Water Pollution Control Facility - Figueroa - Executive Summary |
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The City of Yuma, Arizona, in accordance with the U.S. E.P.A. Risk Management Program Rule for stationary sources with over 2,500 pounds of chlorine in a process, has established this written program for the Public Works Department Water Pollution Control Facility located at 289 North Figueroa, Yuma, Arizona 85364. The City is committed to safety and the protection of human health and the environment while serving our community. There has been no recorded chlorine emergency at this facility. To maintain the safety of our facility, the Public Works Department and the Water Pollution Control Facility have developed procedures, documentation, design and engineering controls, on-going training and program monitoring & evaluation. The Risk Management Plan addresses the 40 CFR 68 requirements for storage, handling and transfer of chlorine gas one Ton cylinders in a comprehensive approach designed to minimize the potential for chlorine release. This Risk Management Plan builds on the OSHA Process Safety Management Plan, Emergency Response Plan, and Standard Operating Procedures already in place at the facility. It includes worst case and alternative case scenarios developed through employee participation. Other participants in the Risk Management Program development include the Yuma Fire Department, and members of the City of Yuma's Environmental Advisory Alliance. The steps taken to obtain the information for this plan include performing a hazard assessment, developing or documenting existing programs for management of systems and change, prevention, emergency response, worst and alternative case scenarios. Included in this submittal are a five year accident history, an off-site consequences analysis including worst and alternative case scenarios, a checklist of dates for review, implementation and recordkeeping for the Risk Management Program, process safety information, process hazard analyses, process standard operating procedures, emergency action and cont rol plans, hot work, incident investigation, compliance audits, pre-startup safety reviews, and contractor information. The information obtained for the development of this plan was used to create the written Risk Management Program. The Risk Management Program will be implemented through initial and on-going training and employee participation in evaluation and implementation procedures. The information will be readily available to employees and local emergency agencies in notebook form containing all elements of the OSHA Process Safety and the EPA Risk Management Plans. This information will be further used to implement procedures in the chlorination process to ensure human health and environemtnal safety. Dialogue with local public safety agencies will incorporate the findings. Plant modifications will be based on their impact on the safety of the chlorine process, system, subsystems, equipment, and the offsite consequences. Some problem areas identified while developing our Process Safety Management Plan for the plant have been set on a timeline for correction. A listing of these items are included in the "Recommendations from the PHA" in the PSM manual. Discrepencies with the standard included the following. Storage area open to vandalism and weather mishaps. Lack of maintenance procedures to preserve the upkeep of the chlorine process regularly. Lack of traffic controls around the chlorine building. Improper ventilation of the chlorine building. PVC piping exposed to sunlight. Lack of monitoring of loading and unloading trchniques. MSDS files not regularly maintained. Local Hazmat team and employees have not rehearsed emergency situation drills. A lack of training all contractors in the dangers of working near or on the chlorine process. Many of the items noted above have already been addressed and corrected, and there is a timeline for addressing the remainder. A Hazmat team drill is also pending. The written Risk Management Plan will b e updated and revised as needed, and annually to ensure that the changes are managed, modifications and repairs are effective and efficient, and that employees are familiar with the procedures and safe operations of the facility. Records that support our Risk MAnagement Plan will be kept for no less than five years, and will be available through the Office of Risk Management and the Public works Department. The City of Yuma has chosen to establish an Emergency Action and Control Plan which involves the use of Hazmat trained firefighters from the local fire department. Water Pollution Control Facility employees should know what type of evacuation is necessary and what their role is in carrying out the plan. In some cases, where the emergency is grave, total immediate evacuation of nonessential employees is necessary. In other emergencies, a partial evacuation of others may be necessary for continued plant operation. In some cases, only those employees in the immediate area of a fi re may be expected to evacuate or move to a safe area such as when a local application fire suppression system discharge employee alarm is sounded. Employees must be sure that they know what is expected of them in all such emergency situations which have been planned in order to provide assurance for their safety from fire or other emergency. The Emergency Action and Control Plan contains the information needed to implement this program. In most emergency cases at the plant, the Yuma Fire Department will be responsible for performing rescue and medical duties. The Fire Department and Hazmat Team are also capable of handling all major situations which may include fire, first aid, chemical spiil or release. Standard Operating Procedures for the chlorine process are outlined in the Process Safety Management notebook and are documented to provide basic understanding and working knowledge of the chlorine system and the interdependence of the subsystems and equipment components essent ial to the system. SOPs are presented as a function of controls over the hazards associated with the chlroine process, engineering designs and the operation and maintenance of the systems and subsystems of the chlorination process. |