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Thomas C. J. Drygas
President/Program Manager
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Mr. Drygas is currently leading a team for the City of St. Augustine (Florida), Water Division, Police and Fire Rescue, which is developing the vulnerability Assessment, updating and implementing the ERP. This program complies with Presidential Directive 63 and the recently enacted Bioterrorism Act, PL 107-188. The Bioterrorism Act updated the EPA's Clean Water Act requiring a vulnerability assessment and update of the ERP. The project includes identification of all water sources, and transmission to the main water plant and distribution systems for the City serving 46,000 individuals. The first phase, the Vulnerability Assessment, characterizes the water system including its mission and objective. Next we determined what threats can affect each part of the system. The likelihood or probability and of the threat is assessed. Based on this, we identified and prioritized adverse consequences for each item. In addition, we evaluated the existing countermeasure or deterrents. Finally, we are developing and prioritizing a plan for risk reduction of each element of the water service system including back up options. The plan will be certified and submitted to the EPA. Following this, the Emergency Response Plan for the Water Management District will incorporate all the results of the Vulnerability Assessment into the ERP. This includes preparedness, response actions and recovery after an event to normal operations plus mitigation for the ongoing security and reliability of the water service. Mr. Drygas is currently leading a team for the Neptune Beach (Florida) Water Division, Police and Fire Rescue, which is developing the vulnerability Assessment, updating and implementing the ERP for Neptune Beach Water Division. This program complies with Presidential directive 63 and the recently enacted Bioterrorism Act, PL 107-188. The Bioterrorism Act updated the EPA's Clean Water Act requiring a vulnerability assessment and update of the ERP. The project includes identification of all water sources, and transmission to the main water plant and distribution systems for Neptune Beach serving 34,000 individuals. The first phase, the Vulnerability Assessment, characterizes the water system including its mission and objective. Next, we determined what threats can affect each part of the system and the likelihood or probability of the threat is assessed. Based on this, we identified and prioritized adverse consequences fro each item. In addition, we evaluated the existing countermeasure or deterrents. Finally, we are developing and prioritizing a plan for risk reduction of each element of the water service system including back up options. The plan will be certified and submitted to the EPA. Following this, the Emergency Response Plan for the Water Management District will incorporate all the results of the Vulnerability Assessment into the ERP. This includes preparedness, response actions and recovery after an event to normal operations plus mitigation for the ongoing security and reliability of the water service. Mr. Drygas is currently leading a team, which is upgrading the process used to manufacture tear gas, Ortho-Chlorobenzalmalononitrile (CS). Mr. Drygas will reduce the production cycle for this product from five days to less than five hours a 24 times process cycle decrease. The product quality and yields will be improved to over 95% and volatile organic emissions will be reduced. This is a win win process improvement. Mr. Drygas is currently leading a team, which is developing and implementing a PSM/RMP program for the City of St Augustine, Florida. Mr. Drygas had completed an audit of the PSM/RMP Program for this City's multiple water and wastewater treatment plants. The EPA required RMP submittal was completed and accepted by the EPA. We included a vulnerability assessment as part of the project. The City's water treatment and the wastewater plants are subject to both OSHA's and EPA's 112 r standards, PSM and RMP. Chlorine is used at both facilities. Mr. Drygas is leading a team upgrade plant policies and operating procedures to comply with each of the comprehensive aspects of OSHA's 29 CFR- 1910.119 regulations and EPA 40 CFR-68. Mr. Drygas prepared, presented and documented the EPA required public meeting for the RMP submittal Mr. Drygas is leading and facilitating establishment of a Jacksonville Beach (Florida) Citywide Risk Management Program. The program includes review of high exposure and risk for both Citywide as well as five key city departments. The initial evaluation phase includes: The goal of the project was to identify potential hazards and recommend/lead in corrective actions efforts. Mr. Drygas has an overall coordinating role with the leaders of the Citywide Safety Council. We have developed citywide policies and procedures for six life-threatening areas. Work continues on an Emergency Response Plan. In addition, Mr. Drygas will provide guidance and training for employees. Mr. Drygas led a team of engineers and scientists in providing a comprehensive Emergency Response Program for Collier County Florida's Utilities Department. The scope of work includes a detailed audit of the County's water treatment and wastewater reclamation facilities related to Risk Management Program requirements and compliance with OSHA general industry standards. Key to the audit was the findings report, which outlined issues (including site security – vulnerability) and recommendations to improve the health safety and operations at the facilities. The second portion of the project is development and presentation of multiple-site Hazardous Material Technician 40-hr, two sessions plus Incident Commander 24-hour training program for the County staff. The training programs included all aspects of emergency response and emergency management requirements as outlined by the OSHA standard, National Fire Protection Association and the Florida State Emergency Response Commission. Finally, Mr. Drygas led the team in upgrading the operating procedures and polices of the Utilities Department to meet Federal, State and County standards. Mr. Drygas completed the development and the implementation of the PSM Program for the City of Orange Park, Florida's multiple water and wastewater treatment plants. The EPA-required RMP submittal was completed and accepted by the EPA. The City's water treatment and the wastewater plants are subject to both OSHA's and EPA's 112 r standards, PSM and RMP. Chlorine is used at both facilities. We upgraded plant policies and operating procedures to comply with each of the comprehensive aspects of OSHA's 29 CFR- 1910.119 regulations. An inventory protocol was developed which eliminated the need to comply with the PSM requirements for one of the regulated OSHA Highly Hazardous Chemicals. Mr. Drygas prepared the hazards analysis and pre-startup safety review of the PSM systems. Next, we prepared, presented and documented training of the operators, maintenance and facility staff (plus contractors) in the PSM procedure implemented. Finally, with PSM in place, we developed the RMP program to include the off-site risk assessment, permit application preparation and RMP submittal package. The package was submitted to the EPA, State of Florida and local LEPC. Mr. Drygas modeled the worst case and several alternate release scenarios using RiskManPRO. and EPA guidance. Mr. Drygas completed the development and implementation of the Risk Management Program for the City of Atlantic Beach, Florida. The project consisted of five water and wastewater treatment plants. He upgraded plant policies and operating procedures to comply with each of the comprehensive aspects of OSHA's 29 CFR-1910.119 and EPA 40 CFR-68 regulations. He prepared, presented and documented a hazards analysis and pre-startup safety review of the PSM systems. With the PSM in place, he developed the RMP program to include the off-site risk assessment, permit application plus RMP submittal package. The package was submitted to the EPA, and regulations made with Florida DEP and local LEPC. Mr. Drygas completed the development and the implementation of the Risk Management program for the City of Neptune Beach, Florida's water and wastewater treatment plants. All City PSM/RMP safety policies were developed. He led the team that prepared, presented and documented a hazards analysis and pre-startup safety review of the PSM systems. With the PSM in place, he developed the RMP program to include the off-site risk assessment, permit application and RMP submittal package. The package was submitted to the EPA, and submissions made with Florida DEP and local LEPC. Mr. Drygas completed development and implementation of a Process Safety Management program for the City of Orange Park, Florida's water and wastewater treatment facilities. He prepared, presented and documented a hazards analysis and pre-startup safety review of the RMP/PSM systems. With the PSM in place, he developed the RMP program to include the off-site assessment, permit applications and RMP submittal package. The package was submitted to the EPA, and submissions made with Florida DEP and local LEPC. Mr. Drygas completed the Risk Management and Process Safety Management program implementation for the City of Melbourne, Florida's three major water and wastewater treatment plants. Mr. Drygas prepared, presented and documented training of the operators, maintenance and facility staff (as well as contractors) in the PSM/RMP procedure implemented. The project included conducting an audit of the facility using OSHA's protocol. He guided the city through the audit significantly reducing both the number and degree of potential violations. The team also developed the Accident Prevention Program. This EPA-required RMP was submitted and accepted by the EPA. Mr. Drygas led a team of engineers and designers providing compliance and engineering services for the Gaylord Container Corporation, Louisiana Paper Mill. One of the key portions of work centered on implementing Process Safety Management (PSM) for highly hazardous chemicals. This included responding to an audit of the facility by OSHA. He prepared a hazard analysis and pre-startup safety review of the turpentine systems. He developed, presented and documented training of the operators, maintenance and facility staff (as well as contractors) in the PSM procedure implemented. Mr. Drygas has led a team of engineers, operators and designers in implementation of a Risk Management Plan for the City of Danville, Virginia water treatment facility. The project included conducting an audit of the facility using EPA's an OSHA's guidelines. He guided the client through the audit significantly reducing both the number and degree of potential violations cited by the auditor. The team developed the EPA required Risk Management Plan. It was submitted and accepted by the EPA. Environmental health and safety related to regulatory requirements, including OSHA and EPA Process Safety Risk Management Program requirements for other highly hazardous chemicals (HHC), was a part of Mr. Drygas's services. Mr. Drygas facilitated Risk Management Program implementation for the City of Frederick, Maryland. The program centered on three water and wastewater utilities. He prepared, presented and documented the operation and other RMP required policies and procedures. He conducted training of the operators, maintenance and facility staff in hazards analysis and pre-startup safety review of the PSM program. The team developed all chlorine and sulfur dioxide systems drawing including P&ID and Flow Diagram. Mr. Drygas completed development and implementation of a Process Safety Management program for Sandoz Chemical, South Carolina. He upgraded plant policies and operating procedures to comply with each of the comprehensive aspects of OSHA's 29 CFR-1910.119 regulations. An inventory protocol was developed which eliminated the need to comply with PSM requirements for one of the regulated OSHA Highly Hazardous Chemicals. Mr. Drygas prepared a Hazards Analysis and pre-startup safety reviews of the PSM systems. Finally, he presented, and documented training of the operators, maintenance, facility staff, and contractors in the PSM procedure implemented. Mr. Drygas led a team of engineers and designers providing all compliance and engineering services for Southern Water Treatment, Greenville, South Carolina. Southern is involved in both chemical manufacturing and hazardous waste recycling processes. The work assignments include installation of new processes, modifications and upgrades to existing units as well as day-to-day problem solving. One of the major portions of work was centered on the implementing of a Process Safety Management Plan (PSM) for two highly hazardous chemicals. This included responding to an audit of the facility by OSHA. The Mr. Drygas team guided the client through the audit, significantly reducing both the number and degree of violations cited by the auditor. Southern relies on Mr. Drygas for air and water permitting as well as operator training and other safety and compliance needs including distillation and blending operations of ready-mix automotive antifreeze. Our state-of-the-art distillers were responsible for cost effective reclamation of the highest quality antifreeze. Mr. Drygas also consulted on processing, storage, transportation and hazardous waste issues. Mr. Drygas currently led a team of scientists and engineers providing all compliance aspects for a chemical formulation and manufacturing firm in the Carolinas. The first part of the annual compliance services included environmental air and water permitting and reporting. Next, the health safety and compliance programs were audited and upgraded. Emphasis was on the material safety data requirements of the products produced. Finally, providing training, resources, programs and class trainings for health and safety. Recently, Mr. Drygas completed conducting a comprehensive audit of the health and safety of two facilities of S.G.L. Carbon. One facility manufactures carbon electrodes and the other installs rubber liners in railcars and other like vessels. Both audits followed OSHA protocols and included evaluation of the policies and procedures, site tour and employee interviews. The audit report outlined findings prioritizing them to permit rapid resolution of compliance issues and is a guide to continuing future improvements and compliance with Federal, State and local regulations. Special emphasis was given to life threatening operations as vessel entry and design of air exchange systems and rates needed to ensure worker safety. Mr. Drygas completed a comprehensive Risk Management Program for SAPPI Fine Paper in Muskegon, Michigan. Mr. Drygas developed the RMP program to include the off-site risk assessment, management system, permit application preparation and two sequential submittal packages. Each package was submitted to the EPA. The submittal followed EPA protocol and included evaluation of their chlorine and chlorine dioxide, bleach and water treatment plants. The submittals demonstrated a 50 times reduction of the area affected by a catastrophic worse case release. This was affected as the mill decommissioned bulk chlorine railcar storage and unloading. That process was replaced with a new state-of-the-art chlorine dioxide generating system. Mr. Drygas completed a comprehensive safety audit of the health and safety of SAPPI Fine Paper in Muskegon, Michigan. The audit followed EPA protocols and included evaluation of their chlorine and chlorine dioxide, bleach and water treatment plants. The audit outlined findings and prioritized them to permit rapid resolution of compliance issues. The report is a guide to continuing future improvements with Federal, State and local regulations. Mr. Drygas provided compliance assessment support for determining applicable RMP requirements for the affected propane process for Blue Circle Cement in Maryland. After finalizing these requirements, Mr. Drygas prepared materials for performing the Hazard Operability Study. Mr. Drygas trained the RMP team and executed the on-site compliance assessment. These materials included handouts, overhead slides, and other written documents as necessary. Mr. Drygas provided compliance assessment support for the City of Frederick, Maryland in determining applicable RMP and PSM requirements for the affected treatment process of thier five-treatment plants. After finalizing requirements, Mr. Drygas prepared materials for performing the Hazard Operability Study (HazOp), training the RMP team and executing the on-site compliance assessment. Mr. Drygas completed development and implementation of a RMP Program for Corning Incorporated Telecommunication Products, Wilmington, Delaware, a major fiber optics manufacturer. Mr. Drygas audited plant policies and operating procedures to comply with each of the comprehensive aspects of OSHA's 29 CFR- 1910.119 regulations. During the review of the PSM program, Mr. Drygas demonstrated that the boundaries of the PSM and RMP covered units could be reduced by about 60%. This reduced Corning's exposure to OSHA's PSM significantly. Corning continues to safely manage the operations removed from the boundary but is not exposed to OSHA's program for that operation. Mr. Drygas modeled the worst case and several alternate release scenarios using RiskManPRO. for alternative releases and EPA guidance for the worst scenarios. Mr. Drygas prepared the off site consequence analysis, the application and submission package as well as all needed internal RMP documents. Finally, Mr. Drygas prepared, presented and documented training of Corning's scientists who will continue to use RiskManPRO. to maintain their RMP program and make updates for the facility staff. The project includes conducting an audit of the facility using OSHA's guidelines. In addition, Mr. Drygas guided the client through the audit significantly reducing both the number and degree of potential violations cited by either EPA or OSHA auditors. Mr. Drygas led a team of engineers and designers providing all compliance and engineering services Southern Water Treatment Corporation in South Carolina. Southern Water is involved in both chemical manufacturing and hazardous waste recycling processes. The work assignments included installation of new processes, modifications and upgrades to existing units as well as day-to-day problem solving. One of the major portions of the work centered on the installation and implementation of the Process Safety Management (PSM) for two highly hazardous chemicals. This included responding to an audit of the facility by OSHA. Mr. Drygas' team guided the client through the audit significantly reducing both the number and degree of violations cited by the auditor. Southern relies on Mr. Drygas' capabilities for air and water permitting as well as operator training and other safety needs. Mr. Drygas completed the PSM procedures and implemented a PSM Program for the Montgomery County Water Treatment Plant in North Carolina, a major water treatment plant. The RMP was submitted and accepted by the EPA. Mr. Drygas upgraded plant policies and operating procedures to comply with each of the comprehensive aspects of OSHA's 29 CFR- 1910.119 regulations. Mr. Drygas prepared a hazards analysis and pre-startup safety review of the PSM systems. Finally, Mr. Drygas prepared, presented and documented training of the operators, maintenance and facility staff (plus contractors) in the PSM procedure implemented. The project included conducting an audit of the facility using OSHA's guidelines. In addition, Mr. Drygas' team guided the client through the audit significantly reducing both the number and degree of potential violations cited by the auditor. Work was completed on the EPA's RMP program including worst and alternate case release impacts. Mr. Drygas led a team of engineers and designers providing all compliance and engineering services for water and wastewater treatment plants for the City of Dallas (Texas). The work assignments included the operating procedures like Process Safety Management (PSM) for chlorination of the water plant drinking water system. A threshold quantify of chlorine was not used. However, the same protocols used for PSM was being adopted for this highly hazardous chemical. The facility relied on Mr. Drygas' capabilities for air and water permitting as well as operator training and other safety needs. Mr. Drygas provided all compliance needs for chlorination at the water treatment facility at the Town of Ranlow in North Carolina. This included review of and compliance with applicable local, state and federal regulations. The client provides wastewater services including screening, separations, flocculation, clarifications and chlorination of the water prior to discharge to a local river. Mr. Drygas also provided consulting on other OSHA-related regulatory issues. Mr. Drygas led a team of engineers and designers providing compliance and engineering services for the Town of Stanley, North Carolina, at its water treatment facility. An audit of the two sites was conducted. Mr. Drygas developed a protocol to eliminate the facility from the requirements of Process Safety Management by reduction of the plant inventory of chlorine to below the threshold limits of 1,500 pounds. The scope of work included engineering review and process safety management using an OSHA audit. Mr. Drygas completed development and implementation of a PSM Program for Sandoz Chemical Corporation, a major chemical manufacturer. Mr. Drygas upgraded plant policies and operating procedures to comply with each of the comprehensive aspects of OSHA's 29 CFR-1910.119 regulations for ethylene oxide, ammonia and other listed HHC. An inventory protocol was developed which eliminated the need to comply with the PSM requirements for one of the regulated OSHA Highly Hazardous Chemicals. Mr. Drygas prepared a hazards analysis and pre-startup safety review and audits of each operation covered by the PSM systems. Finally, Mr. Drygas prepared, presented and documented training of the operators, maintenance and facility staff (and contractors) in the PSM procedure implemented. Mr. Drygas led a team of engineers, operators and designers in providing guidance for the American Anglian Environmental Corporation's municipal wastewater and water treatment facilities nationwide. The EPA required RMP was submitted and accepted by the EPA. Mr. Drygas is presently serving a group of seven facilities. There are nearly 1,125 facilities to still come under the operations design and program upgrades. Key elements include lift pump stations, piping and treatment. In addition, environmental health and safety related to regulatory requirements, including OSHA and EPA Process Safety Risk Management Program requirements for chlorine, sulfur dioxide, and other highly hazardous chemicals (HHC) will be serviced by Mr. Drygas. Mr. Drygas completed the design and development and guided the implementation of a SPCC for Army Air Service Facility Olathe, Kansas. The SPCC Plan is regulated by two primary federal regulations and several State of Kansas regulations. EPA's 40 CFR 112, Oil Pollution Prevention, Army Regulation 200-1 Environmental Protection and Enhancement Chapter 3, Oil and Hazardous Substance Spills, State Department of Health and Environment Regulations including: K.A.R. 28-48 Spill Reporting, K.S.A. 65-171-d, Prevention of Water Pollution and K.S.A. 65-171-v, Clean Up Operation for Water and Soil Pollutants. Kansas has more stringent and diminimous reporting requirements for oil spills to the environment than the EPA's 40 CFR requirements. The SPCC Plan for fuel stored in an underground tank with truck transfer station and heavy expanded mobility tactical trucks (HEMTT) which nominally hold 2,500 gallons each. The facility, therefore, is subject to Federal regulation as it exceeds an aggregation of 1,322 gallons in aboveground tanks. It is exempt from submission of a Facility Response Plan as the total amount at the facility is below the threshold quantity of 42,000 gallons, the trigger for substantial harm to the environment requirements. Mr. Drygas completed the development and implementation of the PSM Program for Jefferson Smurfit Inc. paper mill's chlorine treatment plants. The project included chlorine rail car storage, transfer, evaporation and feed systems into the water used in the mill bleaching operations. The project is subject to both OSHA's and EPA's 112 r standards, PSM and RMP. We upgraded plant policies and operating procedures to comply with each of the comprehensive aspects of OSHA's 29 CFR- 1910.119 regulations. We also developed a maintenance mechanical integrity system for this chemical. Mr. Drygas prepared a hazards analysis and pre-startup safety review of the PSM systems. We prepared, presented and documented training of the operators, maintenance and facility staff (as well as contractors) in the PSM procedure implemented. Finally, with PSM in place, we conducted update Hazards and Operability studies for the process. Mr. Drygas completed the development and implementation of the PSM Program for the Jefferson Smurfit Inc. Paper Mill's turpentine recovery, storage and shipment operations. The project included the Mills gas system for collection of turpentine generated in the pulping operations. Mr. Drygas developed a method to isolate the turpentine system from the collection system significantly reducing the covered processes by this OSHA Regulation. The process design and operations were reviewed and accepted by OSHA's regional compliance office. The project is subject to OSHA's PSM program. We upgraded plant policies and operating procedures to comply with each of the comprehensive aspects of OSHA's 29 CFR- 1910.119 regulations. We also developed a maintenance mechanical integrity system for this chemical. Mr. Drygas prepared a hazards analysis and pre-startup safety review of the PSM systems. We prepared, presented and documented training of the operators, maintenance and facility staff (and contractors) in the PSM procedure implemented. Finally, with PSM in place, we conducted update Hazards and Operability studies for the process. |
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