2013 AWWA IMS Annual Conference September 12, 2013

Presented by:

Bryon Elwell, Director ABS Consulting

September 12, 2013 2013 AWWA IMS 1

PSM/RMP of Water/Wastewater Utilities

Hazardous Chemical Processes

AGENDA 1. Regulated Water/Wastewater Utilities -

Hazardous Chemical Processes 2. EPA’s RMP Program Overview 3. OSHA’s PSM Overview 4. Chemical Security Areas of Concern: Security RBPSs Chlorine System Example

5. Wastewater Utility Case Study for Chlorine: Process Hazard Analysis Compliance Audit

6. Summary of RMP/PSM Security Threat Issues Affecting Water/Wastewater Utilities

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Regulated Water Sector Utilities & Hazardous Chemicals

Current Regulations covering W/WW Facilities EPA’s Risk Management Plan (RMP) EPA’s Clean Air Act OSHA’s Process Safety Management (PSM)

Total RMP regulated W/WW Facilities 3,200 to 4,900

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Regulated Water Sector Utilities & Hazardous Chemicals

Types/#s of Hazardous Chemicals at W/WW Utilities Chemical STQ (lbs) Water Wastewater Chlorine (Cl2) 2,500 2,668 2,638 Methane 10,000 0 200 Ammonia (A) 10,000 183 0 Sulfur Dioxide 5,000 4 107 Ammonia-20% 20,000 41 0 Hydrochloric 15,000 4 0

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Total Water Sector Treatment Facilities with STQ of 2500 lbs. Chlorine-Release 2,934:

Drinking Water Facilities 1,7773

Wastewater Facilities 1,1573

3 CRS Report on Chemical Facility Security (Aug. 2, 2006) (numbers based on June 1, 2005 EPA RMP database)

Regulated Water Sector Utilities & Hazardous Chemicals

Chlor-Alkali Industry Chlorine production generally involves making chlorine and caustic from salt (NaCl or KCl), hence the name Chlor-Alkali industry:

2 NaCl (or KCl) + 2 H2O → Cl2 + H2 + 2 NaOH (or KOH)

Large quantities of chlorine are stored as a refrigerated liquid (boiling point -29°F) Chlorine is generally shipped in barges, 90 ton rail cars, 1 ton containers, and 150 lb cylinders

Chlor-Alkali Industry (contd.)

Chlor-Alkali Industry (contd.)

Chlorine has innumerable uses, including water and wastewater treatment, hydrochloric acid manufacture, bleach production, and hundreds of chlorinated chemical products

Chlor-Alkali Industry (contd.) • Recent chlorine release events:

• Graniteville, South Carolina rail accident (9 deaths, 240 injured, 5,500 evacuated, 2 Trains crashed 1/6/05)

• Festus, Missouri hose failure (3 injuries & 63 med treatment, transfer hose ruptured, 48,000 lbs. released 8/14/02)

• In World War I, it was used with limited success (along with phosgene) as a chemical weapon (Bertholite)

• Chlorine has been used in Iraq as a component in vehicle-borne IEDs

EPA’s RMP Program Overview EPA RMP Regulation (40 CFR 68) Subpart A General Subpart B Hazard Assessment Subpart C Program 2 Prevention Subpart D Program 3 Prevention Subpart E Emergency Response Subpart F Regulated Substances for Accidental

Release Prevention Subpart G Risk Management Subpart H Other Requirements Appendix A Table of Toxic Endpoints

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EPA’s RMP Program Overview (Contd.) Subpart B Hazard Assessment Offsite Consequence Analysis (OCA) Parameters Worst-Case Release Scenario Analysis Alternative Release Scenario Analysis Defining Offsite Impacts – Population Defining Offsite Impacts – Environment Review & Update OCA every 5 years OCA Records must be kept 5-Year Accident History

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EPA’s RMP Program Overview (Contd.) EPA RMP Regulation (40 CFR 68) 3 Program Levels of Applicability

Program Level 1: No release of RMP covered chemical in last 5 years AND Worst Case Release Scenario’s impact distance does not extend off site

Program Level 2: Not Level 1, but covered by PSM regulation and not on EPA’s Industry Codes designated as High Risk

Program Level 3: Not Level 1, but either covered by PSM regulation or on EPA’s Industry Codes designated as High Risk

Most Water/Wastewater Facilities with RMP covered chemicals fall into Program Level 3

Program Levels 2 & 3 have specific Accident Prevention Requirements Level 2 per Subpart C of 40 CFR 68 Level 3 per Subpart D of 40 CFR 68

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EPA’s RMP Program Overview (Contd.) Program Level 2 Subpart C Requirements: Safety Information Maintenance Hazard Review Compliance Audit Operating Procedures Incident Investigation Program Level 3 Subpart D Requirements: Process safety information Pre-startup Review Process hazard analysis Compliance audits Operating procedures Incident investigation Training Employee participation Mechanical Integrity Hot work permit Management of change Contractors

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EPA’s RMP Program Overview (Contd.) Program Level 3 has 12 of OSHA’s 14 PSM Elements EPA focus on protecting public vs. personnel in

workplace with OSHA 2 omitted elements: Trade Secrets & Emergency

Response RMP Subpart E defines Emergency Response

Requirements for Program Levels 2 & 3 Process Hazard Analysis Requirements: Program Level 2 – Hazard Review must be updated

when major change occurs Program Level 3 – PHAs must be

updated/revalidated every 5 years

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EPA’s RMP Program Overview (Contd.) Subpart G Risk Management Plan Submission Executive Summary Registration Offsite consequence analysis (OCA) Five-year accident history Prevention Program/Program 2 or 3 Emergency response program Certification Updates Required Corrections

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EPA’s RMP Program Overview (Contd.) Appendix A Table of Toxic Endpoints CAS No. Chemical Name Toxic Endpoint (mg/L) – used for OCA determination Tables 1 & 2 List of Regulated Toxic Substances & Threshold Quantities for Accidental Release Alphabetical and CAS Number, respectively Chemical Name CAS No. Threshold Quantity (lbs.) Basis for Listing (a, b, c, d, e) Tables 3 & 4 for Flammable Substances (10,000 lbs.) Same elements as Tables 1 & 2 16

PSM Overview

OSHA’s PSM programs are intended to: (1) Help prevent catastrophic releases of highly

hazardous chemicals and

(2) Reduce their potential to pose serious danger to personnel, the public, or the environment.

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Worst Case Safety Events

Bhopal, India (1984) – toxic release pesticide gases including MIC (3 to 4 thousand immediate fatalities) Mexico City (1984) – pipeline leak in LPG facility, multiple fireballs/boiling liquid expanding vapor explosions (BLEVEs) – 600 fatalities Texas City (1947) – ammonium nitrate vessel explosion – 600 fatalities, 25% of town residents injured, blast leveled nearly 1,000 bldgs & 15’ wave water detected over 100 miles away

Bottle Storage Area – Look Closely at upper left corner

Bottle Storage – 3 Minutes Later

PSM Overview (Contd.)

PSM Program has 14 Elements (RMP 12 of 14, Trade Secrets and Emergency Response - NIC): 1. PSI 9. MOC 2. PHA 10. II 3. OP 11. EP 4. TNG 12. CA 5. CONT 13. TS 6. PSSR 14. EPR 7. MI 8. HW

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PSM Overview (Contd.) Process Hazard Analysis (PHA) All findings of PHA team must be resolved All PHA findings and actions taken must be

communicated to affected employees Facility must prioritize its PHA schedule PHAs must use one or more of following: What-If Checklist What-If Checklist HAZOP FMEA Fault Tree Analysis Appropriate Equivalent Method

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PSM Overview (Contd.) PHA: 7 Areas required to be addressed

1. Hazards of process 2. Identify any previous incidents with likely

potential catastrophic consequences in workplace

3. Engineering & administrative controls applicable to hazards

4. Consequences of failure of engineering & admin. controls

5. Facility siting 6. Human factors 7. Qualitative evaluation of range of possible health

& safety effects of failure of controls on employees in workplace

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PSM Overview (Contd.) Compliance Audits (CA) CA required on a 3-year cycle for all covered

processes Personnel who work in covered process access to

CA There can be a number of valid responses to audit

findings including “No action is necessary” CA should follow Facility’s policy regarding safety

orientations or emergency plan training EPA RMP regulation applies to additional chemicals

and chemical concentrations compared to OSHA PHAs of RMP-covered processes are required to

address potential offsite effects

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Chemical Security Areas of Concern Security Risk Based Performance Standards

(RBPSs): 1 Restrict Area Perimeter 2 Secure Site Assets 3 Screen and Control Access 4 Deter, Detect, and Delay 5 Shipping, Receipt, and Storage 6 Theft and Diversion 7 Sabotage 8 Cyber 9 Response

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10 Monitoring 11 Training 12 Personnel Surety 13 Elevated Threats 14 Specific Threats 15 Reporting 16 Security Incidents 17 Officials and

Organization 18 Records

Chemical Security Areas of Concern (Contd.)

Chlorine System Example (Case Study) Security Areas of Concern: Theft/Diversion of Hazardous Chemicals (Chlorine):

Public Health & Safety Release of Hazardous Chemicals at W/WW Facilities:

Employee Health & Safety Public Health & Safety

Hazardous Chemical Safety Features only for largest chemical container: Secondary Containment Chemical Scrubber

Overdosing of Chemicals: Public Health & Safety Treatment Process Upset & Permit Violations Environmental Damage 26

Wastewater Utility Case Study for Chlorine

PHA & Compliance Audit for Wastewater Treatment Plant Chlorine system for wastewater treatment and

effluent disinfection PHA Covered Process Components: Chlorine Tanker – Delivery Vehicle of Cl2

Compressed Air System (offloading of Tanker) Chlorine Unloading Line (offloading of Tanker) Chlorine Storage Tanks - 2 Bulk Storage Tanks Chlorine Feed Line Chlorinator through Dosing Points

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Wastewater Utility Case Study for Chlorine (Contd.)

PHA for Wastewater Treatment Plant (Contd.) Covered Process Components Assessment: Deviation Areas Causes Consequences Safeguards Action Items

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Wastewater Utility Case Study for Chlorine (Contd.)

PHA - Chlorine Tanker Example (Case Study): Deviation Areas: Loss of Containment Causes: PRV failure, Failure of valves or piping, Driver

error, Vehicular crash into tanker, Deviation during startup

Consequences: Release of Chlorine Safeguards: Supplier (Thatcher) mechanical integrity, Off

load same day as arrival of shipment, Tanker removed within 24 hr. after unloading, C kit for spill response, Refuse Tanker, if leaking or otherwise noticeable defect

Action Items: Verify supplier safeguards (get documentation from supplier)

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Wastewater Utility Case Study for Chlorine (Contd.)

PHA - Chlorine System Example (Case Study): Additional Action Items: Do not receive high pressure Chlorine Tanker load during

high temperatures Consider the need to install a moisture detector and

alarm on compressed air Verify if there is a high level alarm and shutdown on

chlorine tanks drawings only show level indication on scales Formalize and document the mechanical integrity

program for chlorine hoses Establish tank inspection per API and/or Chlorine Institute

.

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Wastewater Utility Case Study for Chlorine (Contd.)

PHA for Wastewater Treatment Plant (Contd.) HAZOP Utilities & Services Generic and inherent safeguards protecting

against or mitigating process material releases Facility Siting Checklist Human Factors Checklist

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Wastewater Utility Case Study for Chlorine (Contd.)

HAZOP Example (Case Study): Utilities & Services: Loss of electrical power –

Standby Generator (Chemical Bldg. & Utility Water) Facility Siting Checklist: Relief valves vent inside

building, HVAC & scrubber, no issues identified. Human Factors Checklist: Improving signage &

labeling - Consider providing a visual alarm in the compressor room. PPE requirements are trained but not well documented in procedures - Consider a means to document specific PPE requirements associated with a procedure or task.

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Wastewater Utility Case Study for Chlorine (Contd.)

Compliance Audit – Example (Case Study): Audit Findings & Recommendations: EP: Develop written Plan PSI: Revise Block Flow to include new systems (CL #3 and

#4), Document no process chemistry, Bio Control only, ID and document all Safe Operating Limits (SOL’s), Include consequences of deviation, Review and update “Final Clarifier and Chemical Building Owner’s Manual” to reflect current equipment, U-1 Forms (MFG Data) for Cl2 Tanks, Design Basis for PRV’s, Compliance of equipment with Recognized and Good Acceptable Engineering Practices (RAGAEP) PHA: System to track action items, Communication of actions

to operations, maintenance, and other employees

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Wastewater Utility Case Study for Chlorine (Contd.)

Compliance Audit – Example (Case Study): Audit Findings & Recommendations (Contd.): OP: Address all operating phases, Update switchover

procedures for new systems, Include operating limits and steps required to correct/avoid deviation, Include safety and health considerations, Safety systems and their function, Not readily available for operators, Periodic review, Annual certification SWP/HWP: Availability of procedures for SWP/HWP, Control

over entrance, Training (HWP, CSE) Training: Overview of process, Initial, Refresher, Documented

appropriately, All employees need to complete (safety), Records (specifically, non-CBT) to include: name, date and means to verify

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Wastewater Utility Case Study for Chlorine (Contd.)

Compliance Audit – Example (Case Study): Audit Findings & Recommendations (Contd.): Contractors: Training (Hazards of process, emergency

plans, access to chlorine building) (for other than projects?), Evaluation of contractors safety performance for other than projects (initial and periodic), Injury log, Evaluation of contractors to ensure they address their responsibilities in 1910.119 (n)(3) PSSR: Develop PSSR

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Wastewater Utility Case Study for Chlorine (Contd.)

Compliance Audit – Example (Case Study): Audit Findings & Recommendations (Contd.): MI: Cl2 Tanks, Cl2 Detector PM –Procedure (and others as

necessary), Documentation of Cl2 detector checks, Formal Inspection Test and Preventative Maintenance (ITPM) for all critical equipment (alarm procedure and PHA), Formalize and document training program for Mechanical Integrity (MI), Improve documentation of results of tests/inspections, Quality Assurance, Documenting hose inspections MOC: Improve current procedure to include all

requirements, Develop MOC form, Inform affected employees and contractors of changes, Ensure PSI updated, procedures updated

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Wastewater Utility Case Study for Chlorine (Contd.)

Compliance Audit – Example (Case Study): Audit Findings & Recommendations (Contd.): Incident Investigation: Formalize reporting and

documenting process incidents and near misses, 48 hours to start investigation, System to address and resolve action items, Review reports with affected personnel, Retain reports for 5 years (till next PHA) Emergency Planning and Response: Improve plan, Training

(both for ER Team and all employees), Proper equipment Personal Protection Equipment (PPE), Address coverage problems with emergency alarms (PA, Radios)

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Wastewater Utility Case Study for Chlorine (Contd.)

Compliance Audit – Example (Case Study): Audit Findings & Recommendations (Contd.): Compliance Audits: Ensure conducted every 3 years,

Certified – certification letter example to be provided by ABS, System for resolving recommendations in timely manner and documenting, Retain 2 most recent reports Trade Secrets: None Suggestion: “Compliance Calendar”

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Summary of RMP/PSM Security Threat Issues Affecting Water/Wastewater Utilities

Security Threat Issues affecting W/WW Facilities: Theft/Diversion of Hazardous Chemicals (Chlorine)

Public Health & Safety Release of Hazardous Chemicals at W/WW Facilities

Employee Health & Safety Public Health & Safety

Hazardous Chemical Safety Features only for largest chemical container: Secondary Containment Chemical Scrubber

Overdosing of Chemicals Public Health & Safety Treatment Process Upset & Permit Violations Environmental Damage

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Questions?

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Bryon Elwell, Director of Water/Wastewater Practice ABS Consulting 1111 Brickyard Road, Suite 103 Salt Lake City, UT 84106 (801) 333-7676 office, (801) 870-9709 cell belwell@absconsulting.com