North Charleston Sewer District WWTP Herbert Site - Executive Summary |
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RISK MANAGEMENT PLAN FOR NORTH CHARLESTON SEWER DISTRICT WWTF 1000 HERBERT 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 ensur ing 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 program s. 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 68.16 8 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 i s 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 compl ete 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 mecha nical 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 p re-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 responsib ility 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 responsibi lity 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 req uired 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. RISK MANAGEMENT PLAN FOR NORTH CHARLESTON SEWER DISTRICT WWTF 1000 HERBERT STREET SITE BY FAGGERT CONSULTING ASSOCIATES INC. RICHMOND, VA AND NORTH CHARLESTON SEWER DISTRICT ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE The North Charleston Sewer District (WWTF) Herbert Street site is committed to operating and maintaining all of its processes (especially those using hazardous substance) 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 have been developed and implemented, including: A description of our site 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 An listing of planned improvements at this site 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 Charleston , SC on two sites - the 1000 Herbert Street site and the 1400 Greenleaf Street site. At this Herbert Street site wastewater is disinfected. 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 Chlorine Disinfection of waste water No covered flammable chemicals are utilized at this site. Our a bove mentioned PSM, RMP and EAP 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 scenarios 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 - CHLORINE Chlorine rail car rupture releasing entire contents (180,000 lbs.) To the ground in a ten minute time period. This scenario release mandated by EPA. Estimated Exposure Distance- 14 miles Potentially Impacted Receptors - Industrial, residential and recreational areas; schools, hospitals; as well as, environmental receptors such as wetl ands and national parks. Administrative Controls and Mitigation Measures To Minimize Exposure Distance - Area sensors/interlocks; employee emergency response training; selectively located water sprays; ALTERATIVE RELEASE SCENARIO - Regulated Toxic Chemicals (MORE LIKELY ACCIDENTAL RELEASE CASE) EVENT - CHLORINE Release of 250 pounds over 1 minute period due to pipe failure at rail car unloading station. 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; area chlorine sensors; scheduled PM on transfer hose; 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 prev ention 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: Chlorine leak detection sensors/alarms Safety relief valve protects rail car from over pressure No pumps are used in chlorine service Equipment and piping designed to meet Chlorine Institute recommendations Process hazard analysis completed every 5 years Operational reviews completed for all process changes Annual review of operating procedures Hazard communications training provided for all personnel - operational and maintenance Periodic testing and inspection of equipment and piping Facility emerge ncy 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, sheltering in place, property damage, or environmental damage) during the past five years: YEAR/S CHEMICAL EVENT RESULT 1994 - N o 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 consolidated 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 situations. 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 site to help prevent and/or better respond to accidental chemical releases: Annual Certification of Injection/Equipment by Manufacturer. CERTIFICATION For all covered processes at this facility, the undersigned certifies that, to the best of my knowledge, informa tion, and belief, formed after reasonable inquiry, the information submitted in this RMPlan is true, accurate, and complete. Signature: Title: Date: NCSD RELEASE PREVENTION PROGRAM LEVEL 3 NCSD PREVENTION PROGRAM - LEVEL 3 Introduction NCSD takes a systematic approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of an accidental release prevention program including: Process safety information (PSI) Process hazard analysis Operating procedures Training Mechanical integrity Management of change Pre-startup review Compliance audits Incident investigation Employee participation Hot work permit Contractors These individual elements of our accidental release 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 standards for accident prevention. Process Safety Information In accordance with Section 68.65 of the RMP rule, we systematically control the development, updating, and retention of documentation associated with our process chemicals, process technology, and process equipment. This information is essential for supporting all of the other elements of our risk management program. We also use this information directly to ensure that our equipment is suitable for its intended use. Process Safety Information Details We maintain the following chemical process information for each regulated substance in a covered process as well as for other hazardous materials in both covered and noncovered processes: Tox icity information Permissible exposure limits Physical data Reactivity data Corrosivity data Thermal and chemical stability data Hazardous effects of inadvertent mixing of different materials that could forseeably occur The above information may be found in Attachment "1" Material Safety Data Sheets (MSDS) which comply with OSHA's Hazard Communication Standard 29 CFR 1910.1200. We maintain the following required process technology information: Block flow or simplified process flow diagram Process chemistry Maximum intended inventory Safe upper and lower limits for parameters such as temperature, pressure, flow, or composition Evaluation of the consequences of deviations from established operating limits Materials of construction Piping and instrument diagrams (P&IDs) Electrical classification Relief system design and design basis Ventilation system design Design codes and standards employed Material and energy balances for processes built after 6/21/99 Safety systems (interlocks, detection, or suppression systems) The information required above is included, as appropriate, in a document titled "Chlorination System" which is maintained at the Herbert Street site. This document includes a general description of the Chlorination process and system, as well as sections on Chlorine chemistry, Chlorine Supply, Chlorine Evaporators, Pressure Reducing Valves, Chlorinators and Ejectors, Chlorine Control System, Chlorine Gas Detection System, Instrument Diagrams, Block Diagrams, and Equipment/System Design Specifications. Process Hazard Analysis In accordance with Section 68.67 of the RMP rule, we use process hazard analyses (PHAs) to systematically identify, evaluate, and control process hazards. The most important products of our PHAs are recommendations for reducing the most significant risks of accidental chemical releases. We ensure that all recommendations from our PHAs are resolved appropriately, and we ensure that information from our PHAs (including recommendation resolutions) is communicated to all potentially affected employees. Process Hazard Analysis Details We conduct systematic PHAs of the regulated processes at our facility according to an established schedule. This schedule ensures that we (1) address each process in a prioritized order (based on the extent of process hazards, the number of potentially affected employees and/or offsite population, the age of the process, and the operating history of the process) and (2) update/revalidate each PHA at least every five years (or more often if necessary because of process changes). Initial and updated/revalidated PHA reports, which document the required regulatory items, will be included at a later time once the recommended changes have been approved and implemented. There are no documents which show "cradle to grave" resolution of PHA recommendations. These documents will be available at such time as these recommendations are approved and implemented including all phases of implementation. A Chlorine System Process Hazard Analysis document representing a walk through of the entire chlorine system, potential problems noted, alarm conditions, and emergency action steps which must be taken to ensure employee and public safety has been developed. This walk through was conducted with the assistance of several lead operators and all operators were consulted on the development of this PHA. A "What If Check List" approach was used in the creation of the Hazard Analysis document. Our PHA teams are composed of personnel with engineering and process operating experience, including at least one person who has knowledge and experience in the process to be evaluated and a PHA team leader trained in the application of the hazard evaluation technique used for the PHA. Operating Procedures In accordance with Section 68.69 of the RMP rule, we use operating procedur es to define how process-related job tasks assigned to our personnel should be performed to avoid incidents. We use these procedures to (1) train our employees/contractors before they perform tasks in the field, (2) serve as reference guides for personnel performing tasks, and (3) specify what to do if a process upset or operating emergency occurs. Operating Procedures Details Standard Operating Procedures have been developed and revised to reflect the findings of the PHA> these procedures contain the required steps to run the process for all modes of operations. Also included are documents, which show operator and mechanic certifications for those who are responsible for the chlorine system. These Operating Procedures shall be updated at least annually or whenever a change in the operation of the system occurs. The Chief of Plant Operations shall be the only employee who is authorized to make changes in these procedures with the guidance and approval of the remaining PHA te am members. Training In accordance with Section 68.71 of the RMP rule, we train our employees to safely perform their assigned tasks. Our training program includes initial training as well as periodic refresher training and training updates when major process/equipment changes are made. As part of our training, we include provisions for ensuring that employees understand the training (written tests, field demonstrations, etc.). Training Details The North Charleston Sewer District currently has an employee-training program in effect for the Wastewater Treatment Facility sites. This program combines the training programs and material available from the Chlorine Institute, WEF, Vendors and Suppliers of the Chlorination Equipment and the knowledge and expertise of facility personnel. This section describes the management's role and responsibilities and gives an overview of the program elements. The current outline of the training program is available. The North Charleston Se wer District's Wastewater Treatment Plant's employee training program is administered by the Chief of Plant Operations and Maintenance Superintendent for each of their respective departments. Both of these positions are under the direction and guidance of the Assistant District Manager. The responsibility for ensuring that the employees are properly trained and aware of all safety practices, hazards, emergency procedures, and maintenance procedures associated with their jobs is shared between the above individuals. Keeping the employee informed and trained will only help to minimize the potential for an on site accident. Important elements of the training program include initial training, additional training, and documentation. Mechanical Integrity In accordance with Section 68.73 of the RMP rule, we maintain the mechanical integrity (MI) of our process equipment using an inspection and testing program and a quality assurance program, and we ensure that our equipment is designed and installed correctly so that it operates properly. We train our maintenance personnel in the hazards of the process, and we also provide additional training on procedures for maintaining the ongoing integrity of our process equipment so that job tasks are performed safely. Mechanical Integrity Details An ongoing mechanical integrity program is used to ensure safe process operation. The elements of the mechanical integrity program include the identification and categorization of equipment and instrumentation, inspections and tests, testing and inspection frequencies, development of maintenance procedures, training of maintenance personnel and criteria for acceptable test results, documentation of test and inspection results, and documentation of manufacturer's recommendations as to the mean time for failure of equipment and instrumentation. Equipment used to process, store, or handle chlorine are designed, constructed, installed, and maintained to minimized releases. To ac complish this, an effective mechanical integrity program has been established to ensure the continued integrity of the process equipment. The priority for safe process equipment operation is: Primary Line of Defense 1. Operate and maintain the process as designed and keep chemicals contained. 2. Controlled release of chemicals through venting to appropriate areas designed to Minimized exposure to employees. Secondary Line of Defense 3. Fixed alarm equipment such as Chlorine leak detectors, computer monitoring of system pressures and temperatures and continuous monitoring of parameters. The mechanical integrity program protects the above lines of defense and ensures effective highly hazardous chemicals control. In order to maintain the mechanical integrity of the process equipment, written procedures have been established for the preventive maintenance of process equipment, as well, as inspection and testing procedures. These written procedures must be implemented and performed on process equipment in order to maintain the on going integrity of the process equipment. Documents which show the computerized preventive maintenance system currently in place including the tests/inspections to be performed, and frequency of tests/inspections are in place. Permanent records of the results of these tests/inspections are located in the Maintenance Superintendent's office. Also, mechanic certification documents are located in the section entitled Operating Procedures. This information is in accordance with the equipment vendor technical manuals located in the section entitled Process Safety Information. Management of Change In accordance with Section 68.75 of the RMP rule, we evaluate and approve all proposed changes (i.e., modifications that are not replacements in kind) to covered process chemicals, technology, equipment, and procedures prior to implementation through our management of change (MOC) progr am. This program helps ensure that inadvertent or unintended changes are prevented, that any safety and health impacts are addressed, that affected procedures are updated, and that our employees and contract employees are informed of and trained in the approved changes. We use this close scrutiny of all changes to help ensure that changes do not adversely impact employees, public safety, or the environment. Management of Change Details A Process Change Authorization is required for all changes to ensure the operation procedures contain the operating parameters (pressure limits, temperature ranges, flow rates, etc.) And the importance of operating within the limits. In addition, prior to startup of the changed process or affected part of the process, all employees involved in operating a process, maintaining a process, and contract employees affected by the change will be informed of and trained in the change(s). Written procedures to ensure the proper management of change ha ve been developed and include sections on Initiating the Change Process, Design of Change, Design Review, Installation of Change, Pre-Startup Review, and Startup, as well as a Management of Change checklist. Pre-Start-Up Review In accordance with Section 68.77 of the RMP rule, we perform a pre-startup review as a final check to ensure the safety of a new or modified process before it is placed in service. Pre-Start-Up Review Details Prior to starting the chlorine system after a change or modification, the PHA team shall review and approve a MANAGEMENT OF CHANGE checklist. The Pre-Start Up Safety Review shall consist of the completion of the following essential items to be completed/considered prior to the completion of such change: - Management of Change procedures - Design specs followed - Evaluation of any deviations from existing safety procedures created - PHA reviewed and updated if necessary - PHA team walk-through of system including inspection of safet y measures - Documented employee training on safety ramifications of change Compliance Audit In accordance with Section 68.79 of the RMP rule, we audit our RMP-covered processes to be certain that our prevention programs are effective. Our compliance audit program seeks to confirm that RMP prevention program practices for the covered process are consistent with written programs, that the programs adequately address all requirements of the RMP regulations, and that management systems are in place to ensure continued compliance. Compliance Audit Details The PHA team shall conduct a compliance audit at least every three years. This audit shall certify that all provisions of the RMP Section 68.79 and the OSHA 1910.119 standard are in compliance and are being followed. A report of the findings as a result of this audit shall be submitted to the Assistant District Manager. The next Compliance Audit shall be scheduled to begin no later than January 15, 2001. Our audit teams consist of a team leader and an appropriate number of team members based on the size and complexity of the processes to be audited. We have a plant management committee that promptly reviews the audit findings, determines an appropriate response for each finding, assigns responsibility for implementation of a corrective action, and assigns a target completion date. The corrective actions are placed in a tracking system and progress is monitored quarterly until open issues are resolved. We retain the two most recent audit reports. Incident Investigations In accordance with Section 68.81 of the RMP rule, we perform incident investigations to help ensure that incidents with catastrophic magnitude or potential are thoroughly investigated, root causes are identified and corrected, and relevant findings are communicated throughout our organization to help prevent a recurrence. Incident Investigations Details An incident investigation team has been formed comprising the following personnel: Chief of Plant Operations, Safety and Training Coordinator, and Maintenance Superintendent. All incidents, which caused or could have caused release of chlorine liquid/gas shall be investigated no less than 48 hours after the incident occurred. At the conclusion of the investigation, a report shall be prepared by the Chief of Plant Operations and reviewed by the team. The report shall include at a minimum: the date of the incident, the date the investigation began, a description of the incident, the factors that contributed to the incident, and any recommendations resulting from the incident. The recommendations resulting from the incident shall be presented to the Safety committee at the next regularly scheduled meeting for review. The Safety Committee shall make a formal recommendation to the Chief of Plant Operations. The Chief of Plant Operations will review the final report with the Assistant District Manager; at which time a course of action will be determined. All recommendations and facts relevant to the incident shall be reviewed with all affected personnel whose job tasks are related to the incident or the chlorine system. The incident investigation report shall supplement the supervisor's report of accident and be retained by the Human Resources Department for five years. Employee Participation In accordance with Section 68.83 of the RMP rule, our employee participation plan helps ensure that all employees have appropriate involvement in developing and implementing RMP. Employee Participation Details The Plant Operations department shall hold safety meetings for minimum of (1) hour per month to cover the development and implementation of the PSM/RMP standard compliance guidelines as well as other safety topics as needed. These meetings shall be conducted by each shift supervisor during the course of their normal shift duties and shall include the latest developments on the PSM/RMP standard, the PHA, and provide opportunity for inpu t on the PHA from employees to be relayed to the PHA development team through the Chief of Plant Operations. The Plant Maintenance department shall hold safety meetings for a minimum of (1) hour per month and cover the same topics as above in addition to regularly scheduled topics. Employee input shall be directed through the Maintenance Superintendent to the Chief of Plant Operations for consideration by the PHA development team. The minimum (1) one-hour safety meetings for Plant Operations and for Plant Maintenance shall include the PHA and development of all other elements of the PSM/RMP standard. These are standard requirements of each department and are included here only for "employee participation" purposes. Employees shall have access to all information developed as required by the PSM/RMP standard. Upon full compliance and development of the PSM/RMP standard, training shall be conducted in accordance with 1910.119(g). Additionally, employees shall be involved in the dev elopment and maintenance of all safe work practices including Lock out, Tag out, Hot Work, etc. All information related to the PSM/RMP shall be maintained in a readily accessible location for those employees who operate and maintain the Process. Hot Work Permits In accordance with Section 68.85 of the RMP rule, we use our hot work permit program to ensure that OSHA's fire prevention and protection precautions, specified in 29 CFR 1910.252(a), are in place before hot work (work involving electric or gas welding, cutting, brazing, or similar flame or spark-producing operation) begins on or near an RMP-covered process. Hot Work Permits Details The North Charleston Sewer District has developed a Hot Work Permit form under the direction of the North Charleston District Fire Chief and NFPA Standard 51B. This form is used at any time hot work is planned on or in the direct vicinity of the chlorine system. The Maintenance Superintendent is responsible for ensuring the effective use of the Hot Work Permit System. All permits shall be posted at the sight of the work for the duration of the job. The Fire Watch shall return the Permit to the Maintenance Superintendent upon final inspection of the work area. Contractors In accordance with Section 68.87 of the RMP rule, we have a contractor screening procedure to help ensure that we hire and use only contractors who accomplish the desired job tasks without compromising the safety of our plant employees, the public, or the environment. Contractor Details Contractors working on or adjacent to the chlorine or sulfur dioxide processes must be aware of the hazards involved in working on or near such areas. The Sewer District shall: obtain, review, and evaluate the contractor(s) safety performance and programs, ensure the Contractor informs his employees of the hazards associated with the work, obtain injury and illness records of contracted employees working in these areas. This information shall be include d in all bid specifications to workers bidding on the Plant site work. |