Taos Wastewater Treatment Plant - Executive Summary

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Taos 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 Taos Wastewater Treatment Plant (Taos WWTP), owned by the Town of Taos 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 Taos WWTP RMP for the ammonia system.  OMI has determined that the OSHA Process Safety Management standard also applies to the personnel at the Taos 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 by ensuring that its employees are well-informed regarding the hazards associated with the regulated processes (e.g., ammonia at the  
Taos WWTP) and actively participated in comprehensive process hazard analyses.  The employees that work on the ammonia 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. 
 
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 Taos 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 changes in staffing when they occur. 
 
Stationary Source and Regulated Substances 
 
The Taos WWTP is located at 182 Los Cordova Road, Taos County, New Mexico.  The Taos WWTP treats wastewate 
r through a series of physical and chemical treatment operations.  The facility is a 1.0 MGD activated sludge/oxidation ditch operation. 
 
The Taos WWTP utilizes ammonia in its on-site fertilizer plant.  The ammonia is stored in one-12,000 gallon container (approximately 50,000 pounds) on site.  Therefore, the Taos WWTP is regulated under the RMP rule due to the volume of ammonia 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 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, th 
e 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 Taos WWTP. 
 
Prevention Steps for Ammonia 
 
The prevention program and chemical-specific prevention steps are described in detail in the Taos WWTP RMP manual.  The prevention program includes the following elements: 
 
7 Process safety information, which includes information pertaining to the hazards of ammonia 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 ammonia 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 ef 
fects 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 Taos WWTP employee involved in operating the ammonia system 
 
7 Mechanical integrity procedures to maintain the on-going integrity of the ammonia process equipment 
 
7 Management of change procedures to manage changes (other than "replacements in kind") to the ammonia system 
 
7 Pre-startup safety review for additions or significant modifications to the ammonia process, or any new regulated chemical process 
 
7 Compliance audits at least every three years from 1999 to evaluate Taos 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 ammonia from the Taos WWTP 
 
7 Employee participation in the development and implementation of the Taos WWTP RMP, and employee a 
ccess to RMP information 
 
7 Hot work prohibition policy on or near the ammonia system when ammonia 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 ammonia system, proper notification of contractors regarding known ammonia system hazards and the Taos WWTP emergency evacuation plan, limited access to the ammonia process, and evaluation of contractor performance 
 
Management of Change procedures will be used for the upgrades to the ammonia system. 
 
Accident History 
 
Within the five-year period prior to the submittal of this RMP, there were no accidental releases of ammonia 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 Taos Volunteer Fire Department.  The program is described in detail in the Taos WWT 
P 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 Taos 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 Taos 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 prevent 
ing 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.
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