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Joint Regional Sewerage Board WWTP


Facility #1 : Joint Regional Sewerage Board

Basic Facility Info facility_Basic_Facility_Info help link help link  
Facility ID100000195399
Deregistered (Yes/No)No
Facility NameJoint Regional Sewerage Board WWTP
Street Address Line 1Ecology Lane
CityWest Haverstraw
Zip Code10993
CountyRockland County
113th Congressional DistrictNY17: New York 17
Owner or Operator NameJoint Regional Sewerage Board
Parent CompanyJoint Regional Sewerage Board
Number of RMP Submissions2

Most Recent Submission Info facility_Most_Recent_Submission_Info help link help link  
RMP ID1000023977
Submission Typerevised submission for facility
Submission Date10/06/2011
Reason For Submission5-year update (40 CFR 68.190(b)(1))
Process Toxic Amount Total (lbs)17,500
Process Flammable Amount Total (lbs)0
Process Amount Total (lbs)17,500
Number of Potential Offsite Consequence Processes1
Potential Offsite Consequence Toxic Amount Total (lbs)17,500
Potential Offsite Consequence Flammable Amount Total (lbs)0
Potential Offsite Consequence Amount Total (lbs)17,500
All Process NAICS22132
Exec Summary Submission Date10/06/2011

Executive Summary facility_Executive_Summary help link help link (Facility #1 : Joint Regional Sewerage Board , executive summary: all)

Executive Summary


The Occupational Safety and Health Administration (OSHA) issued regulation 29 CFR 1910.119, Process Safety Management (PSM) of Highly Hazardous Chemicals, in order to prevent or minimize the consequence of a catastrophic release of toxic, reactive, flammable, or explosive chemicals. The regulation requires a written plan to effectively communicate the hazards posed by processes involving hazardous chemicals.

The PSM regulations apply to any chemicals held in larger quantities than the ""threshold"" quantities identified in the regulations. The Joint Regional Sewerage Board Wastewater Treatment Plant ( JRSB WWTP) currently uses only one chemical in larger than the threshold quantity: chlorine (threshold quantity 1,500 pounds). A Process Safety Management (PSM) Plan addressing certain issues is required under 29 CFR 1910.119. The PSM plan must include the following topics:

A employee participation
A process safety information
A process hazard analysis
A operating procedures
A training
A contractors
A pre-startup safety review
A mechanical integrity
A hot work permits
A management of change
A incident investigation
A emergency planning and response
A compliance audits

The OSHA PSM plan is directed at protecting the health and safety of the employees working around the covered chemical process. The different parts of the PSM plan do not consider the possible off-site consequences of a problem with a covered chemical process. An additional program administered by the U.S. Environmental Protection Agency (USEPA) addresses the off-site consequences of problems at facilities with a covered chemical process. This additional program is called the Risk Management Program (RMP) and is described in 40 CFR 68. The information required for the RMP program is nearly identical to the information in the PSM, with one exception. The RMP includes sections regarding the off-site consequences of a chemical release at a facility.

The JRSB WWTP maintains this combined PSM/RMP plan to address the requirements of both the OSHA PSM program and the USEPA RMP program.


An obligation to comply with the PSM and the RMP regulations is incurred if a facility uses more than a threshold quantity of a covered chemical. Each regulation contains a list of covered chemicals, and each chemical has a threshold quantity. If a facility holds a listed chemical in a larger quantity than the threshold quantity, then the facility must have a PSM and RMP in place. The list of chemicals covered, and threshold quantities, is very similar from the PSM to the RMP programs. A significant difference between the programs involves the threshold quantity for chlorine.

PSM Threshold Quantity = 1,500 pounds (29 CFR 1910.119, Appendix A)
RMP Threshold Quantity = 2,500 pounds (40 CFR 68.130, Table 1)

The JRSB WWTP uses chlorine in quantities much larger than either threshold quantity shown above, so both PSM and RMP regulations apply. This document includes all of the information required to describe both the PSM and RMP programs at the JRSB WWTP. All information required for the OSHA PSM program is listed first, in Chapter 2; the additional information for the USEPA RMP program follows in Chapter 3. Recordkeeping requirements for each program are shown in a separate section near the end of the report.


The JRSB WWTP is located on Ecology Lane in West Haverstraw, New York. The fenced facility uses chlorine to disinfect wastewater seasonally (May 15th through October 15th). The chlorine is stored in steel cylinders, each holding either 2,000 pounds (1 ton) or 150 pounds (lbs.) of the liquefied gaseous chemical. The maximum inventory capacity at the site is nine 2,000-lb. cylinders in the Chlorine Building, but generally the JRSB WWTP keeps an operational inventory of no more than eight cylinders on site. Ten 150-lb. cylinders are kept in the Sludge Treatment Building. Th
is equates to a maximum on site inventory of 19,500 lbs. of liquefied gaseous chlorine and a maximum operational inventory of 17,500 lbs.

Chlorine is the only chemical stored and used at the JRSB WWTP that is regulated by OSHA's PSM and RMP regulations.

Submission - Other Facility Info facility_Submission_-_Other_Facility_Info help link help link  
Number of Full Time Employees10
Owner or Operator NameJoint Regional Sewerage Board
Owner or Operator Address Line 1Ecology Lane
Owner or Operator CityWest Haverstraw
Owner or Operator StateNY
Owner or Operator Zip10993
Parent Dun and Bradstreet Number0
Second Parent Dun and Bradstreet Number0
Number of Full Time Employees10
Number of FTE CBI FlagNo
Covered by OSHA PSM StandardYes
Covered by EPCRA Section 302Yes
Covered by CAA Title VNo
Last Safety Inspection Date20040501
Last Safety Inspection ByOSHA
OSHA Star or Merit RankingNo
LEPC NameRockland County LEPC

Submission - Contact Info facility_Submission_-_Contact_Info help link help link (Facility #1 : Joint Regional Sewerage Board , RMP submission #1 : 20111006)
Owner or Operator Phone8454295715
Facility Dun and Bradstreet Number0
RMP ContactPatrick Brady
RMP Contact TitleDirector
RMP Contact
RMP Preparer NameDerek J Henderson
RMP Preparer Address Line 1One Remington Park Drive
RMP Preparer CityCazenovia
RMP Preparer StateNY
RMP Preparer Zip13035
RMP Preparer Phone3156558161

Submission - Additional Info facility_Submission_-_Additional_Info help link help link  
RMP Complete FlagYes
Predictive FilingNo
No RMP Accidents Last 5 YearsNo
Complete Check Date20111006
Error Report Datenull
Postmark Date20111006
Anniversary Date20161006
Confidential Business InformationNo

Submission - Lat/Long Info facility_Submission_-_Lat_Long_Info help link help link (Facility #1 : Joint Regional Sewerage Board , RMP submission #1 : 20111006)
Valid Lat/LongYes
Lat/Long MethodInterpolation - Satellite
Lat/Long Location TypeCenter of Facility

Submission - Counts and Totals facility_Submission_-_Counts_and_Totals help link help link  
Number of RMP Accidents0
RMP Accident Flammable Total (lbs)0
RMP Accident Toxic Total (lbs)0
RMP Accident Amount Total (lbs)0
Number of RMP Accidents0
Number of Processes1
Number of Process Chemicals0
Number of Toxic Worst-case Scenarios1
Number of Toxic Alternate Case Scenarios1
Number of Flammable Worst-case Scenarios0
Number of Flammable Alternate Case Scenarios0
RMP Accident Flammable Total (lbs)0
RMP Accident Toxic Total (lbs)0
RMP Accident Amount Total (lbs)0
Total RMP Accident Deaths0
Total RMP Accident Injuries0
Total RMP Accident Evacuated/Sheltering In Place0
Total RMP Accident Property Damage$0

Processes facility_Processes help link help link (Facility #1 : Joint Regional Sewerage Board , RMP submission #1 : 20111006, process #1 : Chlorine Building)
Process DescriptionChlorine Building
Program Level3
Confidential Business InformationNo
Toxic Amount Total (lbs)17,500
Flammable Amount Total (lbs)0
Process Amount Total (lbs)17,500
Number of Process Chemicals0
Number of Toxic Worst-Case Scenarios1
Number of Toxic Alternate Scenarios1
Number of Flammable Worst-Case Scenarios0
Number of Flammable Alternate Scenarios0

Process Chemicals facility_Process_Chemicals help link help link  
Process Chemical IDChlorine
CAS number007782505
Chemical TypeToxic
Process Chemical Amount (lbs)17,500
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link (Facility #1 : Joint Regional Sewerage Board , RMP submission #1 : 20111006, process #1 : Chlorine Building, process chemical #2)
Process Chemical IDPublic OCA Chemical
CAS number000000000
Process Chemical Amount (lbs)0
Confidential Business InformationNo

Worst-Case Toxic Scenarios facility_Worst-Case_Toxic_Scenarios help link help link  
Percent Weight (Within Mixture)100
Physical StateGas
Model UsedEPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
Release Duration (minutes)10
Wind Speed (meters/sec)1.5
Atmospheric Stability ClassF
Passive Mitigation - DikesNo
Passive Mitigation - EnclosuresNo
Passive Mitigation - BermsNo
Passive Mitigation - DrainsNo
Passive Mitigation - SumpsNo
Confidential Business InformationNo

Alternate Case Toxic Scenarios facility_Alternate_Case_Toxic_Scenarios help link help link (Facility #1 : Joint Regional Sewerage Board , RMP submission #1 : 20111006, process #1 : Chlorine Building, process chemical #2, alternate toxic scenario #1)
Percent Weight (Within Mixture)100
Physical StateGas liquified by pressure
Model UsedEPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
Wind Speed3
Atmospheric Stability ClassD
Passive Mitigation - DikesNo
Passive Mitigation - EnclosuresNo
Passive Mitigation - BermsNo
Passive Mitigation - DrainsNo
Passive Mitigation - SumpsNo
Active Mitigation - SprinklersNo
Active Mitigation - Deluge SystemsNo
Active Mitigation - Water CurtainNo
Active Mitigation - NeutralizationNo
Active Mitigation - Excess Flow ValvesNo
Active Mitigation - FlaresNo
Active Mitigation - ScrubbersNo
Active Mitigation - Emergency ShutdownNo
Confidential Business InformationNo

Process NAICS facility_Process_NAICS help link help link (Facility #1 : Joint Regional Sewerage Board , RMP submission #1 : 20111006, process #1 : Chlorine Building, process NAICS code #1 : 22132)
NAICS Code22132: Sewage Treatment Facilities

Prevention Program 3 facility_Prevention_Program_3 help link help link  
Safety Info Review Date20110930
PHA Update Date20110930
PHA Technique - What IfNo
PHA Technique - ChecklistNo
PHA Technique - What If/ChecklistYes
PHA Technique - HAZOPNo
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Change Completion Date20110930
Hazard Identified - Toxic ReleaseNo
Hazard Identified - FireNo
Hazard Identified - ExplosionNo
Hazard Identified - Runaway ReactionNo
Hazard Identified - PolymerizationNo
Hazard Identified - OverpressureNo
Hazard Identified - CorrosionNo
Hazard Identified - OverfillingNo
Hazard Identified - ContaminationYes
Hazard Identified - Equipment FailureNo
Hazard Identified - Cooling LossNo
Hazard Identified - EarthquakeNo
Hazard Identified - FloodNo
Hazard Identified - TornadoNo
Hazard Identified - HurricaneNo
Process Controls - VentsYes
Process Controls - Relief ValvesYes
Process Controls - Check ValvesYes
Process Controls - ScrubbersNo
Process Controls - FlaresNo
Process Controls - Manual ShutoffsYes
Process Controls - Auto ShutoffsYes
Process Controls - InterlocksNo
Process Controls - AlarmsYes
Process Controls - Keyed BypassNo
Process Controls - Emergency AirNo
Process Controls - Emergency PowerNo
Process Controls - Backup PumpNo
Process Controls - GroundingNo
Process Controls - Inhibitor AdditionNo
Process Controls - Rupture DisksNo
Process Controls - Excess Flow DevicesNo
Process Controls - Quench SystemNo
Process Controls - Purge SystemNo
Process Controls - NoneNo
Mitigation Systems - SprinklersNo
Mitigation Systems - DikesNo
Mitigation Systems - Fire WallsNo
Mitigation Systems - Blast WallsNo
Mitigation Systems - Deluge SystemsNo
Mitigation Systems - Water CurtainsNo
Mitigation Systems - EnclosureYes
Mitigation Systems - NeutralizationNo
Mitigation Systems - NoneNo
Monitoring Systems - Process AreaYes
Monitoring Systems - PerimeterNo
Monitoring Systems - NoneNo
Changes Since PHA - Reduced InventoryNo
Changes Since PHA - Increased InventoryNo
Changes Since PHA - Process ParametersNo
Changes Since PHA - Process ControlsNo
Changes Since PHA - Process DetectionYes
Changes Since PHA - Perimeter MonitoringNo
Changes Since PHA - Mitigation SystemsNo
Changes Since PHA - None RecommendedNo
Changes Since PHA - NoneNo
Procedure Review Date20110907
Training Review Date20110907
Type of Training - ClassroomNo
Type of Training - On the JobYes
Competency Testing - Written TestsNo
Competency Testing - Oral TestsNo
Competency Testing - DemonstrationNo
Competency Testing - ObservationYes
Maintenance Review Date20110907
Maintenance Inspection Date20110907
Equipment Testedchlorine detectors
Management of Change Most Recent Datenull
Management of Change Review Date20110907
Pre-startup Review Date20110907
Compliance Audit Date20110907
Compliance Audit Change Completion Date20110930
Incident Investigation Datenull
Incident Invest. Change Completion Datenull
Participation Plan Review Date20110930
Hot Work Review Date20110930
Contractor Safety Review Date20110930
Contractor Safety Eval. Date20110930
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : Joint Regional Sewerage Board , RMP submission #1 : 20111006, process #1 : Chlorine Building, process NAICS code #1 : 22132, prev. program 3 #1, prev. program 3 chemical: all)
Process Chemical Record ID

Prevention Program 3 Text facility_Prevention_Program_3_Text help link help link  
Prevention Program Description


The JRSB WWTP employees were actively involved in the development of the PSM. The starting point for the PSM is an in-depth look at the current chemical storage and delivery systems used. This study is required by OSHA, and is called a Process Hazard Analysis (PHA). A PHA was performed for the facility in September 7, 2011. The PHA report (and all other safety information) is available for review by employees at the facility. The full PHA report is included in Appendix A.

The safety committee at the plant includes all operators, and holds an annual training meeting to review safety information including the PHA, RMP, and PSM. Any new PHAs performed will include plant employees in the process. The PSM, RMP, and PHA documents are maintained at the plant, and are available for employees to review.


A. Chemical Information.

1. Chlorine (CAS #7782-50-5). The JRSB WWTP uses one-ton and 150-lb. cylinders to store chlorine as a liquefied gas. A contractor delivers chlorine to the site in either the one-ton or 150-lbs. cylinders. Liquefied chlorine presents a health risk if the container or the lines delivering chlorine develop leaks or rupture. Unloading truck shipments, moving from storage to on-line positions and opening or closing valves are operations that increase the risk of a chlorine release.

A liquid chlorine spill will quickly become a gas cloud and diffuse to the surrounding area. Because chlorine is heavier than air, it may collect in still, low-lying areas. The quantity released, the release rate, weather conditions, and the topography determine the speed and direction of spread of the chlorine.

2. Hazards of Chlorine. Chlorine is a toxic gas at low air concentrations. OSHA has established a ceiling concentration, the value never to be exceeded, of 1 part per million (ppm) in air. The primary health risks from chlorine are respiratory and eye irritation and lung damage. The OSHA Permissible Exposure Level (PEL) of 1 ppm has been set to reduce irritation of the nose, throat, and eyes of exposed workers. Also, the American Conference of Governmental Industrial Hygienists (ACGIH) has established a Threshold Limit Value (TLV) of 0.5 ppm. Individuals can begin to smell chlorine at about 0.3 ppm. The level that is Immediately Dangerous to Life and Health (IDLH) is 25 ppm.

a. Toxicity. Toxic gas.

b. PEL. 1-ppm (3 mg/m3) ceiling.

c. Physical Data. Yellow-green gas. Stored as liquid under pressure. Boils at 34AC. Vapor Pressure of 4800 mm Hg at 20AC. Evaporates rapidly to form a gas cloud. Forms a white precipitate in the presence of ammonia.

d. Reactivity. Reacts with aluminum to release hydrogen gas. Oxidizes organic materials and most metals.

e. Corrosivity. Causes burns to skin and eyes.

f. Thermal and Chemical Stability. Indefinite shelf life. Do not store with alkalies, reducing agents, or organic materials.

g. Mixing Hazards. Explodes on contact with acetylene in the presence of heat. Forms heat and a white precipitate on contact with ammonia. May ignite on contact with metals. Violently reacts with alcohols.

B. Process Description.

1. Block Flow Diagram. See Figure 2-1.

2. Process Chemistry and Equipment. Gaseous chlorine flows from the 1-ton steel cylinders in the Chlorine Building to the injector. The gas is drawn out by venture action (vacuum suction) of flowing water, placing the chlorine gas directly in solution. The resulting chlorinated water is added to the wastewater for disinfection.

Gaseous chlorine from the 150-lb, cylinders in the Sludge Treatment Building flows to an injector, which is also drawn out via venture action (vacuum suction), placing the chlorine gas in direct contact with the sludge. This is done to control and neutralize gaseous odors from the sludge.

3. Maximum Intended Inventory. Chlorine is delivered in 2,000-lb. cylinders in the Chlorine Building and 150-lb. cylinders in the Sludge Treatment Building. Up to nine 2,000-lb. cylinders may be stored in the Chlorine Building and ten 150-lb. cylinders at the Sludge Treatment Building. The maximum inventory at the site is 19,500 lbs. Chlorine is primarily consumed based on water flow.

4. Safe Operating Limits. The system is driven by the flowing action of the process water, and no over-pressurization of the chlorine system is possible due to the mechanical action of pumps. The steel cylinders and chlorine delivery process piping will operate safely from a low temperature of 0oF to an upper temperature of 140oF. The chemical storage and process rooms at the Chlorine and Sludge Treatment Buildings is ventilated and must not exceed 140oF.

5. Consequences of Deviation. Excess chlorine in the water leads to taste and odor complaints. A rupture or leak in the supply lines will release chlorine gas in the plant. Employees and residents downwind of the chlorine gas release have the potential for exposure. The PHA considers many different scenarios. A complete copy of the PHA is included later in this report.

C. Process Equipment.

1. Materials of Construction. Both the 2,00-lb. and 150-lb. cylinders are made of steel. Flexible alloy connectors, polyvinyl chloride (PVC) piping, or black iron pipes are used to transfer chlorine gas from the ton cylinders to the chorinators. The chlorinators and ejectors are made from materials that do not corrode with chlorine exposure.

2. Electrical Classification. Chlorine is non-conductive and not explosive. Electrical hazards have not been considered as applicable. The loss of electrical power to the site does not increase the risk of a chlorine leak.

3. Pressure Relief System. The small diameter lines from the steel cylinders lead to the chlorinators. The chlorinators are equipped with a pressure relief valve that vents to the chlorine room.

4. Ventilation System. A chlorine gas sensor in the chlorine room starts an alarm. The exhaust ventilation system is started manually by a manual switch located outside the Chlorine Building door. When started, the exhaust system is designed to discharge chlorine away from the building.

5. Codes and Standards Employed. The facilities were designed to meet recognized and generally accepted good engineering practices at the time of construction.

6. Material and Energy Balance. All of the chlorine is consumed by either the water or sludge to form a chlorinated solution/mixture.

7. Safety Systems. An electronic chlorine gas detector is used to identify any leaks in the chlorine room. The detector is set to respond when the chlorine concentration exceeds 0.5 ppm. The sensor is connected to the chlorine gas detector, which is mounted on the wall in the non-potable room within the Chlorine Building. If the sensor detects the presence of chlorine, an alarm sounds in the control room, and indicator lights go on at the chlorine gas detector in the non-potable room.

8. A release of chlorine gas can be recognized in several ways:

A a leak from a storage container makes a hissing sound
A a greenish-yellow cloud can be seen
A an odor can be sensed
A an alarm from an air monitor can be heard

9. When valves and connectors are examined using ammonia, a chlorine leak is detected by the appearance of a white vapor. Receiving, moving and connecting chlorine cylinders are activities that present the greatest accidental release potential.


The most current PHA was conducted in September 2011 and is contained as Appendix A of this plan.


The JRSB WWTP maintains appropriate procedures for use to assure safe operation of the chemical delivery systems.

A. Operating Phases. The different operating phases include the following:

1. Initial Startup Procedures. The system is in use, so no written procedure for this phase is maintained. If new equipment is added, a startup operating procedure will be developed.

2. Normal Operations Procedures. A written procedure exists.

3. Temporary Operations Procedures. The system has redundant features and equipment, so no temporary operations with other equipment are necessary. If temporary equipment is added, a temporary operating procedure will be developed.

4. Emergency Shutdown Conditions. A written procedure exists.

5. Emergency Operations. The processes are not operated in an emergency. After an emergency shutdown, off-site responders are called in to contain the problem. After the site is safe, the system is placed back in normal operation.

6. Normal Shutdown Procedures. A written procedure exists.

7. Startup Procedures Following a Shutdown. A written procedure exists.

If new process equipment is installed at any facility, the operating procedures will be reviewed and updated as necessary.

B. Information Contained. The operating procedures include the following information:

A operating limits
A health and safety considerations
A safety systems
C. Operating Procedure Accessibility. The operating procedures for the processes are maintained at the appropriate facility. These documents are accessible to employees.

D. Operating Procedure Review and Update. When a change to the operating process, process chemicals, technology, equipment, or facilities occurs, the operating procedures will be reviewed to reflect current operating practice. The operating procedures are reviewed annually by the JRSB WWTP Executive Director.

E. Safe Work Practices. Safe work practices concerning lockout/tagout, confined space entry, and plant operation are administered by the JRSB WWTP Executive Director. These practices will provide for the control of hazards during normal operations.


The JRSB WWTP has a training program which consists of initial training of new employees, and refresher training for all active employees. Training records for employees are kept at the JRSB WWTP.

A. Initial Training. Initial training is required for all employees upon hire. Each employee is trained before the first work assignment. The training includes an overview of the process and operation procedures, and emphasizes specific safety and health hazards, emergency operations, and safe work practices. A record of the training is kept at the facility.

B. Refresher Training. Refresher training is conducted at least once every three years for all current employees in order to ensure that the employee fully understands the current operation procedures for the specific process.

C. Training Documentation. The JRSB WWTP maintains a training record on site that identifies the employee, the date of training, and verification that the employee understood the training.


This section applies to contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to the chlorination process. To help ensure that the employees and contractors are fully aware of the potential dangers involved, the responsibilities of both the employer and contractor are discussed below.

A form used to help ensure compliance with this requirement is included in Appendix C.

A. JRSB WWTP Responsibilities. The employer will take the following actions for any contractor:

1. Check the past safety performance and programs of the contractor.

2. Provide safety and hazard information on the process.

3. Ensure safe practices for controlling the entrance, presence, and exit of contractors to the covered process area.

4. Verify that the contractor acts responsibly.

5. Perform a periodic evaluation of the performance of the contract employers in fulfilling their obligation.

6. Maintain a contract employee injury and illness log.

B. ContractorAs Responsibilities. The contractor will be responsible for the following:

1. Adequate training of employees in safety procedures.

2. Ensuring that contract employees know process hazards and applicable emergency actions.

3. Documentation of training, which shall include the name of the employee, the date of training, and verification that the employee understood the material presented.

4. Ensuring his employees follow facility safety procedures.

5. Informing the facility of any special safety hazards presented by the work they will perform.

6. Informing the facility of any special safety hazards they encounter during the work


This regulation applies only to new and modified facilities, and thus does not apply to the JRSB WWTP. If significant changes are made to the chlorine system at any point in the future than a Pre-Startup Safety Review will be conducted by the JRSB WWTP Executive Director.


The mechanical integrity of the chemical delivery equipment must be maintained in order to ensure it operates properly. This is accomplished using a program of equipment inspection and employee training.

A. Equipment Inspection and Testing. All equipment in the chemical delivery system is inspected and tested on a periodic basis. Each inspection and test is documented. This record identifies the date of the inspection or test, the name of the inspector, the identification number of the equipment, a description of the inspection method, and the results of the inspection. Inspection results are maintained in the control room at the facility. The form used to inspect the chlorine delivery system is shown in Appendix C.

B. Equipment Deficiencies and Replacement. The JRSB WWTP will correct deficiencies that pose a threat to the health and safety of the employees. These corrections will be performed in a safe and timely manner and before further use of the equipment. If the deficiency poses a life threatening risk, the JRSB WWTP will shut down the process until the necessary repairs have been completed.

C. Quality Assurance. In maintenance of existing equipment, exact replacement parts will be used wherever possible. Any part other than exact replacements will be governed by the Management of Change guidelines presented below.


Any hot work performed on or near the covered process will be controlled by the use of a Hot Work Permit. Hot work is defined as welding, brazing, soldering, cutting with a saw or torch, or grinding.

The permit shall be kept on file at the plant until the completion of the hot work operations. A copy of the permit is contained in Appendix C. Instructions on the permit describe the required safety and recordkeeping requirements for hot work.


The Management of Change (MOC) program is used to properly address any permanent or temporary change to the covered process equipment, technology, and procedures.

The following topics shall be addressed prior to any change:

A the technical basis for the proposed change
A the impact of the change on safety and health considerations
A the changes to current operating procedures
A the time period of the change
A authorization requirements for the change

Prior to startup of the changed process, employees and contractors whose job tasks will be affected will receive information and training regarding the change. If a change occurs, the process safety information and operating procedures shall be updated accordingly. A form used to record any changes to the system can be found in Appendix C.


An AincidentA is defined as any problem that resulted in, or could reasonably have resulted in, a catastrophic release of chlorine at the facilities.

A. Investigation Team. An incident investigation will be conducted as soon as possible, but must begin within 48 hours following an incident. The investigation team will consist of a minimum of one knowledgeable person of the process involved. The team will also consist of a contract employee if the incident involved the work of the contractor and other knowledgeable and experienced employees who are capable of thoroughly investigating the incident.

B. Incident Investigation Report. An incident investigation report will be completed at the conclusion of the investigation. This report will contain the following information:

A date of the incident
A date the investigation began
A description of the incident
A factors that contributed to the incident
A recommendations resulting from the investigation

The report will be reviewed with affected personnel. The incident investigation report shall be maintained on site for five years. A blank incident investigation report is contained in Appendix C.

C. Resolution and Correction Action. Recommendations and findings as a result of the investigation report will be addressed promptly at the facility. Documentation of resolutions and corrective actions will be maintained with this plan


The JRSB WWTP has an emergency response plan that is maintained as a stand-alone document. It contains information on how to respond to emergencies, and all current emergency contact telephone numbers. The Emergency Response Plan is reviewed and updated annually.


A compliance audit is required to verify that the procedures and practices developed under the standard are adequate and are being followed. A compliance audit evaluating adherence to the prevention program is required every three years. The audit may be performed by a JRSB WWTP employee or a consultant. A minimum of one person with knowledge of the process must be included in the audit process. An audit form is provided in Appendix C to guide the auditor through the process.

A. Compliance Audit Documentation. The facility will prepare a written report of the audit that addresses the findings, and documents appropriate responses to each finding and corrected deficiencies. The two most recent compliance audit reports shall be maintained at the plant.

Emergency Response Plan Info facility_Emergency_Response_Plan_Info help link help link  
Facility In Community PlanNo
Facility Own Response PlanYes
Specific Facility Response PlanYes
Inform. Procedures in Response PlanYes
Emergency Care in Response PlanYes
Plan Review Date20110930
Response Training Date20050401
Local Response AgencyRockland County Fire Control
Local Response Agency Phone9143648600
Subject To - OSHA EAPYes
Subject To - CWANo
Subject To - RCRANo
Subject To - OPANo
Subject To - State EPCRAYes

Search Criteria Used
RMP Facility ID100000195399