V(B) Approval for the Process Hazard Analysis at 1800 AD Mims Rd Wastewater Treatment Facility and the Decommissioning of Jamela Water Treatment Plant I
Agenda 05-04-04
[tem.V B
Mayor S�'e center of Good��� Commissioners
S. Scott Vandergrift Danny Howell, District 1
#:+.esu^., �'�,., - ;
(� Scott Anderson, District 2
Acting City Manager , Rusty Johnson, District 3
V. Gene Williford ,� = Nancy J. Parker, District 4
STAFF REPORT
TO: The Honorable Mayor and City Commissioners
FROM: Robert Holland, Utilities Superintendent
THROUGH: David A. Wheeler, P.E., Director of Public Works
DATE: April 26, 2004
RE: Process Hazard Analysis at 1800 A.D. Mims Road
Wastewater Treatment Facility
ISSUE:
Should the Mayor and City Commissioners approve the Process Safety Management (PSM)
and the Risk Management Plan (RMP) for the chlorine processes at the Wastewater Treatment
Plant located at 1800 A.D. Mims Road and the decommissioning of the Jamela Water
Treatment Plant as proposed by Golder and Associates?
BACKGROUND:
The EPA,s rule, 40 CFR Part 68, lists chlorine as a regulated toxic substance with a stated
threshold quantity of 2500 lbs. Since the chlorination processes at Ocoee's Jamela Water Plant
and the Wastewater Treatment Plant contain greater than 2,500 lbs. Of chlorine, both processes
were subject to the RMP rule. In May 1999, The City of Ocoee contracted with Golder to provide
the RMP services necessary to comply with the EPA's initial RMP Submittal deadline of June
21, 1999, for both plants. Under that contract, Golder performed the Offsite Consequence
Analysis (OCA) required by the RMP rule, prepared the required RMP* Submit file and assisted
Ocoee in submitting file to the EPA by the June 21, 1999, deadline. The following year, Golder
assisted the City of Ocoee in developing the RMP Prevention Programs required for each of the
sites to further improve Ocoee's compliance with the RMP rule.
Both the RMP rule and PSM Standard require that certain actions occur at periodic intervals.
Additionally, the RMP rule required that the RMP Submittal be updated at least once every 5
years. The five-year anniversary for the Submittals is June 21, 2004. For this reason we are
requesting that this proposal providing for RMP Submittal and other RMP/PSM periodic services
be approved by the Commission. Since the City of Ocoee no longer has chlorine gas at the
Jamela site, the scope of work will be provided for the Wastewater Plant site only. For the
Jamela Water Treatment Plant, Golder will provide a letter required to de-register Jamela from
the EPA's RMP database.
DISCUSSION:
Golder and Associates will review Offsite Consequence Analyses, Update the population and
environmental receptor data, collect RMP information, complete the RMP submittal and prepare
the RMP report. The detailed proposed scope of work has been provided for your review
electronically, the total cost for all tasks outlined in the scope of work is $13,225.00 to be paid
from the Water Contingency fund.
STAFF RECOMMENDATION:
Staff recommends that the City Commission approve the proposed scope of work from Golder
and Associates and that the work be implemented as quickly as possible as the June 21, 2004
date is quickly approaching.
t
PROPOSED SCOPE OF WORK
Golder proposes to perform the following to complete the scope of work.
Task 1 —Process Hazard Analysis
As part of their PSM Program, Ocoee performed a Process Hazard Analysis (PHA) on the
chlorine process at Mims. The PSM Standard requires that PHAs be reviewed and revalidated
every five years and the PHA at Mims is now due for revalidation. Therefore, Ocoee has
requested that Golder provide a proposal for leading a PHA team through the PHA revalidation
process at Mims.
Golder proposes to provide a PHA Leader to lead the PHA revalidation for chlorine process at
Mims. The PHA team will be comprised of Ocoee employees chosen by the facility. Golder will
use the What-If/Checklist PHA technique, incorporating what-if questions from PHAs of
processes previously analyzed by Golder, along with a semi-quantitative risk-ranking technique.
Golder estimates that the PHA revalidation will require one 3 to 4-hour meeting to review and
revise the initial PHA of the process. The revalidation will satisfy the requirements of the PSM
Standard paragraph (e) 6. Golder will use a laptop computer for recording the PHA revalidation
session notes. Within 4 weeks of the PHA, Golder will deliver a draft PHA Revalidation Report
for Ocoee's review and comment. Upon receipt of Ocoee's approval of the draft, Golder will
prepare the final PHA Revalidation Report.
Golder assumes that during the PHA revalidation, Ocoee will provide all Process Safety
Information needed, including Piping and Instrumentation Diagrams, equipment information, and
process technology information. Ocoee will also provide access to Operating Procedures, the
Site Emergency Response Plan, Management of Change documentation, PSM Compliance
Audits, and any other PSM-related documentation that may be referenced during the PHA.
Task 2 -RMP Evaluation and Submittal
The RMP rule requires that Ocoee review and update the Offsite Consequence Analyses (OCAs)
for its facilities at least once every five years. Because Ocoee submitted the first RMP for Mims
June 21, 1999, the updated RMP is due by June 21, 2004. To assist Ocoee in complying with
this requirement, Golder proposes to perform the following tasks for the Mims Water Plant:
• Review the original Offsite Consequence Analyses (OCAS) - If there have been no
changes to the process, and the current worst case and alternative case scenario OCAs
are determined to be valid, Golder will not perform new OCAs. If the OCAs require
revision, Golder can provide ervices to do the required analysis; a separate quote will be
submitted for this task at the time this determination is made.
• Update the population and environmental receptor data-Golder will use the OCA results
and Landview 5 software to update the population data associated with the calculated
worst case and alternative case scenario endpoint distance for the process. Because new
information is available from the 2000 Census,the population data must be updated even
if the OCA results are not changed as a result of the review. Golder will also use USGS
Topographical maps to verify the environmental receptor data reported on the original
RMP Submittal. Golder will update the environmental receptor data if necessary.
• Collect other RMP information-Golder will collect the Accident History and Prevention
Program information from Ocoee personnel during the site visit made for the PHA task.
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The City of Ocoee April 15, 2004
Mr. Robert Holland -2 - PO4-2709
• Complete RMP Submittal -Upon completion of the tasks above, Golder will prepare the
updated RMP Submittal using the EPA developed software RMP*SUBMIT 2004 and
provide it to Ocoee for their review. Upon Ocoee's approval of the RMP Submittal
document, Golder will prepare the final Submittal and assist Ocoee in submitting it to the
EPA by the appropriate deadline.
• Prepare RMP Report — Golder will prepare a report describing the OCA technique,
assumptions, and results. The report will include the population data, and other backup
information required by the RMP rule. The report will also include a complete copy of
the updated RMP Submittal, in printed form and as an electronic database file.
Because Ocoee no longer operates the Jamela Water Plant, the facility can be removed from the
EPA's RMP database. For this facility, Golder will prepare an RMP de-registration letter for
Ocoee to sign and send to the EPA.
Compliance Audit
The PSM and RMP rules require that Compliance Audits of the programs be performed at least
once every three years. Golder proposes to perform an audit of the Mims PSM/RMP Prevention
Program to meet this requirement. The audit will include development of the audit protocol, a
review of the written PSM/RMP Prevention Program, a review of the RMP documentation,
observations of relevant operations, interviews of facility employees, a review of relevant
records, and the preparation of an audit report. By performing this audit, Golder and Ocoee will
satisfy the periodic auditing requirement of the PSM Standard and RMP Rule.
Upon completion of the audit, Golder will prepare report of the findings. In the audit report,
Golder will describe the audit procedure and list the findings, including program highlights as
well as problem areas. If any deficiencies are found, Golder will describe the activities,
procedures, records, or training that must be implemented to bring Ocoee into full compliance.
The final report will include an RMP compliance audit certification form following the format
recommended by the Florida Department of Community Affairs (DCA). Golder will deliver to
Ocoee two copies of the draft PSM/RMP Audit Report within four weeks of the audit completion
date. Upon receipt of Ocoee's comments, Golder will prepare the draft report.
The following table outlines the scope of each audit.
Audit Scope
Audit Stage Description
Audit Scope • All 14 PSM Elements.
• A review of RMP documentation.
• Chlorine process at Mims
• All departments that have PSM and RMP responsibilities.
Audit Preparation • Prepare audit forms to reflect facility work scope.
The Opening Meeting • Review audit scope and objectives with the Senior Project
Engineer.
• Confirm interview and site tour schedules.
The Audit • Discuss PSM/RMP related procedures with appropriate
Golder Associates
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The City of Ocoee April 15, 2004
Mr. Robert Holland -3 - PO4-2709
Audit Stage Description
department representatives.
• Review existing PSM Manual/Prevention Program Manual.
• Review Process Safety Information on covered processes
(drawings, equipment specifications, chemical hazard
information, and process information).
• Review existing PHA.
• Review written operating procedures.
• Review maintenance plan,procedures, and records.
• Review sample of operator and maintenance training records.
• Review contractor procedures and records.
• Review Emergency Response Plan.
• Review Hot Work Permit procedure and other safe work
practices.
• Interview employees of the covered process area.
• Interview contractors, if available.
• Tour process area; observe equipment and operations.
The Closing Meeting • Informal, verbal report of findings to those with PSM/RMP
responsibility.
COST AND SCHEDULE
Golder proposes to provide Ocoee with the services described herein on a time and materials
basis for a total estimated cost not to exceed $15,820. Approximate cost per task is outlined
below:
Task Task Proposed Cost
001 Mims PHA $4275
002 Mims RMP Submittal and Jamela De-
Registration Letter $2500
003 Mims Compliance Audits $6450
Total for All Tasks $13,225
Please see Table 1 for a detailed cost estimate. Golder will bill Ocoee monthly for the work
performed during the month in accordance with the Professional Fee Schedule and the Terms and
Conditions attached. Insurance and indemnity items are included in the Terms and Conditions.
The attached Proposal Acceptance Form is structured to allow Ocoee to consider portions of the
scope of work outlined in this proposal separately. To authorize Golder to begin this work,
please sign and return both copies of the Proposal Acceptance Form. Golder will sign both
originals and return one to Ocoee.
Upon receipt of written notification of project award, Golder will develop a detailed schedule in
coordination with Ocoee staff. All tasks must be completed by June 18, 2004.
Golder Associates