Mill Creek Water Treatment Plant - Executive Summary

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The City of Walla Walla Mill Creek Water Treatment Plant (MCWTP) has quantities of chlorine 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 MCWTP is regulated by the Process Safety Management (PSM), the regulatory program for the process 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.  
 
 
IMPLEMENTATION PLAN 
 
DE&S has performed 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 MCWTP 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 p 
rovided in the Gaps Analysis Report, which is available at the MCWTP.  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 initial 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 man 
agement 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 Mill Creek Water Treatment Plant is operated as safely as possible. 
 
 
MCWTP RISK MANAGEMENT PROGRAM 
 
The following element summaries are brief statements of the current MCWTP Risk Management Program.   
 
1.1   Management 
A formal management system for RMP is currently in place and documented 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 MCWTP's requirements relating to the RMP. 
 
1.2   Hazard Assessment 
The hazard assessment has been performed including the worst case analyses, alternative case an 
alyses, and a five-year accident history for the Mill Creek Water Treatment plant. The modeling suggests the downwind distance to the EPA RMP worst case endpoint health criteria will reach 2.2 miles.  The alternative release for chlorine resulted in an endpoint distance of 0.2 miles.  No release was found in the MCWTP'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 more 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 recommende 
d 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 MCWTP 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 procedure 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 MCWTP/DE&S team has conducted a Process Hazard Analyses  to identify, evaluate, and control the risk associated with the process hazards release scenarios at MCWTP subject to the Washington Ind 
ustrial 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 MCWTP 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 
The Tests/Inspections/ Maintenance (TIMs) schedule for the criti 
cal components of the chlorine systems has been developed to ensure the continued integrity of the regulated process equipment.  Plant equipment files have been established for maintaining the TIM's information.  The detailed maintenance procedures have been developed and training has been 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 re 
porting, 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 clearly, 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 systems as a "permit required" area.  This procedure meets all the requirements of 29 CFR 1910.252 (W 
AC 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 and 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 planning and response for MCWTP includes the development of evacuation procedures, training/drill requirements and methods of notification of all affected individuals during an accidental release.
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