Fort Thomas Filtration Plant - Executive Summary

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    In the event of an accidental release of chlorine from a one ton cylinder located in a storage building of the Fort Thomas Filtration Plant, which is near a residential area,  a Risk Management Program is being implemented to properly handle this type of emergency.  A part of the program involves the  Risk Management Plan which outlines the type of releases that can be encountered at this facility and an estimate of the number of persons that can be affected.  The plan lists the local agencies that would be contacted and information about what mitigation systems, emergency plans and prevention programs are already in place.  The plan also explains any ongoing modifications to the equipment for further  prevention to increase employee and public safety.  The following briefly summarizes the key sections of the risk management plan for the Fort Thomas Filtration Plant. 
 
a.  Accidental Release Prevention and Emergency Response Policies 
 
   The Northern Kentucky Water Services Dist 
rict: Fort Thomas Filtration Plant has in place an Accidental release prevention program and an emergency response program.   
 
   The accidental release prevention involves training employees, employing new safety devices and implementing a process of work safety to prevent potential releases.  This facility conducts Process Hazard Analysis updates, the most recent one was on 9/23/98.  Also, HAZOP changes will be taking place at the end of May, 1999. 
 
   The emergency response policy is constructed such that a safety coordinator is responsible for developing and implementing a response plan to handle potential emergencies.  In the event of an emergency, the safety coordinator evaluates the situation and contacts outside agencies if neccessary.  The emergency response program also includes how to properly inform the public when an emergency occurs.  Another important part of the Emergency Response Program is testing and evaluating the written Emergency Response plan to ensure that the 
plan will work efficiently.  This testing is done through conducting emergency chlorine release drills.  The drills involve the local fire departments, police, the hospital, the HAZMAT team, and other local authorities.  The chlorine release drill simulates a worst case release of chlorine into the air.  The public is notified through the local news stations of the drill that takes place in order to keep them informed of the potential emergency that could happen.   
 
b.  Source and Regulated Substances Handled 
 
    The source of concern for the water treatment facility is twelve one ton cylinders of chlorine in an enclosed building off of Military Parkway.  The chlorine is a liquid under pressure.  The cylinders are interconnected. 
 
c.  Worst Case and Alternative Scenarios 
 
    The worst case scenario examined is taken from the AWWA Guidance document and involves the release of 2000 pounds of chlorine gas in a ten minute time period.  This gives a release rate of 200 lbs chlorine/min 
.  The topography was found to be urban from using a population estimate.  Using the information listed above along with the AWWA reference tables, it was determined that a 2.6 mile radius would be the affected area.  The population in the affected area is 47,706 people.  The atmospheric conditions that are assumed are a wind speed of 1.5 m/s, and stability class F. 
 
    The alternative scenario is a more realistic representation of what kind of release of chlorine would take place at this facility.  In this case, a release of 2000 pounds of chlorine takes place due to a transfer hose failure in 31 minutes.  With a release rate of 64 pounds of chlorine per minute, the estimated downwind distance to the endpoint is 1.3 miles.  A population of 10,396 people are affected within this radius.  For the alternative scenario,  the assumed atmospheric conditions are a wind speed of 3.0 meters per second, and Stability class D.   
 
d.  General Accidental Release Prevention Program and Chemical S 
pecific Prevention Program 
 
   The accidental release prevention program is centered around identifying potential hazards and what process controls and mitigation systems are in place to handle these hazards.  The hazards identified for this facility are toxic release, contamination, equipment failure, and loss of electricity or power.  The process controls currently in place are relief valves, chlorine concentration controls, automatic shutoffs, and alarms.   The mitigation systems that are in place at this facility are diked areas, process area detectors, and chlorine monitors to detect a chlorine concentration of 3 ppm.  The program also involves routine employee training of correct and safe operating procedures to avoid any accidents.  This program requires the employees to take a written test after the training is completed.  The employee participation plans were revised on 8/12/98.  Finally, the chlorine monitors have been inspected at the beginning of 1999.   
 
e.  Accident Hist 
ory 
 
   The Fort Thomas Filtration Plant has had no accidents within the past five years.   
 
f.  Emergency Response Plan 
 
    The facility has its own written emergency response plan, which includes procedures for handling toxic releases of this nature.  The date of the most recent review for this plan took place on 8/29/1998. Employees of this facility had training on the same date.  The plan is developed by the Safety Coordinator. The plan consists of addressing each employee's roles and the proper communication procedure that should be followed.  The employees are trained to recognize emergencies and how to prevent one from occurring.  Medical attention and first aid treatment, decontamination,  and evacuation procedures are several items covered in this plan.  In general, when an emergency occurs, the safety coordinator is notified and evaluates the situation to determine if the fire department or other outside agency needs to be notified.  Then the fire department is notified to 
contain the spill or leak using proper personal protective equipment.  Employees follow the evacuation routes, medical attention is given, and decontamination is performed.  When notifying the public, an alarm is sounded and the dispatch center is called.  To be fully prepared for an emergency, the proper spill containment equipment, personal protective equipment and evacuation routes are posted at various stations throughout the facility where an emergency is most likely to occur. 
 
g.  Any changes made by facility to improve safety             
 
Several items were taken care of in order to improve the facility's safety.  First, an additional chlorine monitor was placed near the chlorine feed line.  Then, the feed lines for the chlorine were moved away from the tanks in order to allow more work space.  Finally, the high pressure tubing was replaced, and guard tubing was installed.
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