Big Dry Creek Water Reclamation Facility - Executive Summary |
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Big Dry Creek Water Reclamation Facility RMP Plan Executive Summary Executive Summary This executive summary provides a brief overview of the Risk Management Program (RMP) and the associated policies at the Big Dry Creek Water Reclamation Facility owned and operated by the City of Westminster. Prevention and Response Policies The City of Westminster believes that it is important to provide a safe workplace to its employees and minimize the impact of its operations on the surrounding community and the environment. Accordingly, the City of Westminster has developed proactive safety and environmental programs, which are reliant upon active employee participation and management leadership and support. This same proactive philosophy was employed in the development and implementation of the Big Dry Creek Water Reclamation Facility RMP for the chlorine system. The City of Westminster has determined that the OSHA Process Safety Management standard will eventually apply to the personnel at the Big Dry Creek Water Reclamation Facility and therefore has prepared this RMP to comply with the RMP Program 3 requirements. By doing so, the City of Westminster affirms its proactive safety and environmental philosophy and acknowledges the inherent value of full RMP compliance. The RMP prevention program is arguably the most important element of the rule. Its program elements require the active participation of facility employees and management in conducting activities aimed at preventing accidental releases of regulated chemicals. If prevention activities could be completely successful, there would be no need for emergency response activities, since no releases would occur. Accordingly, a well-developed and properly-implemented prevention program will lower the possibility of an accidental release and minimize the consequences of a release should one occur. The City of Westminster takes an active role in preventing accidental releases at all of the facilities it operate s by ensuring that its employees are well-informed regarding the hazards associated with the regulated processes (e.g., chlorine at the Big Dry Creek Water Reclamation Facility) and actively participated in comprehensive process hazard analyses. The employees that work on the chlorine system are properly trained in the safe operation of the covered processes and the safe handling of treatment chemicals. They are aided in this work by complete, understandable system operating procedures. The City of Westminster management understands its duty to provide a safe working environment and to take measures to prevent accidents that may have an effect on the surrounding community. This understanding is reflected in procedures described and referenced in the Big Dry Creek Water Reclamation Facility RMP procedures and policies. As for emergency response, the City of Westminster has established and maintained procedures for emergency notification and response. These are reviewed with employ ees on a periodic basis and revised to accommodate changes in staffing when they occur. Stationary Source and Regulated Substances The Big Dry Creek Water Reclamation Facility is located at 13150 N. Huron, Adams County, Colorado. The Big Dry Creek Water Reclamation Facility utilizes chlorine to disinfect the water it treats prior to discharge to the Big Dry Creek. The Big Dry Creek Water Reclamation Facility treats the wastewater for the northern portion of Westminster. It is an activated sludge plant designated by the State of Colorado as a Class A plant. The Facility received an award from EPA for the best plant operating in Region VIII in 1986 and 1992. The Big Dry Creek Water Reclamation Facility utilizes chlorine as a biocide in the treatment of water. The chlorine is stored in one-ton containers with a maximum intended inventory of six containers (12,000 pounds) on site. Therefore, the Big Dry Creek Water Reclamation Facility is regulated under the RMP rule due to the vo lume of chlorine stored and used at the facility. Release Scenarios Worst-case and alternative release scenarios have been determined after careful review of the regulation and consideration of the storage vessel configuration at the facility. For the worst-case release scenario, the regulation is clear. The assumption is that a full one-ton container of chemical is released over a ten-minute period. No active mitigation may be considered. Worst-case meteorological conditions as specified in the RMP regulation are also assumed to be present. The release is also assumed to occur outdoors. For the alternative release scenario, the facility reviewed the consequences of a valve breaking off at the container connector during hookups in the storage area. No active mitigation was considered. Results of the off-site consequence analyses are described in Sections 2 and 3 of the RMP*Submit plan for the Big Dry Creek Water Reclamation Facility. Prevention Steps for Chlorine The preven tion program and chemical-specific prevention steps are described in detail in the Big Dry Creek Water Reclamation Facility RMP manual. The prevention program includes the following elements: ? Process safety information, which includes information pertaining to the hazards of chlorine in the process, process technology, and process equipment ? Process hazard analysis (PHA), which includes a systematic evaluation (by an employee team) of: the hazards of the chlorine process, identification of previous process incidents, engineering and administrative controls, consequences of failure of the engineering and administrative controls, facility siting, human factors, and possible safety and health effects of failure of controls ? Operating procedures, which include steps for each operating phase, operating limits, safety and health considerations, and safety systems and their functions ? Training for each Big Dry Creek Water Reclamation Facility employee involved in operating the chlo rine system ? Mechanical integrity procedures to maintain the on-going integrity of the chlorine process equipment ? Management of change procedures to manage changes (other than "replacements in kind") to the chlorine system ? Pre-startup safety review for additions or significant modifications to the chlorine process, or any new regulated chemical process ? Compliance audits at least every three years from 1999 to evaluate Big Dry Creek Water Reclamation Facility RMP compliance ? Incident investigation, to be conducted and documented for each incident that resulted in, or could have reasonably resulted in, a catastrophic release of chlorine from the Big Dry Creek Water Reclamation Facility ? Employee participation in the development and implementation of the Big Dry Creek Water Reclamation Facility RMP, and employee access to RMP information ? Hot work prohibition policy on or near the chlorine system when chlorine is present in the affected section of the process ? Contracto r management program, to ensure appropriate evaluation and selection of qualified contractors for work on or near the chlorine system, proper notification of contractors regarding known chlorine system hazards and the Big Dry Creek Water Reclamation Facility emergency evacuation plan, limited access to the chlorine process, and evaluation of contractor performance In addition to these elements, the chlorine storage room and chlorine injection room at the Big Dry Creek Water Reclamation Facility are equipped with chlorine leak detection devices that continuously monitor the air for chlorine gas. If the chlorine sensor detects a specified level, audio and visual alarms will be activated. The alarm system is maintained and tested on a regular basis to ensure proper operation should there be a chlorine release. Management of Change procedures will be used for the upgrades to the chlorine system. Accident History Within the five-year period prior to the submittal of this RMP, there we re no accidental releases of chlorine meeting the requirements of 40 CFR 68.42. Emergency Response Program This facility has established and maintains an emergency response program that is coordinated with local response agencies, including the Westminster Fire Department. The program is described in detail in the Big Dry Creek Water Reclamation Facility RMP manual and meets the requirements of 40 CFR 68.95, which include facility notification of emergency responders and evacuation. The goals of the program are to protect onsite employees from the hazardous effects of chemical releases and to minimize the effects of releases on the general public. The program is routinely reviewed and updated to reflect personnel and regulatory changes. Planned Changes for Improved Safety Ideas for changes to improve safety are actively sought from employees. Employee meetings that focus on safety issues are held regularly at the Big Dry Creek Water Reclamation Facility. Employees are encourag ed and trained to recognize hazards and to present ideas to eliminate them or to minimize the potential consequences of those hazards. As part of the development of the Big Dry Creek Water Reclamation Facility program, process hazard analyses were conducted with key employees to meet the prevention program requirements. During these sessions, recommendations were made for the purpose of improving safety and preventing accidental chemical releases. Each recommendation has been or will be considered for implementation. Though not all recommendations may be implemented, all will be considered. The exercise has provided all affected employees with a heightened awareness of safety issues related to the covered process. Several changes were made to the facility since the original RMP was developed in 1999 to improve safety and to accomodate the new "Reclaim Plant". The changes completed in 2000 include raising the level of the chlorine tanks and adding new scales in the storage room ; adding a second tethered air system; hanging valves from the ceiling and adding automatic shut-off systems that activate upon leak detection; adding chlorine lines from the existing facility to the new Reclaim Plant under Big Dry Creek; and adding two new chlorine feeders. The RMP has been modified to reflect the changes. All changes were designed with safety in mind and were analyzed in a second PHA conducted at the facility on November 30, 2000. |