West Biloxi Wastewater Treatment Plant - Executive Summary

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West Biloxi Wastewater Treatment Plant 
 
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 West Biloxi Wastewater Treatment Plant (West Biloxi WWTP), one of several facilities owned by the Harrison County Wastewater and Solid Waste Management District and operated by Operations Management International, Inc. (OMI). 
 
Prevention and Response Policies 
 
OMI 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, OMI 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 West Biloxi WWTP RMP for the chlorine and sulfur dioxide systems.  OMI has determined that the OSHA P 
rocess Safety Management standard also applies to the personnel at the West Biloxi WWTP and therefore has prepared this RMP to comply with the RMP Program 3 requirements.  By doing so, OMI 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. 
OMI takes an active role in preventing accidental releases at all of the facilities it operates b 
y ensuring that its employees are well-informed regarding the hazards associated with the regulated processes (e.g., chlorine and sulfur dioxide at the West Biloxi WWTP) and actively participated in comprehensive process hazard analyses.  The employees that work on the chlorine and sulfur dioxide systems 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. 
 
OMI 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 West Biloxi WWTP RMP procedures and policies. 
As for emergency response, OMI has established and maintained procedures for emergency notification and response.  These are reviewed with employees on a periodic basis and revised to accommodate ch 
anges in staffing when they occur. 
 
Stationary Source and Regulated Substances 
 
The West Biloxi WWTP is located at 370 Rosalie Maria Drive in Biloxi, Harrison County, Mississippi.  The West Biloxi WWTP treats wastewater through a series of physical and chemical treatment operations.  This activated sludge plant has aerobic digesters, a 2.0-meter belt filter press, and secondary clarification.  Average design flow is 9 MGD, with a peak capacity of 27.1 MGD.  Sludge is transported to a disposal site by a separate contractor.  OMI developed an equipment repair program and an ongoing training program. 
The West Biloxi WWTP utilizes chlorine as a biocide in the treatment of wastewater.  The chlorine is stored in one-ton containers with a maximum intended inventory of eight containers (16,000 pounds) on site.  In addition, the West Biloxi WWTP utilizes sulfur dioxide for the dechlorination of treated effluent.  The sulfur dioxide is stored in one-ton containers with a maximum intended invento 
ry of four containers (8,000 pounds) on site.  Therefore, the West Biloxi WWTP is regulated under the RMP rule due to the volume of chlorine and sulfur dioxide 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.  The same scenario was assumed for both chlorine and 
sulfur dioxide. 
 
Results of the off-site consequence analyses are described in Sections 2 and 3 of the RMP*Submit plan for the West Biloxi WWTP. 
 
Prevention Steps for Chlorine 
 
The prevention program and chemical-specific prevention steps are described in detail in the West Biloxi WWTP RMP manual.  The prevention program includes the following elements: 
 
7 Process safety information, which includes information pertaining to the hazards of chlorine in the process, process technology, and process equipment 
 
7 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 
 
7 Operating procedures, which include steps for each operating phase, operating limits, safety and 
health considerations, and safety systems and their functions 
 
7 Training for each West Biloxi WWTP employee involved in operating the chlorine system 
 
7 Mechanical integrity procedures to maintain the on-going integrity of the chlorine process equipment 
 
7 Management of change procedures to manage changes (other than "replacements in kind") to the chlorine system 
 
7 Pre-startup safety review for additions or significant modifications to the chlorine process, or any new regulated chemical process 
 
7 Compliance audits at least every three years from 1999 to evaluate West Biloxi WWTP RMP compliance 
 
7 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 West Biloxi WWTP 
 
7 Employee participation in the development and implementation of the West Biloxi WWTP RMP, and employee access to RMP information 
 
7 Hot work prohibition policy on or near the chlorine system when chl 
orine is present in the affected section of the process 
 
7 Contractor 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 West Biloxi WWTP emergency evacuation plan, limited access to the chlorine process, and evaluation of contractor performance 
 
In addition to these elements, the chlorine storage area and chlorine feed room at the West Biloxi WWTP 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 and a high rate ventilation system can be activated in the chlorine feed room.  The ventilation system withdraws chlorine and air from a low elevation in the chlorine storage room to a safe outdoor location.  The alarm systems are 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. 
 
Prevention Steps for Sulfur Dioxide 
 
The prevention program and chemical-specific prevention steps are described in detail in the West Biloxi WWTP RMP manual.  The prevention program includes the following elements: 
 
7 Process safety information, which includes information pertaining to the hazards of sulfur dioxide in the process, process technology, and process equipment 
 
7 Process hazard analysis (PHA), which includes a systematic evaluation (by an employee team) of:  the hazards of the sulfur dioxide 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 
 
7 Operating procedures, which include steps for each operating phase, operating limits, safet 
y and health considerations, and safety systems and their functions 
 
7 Training for each West Biloxi WWTP employee involved in operating the sulfur dioxide system 
 
7 Mechanical integrity procedures to maintain the on-going integrity of the sulfur dioxide process equipment 
 
7 Management of change procedures to manage changes (other than "replacements in kind") to the sulfur dioxide system 
 
7 Pre-startup safety review for additions or significant modifications to the sulfur dioxide process, or any new regulated chemical process 
 
7 Compliance audits at least every three years from 1999 to evaluate West Biloxi WWTP RMP compliance 
 
7 Incident investigation, to be conducted and documented for each incident that resulted in, or could have reasonably resulted in, a catastrophic release of sulfur dioxide from the West Biloxi WWTP 
 
7 Employee participation in the development and implementation of the West Biloxi WWTP RMP, and employee access to RMP information 
 
7 Hot work prohibition policy on o 
r near the sulfur dioxide system when sulfur dioxide is present in the affected section of the process 
 
7 Contractor management program, to ensure appropriate evaluation and selection of qualified contractors for work on or near the sulfur dioxide system, proper notification of contractors regarding known sulfur dioxide system hazards and the West Biloxi WWTP emergency evacuation plan, limited access to the sulfur dioxide process, and evaluation of contractor performance 
 
In addition to these elements, the sulfur dioxide storage area and sulfur dioxide feed room at the West Biloxi WWTP are equipped with sulfur dioxide leak detection devices that continuously monitor the air for sulfur dioxide gas.  If the sulfur dioxide sensor detects a specified level, audio and visual alarms will be activated and a high rate ventilation system can be activated in the sulfur dioxide feed room.  The ventilation system withdraws sulfur dioxide and air from a low elevation in the sulfur dioxide storage r 
oom to a safe outdoor location.  The alarm systems are maintained and tested on a regular basis to ensure proper operation should there be a sulfur dioxide release.  Management of Change procedures will be used for the upgrades to the sulfur dioxide system. 
 
Accident History 
 
Within the five-year period prior to the submittal of this RMP, there were no accidental releases of chlorine or sulfur dioxide 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 Biloxi Fire Department.  The program is described in detail in the West Biloxi WWTP 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.  T 
he 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 West Biloxi WWTP.  Employees are encouraged 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 West Biloxi WWTP 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 th 
e covered process.
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