM MAKEUP 
A team will investigate the incident.  The team makeup is defined in The Town of Orange Park's Incident Investigation Policy and at a minimum includes: 
3.10.2.1. One person knowledgeable in the process 
3.10.2.2. One employee involved in the operation 
3.10.2.3. A contractor representative if a contractor was involved. 
3.10.3. REPORT STRUCTURE 
A written report is prepared at the conclusion of the investigation including:  
3.10.3.1. Date of incident; 
3.10.3.2. Date investigation began; 
3.10.3.3. A description of the incident; 
3.10.3.4. The factors that contributed to the incident, including the root cause; and 
3.10.3.5. Any recommendations resulting from the  
investigation. 
3.10.4. FINDINGS RESOLUTION 
The Town of Orange Park promptly addresses and resolves the investigation findings and recommendations.  All resolutions and corrective actions are documented. 
3.10.5. FINDINGS REVIEW 
The findings are reviewed with all personnel, whose job tasks are affected by the findings, including contractors. 
3.10.6. RECORDS RETENTION 
Investigation summaries are retained for at least five years.  If the accident involves personnel injury, the medical records are retained as long as the person is employed plus 30 years. 
3.11. EMPLOYEE PARTICIPATION (68.83) 
The Town of Orange Park requires employee participation as a key facet of the management of their facility.  Employees are the most valuable resource at the facility and their participation is essential to the continued safe production of quality the Town of Orange Park products. 
3.11.1. WRITTEN PLAN OF ACTION  
The Town of Orange Park developed and implemented a detailed plan to ensure employee part 
icipation.  This is described in detail in the Town of Orange Park's Process Safety Management Program. 
3.11.2. EMPLOYEE CONSULTATION  
The Town of Orange Park consults with employees and their representatives.  The Town of Orange Park includes employees in the Hazards Analysis and Area Safety Teams.  This ensures direct involvement in conducting and developing each element of process safety management required by both the OSHA and EPA rules.  
3.11.3. INFORMATION AVAILABILITY  
Employees and their representatives have a thorough process safety orientation so that they understand the basic requirement of the PSM and RMP standard.  The results of Process Hazards Analysis are discussed during shift meetings.  Finally the reports and findings from the Process Hazards Analysis, incident investigations and other safety-related material are made available through the safety meeting. 
3.12. HOT WORK PERMIT (68.85) 
The Town of Orange Park uses a Hot Work Permit that meets the requirements of the 
regulations.  OSHA 29 CFR 1910.119 and like EPA Requirements. 
3.12.1. PERMIT PROCEDURE  
A permit is required to be complied with and approved by the responsible operator in charge before working on any covered system. 
3.12.2. PERMIT REQUIREMENTS  
The permit requires documentation of all fire prevention activities per 29 CFR 1910.252(a), and must be in place at the facility before beginning the hot work and kept until the completion of the hot work.  Data included in the documentation are as follows: 
3.12.2.1. Date of authorized hot work,  
3.12.2.2. Identity of the object on which work will be performed. 
3.12.2.3. All safety measures required and in place. 
3.12.2.4. Authorization Signatures. 
3.13. CONTRACTORS   (68.87) 
The Town of Orange Park uses contractors to augment the work force.  A strong contractor policy is in place, which requires all contractors on site to adhere to the Town of Orange Park's policies and procedures.  Specifically, contractors working in areas covered in t 
he PSM/RMP follow the requirements below.   
3.13.1. APPLICATION  
This section applies to contractors performing maintenance or repair, turnaround, major renovation, delivery of covered chemical, or specialty work on or adjacent to a covered process.  It does not apply to contractors providing incidental services which do not influence process safety.  These include services such as janitorial work, food and drink services, laundry, delivery or other supply services. 
3.13.2. THE TOWN OF ORANGE PARK'S RESPONSIBILITIES  
3.13.2.1. It is the Town of Orange Park's policy that when selecting a contractor, information regarding the contractor's safety performance and programs are obtained and evaluated. 
3.13.2.2. The Town of Orange Park informs the contract owner or operator (contractor) of the known potential for fire, explosion, or toxic release hazards related to the contractor's work and the chlorination process. 
3.13.2.3. The Town of Orange Park explains to the contractors about the app 
licable provisions of the site emergency response plan and actions needed in the event of an emergency. 
3.13.2.4. The Town of Orange Park developed and implemented safe work practices including:  
3.13.2.4.1.  vessel entry,  
3.13.2.4.2.  hot work permit,  
3.13.2.4.3.  lock out/tag out,  
3.13.2.4.4.  breaking into chemical vessels and lines, 
3.13.2.4.5.  entry protocol to control the entrance, presence, and   exit of the contractors and their employees in covered  process areas. 
3.13.2.5. The Town of Orange Park periodically evaluates the performance of the contractors in fulfilling their obligations as specified above. 
3.13.3. CONTRACTOR RESPONSIBILITIES 
The Town of Orange Park requires that all contractors performing services on or near the covered process to comply with the Contractor Safety Program.  These requirements include the following: 
3.13.3.1. Certifies that each contract employee is trained in the work practices necessary to safely perform his/her job. 
3.13.3.2. Certify tha 
t each contract employee is instructed in the potential for fire, explosion, or toxic release hazards related to his/her job and the process, and the applicable provisions of the Town of Orange Park's emergency action plan. 
3.13.3.3. Document that each contract employee has received and understood the training required by the Contractor Program, including a record which contains the identity of the contract employee, the date of training, and the means used to verify that the employee understood the training. 
3.13.3.4. Assure that each contract employee follows the safety rules of Ash Street Facility including the safe work practices required by the Town of Orange Park Contractor Policy and EPA and OSHA rules. 
3.13.3.5. Inform the Town of Orange Park of any unique hazards presented by the contractor's work or if any hazards are discovered. 
4. EMERGENCY RESPONSE   (SUBPART E) 
The Town of Orange Park emergency response policy involves the preparation of response plans.  The Emergency Re 
sponse Procedure is specifically tailored to this site, the chlorine process, and to the emergency response services available in the Town of Orange Park, Florida community.  The Town of Orange Park Emergency Response Plan is in compliance with the EPA Emergency Response Program requirements. 
4.1. APPLICABILITY  (68.90) 
The Town of Orange Park is an operations first responder: The Town of Orange Park employees respond to chlorine accidental releases.  The Town of Orange Park, on determination of the extent of an emergency, either resolves it internally if no local public or environmental impact is possible, or notifies and coordinates with the local emergency response teams in Clay County, Florida.  This includes both the Town of Orange Park Fire Department and the Clay County LEPC.  The closest HazMat team, which responds, is the Green Cove Springs, Florida team at (904) 269-1047. 
The Town of Orange Park has developed and implemented a comprehensive Emergency Response Procedure for th 
e purpose of protecting public health, the environment, and employees.  The following elements are included: 
4.1.1. EMERGENCY RESPONSE PROCEDURE  (68.95) 
An emergency response plan, maintained at the plant contains: 
4.1.1.1. Procedures for informing the public and local emergency response agencies about accidental releases; 
4.1.1.2. Evacuation procedure to a minimum of 1.3 miles with a 4 mile evacuation recommendation at the discretion of the incident commander responding to the release; 
4.1.1.3. Documentation of proper first-aid and emergency medical treatment necessary to treat accidental human exposures; 
4.1.1.4. Procedures and measures for emergency response after an accidental chlorine release; 
4.1.1.5. Procedures for the use, inspection, testing and maintenance of emergency response equipment; 
4.1.1.6. Training in all relevant procedures for employees involved with the chlorine process; 
4.1.1.7. Procedures to review and update, as appropriate, the emergency response plan to ens 
ure that the employees are informed of changes. The facility's Emergency Response Plan is coordinated (reviewed) with the Town of Orange Park Fire Department, which received a copy of this report.  This agency is a member of the Local Emergency Response Planning Committee (LEPC), and was involved with the development of a community-wide emergency response plan; 
4.1.1.8. Emergency response procedures are discussed in the Town of Orange Park Contingency Plan (Emergency Response Plan) of the PSM/RMP Document, which includes an emergency response decision tree and a notification plan.
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