Key West Wastewater Treatment Plant - Executive Summary |
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Key West 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 Key West Wastewater Treatment Plant (Key West WWTP), owned by the City of Key West 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 Key West WWTP RMP for the chlorine and sulfur dioxide systems. OMI has determined that the OSHA Process Safety Management standard also applies to the personnel at the Key West 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 t he regulated processes (e.g., chlorine and sulfur dioxide at the Key West 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 Key West 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 Key West WWTP is located at OMI Trumbo Point Annex' Fleming Key, in Key West, Monroe County, Florida. The Key West WWTP treats wastewater through a series of physical and chemical treatment operations. The plant is a 7.2 MGD extended aeration activated sludge plant. The Key West 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 ten containers (20,000 pounds) on site. In addition, the Key West WWTP utilizes sulfur dioxide for the dechlorination of treated effluent. The sulfur dioxide is stored in one-ton containers with a maximum intended inventory of four containers (8,000 pounds) on site. Therefore, the Key West 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 ves sel 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 Key West WWTP. Prevention Steps for Chlorine The prevention program and chemical-specific prevention steps are described in detail in the Key West WWTP RMP manual. The prevention program includes the following elements: 7 P rocess 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 Key West 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 sys tem 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 Key West 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 Key West WWTP 7 Employee participation in the development and implementation of the Key West WWTP RMP, and employee access to RMP information 7 Hot work prohibition policy on or near the chlorine system when chlorine 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 Key West WWTP emergency evacuation plan, limited access to the chlorine process, and ev aluation of contractor performance In addition to these elements, the chlorine storage area and chlorine feed room at the Key West 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 Key West WWTP RMP manual. The prevention program includes the following elements: 7 Process safety information, w hich 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, safety and health considerations, and safety systems and their functions 7 Training for each Key West 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 s ystem 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 Key West 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 Key West WWTP 7 Employee participation in the development and implementation of the Key West WWTP RMP, and employee access to RMP information 7 Hot work prohibition policy on or 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 Key West 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 Key West 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 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 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 dio xide 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 Naval Air Station Fire Department. The program is described in detail in the Key West 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. 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 Key West 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 Key West 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 the covered process. |