City of Walla Walla Wastewater Treatment Facility - Executive Summary |
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The City of Walla Walla Wastewater Treatment Plant (WWTP) has quantities of chlorine and sulfur dioxide in excess of the threshold defined in 40 CFR 68 and Washington Administrative Code (WAC) 296-67; therefore, compliance with the regulations is necessary. Because the wastewater treatment plant is regulated by the Process Safety Management (PSM), the regulatory program for these processes is Program 3. Duke Engineering & Services, Inc. (DE&S), on behalf of the City of Walla Walla, has developed a city-wide Risk Management Program (RMP) in compliance with EPA's RMP requirements. TREATMENT PROCESS MODIFICATION Both chlorine and sulfur dioxide systems are scheduled for removal by December 1999. The replacement systems for the current regulated processes are the on-site generation system for chlorination and the sodium disulfide system for dechlorination. The new systems will not use the regulated chemicals listed in the Risk Management Program. IMPLEMENTATION PLAN DE&S has perfo rmed a thorough review of the existing program documentation against the requirements of 40 CFR 68 and WAC 296-67. The review determined some of the existing WWTP documentation and programs have, at least in part, satisfied the EPA RMP regulation. However, some additions and modifications were necessary. An implementation plan showing detailed tasks/subtasks and a recommended sequence of execution were provided in the Gaps Analysis Report, which is available at the WWTP. To achieve compliance with the requirements of the Risk Management Program, the implementation plan can be summarized according to the following steps: 7 DE&S has developed program documents, beginning with the management system procedures which provide the guidance, methodology and the format for developing other program documents. 7 The hazard assessment and prevention program elements were developed along parallel paths. These steps involved the majority of the time and resources required for completing the i nitial RMP, outlined in Section 1.3. 7 Following the completion of the hazard assessment and prevention program documents, the defined safeguards, procedures and training programs were used as a basis for emergency planning and coordination with the public and local emergency response organizations. 7 Following the development of program documents, the implementation began with documented training on management procedures, emergency response, operating procedures, and maintenance procedures. Full implementation carrying the program into everyday use is one of the most challenging aspects of compliance with the rule. This is the most critical for ensuring that compliance is maintained and the City of Walla Walla Wastewater Treatment Plant is operated as safely as possible. WWTP RISK MANAGEMENT PROGRAM The following element summaries are brief statements of the current WWTP Risk Management Program. 1.1 Management A formal management system for RMP is currently in place and do cumented via a formal management procedure that defines program element responsibilities and documentation requirements. The management procedure provides a good program overview. The control document is placed at a central location for WWTP's requirements relating to the RMP. 1.2 Hazard Assessment The hazard assessment has been performed including the worst case analyses, alternative case analyses, and a five-year accident history for the Wastewater Treatment plant. The modeling suggests the downwind distance to the EPA RMP worst case endpoint health criteria will reach 1.3 miles. The alternative release for chlorine and sulfur dioxide resulted in an endpoint distance of 0.1 miles. No release was found in the WWTP's five-year accident history. The worse case scenario is extremely unlikely and EPA does not expect it to be selected as the basis for emergency planning under the RMP rules. EPA suggests that emergency planning should focus on the alternative release, which is mo re likely to occur. The City of Walla Walla presented the worst case scenario in the Risk Management Program public meeting. The hazard assessment information is available to the public. The City of Walla Walla is prepared to explain to concerned citizens both the meaning of these results and what the city is doing to prevent such incidents through the Process Safety/Risk Management program. As recommended by EPA, the City of Walla Walla used the results from the alternative endpoint criteria for emergency planning and response. Should the worse case scenario occur, the City is prepared for rapid action in the effected areas. 1.3 Prevention Program 3 1.3.1 Process Safety Information The City of Walla Walla WWTP has kept up-to-date process safety information to successfully implement the PSM/RMP elements, including Process Hazards Analysis (PHA), training, emergency planning and response, management of change, incident investigation, and compliance audits. A management proced ure has been developed to ensure current written process safety information is developed and maintained in a format that provides easy access by employees, PHA teams, and auditors. 1.3.2 Process Hazards Analysis The WWTP/DE&S team has conducted a Process Hazard Analyses to identify, evaluate, and control the risk associated with the process hazards release scenarios at WWTP subject to the Washington Industrial Safety and Health Administration (WISHA) PSM and/or EPA RMP regulations. The overall purpose of the PHA is to comply with these regulations and to prevent or minimize the effects of a chemical release. 1.3.3 Standard Operating Procedures The City of Walla Walla WWTP has updated its Operating Procedures (OPs) and continues to maintain up-to-date, accurate, written OPs that provide clear instructions for all covered processes. Effective OPs, when combined with operator training, are instrumental in ensuring safe operation of the systems and preventing accidental releases. 1. 3.4 Training A formal training program has been developed which defines the training to be completed, contents of the training, three-year refresher training, and competency testing. The "on-the-job" initial training for new operators has been performed. The operating procedures will continue to be documented. 1.3.5 Mechanical Integrity Plant maintenance activities are tracked via a logbook. The maintenance request form is completed by the plant operator and signed off by the maintenance technician when the work is completed. The Tests/Inspections/ Maintenance (TIMs) schedule for the critical components of chlorine and sulfur dioxide systems has been developed to ensure the continued integrity of the regulated process equipment. The TIM's information, currently maintained in the plant files, will be tracked with the Computerized Maintenance Management System, which is in the process of being upgraded. The detailed maintenance procedures have been developed and training has b een implemented. 1.3.6 Management of Change A change review procedure has been developed to clearly define the necessary steps for any major process changes. In addition, the procedure identifies responsibilities for the process changes and required review form submittal. 1.3.7 Pre-Startup Safety Review The developed Pre-Startup Safety Review (PSSR) procedure includes specific identification of responsibilities and criteria for conducting the review. PSSR will also be performed in conjunction with the Management of Change procedure for major modifications. 1.3.8 Compliance Audits A compliance audit procedure has been developed to address the requirements of the RMP and to define a method for reporting, tracking, and resolving identified deficiencies. 1.3.9 Incident Investigation The current accident investigation procedure found in the City Safety and Health Manual meets most of the requirements. To address all regulatory documentation and recordkeeping requirements more c learly, an addition to the City's procedure has been developed. The addition defines the composition of the investigation team, provides space for team input on its evaluation beyond the initial supervisor's report, and encourages a more thorough identification of contributing and root causes. 1.3.10 Employee Participation The employee participation procedure provides the employees' right to access PHAs and all PSM/RMP information and the documentation of employee participation in the program. 1.3.11 Hot Work Permits A Hot Work permit procedure has been developed to specifically address the chlorine and sulfur dioxide systems as a "permit required" area. This procedure meets all the requirements of 29 CFR 1910.252 (WAC 296-24-695). 1.3.12 Contractors A defined process for reviewing the safety performance of contractors has been developed as part of the contractor selection for the RMP program. The RMP management procedure clearly defines the process of hazard communication an d the control of contractor entry/exit from the regulated area. The procedure for contractor safety includes all of the elements defined in 40 CFR 68.87. 1.4 Emergency Response The emergency response plan for WWTP includes the development of evacuation procedures, training/drill requirements and methods of notification of all affected individuals during an accidental release. |