Sanitary District of Hammond - Executive Summary
This submission revises the Sanitary District of Hammond (HSD) Risk Management Plan (RMP) dated June 17, 1999. The purpose of the revision is to incorporate Process Hazard Analysis (PHA) and other information pertaining to the Occupation Safety and Health Administration (OSHA) Process Safety Management (PSM) regulations (29 CFR 1910.38 and 1910.119). This revision also corrects an error found in our original submission. In Section 1.1.2 (c) of the original RMP, it was erroneously indicated that HSD was covered by CAA Title V.
Accidental Release Prevention and Emergency Response Policies:
HSD is a municipal wastewater treatment facility located in Hammond, Indiana. Employees of HSD, as well as contractors and subcontractors, are subject to potential risks of personal injury from exposure to noxious gases. The gases of concern are chlorine (Cl2) and sulfur dioxide (SO2) which are listed under Section 112 (r) (risk management program to prevent and respond to accide
ntal releases of regulated substances) of the Federal Clean Air Act Amendments. In addition, HSD is required to comply with Federal, State and Local regulations on wastewater treatment and solid waste management as they apply to waste treatment facilities. HSD has prepared this RMP to meet Section 112 (r) requirements, which is summarized herein. Since the facility is subject to the OSHA PSM regulations, Program 3 of the risk management program is applicable to the covered processes, i.e., storage of Cl2 and SO2 at HSD.
The Facility and the Regulated Substances Handled:
HSD uses Cl2 and SO2 in the treatment of wastewater to ensure that microbes in the discharge or effluent are substantially killed or destroyed and the chlorine level in the effluent is sufficiently low and does not impact water quality of the receiving stream, i.e., Grand Calumet River. Cl2 and SO2 are supplied as a liquefied compressed gas in one-ton containers having the capacity of 2,000 pounds each. Standard
containers valves are provided for the ton containers which are equipped with fusible metal pressure relief devices (fusible plugs). These fusible plugs are designed to yield or melt between 158 F and 165 F to relieve pressure and prevent rupture of the container in case of fire or other exposure to high temperature.
Employees are responsible for the transfer of ton containers from the delivery truck to the facility (Chlorine Building). The off-loading or transfer is achieved by using an overhead crane or hoist to avoid damaging the valves. All containers are stored on designated wooden racks or scales in a horizontal position. On-line use, staging and storage of all full ton containers occur inside the Chlorine Building located approximately 200 feet east of the Administration Building. Standard Operating Procedures (SOPs) have been developed and are currently being followed by the facility personnel. The SOPs include handling of ton containers during loading/offloading, stagin
g, and storage. MSDS sheets regarding specific chemical information and safe handling are kept on site and made available to all employees. Formal process has been implemented and documented to meet PHA requirements. To date, employees who work at the Chlorine Building have been trained and have a good understanding of what the hazards are and the safety procedures for handling chemicals used in the processes. Written maintenance procedures have been prepared to document the maintenance program for the facility's covered processes. Maintenance personnel perform regular inspections of the Chlorine Building and the associated equipment, and provide preventive maintenance as necessary.
The amount of chemical in use and in storage at the facility at all times is as follows: Chlorine (approximately 24,000 lbs) and SO2 (approximately 18,000 lbs). Workers at the facility could potentially be exposed to Cl2 and SO2 gases should an accidental release occur. Risks to workers include exp
osure to noxious gases from a leaking or ruptured container and leaking or broken pipes leading from the containers into the header pipe and vaporizers. Therefore, this RMP has been prepared to address this realistic release scenario; other release scenarios should be similar or of a lesser degree to this scenario. The impacts of natural catastrophies on the covered processes are not evaluated in the RMP. Please note that where no information is provided in the RMP Submit, the requirement is either not applicable or the requirement is currently being addressed or implemented. As appropriate, revised RMPs will be periodically submitted in the future to update information presented in this revised submission (revision date is identified in the footer of the plan).
The Worst-Case Release Scenario and the Alternative Release Scenario(s):
Offsite Consequence Analysis (OCA) modeling was performed for worst-case and alternative release scenarios of Cl2 and SO2 using the OCA Guidance pu
blished by the U.S. Environmental Protection Agency (EPA). Toxic endpoints, based on Emergency Response Planning Guidelines (ERPG) - 2, are 0.0087 milligram (Cl2) per liter (air) (mg/L) or 3 parts per million (ppm) and 0.0078 mg/L or 3 ppm for SO2:
Worst-case release modeling was performed using RMP*CompTm (Version 1.06). Worst-case is represented by the release of Cl2 and SO2 gas to the immediate environment. Assumptions made include: the entire amount (2,000 lbs) of the container be released in 10 minutes and a passive mitigation factor of 55% due to the container's location (inside the Chlorine Building). The toxic endpoint distance for both Cl2 and SO2 is 0.9 miles (4752 feet) or 1.4 kilometers (Km).
Alternative release modeling was performed using Automated Resource for Chemical Hazard Incident Evaluation (ARCHIE) (Version 1.0). Alternative release is represented as a 1/2-inch break occurring at the hose or piping to the header manifold. Assumptions made include: 80% of
the total amount (i.e., 4,000 lbs) is released, 19.17% of the liquid is flashed or volatilized, and passive mitigation factor provided by the building is 55%. The toxic endpoint distance for Cl2 is 0.48 miles or 2508 feet (0.76 Km). The toxic endpoint distance for SO2 is 0.70 miles or 3688 feet (1.1 Km).
A prevention program is in place at HSD to meet the requirements of OSHA Standard 29 CFR 1910.119 PSM of Highly Hazardous Substances and the RMP Program 3 (40 CFR Part 68 Subpart D). Responsibilities for the program include but are not limited to the following:
? assignment of qualified operators and supervisors to ensure safe operations and oversight in the handling and management of Cl2 and SO2;
? training of operators on hazard awareness, safe operating procedures, and good engineering practices
- monitoring/maintenance of storage containers and the associated process equipment;
? documentation of information, activities and inspections required by the program;
? provide PSM tr
aining for all new employees; and
? ensuring that operators comply with PSM rule and actively participate in the PSM program.
Five-year Accident History:
There have been no accidental releases of chlorine or sulfur dioxide in the past five years at the facility.
The Emergency Response Program:
The Sanitary District of Hammond has a written emergency response plan. The facility?s emergency response program is coordinated with the Hammond Fire Department (dial 911) and the Local Emergency Planning Committee (LEPC) (Attn: Bill Timmer, Lake County Emergency Management (LCEM), 2900 W 93rd Ave., Crown Point, IN 46307, Phone: (219) 756-8302. For large spills or releases, the Fire Department may solicit assistance from the Lake County HazMat Team, Phone: (219) 755-3512.