City of Dallas Water Treatment Plant - Executive Summary |
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Executive Summary Introduction Chemicals are widely used in industry, in the home, in the environment. They are transported on roads, water, and railways. We at the Dallas Water Treatment Plant (Dallas WTP) use chemicals, too. For example, we use chlorine to disinfect our water to provide safe drinking water to the citizens of Dallas. Storing large qualities of chlorine can be a hazard. We take our safety obligations in storing and using chlorine as seriously as we do take providing the community with safe disinfected drinking water. The following document describes what could happen if there were to be an accident, the steps we take everyday to ensure a safely operating plant, and what to do in event of an emergency. Accidental Release Prevention and Emergency Response Policies The City of Dallas accidental release prevention policy involves proven technology and staff that has been well trained on operation and maintenance practices. All applicable procedures of the U.S. Environm ental Protection Agency (EPA) Prevention Program are adhered to, including key elements such as training, systems management, and emergency response procedures. This document complies with the U.S. Environmental Protection Agency's (EPA's) Risk Management Program, under Section 112 (r) of the Clean Air Act (CAA) Amendments of 1990, 40 Code of Federal Regulations (CFR) Part 68. The Dallas WTP has a chlorination system that uses chlorine gas fed from liquid chlorine storage containers. This document summarizes our existing health and safety programs, our internal management response team, policies, procedures, and on-going actions that are designed to prevent or minimize impacts of accidental releases of chlorine to the environment. The Dallas WTP has prepared a detailed and comprehensive emergency response plan to handle any potential accidental releases that is designed to safeguard both on- and off-site people. To date, we have had an excellent record in preventing accidents from occ urring. General Facility and Regulated Substances Information The Dallas WTP, operating since 1971 and modified in 1992, is located at 16375 W. Ellendale Rd. in the City of Dallas in Polk County. The plant, located on an acre of property, is about 1.2 miles west of the city limits of Dallas. Water is supplied to the plant via Rickreall Creek from Mercer Reservoir. Water from the plant services Dallas and Ellendale Water District. Treatment processes used at the plant include preliminary screening, flocculation and settling, sand bed filtration and chlorination. The Dallas WTP produces 8.5 million gallons per day (MGD). The facility currently stores chlorine in two, 1-ton steel storage tanks containing a maximum in each tank of 2,000 pounds of chlorine. The facility has the capacity to hold two more 1-ton containers, but seldom does so. This chlorine storage exceeds the listed threshold quantities in the RMP regulation. Chlorine gas is injected from chlorine containers into a soluti on that is used in a variety of plant processes, primarily for final effluent disinfection. Gaseous chlorine, pulled from a storage container by an ejector, flows through chlorinators that control and measure the flow of gaseous chlorine. The gaseous chlorine is mixed with plant effluent water, and the solution is distributed to several locations in the plant. Chlorine leak detectors continuously monitor for leaks in the bulk storage area and in the chlorination room. Other alarms include feed and evaporator malfunction and low bulk storage tank weight. These alarms are annunciated at the chlorine control panel, as well as, in the case of a leak an audible alarm and red flashing warning light on top of the building. The bulk storage tanks and the chlorinators are enclosed in separate rooms. Each rooms is equipped with a ventilation system. Emergency showers and eye wash stations are provided outside the storage room and on the same floor as the chlorinator room. Self-contained breathi ng apparatus (SCBA) equipment is available on site. The Dallas WTP access is controlled on a private road by a gate. Visitors and contractors must be approved by Dallas WTP staff prior to entry into the facility. The plant is manned during the day, year round, and alarms notify on-call staff during off-hours of any problems or situations that require follow-up investigations. The chlorination facilities are also provided with emergency generators. These generators will start within one second after a loss of power and will supply power to the leak detectors, lighting, and ventilation systems. Offsite Consequence Analysis Results The offsite consequence analysis includes consideration of two release scenarios, identified as "worst case" and "alternative" release scenarios. The worst-case scenario requires that that single largest vessel or pipe be evaluated for off-site impacts from a chlorine tank rupture. The alternative release scenario for chlorine is a more likely release. The worst-case scenario assumes that the entire contents of the largest single container are released, regardless of how improbable that may be. In addition, only "passive" mitigation methods such as buildings or dikes (for liquids) can be considered. Passive mitigation, as defined, requires no mechanical, electrical, or human input. The regulations require that the worst-case scenario assume atmospheric conditions that are conservative and result in large impact areas. According to EPA's rule, the toxic gas worst-case scenario must assume the release of the single largest vessel or container over a period of 10 minutes. For worst-case scenarios, releases are assumed to take place without consideration for physical cause or likelihood of occurrence. At the WTP, chlorine containers are stored in a building immediately after arrival. Since the time the containers are outside the storage room is very short, the worst-case scenario was modeled using a release in an enclosed space, in dire ct contact with outside air, which results in a passive mitigation of any chlorine release. The release rate reduction from the enclosed building is approximately 55 percent of the release rate from the bulk tank, per guidance from EPA regarding control efficiencies levels for buildings storing chlorine. The release rate will, accordingly, be 110 pounds per minute (lbs./min). The bulk tank rupture resulting in a chlorine release could be caused by catastrophic events, such as an earthquake. The released liquid is assumed to quickly volatilize and to disperse as a vapor cloud. The distance to the toxic endpoint was estimated using the EPA model RMP*Comp version 1.06. The toxic endpoint was conservatively set by EPA to ensure public notification and that local emergency respond planning takes into account the greatest possible impacted area surrounding the release point. In practice this type of total release of a bulk tank would be unlikely and never occur during the lifetime of the p lant. The toxic endpoint selected by EPA was 3 ppm. In addition, all required EPA-model input parameters were included in completing this activity, including conservative meteorological conditions - Stability F class, wind speed of 1.5 meters per second, air temperature (77 degree F), and average humidity (50 percent). The results of the dispersion modeling analysis for this worst-case release scenario indicate that this scenario has an offsite impact. The estimated distance to the toxic endpoint was determined to be 0.9 miles. The alternative release scenario is more of a possible release scenario that could occur compared to the worst-case release scenario. Unlike the worst-case release scenario, active controls can be applied to minimize the leak or impacts. Active controls consist of mechanical, electrical, or human input. The alternative scenario used was a release of gaseous chlorine through the container valve. The tanks, evaporators, and associated piping are all in a building ; and the building mitigation was considered. Chlorine is piped as a gas from the one-ton containers to the chlorinating system. The alternative case scenario assumes that chlorine gas is released through a container valve with a diameter of 5/16 inch. This scenario assumes the release occurs for 60 minutes, an estimated time for plant operators to respond to the event. The RMP*Comp model calculated a chlorine release rate of 14.6 pounds per minute. The same modeling approach was used as for the worst case release scenario, except meteorological conditions were adjusted to more likely conditions of Stability D Class, wind speed of 3.0 meters per second, average air temperature of 77 degrees F, and average humidity of 50 percent. The distance to the chlorine toxic endpoint (3 ppm) was determined to be 0.1 miles. The area within the distance to the toxic endpoint is 0.03 square miles. Using EPA's Landview III block group uniform density method, the estimated population within the chlori ne endpoint circle is 3 people. Finally, no chlorine releases that could have cause safety or health hazard (no deaths, injuries, property or environmental damage, evacuations, or sheltering in place) occurred at Dallas WTP during the last five years. Some minor, incidental releases may have occurred over this period, but they were quickly handled by staff, were neutralized, or posed no safety or health hazards. Summary of the Accidental Release Prevention Program and Chemical-specific Prevention Steps Dallas WTP is in compliance with Federal and State Process Safety Management (PSM) requirements. Chemical specific prevention steps include availability of self-contained escape breathing apparatus, should a leak occur when changing chlorine supply tanks, awareness of the hazardous and toxic properties of chlorine, and the presence of chlorine detectors and alarms. Dallas WTP accidental release prevention program is based on the following key elements: * Comprehensive safety proces s information that is readily available to staff, emergency responders, and contractors * Comprehensive preventive maintenance program * Use of inherently safe vacuum supply system in which pipe component leaks bring air into the system rather than discharging chlorine to atmosphere * Completed a process hazard analysis of equipment and procedures with operation and maintenance staff participation and review. * Use of state-of-the-art process and safety equipment * Use of accurate and effective operating procedures, written with operations and maintenance staff participation * High level of training of operators and maintenance staff * Implementation of an incident investigation, inspection, and auditing program using qualified staff. Process and Chemical Safety Information Comprehensive chemical data have been assembled to include regulatory reporting and action thresholds, health hazard, and chemical exposure limitations, as well as detailed physical properties of each regulated su bstance. This information was compiled from numerous sources and is intended to be a one-stop source for the reader seeking data about these substances. This information includes chlorine background information, Material Safety Data Sheets, and chlorine reaction chemistry. Equipment safety information was meticulously compiled on the chlorine process. Specifications for each process are collected in one place for easy reference. Details such as maximum intended inventory; safe upper and lower temperatures; safe upper and lower pressures; and codes and standards used to design, build, and operate the processes are on file at the facility. We also have procedures in place that are triggered to update safety information if there is a major change that makes existing information inaccurate. Process Hazard Analysis In 1999, a detailed process hazard analysis (PHA) was conducted with plant staff, engineering, and administrative staff for the regulated process. The team consisted of proc ess operating and maintenance experts and process design engineers. The PHA technique used was the What-If / Checklist study, per acceptable approach guidance from EPA. The PHA was lead by knowledgeable person on the type of process being reviewed. This review and will be updated again within a five-year period or whenever there is major change in the process. A list of actions to resolve any found significant hazard review findings was prepared and staff is currently working to resolve this action item list. Staff will document completion of any action item. Operating Procedures Dallas WTP maintains up-to-date, accurate, written operating procedures that give clear instructions for the chlorine process. Dallas WTP ensures effective operating practices by combining them with operating and maintenance training programs. Procedures include startup, shutdown, and normal, alternate, and emergency operation. Also included is maintenance and troubleshooting procedures, including consequenc es of deviation and the steps to avoid correct deviations. Dallas WTP will update procedures whenever a change occurs that alters the steps needed to operate safely. Operating procedures will be developed and in place prior to any new process equipment coming on line or a changed process starting back up. Operations and Maintenance Training Program Each Dallas WTP employee presently involved in operating or maintaining the chlorine process is trained in an overview of the process and detailed, applicable operating and maintenance procedures. Dallas WTP helps their employees understand through training the nature and cause of problems arising from operations involving chlorine on site, and to increase their awareness with respect to these hazards. Dallas WTP's training program includes both initial and refresher training that covers 1) a general overview of the processes, 2) the properties and hazards of the substances in the process, and 3) a detailed review of the process operating procedures and safe work practices. Oral reviews and written self-evaluations are used to verify that an employee understands the training material before the process work can be resumed. Training documentation includes: date of most recent review or revision to the training program, type of training required and the type of competency testing used to ensure staff understands the training. Contractors Dallas WTP has procedures and policies in place that ensure that only contractors with good safety programs are selected to perform work on and around the chlorine process and that the contractors are properly informed of the hazards of chlorine, our access limitations to the chlorination process areas, our emergency response procedures. We oversee contractors' performance to assure that they are prepared to safely complete the work. Dallas WTP sets minimum contractor safety performance requirements to do work at the Dallas WTP, holds contractor safety briefings before allowing them n ear or in the process area; controls access to the process areas, and evaluate the contractor's performance. Pre-Startup Safety Review and Mechanical Integrity Program Dallas WTP ensures that a pre-startup safety review is completed for any new covered-by-the-rules process at the plant, or for significant modifications to an existing covered process that requires a change in the process safety information. Dallas WTP maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger workers, the public, or the environment. Dallas WTP believes that this program is the primary line of defense against a release and addresses equipment testing and inspection, preventative maintenance schedules, and personnel training. Dallas WTP's mechanical integrity program includes the following: * Written procedures for maintaining mechanical integrity through inspection and testing of process equipment, based on instructions of equipment vendors, industry codes, and prior operating experience * Implementation of the written procedures by performing inspections and tests on process equipment at specified intervals * Training of maintenance personnel in procedures for safe work practices such as lockout/tagout, line or equipment opening, and avoidance and correction of unsafe conditions * Procedures specifying training requirements for contract maintenance employees, as well as requiring contractors to use plant developed maintenance procedures for process areas. Hot Work Permits and Management of Change Dallas WTP requires employees and contractors to employ safe work practices when performing "hot work" in, on, or around the chlorination system. Dallas WTP uses a comprehensive permitting and training program to ensure hot work is conducted safely. Dallas WTP provides a system and approach to maintain and implement any management of changes or modifications to equipment, procedures, chemicals, and processing conditions. This system allows Dallas WTP employees to identify and review safety hazards or provide addition safety, process, or chemical information to existing data before the propose change would either comprise system safety or need training to be completed. Internal Compliance Audits Internal compliance audits are conducted every 3 years to verify compliance with the programs and procedures contained in the RMP. Dallas WTP assembles an audit team that includes personnel knowledgeable in the Risk Management Program rule and in the process, and this team evaluates whether the prevention program satisfies the requirements of the Risk Management Program rule and whether the prevention program is sufficient to help ensure safe operation of the process. The results of the audit are documented, recommendations are resolved, and appropriate enhancements to the prevention program are implemented. Incident Investigation Dallas WTP investigates all incidents that could reasonably have resulted in a serious in jury to personnel, the public, or the environment so that similar accidents can be prevented. Dallas WTP trains employees to identify and report any incident that requires investigation. An investigation team is assembled and the investigation is initiated within 48 hours of the incident. The results of the investigation are documented, recommendations are resolved, and appropriate process enhancements are implemented. Information found during the investigation is reviewed by affected staff, added or used to revise operating and maintenance procedures, and passed onto the training unit for their inclusion in existing training programs, if warranted to prevent a future event. Five-year Accident History Summary No chlorine releases that could have cause safety or health hazard (no deaths, injuries, property or environmental damage, evacuations, or sheltering in place) occurred at Dallas WTP during the last five years. Emergency Response Program Summary Dallas WTP has established a w ritten emergency response program that is followed by the employees to help safely respond to accidental releases of hazardous substances. This program has been coordinated (reviewed) by the City of Dallas Fire Department. This program includes an emergency response notification plan. Emergency response drills and drill evaluations are conducted every ?? months; emergency operation and response procedures are also reviewed at that time. Planned Changes to Improve Safety Several changes to improve safety (recommended actions) were identified for the chlorination process during the 1999 Process Hazard Analysis under the federal EPA RMP program. It is expected that the recommended actions will be evaluated and implemented by December 1999. The implementation of these recommendations will further improve the safety of the covered processes. Executive Summary Introduction Chemicals are widely used in industry, in the home, in the environment. They are transported on roads, water, and ra ilways. We at the Dallas Water Treatment Plant (Dallas WTP) use chemicals, too. For example, we use chlorine to disinfect our water to provide safe drinking water to the citizens of Dallas. Storing large qualities of chlorine can be a hazard. We take our safety obligations in storing and using chlorine as seriously as we do take providing the community with safe disinfected drinking water. The following document describes what could happen if there were to be an accident, the steps we take everyday to ensure a safely operating plant, and what to do in event of an emergency. Accidental Release Prevention and Emergency Response Policies The City of Dallas accidental release prevention policy involves proven technology and staff that has been well trained on operation and maintenance practices. All applicable procedures of the U.S. Environmental Protection Agency (EPA) Prevention Program are adhered to, including key elements such as training, systems management, and emergency response procedures. This document complies with the U.S. Environmental Protection Agency's (EPA's) Risk Management Program, under Section 112 (r) of the Clean Air Act (CAA) Amendments of 1990, 40 Code of Federal Regulations (CFR) Part 68. The Dallas WTP has a chlorination system that uses chlorine gas fed from liquid chlorine storage containers. This document summarizes our existing health and safety programs, our internal management response team, policies, procedures, and on-going actions that are designed to prevent or minimize impacts of accidental releases of chlorine to the environment. The Dallas WTP has prepared a detailed and comprehensive emergency response plan to handle any potential accidental releases that is designed to safeguard both on- and off-site people. To date, we have had an excellent record in preventing accidents from occurring. General Facility and Regulated Substances Information The Dallas WTP, operating since 1971 and modified in 1992, is located at 16375 W. Ell endale Rd. in the City of Dallas in Polk County. The plant, located on an acre of property, is about 1.2 miles west of the city limits of Dallas. Water is supplied to the plant via Rickreall Creek from Mercer Reservoir. Water from the plant services Dallas and Ellendale Water District. Treatment processes used at the plant include preliminary screening, flocculation and settling, sand bed filtration and chlorination. The Dallas WTP produces 8.5 million gallons per day (MGD). The facility currently stores chlorine in two, 1-ton steel storage tanks containing a maximum in each tank of 2,000 pounds of chlorine. The facility has the capacity to hold two more 1-ton containers, but seldom does so. This chlorine storage exceeds the listed threshold quantities in the RMP regulation. Chlorine gas is injected from chlorine containers into a solution that is used in a variety of plant processes, primarily for final effluent disinfection. Gaseous chlorine, pulled from a storage container by an e jector, flows through chlorinators that control and measure the flow of gaseous chlorine. The gaseous chlorine is mixed with plant effluent water, and the solution is distributed to several locations in the plant. Chlorine leak detectors continuously monitor for leaks in the bulk storage area and in the chlorination room. Other alarms include feed and evaporator malfunction and low bulk storage tank weight. These alarms are annunciated at the chlorine control panel, as well as, in the case of a leak an audible alarm and red flashing warning light on top of the building. The bulk storage tanks and the chlorinators are enclosed in separate rooms. Each rooms is equipped with a ventilation system. Emergency showers and eye wash stations are provided outside the storage room and on the same floor as the chlorinator room. Self-contained breathing apparatus (SCBA) equipment is available on site. The Dallas WTP access is controlled on a private road by a gate. Visitors and contractors must be approved by Dallas WTP staff prior to entry into the facility. The plant is manned during the day, year round, and alarms notify on-call staff during off-hours of any problems or situations that require follow-up investigations. The chlorination facilities are also provided with emergency generators. These generators will start within one second after a loss of power and will supply power to the leak detectors, lighting, and ventilation systems. Offsite Consequence Analysis Results The offsite consequence analysis includes consideration of two release scenarios, identified as "worst case" and "alternative" release scenarios. The worst-case scenario requires that that single largest vessel or pipe be evaluated for off-site impacts from a chlorine tank rupture. The alternative release scenario for chlorine is a more likely release. The worst-case scenario assumes that the entire contents of the largest single container are released, regardless of how improbable that may be. In a ddition, only "passive" mitigation methods such as buildings or dikes (for liquids) can be considered. Passive mitigation, as defined, requires no mechanical, electrical, or human input. The regulations require that the worst-case scenario assume atmospheric conditions that are conservative and result in large impact areas. According to EPA's rule, the toxic gas worst-case scenario must assume the release of the single largest vessel or container over a period of 10 minutes. For worst-case scenarios, releases are assumed to take place without consideration for physical cause or likelihood of occurrence. At the WTP, chlorine containers are stored in a building immediately after arrival. Since the time the containers are outside the storage room is very short, the worst-case scenario was modeled using a release in an enclosed space, in direct contact with outside air, which results in a passive mitigation of any chlorine release. The release rate reduction from the enclosed building is approximately 55 percent of the release rate from the bulk tank, per guidance from EPA regarding control efficiencies levels for buildings storing chlorine. The release rate will, accordingly, be 110 pounds per minute (lbs./min). The bulk tank rupture resulting in a chlorine release could be caused by catastrophic events, such as an earthquake. The released liquid is assumed to quickly volatilize and to disperse as a vapor cloud. The distance to the toxic endpoint was estimated using the EPA model RMP*Comp version 1.06. The toxic endpoint was conservatively set by EPA to ensure public notification and that local emergency respond planning takes into account the greatest possible impacted area surrounding the release point. In practice this type of total release of a bulk tank would be unlikely and never occur during the lifetime of the plant. The toxic endpoint selected by EPA was 3 ppm. In addition, all required EPA-model input parameters were included in completing this activity, i ncluding conservative meteorological conditions - Stability F class, wind speed of 1.5 meters per second, air temperature (77 degree F), and average humidity (50 percent). The results of the dispersion modeling analysis for this worst-case release scenario indicate that this scenario has an offsite impact. The estimated distance to the toxic endpoint was determined to be 0.9 miles. The alternative release scenario is more of a possible release scenario that could occur compared to the worst-case release scenario. Unlike the worst-case release scenario, active controls can be applied to minimize the leak or impacts. Active controls consist of mechanical, electrical, or human input. The alternative scenario used was a release of gaseous chlorine through the container valve. The tanks, evaporators, and associated piping are all in a building; and the building mitigation was considered. Chlorine is piped as a gas from the one-ton containers to the chlorinating system. The alternative case scenario assumes that chlorine gas is released through a container valve with a diameter of 5/16 inch. This scenario assumes the release occurs for 60 minutes, an estimated time for plant operators to respond to the event. The RMP*Comp model calculated a chlorine release rate of 14.6 pounds per minute. The same modeling approach was used as for the worst case release scenario, except meteorological conditions were adjusted to more likely conditions of Stability D Class, wind speed of 3.0 meters per second, average air temperature of 77 degrees F, and average humidity of 50 percent. The distance to the chlorine toxic endpoint (3 ppm) was determined to be 0.1 miles. The area within the distance to the toxic endpoint is 0.03 square miles. Using EPA's Landview III block group uniform density method, the estimated population within the chlorine endpoint circle is 3 people. Finally, no chlorine releases that could have cause safety or health hazard (no deaths, injuries, property or enviro nmental damage, evacuations, or sheltering in place) occurred at Dallas WTP during the last five years. Some minor, incidental releases may have occurred over this period, but they were quickly handled by staff, were neutralized, or posed no safety or health hazards. Summary of the Accidental Release Prevention Program and Chemical-specific Prevention Steps Dallas WTP is in compliance with Federal and State Process Safety Management (PSM) requirements. Chemical specific prevention steps include availability of self-contained escape breathing apparatus, should a leak occur when changing chlorine supply tanks, awareness of the hazardous and toxic properties of chlorine, and the presence of chlorine detectors and alarms. Dallas WTP accidental release prevention program is based on the following key elements: * Comprehensive safety process information that is readily available to staff, emergency responders, and contractors * Comprehensive preventive maintenance program * Use of inher ently safe vacuum supply system in which pipe component leaks bring air into the system rather than discharging chlorine to atmosphere * Completed a process hazard analysis of equipment and procedures with operation and maintenance staff participation and review. * Use of state-of-the-art process and safety equipment * Use of accurate and effective operating procedures, written with operations and maintenance staff participation * High level of training of operators and maintenance staff * Implementation of an incident investigation, inspection, and auditing program using qualified staff. Process and Chemical Safety Information Comprehensive chemical data have been assembled to include regulatory reporting and action thresholds, health hazard, and chemical exposure limitations, as well as detailed physical properties of each regulated substance. This information was compiled from numerous sources and is intended to be a one-stop source for the reader seeking data about these substanc es. This information includes chlorine background information, Material Safety Data Sheets, and chlorine reaction chemistry. Equipment safety information was meticulously compiled on the chlorine process. Specifications for each process are collected in one place for easy reference. Details such as maximum intended inventory; safe upper and lower temperatures; safe upper and lower pressures; and codes and standards used to design, build, and operate the processes are on file at the facility. We also have procedures in place that are triggered to update safety information if there is a major change that makes existing information inaccurate. Process Hazard Analysis In 1999, a detailed process hazard analysis (PHA) was conducted with plant staff, engineering, and administrative staff for the regulated process. The team consisted of process operating and maintenance experts and process design engineers. The PHA technique used was the What-If / Checklist study, per acceptable approach guidance from EPA. The PHA was lead by knowledgeable person on the type of process being reviewed. This review and will be updated again within a five-year period or whenever there is major change in the process. A list of actions to resolve any found significant hazard review findings was prepared and staff is currently working to resolve this action item list. Staff will document completion of any action item. Operating Procedures Dallas WTP maintains up-to-date, accurate, written operating procedures that give clear instructions for the chlorine process. Dallas WTP ensures effective operating practices by combining them with operating and maintenance training programs. Procedures include startup, shutdown, and normal, alternate, and emergency operation. Also included is maintenance and troubleshooting procedures, including consequences of deviation and the steps to avoid correct deviations. Dallas WTP will update procedures whenever a change occurs that alters the steps needed to operate safely. Operating procedures will be developed and in place prior to any new process equipment coming on line or a changed process starting back up. Operations and Maintenance Training Program Each Dallas WTP employee presently involved in operating or maintaining the chlorine process is trained in an overview of the process and detailed, applicable operating and maintenance procedures. Dallas WTP helps their employees understand through training the nature and cause of problems arising from operations involving chlorine on site, and to increase their awareness with respect to these hazards. Dallas WTP's training program includes both initial and refresher training that covers 1) a general overview of the processes, 2) the properties and hazards of the substances in the process, and 3) a detailed review of the process operating procedures and safe work practices. Oral reviews and written self-evaluations are used to verify that an employee understands the training material b efore the process work can be resumed. Training documentation includes: date of most recent review or revision to the training program, type of training required and the type of competency testing used to ensure staff understands the training. Contractors Dallas WTP has procedures and policies in place that ensure that only contractors with good safety programs are selected to perform work on and around the chlorine process and that the contractors are properly informed of the hazards of chlorine, our access limitations to the chlorination process areas, our emergency response procedures. We oversee contractors' performance to assure that they are prepared to safely complete the work. Dallas WTP sets minimum contractor safety performance requirements to do work at the Dallas WTP, holds contractor safety briefings before allowing them near or in the process area; controls access to the process areas, and evaluate the contractor's performance. Pre-Startup Safety Review and Mechanica l Integrity Program Dallas WTP ensures that a pre-startup safety review is completed for any new covered-by-the-rules process at the plant, or for significant modifications to an existing covered process that requires a change in the process safety information. Dallas WTP maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger workers, the public, or the environment. Dallas WTP believes that this program is the primary line of defense against a release and addresses equipment testing and inspection, preventative maintenance schedules, and personnel training. Dallas WTP's mechanical integrity program includes the following: * Written procedures for maintaining mechanical integrity through inspection and testing of process equipment, based on instructions of equipment vendors, industry codes, and prior operating experience * Implementation of the written procedures by performing inspections and tests on process equipment at specifi ed intervals * Training of maintenance personnel in procedures for safe work practices such as lockout/tagout, line or equipment opening, and avoidance and correction of unsafe conditions * Procedures specifying training requirements for contract maintenance employees, as well as requiring contractors to use plant developed maintenance procedures for process areas. Hot Work Permits and Management of Change Dallas WTP requires employees and contractors to employ safe work practices when performing "hot work" in, on, or around the chlorination system. Dallas WTP uses a comprehensive permitting and training program to ensure hot work is conducted safely. Dallas WTP provides a system and approach to maintain and implement any management of changes or modifications to equipment, procedures, chemicals, and processing conditions. This system allows Dallas WTP employees to identify and review safety hazards or provide addition safety, process, or chemical information to existing data befo re the propose change would either comprise system safety or need training to be completed. Internal Compliance Audits Internal compliance audits are conducted every 3 years to verify compliance with the programs and procedures contained in the RMP. Dallas WTP assembles an audit team that includes personnel knowledgeable in the Risk Management Program rule and in the process, and this team evaluates whether the prevention program satisfies the requirements of the Risk Management Program rule and whether the prevention program is sufficient to help ensure safe operation of the process. The results of the audit are documented, recommendations are resolved, and appropriate enhancements to the prevention program are implemented. Incident Investigation Dallas WTP investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public, or the environment so that similar accidents can be prevented. Dallas WTP trains employees to identify and report any incident that requires investigation. An investigation team is assembled and the investigation is initiated within 48 hours of the incident. The results of the investigation are documented, recommendations are resolved, and appropriate process enhancements are implemented. Information found during the investigation is reviewed by affected staff, added or used to revise operating and maintenance procedures, and passed onto the training unit for their inclusion in existing training programs, if warranted to prevent a future event. Five-year Accident History Summary No chlorine releases that could have cause safety or health hazard (no deaths, injuries, property or environmental damage, evacuations, or sheltering in place) occurred at Dallas WTP during the last five years. Emergency Response Program Summary Dallas WTP has established a written emergency response program that is followed by the employees to help safely respond to accidental releases of hazardous substances. This progr am has been coordinated (reviewed) by the City of Dallas Fire Department. This program includes an emergency response notification plan. Emergency response drills and drill evaluations are conducted every ?? months; emergency operation and response procedures are also reviewed at that time. Planned Changes to Improve Safety Several changes to improve safety (recommended actions) were identified for the chlorination process during the 1999 Process Hazard Analysis under the federal EPA RMP program. It is expected that the recommended actions will be evaluated and implemented by December 1999. The implementation of these recommendations will further improve the safety of the covered processes. |