North Charleston Sewer District WWTF Greenleaf Sit - Executive Summary |
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RISK MANAGEMENT PLAN FOR NORTH CHARLESTON SEWER DISTRICT WWTF 1400 GREENLEAF STREET SITE BY FAGGERT CONSULTING ASSOCIATES INC. RICHMOND, VA AND NORTH CHARLESTON SEWER DISTRICT RMP MANAGEMENT SYSTEM NORTH CHARLESTON SEWER DISTRICT NORTH CHARLESTON, SC OVERALL RESPONSIBILITY The Chief of Plant Operations (CPO) has the overall responsibility for ensu ring that the North Charleston Sewer District Waste Water Treatment Facility (NCSD WWTF) (two sites, Herbert Street and Greenleaf Street) operates in a safe and reliable manner. However, initially the Assistant District Manager, NCSD (the CPO's supervisor) will have the responsibility for overseeing the implementation of the elements of the risk management program (RMP) at this site. This activity will include the development, implementation, and integration of the EPA RMP elements and the elements of OSHA's PSM program (where applicable) as required under Section 68.15 of the RMP rule. Once the facility RMP is in place, the Chief of Plant Operations will assume responsibility for compliance and on-going maintenance of the program. The Assistant District Manager will serve as the chairman of the facility's PSM/RMP Steering Committee. This committee comprises members with responsibilities for developing and managing specific elements of the risk management and process safety progra ms. The Assistant District Manager assigns the members of this committee. Currently, the members of the PSM/RMP Steering Committee include the following: Assistant District Manager Chief of Plant Operations Systems Maintenance Superintendent Safety and Training Coordinator The following sections identify the specific responsibilities for each aspect of the risk management and process safety management programs. HAZARDS ASSESSMENT The Assistant District Manager has the responsibility for (1) ensuring that offsite consequence analysis for each regulated process are consistently performed and documented in accordance with Sections 68.20 through 68.38 and (2) selecting the scenarios that will be reported in the facility RMPlan as required under Section 68.165. The Assistant District Manager also is responsible for ensuring that the accident history for each covered process is appropriately documented and maintained in accordance with Section 68.42 and 68.1 68 of the RMP rule. PREVENTION PROGRAMS The Assistant District Manager has the responsibility for ensuring that the facility has an integrated, effective, and compliant prevention program that meets EPA RMP (Sections 68.65 through 68.87 of the RMP rule) and OSHA PSM requirements. Although the Assistant District Manager has some specific individual responsibilities, many of the responsibilities for specific program elements are assigned to other members of the PSM/RMP Steering Committee (as listed in the following sections). Process Safety Information The responsibility for process safety information (PSI) (Section 68.65 of the RMP rule) is divided into three areas. The Chief of Plant Operations has responsibility for process chemical information and responsibility for process technology information, and the Maintenance Superintendent has responsibility for equipment information. The Chief of Plant Operations has the responsibility of ensuring that all of this information is readily accessible for use. Process Hazard Analysis In accordance with Section 68.67 of the RMP rule, the Chief of Plant Operations has the responsibility for ensuring that process hazard analyses (PHAs) are scheduled, conducted, and documented by trained personnel for all regulated processes. The Chief of Plant Operation identifies candidate PHA team leaders from within the facility and ensures that they receive appropriate training before leading PHAs. The Chief of Plant Operations also uses outside contractors to lead PHAs when appropriate. The other members of the PSM/RMP Steering Committee are responsible for (1) ensuring that the information and personnel necessary to conduct PHAs are available according to the PHA implementation schedule and (2) resolving recommendations that are assigned to their respective areas. Operating Procedures In accordance with Section 68.69 of the RMP rule, the Chief of Plant Operations has the responsibility for ensuring that comp lete and accurate operating procedures are in place for all regulated processes. The Chief of Plant Operations works closely with the Maintenance Superintendent to develop and maintain the facility's safe work practices. Training In accordance with Section 68.71 of the RMP rule, the Chief of Plant Operations has the responsibility for (1) ensuring that operations employees receive and understand training applicable to their specific jobs and the associated processes and (2) documenting the training. The Chief of Plant Operations also has the responsibility for (1) ensuring that all facility employees receive and understand training in safe work practices applicable to their jobs and (2) documenting the training. (The Maintenance Superintendent addresses training for maintenance workers under the mechanical integrity program.) Mechanical Integrity In accordance with Section 68.73 of the RMP rule, the Maintenance Superintendent has the responsibility for the overall mech anical integrity program, with specific emphasis on written procedures, maintenance training, the equipment and instrumentation inspection/test program and documentation, and equipment deficiency resolution. The Chief of Plant Operations and the Safety and Training Coordinator work with the Maintenance Superintendent to define and maintain appropriate quality assurance procedures for all types of equipment acquisitions/installations/repairs. Management of Change In accordance with Section 68.75 of the RMP rule, the Chief of Plant Operations has the responsibility for the overall management of change (MOC) program; however, the Operations Shift Supervisors, the Maintenance Superintendent and the Safety and Training Coordinator each have responsibility for ensuring that the overall MOC program is effectively implemented in their areas. Pre-Start-Up Review In accordance with Section 68.77 of the RMP rule, the Chief of Plant Operations has the responsibility for the overall pre-startup review program, which is closely related to the MOC program. The Chief of Plant Operations, through the Operations Shift Supervisors, has the primary responsibility for ensuring that this program is effectively implemented before affected operations begin. Compliance Audit In accordance with Section 68.79 if the RMP rule, the Assistant District Manager has the responsibility for ensuring that compliance audits regularly occur (and are documented) to verify that the prevention program is working and meets EPA/OSHA requirements. Each member of the PSM/RMP Steering Committee has responsibility for resolving any identified deficiency in their area. Incident Investigations In accordance with Section 68.81 of the RMP rule, the Chief of Plant Operations has the responsibility for designing and managing the incident investigation program, including tracking resolution of investigation findings and recommendations. The Chief of Plant Operations also has the responsi bility of ensuring that only trained personnel lead the investigations. The Operations Shift Supervisors and Maintenance Superintendent each have responsibility for ensuring that all incidents in their areas are reported and investigated, and the investigations findings are resolved, documented, and communicated to affected personnel. Employee Participation In accordance with Section 68.83 of the RMP rule, the Chief of Plant Operations working with the Operations Shift Supervisors, has the responsibility of involving employees in the planning and implementation of the facility's prevention program elements. Hot Work Permits In accordance with Section 68.85 of the RMP rule, the Maintenance Superintendent working closely with the Chief of Plant Operations, has the responsibility of developing and maintaining the facility's hot work permit program. Contractors In accordance with Section 68.87 of the RMP rules, the Maintenance Superintendent has the overall responsib ility for the contractor program; however, the Maintenance Superintendent and the Chief of Plant Operations are responsible for ensuring that the requirements of the program are implemented in their areas of responsibility. EMERGENCY RESPONSE PROGRAM In accordance with Sections 68.90 and 68.95 of the RMP rules, the Chief of Plant Operations, with assistance from the Assistant District Manager, is responsible for designing, implementing, and maintaining the facility's emergency action plan and ensuring that all associated training is conducted and documented as necessary. Coordinating the site emergency action plan with the community emergency response plan and responding to local emergency planners/responders when questions arise in the responsibility of the Assistant District Manager. RMP PLAN PREPARATION AND SUBMISSION The Assistant District Manager is responsible for preparing and submitting the RMPlan for the facility (after review and approval by the District Manager) as re quired under Sections 68.150 through 68.185 of the RMP rule. RMP PLAN COMMUNICATION The NCS District Manager, with assistance from the Assistant District Manager, has the responsibility of providing RMPlan information (other than the required EPA submission) to the public and all employees as required under Section 68.210 of the RMP rule. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE The North Charleston Sewer District (WWTF) Greenleaf Street site is committed to operating and maintaining all of its processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of our Process Safety Management (PSM) of Highly Hazardous Chemicals program, our Accidental Release Prevention (RMP) program and Emergency Action program (EAP) to help ensure the safety of our employees, the surrounding public and to provide protection for the environment. This document presents a brief overview of the comprehensive risk management program that ha ve been developed and implemented, including: A description of our facility and use of the chemical covered by the RMP regulation A summary of the potential offsite consequences from accidental chemical releases from our facility An overview of our accidental release prevention program A five-year accident history for accidental releases of chemicals covered by the RMP rule A summary of our emergency action program A listing of planned improvements at this facility to help prevent accidental chemical releases The certification that the RMP rule requires us to provide The detailed information (called data elements) about our risk management program STATIONARY SOURCE AND REGULATED SUBSTANCES The NCSD facility is a wastewater treatment operation (WWTF) located in North Charleston, SC on two sites - the 1000 Herbert Street site and the 1400 Greenleaf Street site. At this Greenleaf Street site wastewater is dechlorinated. In so doing, we use the following toxic chemical that EPA has identified as having the potential to cause significant off site consequences in the event of a substantial accidental release: CHEMICAL NAME USE Sulfur Dioxide Dechlorination of wastewater No covered flammable chemicals are utilized at this site. Our above mentioned PSM, RMP and ERP programs help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of this chemical. KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS The RMP rule requires that NCSD provide information about the worst-case release scenario and one alternative release scenario for our site. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: WORST-CASE RELEASE SCENARIO - Regulated Toxic Chemicals EVENT SULFUR DIOXIDE (SO2) SO2 Storage tank rup ture releasing entire contents (68,585 lbs.) to the ground in a ten minute time period. This scenario release mandated by EPA. Estimated Exposure Distance - 8.8 miles Potentially Impacted Receptors - Industrial, residential and recreational areas; schools, hospitals; as well as, environmental receptors such as wetlands and national parks. Administrative Controls and Mitigation Measures to Minimize Exposure Distance - Area sensors/interlocks; employee emergency response training. ALTERATIVE RELEASE SCENARIO - Regulated Toxic Chemicals (MORE LIKELY ACCIDENTAL RELEASE CASE) EVENT - SULFUR DIOXIDE Release of 250 pounds over 10 minute period due to pipe failure at storage tank area during loading. Estimated Exposure Distance - 0.3 miles Potentially Impacted Receptors - Industrial, residential and recreational areas Administrative Controls and Mitigation Measures To Minimize Exposure Distance - Isolation of leaking piping by operator, operation of excess flow valves; schedul ed PM on piping; ACCIDENT RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS NCSD takes a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs including: Process safety information Process hazard analysis Operating procedures Training Mechanical integrity Management of change Pre-startup review Compliance audits Incident investigation Employee participation Hot work permit Contractors As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: Safety relief valve protects storage tank from over pressure No pumps are used in SO2 service Process hazard analysis completed every 5 years Operational reviews completed for all process changes Annual review of operating procedures Hazard communications train ing provided for all personnel - operational and maintenance Periodic testing and inspection of equipment and piping Facility emergency action program in place Formal investigations conducted for all significant releases Formal facility audits These individual elements of our prevention program work together to prevent accidental chemical releases. NCSD and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. FIVE YEAR ACCIDENT HISTORY NCSD keeps records for all significant accidental chemical releases that occur at our sites. The following is a brief summary of accidental chemical releases involving materials covered under EPA's RMP rule (releases that result in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, shelterin g in place, property damage, or environmental damage) during the past five years: YEAR/S CHEMICAL EVENT RESULT 1994 - No covered chemical release has occurred that would meet the above criteria. 1999 EMERGENCY ACTION PLAN NCSD has in place a facility emergency action plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situation. Furthermore, we coordinate our plan with the community emergency response plan. A summary of our Emergency Action Program is included in the Appendix of this report. PLANNED CHANGES TO IMPROVE SAFETY The following is a list of improvements that NCSD is planning to implement at the facility to help prevent and/or better respond to accidental chemical releases: Utilize a numeric tagging system for valve identif ication. Would allow for a more rapid response to securing various elements of a system during an emergency situation.. Install automatic shut off valves. Internal & External inspection of storage tank every 3 years. Install Nitrogen purge connection to allow for testing of piping and equipment. Annual Certification of injection equipment by manufacturer. CERTIFICATION For all covered processes at this site, the undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted in this RMPlan is true, accurate, and complete. Signature: Title: Date: |