Claude H. Dyal Water Treatment Plant - Executive Summary

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CITY OF COCOA 
CLAUDE H. DYAL WATER TREATMENT PLANT 
RMP Executive Summary 
 
 
1.0 Introduction and Background 
 
The USEPA's Clean Air Act Amendments of 1990 included provisions that require facilities that use certain substances to develop a plan to reduce the likelihood of an accidental release of the substances to the atmosphere and reduce the likelihood of serious harm to the public and the environment.  The requirements of this plan, commonly referred to as a Risk Management Plan (RMP), are detailed and codified in 40 CFR Part 68. 
 
The City of Cocoa's Claude H. Dyal Water Treatment Plant (WTP) treats and supplies potable water to the City's service area. Chlorine is used to disinfect the potablewater supply.  Chlorine is stored in quantities above the regulatory thresholds at which a RMP or OSHA Process Safety Management Program (PSM) is required. The RMP consists of three compliance programs, each with progressively stricter compliance standards. The chlorination process at the WTP is 
subject to Program 3, the most stringent of the three programs, because the WTP is subject to the OSHA PSM Program and a worst-case release of chlorine could affect the public. 
 
The RMP consists of three major parts. The first part is the "Hazard Assessment". The Hazard Assessment is done to determine the effects that a release of a regulated substance could have on the public. The second part is a "Prevention Program" that consists of 12 elements designed to improve the system safety and decrease the likelihood of a release. The third part is the "Emergency Response Program", which develops a plan for dealing with a release in the unlikely event that one would occur. Because the regulations are very similar, the Prevention Program and the Emergency Response Program also serve as the OSHA PSM plan, and this document is therefore is referred to as the RMP/PSM plan. 
 
2.0 Hazard Assessment 
 
A hazard assessment was performed to determine the effects a release would have on the public. For 
chlorine, the distance a set endpoint concentration of the gas would travel must be determined.  In addition, an estimate of the population that could be affected by a release of chlorine was determined, and sensitive receptors such as hospitals, schools, and nursing homes were identified. The hazard assessment considers two release scenarios-a "worst case" and an "alternative case" and also compiles the five-year accident history for the WTP chlorine system. 
 
2.1 Worst-Case Scenario 
 
The regulations require the development of a worst-case release scenario based on conservative assumptions. For example, it is required to assume that the entire contents of the largest single container of chlorine will be released over 10 minutes. This is unlikely to occur since the properties of chlorine would cause a freeze and thaw cycle to occur at the leak, which would slow the release.  The worst-case scenario also requires that conservative atmospheric conditions be assumed which results in a lar 
ge area of impact. 
 
The hazard assessment requires that the "toxic endpoint" or distance from the point of release to a location at which the chemical concentration equals or exceeds a certain concentration must be determined. That concentration is defined as the maximum airborne concentration below which individuals could be exposed for up to 1 hour without experiencing or developing irreversible or other serious health effects, or symptoms that could impair an individual's ability to take protective action. For chlorine, the toxic endpoint concentration is set at 3 parts per million (ppm) by volume.  Because the cloud from a chlorine leak would disperse relatively quickly, an individual at a toxic endpoint would be exposed to the exposure limit concentration for much less than the 1 hour assumed by the limit. In addition, the exposure limit concentrations result in relatively minor health effects. Therefore, an individual at the toxic endpoint would be affected less than the results  
of the worst-case scenario may imply.  For the Dyal WTP, the estimated distance to the toxic endpoint is 3 miles for the worst case scenario based on the EPA RMP*Comp Software Program. 
 
2.2 Alternative Scenario 
 
The RMP rule also requires that at least one alternative release scenario be evaluated for chlorine. The alternative scenarios reflect a type of release that is more likely to occur compared to the worst-case scenario. It assumes local, typical meteorology, which is more realistic than the conservative meteorological conditions that must be assumed for the worst-case scenario. The alternative release scenario for chlorine was a release of chemical based on a vacuum regulator release.  This alternative release scenario is considered to be more representative of the effects likely in the event of a release. For the Dyal WTP, the estimated distance to the toxic endpoint is 0.20 miles for the alternative scenario based on the EPA RMP*Comp Software Program. 
 
2.3 Population and Envir 
onmental Receptors Potentially Exposed to Accidental Releases 
 
For the worst case and alternative case scenarios, the RMP regulations require an estimation of the residential population within the toxic endpoint circle. Additionally, the presence of public and environmental receptors such as schools, hospitals, prisons, public recreational areas, and major industrial or commercial areas must be identified in the Risk Management Plan.   The Dyal WTP is located in an area surrounded by the Deseret Ranch Property.  The Deseret Ranch is one of the largest single properties in the State of Florida and is several hundreds of thousands of acres in size. 
 
The population affected by each accidental release was determined using Landviewb III, a computer database program developed by the U.S. Department of Commerce, Bureau of the Census.  Landview III estimates populations within a specified radius by proportioning each census block according to the percentage that participates in the toxic endpo 
int circle.  The Dyal WTP is located within a census block with a large area since it is in a rural setting.  Landview calculates the density of the population within a census block and applies that to the area within the toxic endpoint circle to determine population.  Therefore, this is not an exact population count for the Dyal WTP release scenarios.  The estimate of 381 people for the worst case release scenario appears to be greatly exaggerated upon review of maps and satellite photos.  There are a few residential dwellings near the Dyal WTP for which the City has on a list to notify in the event of an emergency.  For the alternative release scenario, effected population was estimated at 2 people. 
 
Landview III also contains information regarding residences, schools, and hospitals.  However, the database was compiled in 1991, and may not contain the most current data. Site inspections, the Microsoft Terraserver Website, and communication with local plant personnel were incorporated 
to identify additional public and environmental receptors within the toxic endpoints.  There appears to be no public or environmental receptors within the worst case or alternative toxic endpoints. 
 
2.4 Five-Year Accident History 
 
There were no reportable accidents at the Dyal WTP between June 21, 1994, and the present date. 
 
3.0 Prevention Program 
 
The prevention program consists of 12 elements designed to improve the system safety and decrease the likelihood of a release. 
 
3.1 Employee Participation 
 
The participation of the Cocoa WTP staff in preparing the RMP/PSM program was critical to the program's successful implementation. Employee participation is valuable because it increases the safety awareness of the staff and it allows the staff's experience in operating and maintaining the processes to be incorporated into the plan. 
 
WTP staff participated in the development of the Prevention Program through a series of meetings and workshops. Another way that the WTP staff participated 
in the development of the RMP/PSM was the Process Hazard Analysis that is described below.  WTP staff received RMP/PSM awareness training that instructed staff on how the RMP/PSM requirements may impact their jobs. Staff who operate and maintain the RMP/PSM processes were trained in how to safely maintain and operate the processes. 
 
3.2 Process Safety Information 
 
The RMP regulations require that information concerning process chemicals, technology, and equipment be compiled as part of a RMP program. Emergency response planners can use such information to develop training programs and procedures, or as a general resource. The information will be supplied to contractors who will work in the process area as part of the requirements outlined in the Contractors element.  Process safety information was compiled as required by the RMP regulations.  
 
3.3 Process Hazard Analysis 
 
A process hazard analysis (PHA) was conducted systematically to evaluate potential causes and consequences of acci 
dental releases. This information was used by WTP staff to improve safety and reduce the consequences of accidental releases. Equipment, instrumentation, utilities, human actions, and external factors that might affect the process were the focus of the PHAs that were performed for the chlorine process. 
 
The chlorine PHA was conducted by an interdisciplinary team of WTP staff familiar with the process operation and maintenance and plant management. The PHA was done using the "What-If" method. Based on the results of the PHA, some procedural changes in  process safety management procedures that would improve the overall safety of the WTP were identified.  These changes will be adopted by the WTP and incorporated as part of the overall Process Safety Management Program.  
 
3.4 Operating Procedures 
 
Operating procedures for the chlorination processe have been developed as part of the RPM/PSM. Written operating procedures assure continuous, efficient, and safe operation of the facility. The  
goal of the operating procedures is to provide clear instructions to safely operate the process. Operating procedures are also used to train new employees and to provide refresher training for existing staff. 
 
The detailed operating procedures include startup and shutdown procedures. The procedures describe how the system should be operated in order to minimize the chances of an accidental release.  
 
3.5 Training 
 
An effective RMP/PSM training program can significantly reduce the number and severity of accidental release incidences. Employees involved in operating or maintaining the chlorination process must receive training that includes applicable operating and maintenance procedures and an overview of the process. Training must emphasize safety and health hazards and safe work practices. 
 
Cocoa WTP staff have received initial training on the operations and maintenance of the regulated processes, an overview of each of the RMP/PSM plan elements, and the procedures that must be follow 
ed to comply with the requirements of the RMP/PSM plan.  Refresher process operation training must be provided at least every 3 years. Refresher training for emergency response is conducted annually. 
 
3.6 Contractors 
 
The WTP must make contractors aware of the known hazards of the chlorine process related to the contractors' work. In addition, the WTP must make contractors aware of the applicable elements of its emergency response plan. The WTP should screen contractors for ones who can perform work on or adjacent to the chlorine process without compromising the safety and health of employees at the facility. 
 
Before allowing a contractor to work on or adjacent to the chlorine process, the WTP must obtain and evaluate information regarding the contractor's safety performance and programs. When a contract involving work on or adjacent to the chlorine process is to be bid, the bidding procedures must ensure that contractor safety management requirements are met. If a contractor is to wo 
rk in or adjacent to any covered processes, a safety briefing, to make the contractor aware of the WTP's RMP/PSM plan requirements, must be conducted before work begins. Upon arriving at the plant for the first time to perform work, the contractor will be presented a Contractor Safety Checklist Form that must be read and signed. All contractors should receive an Emergency Response Summary Sheet.  
 
3.7 Pre-startup Review 
 
A pre-startup safety review must be conducted for any new covered process or for significant modifications to the existing chlorine process that necessitate a change in the process safety information. No new or significantly modified process will start up and no acutely hazardous chemicals will be introduced into such a process prior to the pre-startup safety review. The purpose of the pre-startup safety review is to ensure that the facility is ready to operate new and modified regulated processes safely.  
 
To initiate the pre-startup safety review, all updated element 
s of the Process Safety Management Plan are assembled for review. This includes all process safety information, process hazard analysis, operating procedures, employee training and mechanical integrity. A pre-startup safety review team completes a pre-startup checklist. The pre-startup safety review team should complete and sign a Pre-startup Safety Review Form. This form documents the process, and helps ensure that the review has been properly performed. The Pre-startup Safety Review Form must be authorized before startup. 
 
3.8 Mechanical Integrity 
 
An effective mechanical integrity program is one of the primary lines of defense against a release. The mechanical integrity program also addresses equipment testing and inspection, preventative maintenance schedules, and personnel training. The intent is to ensure that equipment used to process, store, or handle chlorine is maintained and installed to minimize the risk of releases. 
 
The WTP maintenance staff is currently implementing a ma 
intenance management system to store equipment information, generate and prioritize work orders, schedule preventative maintenance (PM), provide safety procedures for work orders, and maintain an inventory of parts and materials.  The system is scheduled to be in place by December 1999.  In addition to preventative maintenance, the WTP staff performs corrective maintenance in the event of equipment malfunction or breakdown. Work orders indicate what safety precautions must be followed including whether lockout/tagout or confined space entry provisions are applicable. The staff that carryout maintenance are all trained as part of the RMP/PSM. 
 
3.9 Hot Works Permits 
 
RMP/PSM regulations require employees and contractors to employ safe work practices when performing "hot work" in, on, or around the chlorine process. To ensure that hot work is done safely, a Hot Work Permit Program has been developed that requires a permit to be issued before hot work is performed. Hot work is defined as t 
he use of oxyacetylene torches, welding equipment, grinders, cutting, brazing, or similar flame- or spark-producing operations. 
 
The process of completing the hot work permit makes it necessary to identify the hazard, recognize what safeguards are appropriate, and then initiate the safeguards necessary to ensure a fire-safe workplace. Following the standards outline in this section aid in complying with the OSHA Hot Works Regulations (1910.252(a)). 
 
3.10 Management of Change 
 
A system for the proper management of changes and modifications to equipment, procedures, chemicals, and processing conditions is required under the RMP/PSM. Modifications to the chlorine system will be reviewed before they are implemented to determine if the modification would compromise system safety. An effective change management system will help minimize the chance for an accidental release. 
 
If a modification covered under RMP/PSM is made, its effects must be addressed, employees must be informed, and the wr 
itten procedures must be updated. The intent is to require that all modifications to equipment, procedures, and processing conditions other than "replacement in kind" be managed by identifying and reviewing them before implementation. A Management of Change Committee will evaluate any modifications that are covered under the RMP/PSM. The Management of Change Committee will complete a Management of Change Form that the Plant Superintendent will review and authorize prior to initiation of a covered change. 
 
3.11 Incident Investigation 
 
Each incident that resulted in or could reasonably have resulted in a catastrophic release of chlorine must be investigated. A process to identify the underlying causes of incidents and to implement procedures for preventing similar events has been developed. To investigate an incident, an investigation team will be established. As part of the investigation, an incident report will be prepared to recommend system changes. 
 
The investigation team should ask 
questions such as what equipment failed, which behavior failed, and which material leaked, reacted, or exploded. As part of the incident review, staff actions that may have contributed to the incident will also be reviewed. A determination will be made as to whether it is necessary to institute additional training for the employees to prevent the incident from occurring in the future. On the incident report form, the Plant Superintendent identifies which of the recommended system changes are approved for implementation. The incident investigation report and any changes resulting from the report will be reviewed with all staff members who operate and maintain the applicable system.  
 
3.12 Compliance Audit 
 
The Cocoa WTP is required to complete a compliance audit for the RMP/PSM program. The primary goals of conducting an internal compliance audit are to gather sufficient data to verify compliance with RMP/PSM requirements and good process safety practices, identify process safety defic 
iencies and develop corrective actions, and increase safety awareness among plant staff. 
 
The compliance audit methodology is modeled after OSHA's guidelines for conducting regulatory PSM compliance audits: Compliance Guidelines and Enforcement Procedures, OSHA Instruction CPL 2-2.45A (September 28, 1995). An internal compliance audit must be conducted at the plant at least once every 3 years for the chlorine process. A team that includes at least one person knowledgeable in the covered processes and an audit leader knowledgeable in RMP/PSM requirements and audit techniques will conduct the audits. The Plant Superintendent and the audit team will promptly determine an appropriate corrective action for each deficiency identified during the audit and document the corrective actions and the dates by which they must be taken. 
 
4.0 Emergency Response Program 
 
The Emergency Response Program develops a plan for dealing with a release. OSHA Process Safety Management regulation 29 CFR 1910.119( 
n) and EPA RMP regulation 40 CFR 68 Subpart E require that an Accidental Release Emergency Response Plan be prepared. The plan must be prepared in accordance with the provisions of another overlapping OSHA regulation-Employee Emergency Plans (29 CFR 1910.38(a)). In addition, provisions of the OSHA hazardous waste and emergency response standard, 29 CFR 1910.120 (q), must also be considered.  
 
The Emergency Planning and Response plan provides specific emergency response procedures for accidental releases of chlorine, and the city of Cocoa has coordinated with the Orange County Fire and Rescue Department concerning emergency planning. 
 
5.0 Planned Changes to Improve Safety 
 
The preparation of the RMP/PSM assisted with the identification of areas requiring improvements.  The City of Cocoa will incorporate some procedural changes including developing and/or modifying operating procedures for high wind events, visual inspection of equipment, and education of outside contractors.  Cocoa will 
also be implementing a maintenance management system, which will incorporate a preventive maintenance schedule for the chlorine process.  Additional components will be added to the Emergency Response Plan, as required by OSHA regulations, to ensure greater safety in the case of an emergency event.
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