Main Street Wastewater Treatment Plant - Executive Summary |
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As a Program 3 source the primary portion of ECUA's RMP is built upon the Process Safety Management Program (PSM). The ECUA formed a PSM Committee to review the requirements of the Occupational Safety and Health Administration's regulation on Process Safety Management found at 29 CFR 1910.119, and to formulate a Process Safety Management (PSM) Plan. The Process Safety Management Committee comprises supervisor and employee representatives from the three wastewater treatment plants (WWTP's), Water Production and the Instrument/Electrical Division. The committee used staff assistance from Support Services, Internal Programs and the Risk Management/Safety Office. The first requirement of the PSM regulation is the performance of a Process Hazard Analysis (PHA). The initial step of the PHA was the identification of toxic and/or flammable substances that may fall under the standard. Following a review of the substances in use at ECUA, the committee identified chlorine and sulfur dioxi de as the only two substances used by ECUA that meet the criteria for inclusion in the PSM Plan and also held at a high enough threshold to be included in RMP. The committee as a whole performed the PHA with additional participation from employees whose work involves chlorine and sulfur dioxide and who were not committee members. Nearly all of the committee members have many years of experience dealing with chlorine and sulfur dioxide systems. After the substances were identified, the next step was the compilation of written process safety information. This was done for each plant and for water wells in Water Production (the wells were not covered sites). The information reviewed included manufacturers' maintenance manuals, the Chlorine Institute Manual, Material Safety Data Sheets, and various chlorine safety manuals. Because of the similarity of the hazards presented by the two chemicals and the similarity of the delivery systems it was decided that the qualitative "what-if? /checklist" method of hazard analysis would be appropriate and that the hazard analysis for the two chemicals would be identical. The PHA revealed that the most likely cause of a catastrophic release of either chemical would be failure of the container or of one of its components, i.e., the valves or fusible plugs. Delivery system leaks were determined to be easier to control and stop and likely not to be catastrophic. In fact one of the actions taken by ECUA was to install automatic shut-off valves on all chlorine and sulfur dioxide cylinders which provide remote closure of the valves on the cylinders which immediately minimizes any delivery system leaks. The operations involving ECUA personnel that present the greatest possibilities of container failure are unloading of all sizes of cylinders and changing of one-ton containers. In these operations the containers may be as high as eight feet off the ground. The changing procedure requires lifting one-ton containers and moving them over on-line containers. There have been equipment failures in the past in which one-ton and 150-pound containers have dropped from various heights, in some cases striking other cylinders. Other possibilities for container failure include fires, such as occurred at the Scenic Hills facility (now closed) and storm surge from hurricanes tearing containers loose and hitting them against buildings or other objects. The next requirement of the PSM regulation was the development of operating procedures that would ensure that operations involving the subject chemicals are conducted safely. Water Production and each WWTP have site specific operating procedures. The committee developed generic procedures to cover loading and unloading as well as cylinder changes in order to be sure that all safety issues are covered and documented. These procedures also cover cylinder inspection to assure that faulty cylinders are not brought on-site by vendors. All operations employees in Water R eclamation and Water Production are trained in chlorine and sulfur dioxide safety and handling as a matter of course. However, the regulation requires more in-depth training and documentation. A list of subjects and the personnel to be trained was developed and has been forwarded to ECUA Internal Programs/Training. The PSM regulation requires ECUA to evaluate past safety experience of contractors performing work on or near affected systems. It also requires ECUA to maintain a contract employee injury and illness log and to control entrance, presence and exit of contract employees at affected sites. The PSM Plan also requires a preconstruction conference with the selected contractor to discuss the PSM issues and to provide information concerning ECUA safety policies, on site control, confined space, hot work permits, emergency response plus chemical hazards. The PSM Plan requires the contractor to certify that all on-site contractor employees have received training on these poli cies and to document the training. The Plan also requires the appointment of an ECUA Site Control Officer to assure compliance with PSM policies' on-site. The PSM Plan requires that bid specifications for the purchase of chlorine and sulfur dioxide require that all potential supply vendors follow industry standard quality control procedures. This is required as part of the mechanical integrity requirements of the regulation. In addition to the initial requirements there are ongoing mandates of the PSM regulation. These include refresher training of affected employees every three years, PHA review every five years, inspection and tests of PSM affected systems, management of change procedures, pre-startup safety review for PSM-covered systems, incident investigations for PSM-covered substances and compliance audits every three years. In terms of emergency response to an actual leak, the written emergency response plan requires ECUA employees to make the first response with Supervisory Control and Data Aquisition employees monitoring on the computer system and telephone. The emergency number 911 will be callled in case of any leak thus notifying Escambia County Emergency Management (ECEM). If the leak is handled by on-sight employees then ECEM will be called and notified that the leak is controlled. If the leak is beyond our capacity ECEM will be notified and send other hazardous materials firms and organizations they have agreements with. Offsite consequence analysis was performed and came out the same for both chemicals. The population numbers given are for total population within the potential evacuation zone. The worst case scenario includes the population of Gulf Breeze, FL along with the population of Pensacola, FL. |