Semper Water Treatment Facility - Executive Summary |
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Semper Water Treatment Facility RMP Plan Executive Summary Executive Summary This executive summary provides a brief overview of the Risk Management Program (RMP) and the associated policies at the Semper Water Treatment Facility owned and operated by the City of Westminster. Prevention and Response Policies The City of Westminster believes that it is important to provide a safe workplace to its employees and minimize the impact of its operations on the surrounding community and the environment. Accordingly, the City of Westminster has developed proactive safety and environmental programs, which are reliant upon active employee participation and management leadership and support. This same proactive philosophy was employed in the development and implementation of the Semper Water Treatment Facility RMP for the chlorine system. The City of Westminster has determined that the OSHA Process Safety Management standard will eventually apply to the personnel at the Semper Water Treatm ent Facility and therefore has prepared this RMP to comply with the RMP Program 3 requirements. By doing so, the City of Westminster affirms its proactive safety and environmental philosophy and acknowledges the inherent value of full RMP compliance. The RMP prevention program is arguably the most important element of the rule. Its program elements require the active participation of facility employees and management in conducting activities aimed at preventing accidental releases of regulated chemicals. If prevention activities could be completely successful, there would be no need for emergency response activities, since no releases would occur. Accordingly, a well-developed and properly-implemented prevention program will lower the possibility of an accidental release and minimize the consequences of a release should one occur. The City of Westminster takes an active role in preventing accidental releases at all of the facilities it operates by ensuring that its employees are well-informed regarding the hazards associated with the regulated processes (e.g., chlorine at the Semper Water Treatment Facility) and actively participated in comprehensive process hazard analyses. The employees that work on the chlorine system are properly trained in the safe operation of the covered processes and the safe handling of treatment chemicals. They are aided in this work by complete, understandable system operating procedures. The City of Westminster management understands its duty to provide a safe working environment and to take measures to prevent accidents that may have an effect on the surrounding community. This understanding is reflected in procedures described and referenced in the Semper Water Treatment Facility RMP procedures and policies. As for emergency response, the City of Westminster has established and maintained procedures for emergency notification and response. These are reviewed with employees on a periodic basis and revised to accommodate chan ges in staffing when they occur. Stationary Source and Regulated Substances The Semper Water Treatment Facility is located at 8900 Pierce Street, Jefferson County, Colorado. The Semper Water Treatment Facility utilizes chlorine to disinfect the water it produces for residential and industrial consumption. Treatment consists of coagulation, sedimentation, filtration and disinfection prior to pumping the finished water into the municipal distribution system. The Semper Water Treatment Facility utilizes chlorine as a biocide in the treatment of water. The chlorine is stored in one-ton containers with a maximum intended inventory of fifteen containers (30,000 pounds) on site. Therefore, the Semper Water Treatment Facility is regulated under the RMP rule due to the volume of chlorine stored and used at the facility. Release Scenarios Worst-case and alternative release scenarios have been determined after careful review of the regulation and consideration of the storage vessel confi guration at the facility. For the worst-case release scenario, the regulation is clear. The assumption is that a full one-ton container of chemical is released over a ten-minute period. No active mitigation may be considered. Worst-case meteorological conditions as specified in the RMP regulation are also assumed to be present. The release is also assumed to occur outdoors. For the alternative release scenario, the facility reviewed the consequences of a valve breaking off at the container connector during hookups in the storage area. No active mitigation was considered. Results of the off-site consequence analyses are described in Sections 2 and 3 of the RMP*Submit plan for the Semper Water Treatment Facility. Prevention Steps for Chlorine The prevention program and chemical-specific prevention steps are described in detail in the Semper Water Treatment Facility RMP manual. The prevention program includes the following elements: 7 Process safety information, which includes information pertaining to the hazards of chlorine in the process, process technology, and process equipment 7 Process hazard analysis (PHA), which includes a systematic evaluation (by an employee team) of: the hazards of the chlorine process, identification of previous process incidents, engineering and administrative controls, consequences of failure of the engineering and administrative controls, facility siting, human factors, and possible safety and health effects of failure of controls 7 Operating procedures, which include steps for each operating phase, operating limits, safety and health considerations, and safety systems and their functions 7 Training for each Semper Water Treatment Facility employee involved in operating the chlorine system 7 Mechanical integrity procedures to maintain the on-going integrity of the chlorine process equipment 7 Management of change procedures to manage changes (other than "replacements in kind") to the chlorine system 7 Pre-startup safet y review for additions or significant modifications to the chlorine process, or any new regulated chemical process 7 Compliance audits at least every three years from 1999 to evaluate Semper Water Treatment Facility RMP compliance 7 Incident investigation, to be conducted and documented for each incident that resulted in, or could have reasonably resulted in, a catastrophic release of chlorine from the Semper Water Treatment Facility 7 Employee participation in the development and implementation of the Semper Water Treatment Facility RMP, and employee access to RMP information 7 Hot work prohibition policy on or near the chlorine system when chlorine is present in the affected section of the process 7 Contractor management program, to ensure appropriate evaluation and selection of qualified contractors for work on or near the chlorine system, proper notification of contractors regarding known chlorine system hazards and the Semper Water Treatment Facility emergency evacuation plan , limited access to the chlorine process, and evaluation of contractor performance In addition to these elements, the chlorine storage room and the chlorine injection room at the Semper Water Treatment Facility are equipped with chlorine leak detection devices that continuously monitor the air for chlorine gas. If the chlorine sensor detects a specified level, audio and visual alarms will be activated. The alarm system is maintained and tested on a regular basis to ensure proper operation should there be a chlorine release. Management of Change procedures will be used for the upgrades to the chlorine system. Accident History Within the five-year period prior to the submittal of this RMP, there were no accidental releases of chlorine meeting the requirements of 40 CFR 68.42. Emergency Response Program This facility has established and maintains an emergency response program that is coordinated with local response agencies, including the Westminster Fire Department. The program is described in detail in the Semper Water Treatment Facility RMP manual and meets the requirements of 40 CFR 68.95, which include facility notification of emergency responders and evacuation. The goals of the program are to protect onsite employees from the hazardous effects of chemical releases and to minimize the effects of releases on the general public. The program is routinely reviewed and updated to reflect personnel and regulatory changes. Planned Changes for Improved Safety Ideas for changes to improve safety are actively sought from employees. Employee meetings that focus on safety issues are held regularly at the Semper Water Treatment Facility. Employees are encouraged and trained to recognize hazards and to present ideas to eliminate them or to minimize the potential consequences of those hazards. As part of the development of the Semper Water Treatment Facility program, process hazard analyses were conducted with key employees to meet the prevention program require ments. During these sessions, recommendations were made for the purpose of improving safety and preventing accidental chemical releases. Each recommendation has been or will be considered for implementation. Though not all recommendations may be implemented, all will be considered. The exercise has provided all affected employees with a heightened awareness of safety issues related to the covered process. |