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Little Cottonwood Water Treatment Plant


Facility #1 : Little Cottonwood Water Treatm

Basic Facility Info facility_Basic_Facility_Info help link help link  
Facility ID100000108028
Deregistered (Yes/No)No
Facility NameLittle Cottonwood Water Treatment Plant
Street Address Line 13430 East Danish Road
CityCottonwood Heights
Zip Code84093
CountySalt Lake County
113th Congressional DistrictUT03: Utah 3
Owner or Operator NameMetropolitan Water District of SLS
Parent CompanyMetropolitan Water District of Salt Lake & Sandy
Number of RMP Submissions4

Most Recent Submission Info facility_Most_Recent_Submission_Info help link help link  
RMP ID1000045009
Submission Typerevised submission for facility
Submission Date06/25/2014
Reason For Submission5-year update (40 CFR 68.190(b)(1))
Process Toxic Amount Total (lbs)40,000
Process Flammable Amount Total (lbs)0
Process Amount Total (lbs)40,000
Number of Potential Offsite Consequence Processes1
Potential Offsite Consequence Toxic Amount Total (lbs)40,000
Potential Offsite Consequence Flammable Amount Total (lbs)0
Potential Offsite Consequence Amount Total (lbs)40,000
All Process NAICS22131
Exec Summary Submission Date06/25/2014

Executive Summary facility_Executive_Summary help link help link (Facility #1 : Little Cottonwood Water Treatm, executive summary: all)

Executive Summary

The USEPA's Clean Air Act Amendments of 1990 included provisions that require facilities that use certain substances to develop a plan to reduce the likelihood of an accidental release of the substances to the atmosphere and reduce the likelihood of serious harm to the public and the environment. The plan must also include mitigation measures to reduce the potential impact on the public in the unlikely event of a release. The requirements of this plan, commonly referred to as a Risk Management Plan (RMP), are detailed and codified in 40 CFR Part 68.

The Metropolitan Water District of Salt Lake & Sandy (the District) supplies drinking water on a wholesale basis to Salt Lake City, Sandy City and other water supply agencies in the Salt Lake County area. The District operates and maintains facilities in Wasatch County, Utah County and Salt Lake County. The Little Cottonwood Water Treatment Plant is a 150 million gallon per day treatment facility which treats water from Little Cottonwood Creek and the Deer Creek Reservoir. The District's Little Cottonwood Water Treatment Plant (LCWTP) stores chlorine in quantities above the regulatory thresholds at which a RMP/PSM is required. Chlorine is used at the LCWTP to disinfect the drinking water prior to public consumption. The District has voluntarily installed a chlorine scrubber to operate in the event of a chlorine leak. If a leak occurs, the chlorine scrubber will treat the chlorine in a manner that should not pose a threat to the outside environment.

The District takes safety very seriously and has not had a reportable incident related to chlorine since June 21, 1994.

The RMP/PSM consists of three compliance programs, each with progressively stricter compliance standards. Since the District is a political subdivision of the State of Utah, State and federal OSHA regulations do not expressly apply. However, the District is required by the Utah Labor Code to operate and maintain an oc
cupational safety and health program equivalent to the program for other employers in the state. The District generally does this by looking to OSHA regulations for guidance, subject to the District's ability to independently make decisions which best meet its safety needs. Consistent with this approach the District has chosen to use the OSHA Process Safety Management (PSM) Standards as a guide. For this reason, and the fact that a worst-case release of chlorine could affect the public, the chlorination process at LCWTP will be treated as subject to Program 3, the most stringent of the three programs.

The RMP/PSM consists of three major parts. The first part is the Hazard Assessment, which evaluates the potential effects that a release of a regulated substance could have on the public and is not included in this executive summary for security reasons. The second part is a Prevention Program that consists of 12 elements designed to improve the system safety and decrease the likelihood of a release. The third part is the Emergency Response Program, which develops a plan for dealing with a release in the unlikely event that one would occur. Because the RMP and PSM regulations are very similar, the Prevention Program and the Emergency Response Program for the EPA RMP also serve as a substantively equivalent OSHA PSM plan.


The Prevention Program, together with the Emergency Response Program, make up the RMP/PSM. The Prevention Program consists of 12 elements designed to improve the system safety and decrease the likelihood of a release.


The participation of the District staff in preparing the RMP/PSM program was critical to the program's successful implementation. Employee participation is valuable because it increases the safety awareness of the staff and it allows the staff's experience in operating and maintaining the processes to be incorporated into the plan.

District staff participated in the developmen
t of the Prevention Program by participating in the Process Hazard Analysis that is described below. The operations and maintenance staff also participated in the development of the RMP by reviewing and commenting on operating and maintenance procedures and safe work practices; these personnel will continue to review and update these practices and procedures on a regular basis. All District staff received RMP/PSM awareness training that instructed staff on how the RMP/PSM requirements may impact their jobs. Staff who operate and maintain the RMP/PSM processes were trained in how to safely maintain and operate the processes.


The RMP regulations require that information concerning process chemicals, technology, and equipment be compiled as part of a RMP program. Emergency response planners can use such information to develop training programs and procedures, or as a general resource. The information will be supplied to contractors who will work in the chlorine areas as part of the requirements outlined in the Contractors element. All the required process safety information was compiled as required by the RMP regulations. The information meets and in many cases exceeds the minimum required by the regulations.


A process hazard analysis (PHA) was conducted to systematically evaluate potential causes and consequences of accidental releases. This information was used by District staff to improve safety and reduce the consequences of accidental releases. Equipment, instrumentation, utilities, human actions, and external factors that might affect the process were the focus of the PHAs that were performed for the chlorine process.

The chlorine PHA was conducted by an interdisciplinary team of District staff familiar with the process operation and maintenance and plant management. The PHA was done using a combination of 'What-If' and 'Checklist' methods. Based on the results of the PHAs, numerous changes in ope
rating, maintenance, and other process safety management procedures that would improve the overall safety of the District were identified. The changes that most affect the severity and likelihood of a release have been adopted by the District and incorporated as part of the overall Process Safety Management Program. The other improvements and process modifications to reduce or eliminate potential hazards will be reviewed and scheduled to be implemented or incorporated as appropriate.


Operating procedures for the chlorination process have been updated as part of the RPM/PSM. Written operating procedures assure continuous, efficient, and safe operation of the facility. The goal of the operating procedures is to provide clear instructions to safely operate the process. Operating procedures are also used to train new employees and to provide refresher training for existing staff.

The detailed operating procedures include startup, shutdown and emergency operating procedures. The procedures describe how the system should be operated in order to minimize the chances of an accidental release. The procedures also empha safety considerations during operation and address hazardous situations that can occur and how to correct them.


An effective RMP/PSM training program can significantly reduce the number and severity of accidental release incidences. Employees involved in operating or maintaining the chlorination process must receive training that includes applicable operating and maintenance procedures and an overview of the process. Training must empha safety and health hazards and safe work practices.

District staff have received initial training on the operations and maintenance of the regulated processes, an overview of each of the RMP/PSM plan elements, and the procedures that must be followed to comply with the requirements of the RMP/PSM plan. In addition to RMP/PSM plan training, select District staff have been trained to
respond to an accidental release. Refresher process operation training must be provided at least every 3 years. Refresher training for emergency response is conducted annually.


The District makes contractors aware of the known hazards of the chlorine process related to the contractors' work. In addition, the District makes contractors aware of the applicable elements of its emergency response plan. The District considers the contractors' ability to perform work on or adjacent to the chlorine process without compromising the safety and health of employees at the facility in the selection process.

Before allowing a contractor to work on or adjacent to the chlorine process, the District obtains and evaluates information regarding the contractor's safety performance and programs. When a contract involving work on or adjacent to the chlorine process is to be bid, the bidding procedures ensure that contractor safety management requirements are met. If a contractor is to work in or adjacent to any covered processes, a safety briefing, to make the contractor aware of the District's RMP/PSM plan requirements, is conducted before work begins. Upon arriving at the plant for the first time to perform work, the contractor will be presented a Contractor Safety Management Briefing Form that must be read and signed. All contractors should receive an Emergency Response Summary Sheet.


A pre-startup safety review must be conducted for any new covered process or for significant modifications to the existing chlorine process that necessitate a change in the process safety information. No new or significantly modified process will start up and no acutely hazardous chemicals will be introduced into such a process prior to the pre-startup safety review. The purpose of the pre-startup safety review is to ensure that the facility is ready to operate new and modified regulated processes safely.

To initiate the pre-startup safety review, all u
pdated elements of the Process Safety Management Plan are assembled for review. This includes all process safety information, process hazard analysis, operating procedures, employee training and mechanical integrity. A pre-startup safety review team completes a pre-startup checklist. The pre-startup safety review team should complete and sign a Pre-startup Safety Review Form. This form documents the process, and helps ensure that the review has been properly performed. The Pre-startup Safety Review Form must be authorized before startup.


An effective mechanical integrity program is one of the primary lines of defense against a release. The mechanical integrity program also addresses equipment testing and inspection, preventative maintenance schedules, and personnel training. The intent is to ensure that equipment used to process, store, or handle chlorine is maintained and installed to minimize the risk of releases.

The District maintenance staff use a computerized maintenance management system to store equipment information, generate and prioritize work orders, schedule preventative maintenance, provide safety procedures for work orders, and maintain an inventory of parts and materials. This computer system is used to generate work orders for preventative maintenance. In addition to preventative maintenance, the District staff performs corrective maintenance in the event of equipment malfunction or breakdown. Work orders indicate what safety precautions must be followed including whether lockout/tagout or confined space entry provisions are applicable. The staff that carryout maintenance are all trained as part of the RMP/PSM.


RMP/PSM regulations require employees and contractors to employ safe work practices when performing 'hot work' in, on, or around the chlorine process. To ensure that hot work is done safely, a Hot Work Permit Program has been developed that requires a permit to be issued before any hot work
is performed. Hot work is defined as the use of oxyacetylene torches, welding equipment, grinders, cutting, brazing, or similar flame- or spark-producing operations.

The process of completing the hot work permit makes it necessary to identify the hazard, recognize what safeguards are appropriate, and then initiate the safeguards necessary to ensure a fire-safe workplace. Following the standards outline in this section aid in complying with the OSHA Hot Works Regulations (1910.252(a)).


A system for the proper management of changes and modifications to equipment, procedures, chemicals, and processing conditions is required under the RMP/PSM. Modifications to the chlorine process will be reviewed before they are implemented to evaluate if the modification would compromise system safety. An effective change management system will help minimize the chance for an accidental release.

If a modification covered under RMP/PSM is made, its effects must be addressed, employees must be informed, and the written procedures must be updated. The intent is to require that all modifications to equipment, procedures, and processing conditions other than 'replacement in kind' be managed by identifying and reviewing them before implementation. A Management of Change Committee will evaluate any modifications that are covered under the RMP/PSM. The Management of Change Committee will complete a Management of Change Form that the Environmental Services Manager will review and authorize prior to initiation of a covered change.


Each incident that resulted in or could reasonably have resulted in a catastrophic release of chlorine must be investigated. A process to identify the underlying causes of incidents and to implement procedures for preventing similar events has been developed. To investigate an incident, an investigation team will be established. As part of the investigation, an incident report will be prepared to recommend
system changes.

The investigation team should ask questions such as what equipment failed, which behavior failed, and which material leaked, reacted, or exploded? As part of the incident review, staff actions that may have contributed to the incident will also be reviewed. A determination will be made as to whether it is necessary to institute additional training for the employees to prevent the incident from occurring in the future. On the incident report form, the Environmental Services Manager identifies which of the recommended system changes are approved for implementation. The incident investigation report and any changes resulting from the report will be reviewed with all staff members who operate and maintain the applicable system.


The District is required to complete a compliance audit for the RMP/PSM program. The primary goals of conducting an internal compliance audit are to gather sufficient data to verify compliance with RMP/PSM requirements and good process safety practices, identify process safety deficiencies and develop corrective actions, and increase safety awareness among District staff.

The compliance audit methodology is modeled after OSHA's guidelines for conducting regulatory PSM compliance audits: Compliance Guidelines and Enforcement Procedures, OSHA Instruction CPL 2-2.45A CH-1 (September 13, 1994). An internal compliance audit must be conducted at the plant at least once every 3 years for the chlorine process. A team that includes at least one person knowledgeable in the covered processes and an audit leader knowledgeable in RMP/PSM requirements and audit techniques will conduct the audits. The Environmental Services Manager and the audit team will promptly determine an appropriate corrective action for each deficiency identified during the audit and document the corrective actions and the dates by which they must be taken.


The Emergency Response Program documents a plan for
dealing with a release. OSHA Process Safety Management regulation 29 CFR 1910.119(n) and EPA RMP regulation 40 CFR 68 Subpart E require that an Accidental Release Emergency Response Plan be prepared. The plan must be prepared in accordance with the provisions of another overlapping OSHA regulation - Employee Emergency Plans (29 CFR 1910.38(a)). In addition, provisions of the OSHA hazardous waste and emergency response standard, 29 CFR 1910.120 (q), must also be considered. The Emergency Planning and Response Plan described in this section complies with the requirements of 40 CFR 68.95, 29 CFR 1910.38(a), and 29 CFR 1910.120(q).

The Emergency Planning and Response plan , 'Metropolitan Water District of Salt Lake & Sandy Facility Emergency Response Plan', provides specific emergency response procedures for accidental release of chlorine. The emergency response procedures cover a release from the initial alarm stage through either leak stoppage or HAZMAT assistance. As part of the emergency response procedures there are plans for victim rescue, leak investigation, and communication with additional support agencies. In addition, critical plant operations are identified to insure that, if possible, the critical District functions are kept operational. The Emergency Response Plan also indicates the level of training needed to carryout the emergency response procedures. Only personnel trained at the Hazardous Materials Technician Level can attempt to stop a leak. The emergency response procedures also covers situations where plant evacuation is necessary.

Emergency Response Plan also addresses plant site communication, emergency response equipment, first aid and medical treatment, medical surveillance and consultation, and emergency response drills.
Submission - Other Facility Info facility_Submission_-_Other_Facility_Info help link help link  
Number of Full Time Employees67
Owner or Operator NameMetropolitan Water District of SLS
Owner or Operator Address Line 13430 East Danish Road
Owner or Operator CityCottonwood Heights
Owner or Operator StateUT
Owner or Operator Zip84093
Parent Dun and Bradstreet Number0
Second Parent Dun and Bradstreet Number0
Number of Full Time Employees67
Number of FTE CBI FlagNo
Covered by OSHA PSM StandardYes
Covered by EPCRA Section 302Yes
Covered by CAA Title VNo
Last Safety Inspection Date20070822
Last Safety Inspection ByEPA
OSHA Star or Merit RankingNo
LEPC NameSalt Lake County LEPC

Submission - Contact Info facility_Submission_-_Contact_Info help link help link (Facility #1 : Little Cottonwood Water Treatm, RMP submission #1 : 20140625)
Owner or Operator Phone8019421391
Facility Phone8019421391
Facility Dun and Bradstreet Number0
RMP ContactClaudia Wheeler
RMP Contact TitleEnvironmental Services Manager
RMP Contact

Submission - Additional Info facility_Submission_-_Additional_Info help link help link  
RMP Complete FlagYes
Predictive FilingNo
No RMP Accidents Last 5 YearsNo
Complete Check Date20140625
Error Report Datenull
Postmark Date20140625
Anniversary Date20190625
Confidential Business InformationNo

Submission - Lat/Long Info facility_Submission_-_Lat_Long_Info help link help link (Facility #1 : Little Cottonwood Water Treatm, RMP submission #1 : 20140625)
Valid Lat/LongYes
Lat/Long MethodInterpolation - Other
Lat/Long Location TypeCenter of Facility
FRS Latitude40.5885
FRS Longitude-111.799

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 : Little Cottonwood Water Treatm, RMP submission #1 : 20140625, process #1 : Water Treatment Plant)
Process DescriptionWater Treatment Plant
Program Level3
Confidential Business InformationNo
Toxic Amount Total (lbs)40,000
Flammable Amount Total (lbs)0
Process Amount Total (lbs)40,000
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)40,000
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link (Facility #1 : Little Cottonwood Water Treatm, RMP submission #1 : 20140625, process #1 : Water Treatment Plant, 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  
Physical StateGas liquified by pressure
Model UsedEPA's RMP*Comp(TM)
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 : Little Cottonwood Water Treatm, RMP submission #1 : 20140625, process #1 : Water Treatment Plant, process chemical #2, alternate toxic scenario #1)
Physical StateGas liquified by pressure
Model UsedEPA's RMP*Comp(TM)
Wind Speed6.7
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 : Little Cottonwood Water Treatm, RMP submission #1 : 20140625, process #1 : Water Treatment Plant, process NAICS code #1 : 22131)
NAICS Code22131: Water Supply and Irrigation Systems

Prevention Program 3 facility_Prevention_Program_3 help link help link  
Safety Info Review Date20140623
PHA Update Date20140424
PHA Technique - What IfYes
PHA Technique - ChecklistNo
PHA Technique - What If/ChecklistNo
PHA Technique - HAZOPNo
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Change Completion Date20140620
Hazard Identified - Toxic ReleaseYes
Hazard Identified - FireYes
Hazard Identified - ExplosionYes
Hazard Identified - Runaway ReactionNo
Hazard Identified - PolymerizationNo
Hazard Identified - OverpressureNo
Hazard Identified - CorrosionNo
Hazard Identified - OverfillingNo
Hazard Identified - ContaminationYes
Hazard Identified - Equipment FailureYes
Hazard Identified - Cooling LossYes
Hazard Identified - EarthquakeYes
Hazard Identified - FloodYes
Hazard Identified - TornadoNo
Hazard Identified - HurricaneNo
Hazard Identified - OtherSabbotage
Process Controls - VentsYes
Process Controls - Relief ValvesYes
Process Controls - Check ValvesYes
Process Controls - ScrubbersYes
Process Controls - FlaresNo
Process Controls - Manual ShutoffsYes
Process Controls - Auto ShutoffsYes
Process Controls - InterlocksYes
Process Controls - AlarmsYes
Process Controls - Keyed BypassNo
Process Controls - Emergency AirNo
Process Controls - Emergency PowerYes
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
Process Controls - OtherSCBAs
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 - NeutralizationYes
Mitigation Systems - NoneNo
Mitigation Systems - OtherEmergency Scrubber
Monitoring Systems - Process AreaYes
Monitoring Systems - PerimeterYes
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 DetectionNo
Changes Since PHA - Perimeter MonitoringNo
Changes Since PHA - Mitigation SystemsNo
Changes Since PHA - None RecommendedYes
Changes Since PHA - NoneNo
Procedure Review Date20140623
Training Review Date20140623
Type of Training - ClassroomYes
Type of Training - On the JobYes
Type of Training - Othervideos
Competency Testing - Written TestsYes
Competency Testing - Oral TestsYes
Competency Testing - DemonstrationYes
Competency Testing - ObservationYes
Maintenance Review Date20140623
Maintenance Inspection Date20140618
Equipment TestedChlorine scrubber and leak detectors
Management of Change Most Recent Datenull
Management of Change Review Date20140623
Pre-startup Review Datenull
Compliance Audit Date20140525
Compliance Audit Change Completion Date20170525
Incident Investigation Date20130625
Incident Invest. Change Completion Datenull
Participation Plan Review Date20140623
Hot Work Review Date20140623
Contractor Safety Review Date20140623
Contractor Safety Eval. Date20140623
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : Little Cottonwood Water Treatm, RMP submission #1 : 20140625, process #1 : Water Treatment Plant, process NAICS code #1 : 22131, 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
Chlorination of drinking water prior to distribution

Emergency Response Plan Info facility_Emergency_Response_Plan_Info help link help link  
Facility In Community PlanYes
Facility Own Response PlanYes
Specific Facility Response PlanYes
Inform. Procedures in Response PlanYes
Emergency Care in Response PlanYes
Plan Review Date20140308
Response Training Date20140430
Local Response AgencyUnified Fire Authority
Local Response Agency Phone8017437100
Subject To - OSHA EAPNo
Subject To - CWANo
Subject To - RCRAYes
Subject To - OPANo
Subject To - State EPCRAYes

Search Criteria Used
RMP Facility ID100000108028