City of Lancaster Wastewater Treatment Facility - Executive Summary

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Introduction 
 
The following Risk Management Program (RMP) information is taken directly from Environmental Publication (EPA) 550-B-98-010.  This publication has specific guidance requirements and calculation procedures for Wastewater Treatment Plants regulated under section 112 of the Clean Air Act. 
 
It has been determined that the City of Lancaster Advanced Wastewater Treatment Facility has to comply with Part 68 of Title 40 of the Code of Federal Regulations (CFR). 
 
"The phrase "risk management program" refers to all of the requirements of part 68, which must be implemented on an on-going basis.  The phrase "risk management plan " refers to the document summarizing the risk management program that you must submit to EPA." 
 
Due to the fact that the WWTP is covered under this regulation, the following activities must be undertaken: 
    
"Covered facilities must develop and implement a RMP and maintain documentation of the program at the site.  The RMP will include and analysis of the po 
tential offsite consequences of an accidental release, a five-year accident history, a release prevention program, and an emergency response program."  
 
"Covered facilities also must develop and submit a Risk Management Plan, which includes registration information, to EPA no later than June 21, 1999, or the date on which the facility first has more than a threshold quantity in a process, whichever is later.  The Risk Management Plan provides a summary of the Risk Management Program.  The RMP will be available to federal, state, and local government agencies and the public." 
 
"Covered facilities also must continue to implement the RMP and update their RMPs periodically or when processes change, as required by the rule." 
 
 
The WWTP is covered because it is a stationary source that stores chlorine above the threshold quantity of 2,500 pounds in a single process. 
 
   Process:    Any group of vessels that are interconnected, or separate vessels that are located such that a regulated substance c 
ould be involved in a potential release, shall be considered a single process.  
 
   Vessel:    Any container, from a single drum or pipe to a large storage tank or sphere. 
 
The WWTP stores one (1) ton chlorine cylinders for the purpose of disinfecting wastewater before it enters the Conestoga River.  The maximum quantity stored on site is ten (10) full cylinders.  Of these ten (10) cylinders, six (6) full cylinders are stored inside and four (4) are stored outside.  The maximum amount of chlorine stored outside is four (4) full cylinders.  Once cylinders become empty, they are moved from inside the chlorination building to the outside storage area. 
 
"In general, if you have two or more vessels containing a regulated substance that are connected through piping or hoses for the transfer of the regulated substance, you must consider the total quantity of a regulated substance in all the connected vessels and piping when determining if you have a threshold quantity in a process." (1-6) 
 
If only 
one cylinder was used at a time, the City's WWTP would not be required to develop a Risk Management Program because they would be under the 2,500 pound threshold quantity.  Due to the amount of wastewater chlorinated at the Lancaster WWTP, it is necessary to manifold two chlorine cylinders together.  
 
 
   Flow Diagram:  Two cylinders---> vacuum regulator --->  chlorinator ---> chlorine ejector 
 
As the diagram above shows, two cylinders are connected together resulting in a threshold quantity over the 2,500 pound limit.  Interconnecting the two vessels together creates a single process.  Thus, the WWTP must develop a Risk Management Program. 
 
"The third possibility you must consider is whether you have separate vessels that contain the same regulated substance that are located such that they could be involved in a single release.  If so, You must add together the total quantity in all such vessels to determine if you have more than a threshold quantity." (1-7) 
 
The possibility of an acci 
dent effecting two or more full chlorine cylinders stored outside is nonexistent.  The outside storage area is a brick and steel structure capable of withstanding fire, earthquake, and collision hazards.  Pillions made of steel and cement protect the area from collisions and the escape of cylinders.  A release from one chlorine cylinder would not lead to a release from another cylinder located next to it. 
It has been determined that the two cylinders connected together are considered to be a single process.  The associated piping is also considered to be a part of that process. 
 
    
When does the process end?    
 
   "The process ends when the concentration of chlorine in the wastestream is no longer above one percent, unless other regulated substances are present above their threshold quantities or the vessel is otherwise considered part of the process because it could cause a release of the covered vessels holding regulated substances or hinder a response to such a release." 
 
   Process end 
s when the Cl2 mixes with the process water. 
   * 150 gal/min of process water 
   * 1000 LB/day maximum Cl2 input 
 
1.8 million LB/day of process water to 1000 LB/ day Cl2 creates a .05 % chlorine solution.   
 
 
"If your process consists of two or more interconnected vessels, you must determine the maximum quantity for each vessel and the connecting pipes or hoses.  The maximum for each individual vessel and pipe is added together to determine the maximum for the process." 
 
Standard operating procedure at the Lancaster WWTP directs personnel to only change chlorine when all chlorine is removed from the network by vacuum.  After all chlorine is drained for the system, two new cylinders are connected to the manifold.  At no time is there more than 4,000 pounds of chlorine within the process. 
 
Since it has been determined that the Lancaster WWTP has to develop a RMP and it falls under the classification of a Program 2, the following is required: 
 
 
(1) Hazard Assessment 
   (a) Worst-case analysis 
 
   (b) Alternative releases 
   (c) 5-year accident history 
(2) Management Program 
   (a) Document management system 
 
(3) Prevention Program 
   (a) Safety information 
   (b) Hazard review 
   (c) Operating procedures 
   (d) Training 
   (e) Maintenance / Mechanical integrity 
   (f) Incident investigation 
   (g) Compliance audit 
(4) Emergency Response Program 
   (a) Develop plan and program 
(5) Risk Management Plan Contents 
   (a) Executive summary 
   (b) Registration 
   (c) Worst-case data 
   (d) Alternative release data 
   (e) 5-year accident history 
   (f) Prevention program data 
   (g) Certification 
 
 
 
 
Offsite Consequence Analysis 
 
"You are required to conduct an offsite consequence analysis to provide information to the government and the public about the potential consequences of an accidental chemical release at your facility.  The offiste consequence analysis (OCA) consists of two elements:  
 
* A worst-case release scenario  
* Alternative release scenario 
 
"To simplify the analysis and ensure a common basis for comp 
arisons, EPA has defined the worst-case scenario as the release of the largest quantity of a regulated substance from a single vessel or process line failure that results in the greatest distance to an endpoint." (4-1) 
 
   Estimating Offsite Receptors 
 
"The rule requires that you estimate residential populations within the circle of your worst-case and alternative release scenarios.  In addition, you must report in the RMP whether types of public receptors and environmental receptors are within the circles." 
    
Population estimates were obtained from the United States Bureau of Census.  Landview III software was downloaded off of the Internet and used to determine the population within the release area.  The rule requires that you estimate the population to two significant digits. 
 
The RMP also states that you must identify what types of receptors are located within the release area.  Receptors are classified by the following terms: 
 
Public receptors: residences, schools, hospitals, priso 
ns, public recreation areas, and major commercial or industrial areas 
 
   Recreational areas: public swimming pools, public parks 
 
Environmental receptors: National or State Parks, forests, monuments, wildlife sanctuaries, Federal wilderness areas 
 
 
(1)Development of the Worst-Case Scenario 
 
The worst-case release quantity Q (lb) was determined to be the contents of one cylinder of chlorine. 
 
    
"For vessels, you need only consider the largest amount in the vessel, regardless of interconnections with pipes and other vessels. ... You may be able to think of scenarios in which a quantity greater that Q as defined above can be released, but EPA does not require you to model such scenarios as worst-case (you may want to consider modeling them as alternative scenarios)." (4-3) 
 
From this definition, the worst-case release quantity (Q), would be that of a one ton cylinder of chlorine, 2,000 lbs.  The worst-case scenario also assumes that this quantity would be released over a period of 10 minut 
es.  The worst-case release rate would then be 200 lb/min. 
 
The worst-case scenario is assumed to take place at ground level under specific default weather conditions. 
 
   Default weather conditions: 
       * 1.5 m/s Wind Speed  
       * F Atmospheric Stability 
       * 25oC (77oF) Ambient Temperature 
       * 50 percent Humidity   
 
The toxic endpoint for chlorine is 0.0087 mg/L (3ppm). 
    
"These airborne concentrations are the maximum airborne concentrations below which it is believed that nearly all individuals can be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ability to take protective action." 
 
Both the worst-case and alternative-case release will take place under urban conditions.  Urban conditions are modeled because the Lancaster WWTP is located amongst hills, trees, and numerous buildings.  The release modeled for the RMP can only occur within the chlorination building due to the threshold q 
uantity of 2,500 pounds only being located inside the building.  If a cylinder would release chlorine outside the building, it would be a single vessel under the 2,500 pound threshold. 
 
The worst-case scenario will be modeled as if it where to occur outside.  This scenario is used to represent an event in which the building doors are open, the building in not leak-tight, or the ventilation system is on. 
EPA Guidance 550-B-98-010 Exhibit 4-3 was used to determine the distance to toxic endpoint. 
    
Worst-case scenario distance to toxic endpoint - 1.3 miles 
 
"Note that the release rate estimated by the method above is conservative.  As the release proceeds, chlorine continuously evaporates from the liquid surface in the cylinder.  This causes the liquid to cool, the vapor pressure to decrease, and the rate of release to decline.  However, the equations for calculating this effect are rather complex and not included in this guidance." (4-26) 
 
Landview III software was used to determine the  
population within the release radius. 
    
The population affected by a release with a radius of 1.3 miles would be 15,000 people. 
 
   Public and Recreational receptors would be affected. 
 
 
(2)Development of the Alternative Release Scenario 
 
"Your alternative scenario for a covered process must be one that is more likely to occur than the worst-case scenario and that reaches an endpoint offsite, unless no such scenario exists.  You do not need to demonstrate greater likelihood of occurrence or carry out and analysis of probability of occurrence; you only need to use reasonable judgement and knowledge of the process." (4-20) 
 
The alternative release scenario for the Lancaster Advanced Wastewater Treatment Facility is modeled under the average weather conditions for Lancaster, Pennsylvania.  These conditions were obtained from the National Climatic Data Center on March 11, 1999.     
   * 10.9oC (51.7oF) Average Ambient Temperature 
   * D Atmospheric Stability 
   * 3.7 m/s Wind Speed 
   * 50 percent Humi 
dity 
 
A break or crack in the flexible connection between the cylinder and the header could easily be stopped by closing the cylinder valve.  If a chlorine leak were to occur, it would most likely occur during the hookup of new cylinders.  For the Lancaster WWTP, the most probable incident resulting in a chlorine release would be the shearing of the cylinder valve. Other scenarios were examined but determined to be less likely of ever occurring.  The outside diameter of the chlorine cylinder valve is one inch.  The actual opening inside the valve for chlorine to escape is only 3/8 inch.   
 
The alternative scenario will be modeled as if it where to occur outside.  This scenario is used to represent an event in which the building doors are open, the building in not leak-tight, or the ventilation system is on.  The release takes place in an urban environment. 
 
EPA Guidance 550-B-98-010 Exhibit 4-15 was used to determine the distance to toxic endpoint.  The atmospheric stability and wind s 
peed for the WWTP's location is the closest available.  Exhibit 4-15 uses an atmospheric stability of  D and a wind speed of    3 m/s.  A hole of 5/16 resulted in a release rate of 15 lbs/min. 
 
Alternative scenario distance to toxic endpoint - 0.1 miles 
 
"Note that the release rate estimated by the method above is conservative.  As the release proceeds, chlorine continuously evaporates from the liquid surface in the cylinder.  This causes the liquid to cool, the vapor pressure to decrease, and the rate of release to decline.  However, the equations for calculating this effect are rather complex and not included in this guidance." (4-26) 
 
 
Landview III software was used to determine the population within the release radius. 
    
The population affected by a release with a radius of 0.1 miles would be 25 people. 
 
   Public and recreational receptors would be affected. 
 
 
 
 
Five Year Accident History 
 
The City of Lancaster Advanced Wastewater Treatment Facility had no reportable releases during 
the past five years. 
 
 
 
 
Management System 
 
The management system was developed to oversee the coordination and implementing of the Risk Management Program element. 
 
The Plant's Utility Engineer will have the overall responsibility for the Risk Management Program elements.    
 
"Remember that the only element of your management system that you must report in the RMP is the name of the qualified person or position with overall responsibility." (5-2) 
 
 
 
 
Lines of Authority for RMP purposes: 
 
 
 
                 William Horst 
       (Superintendent of Wastewater Operations) 
                   * 
      ********************************************** 
   Bryan Harner          Gary Bowers        Edward Mastromatteo 
(Utility Engineer)     (Chief Operator)     (Maintenance Supervisor) 
                   *            * 
                   *            * 
                 Terry Dickel             Jim Csoka 
              (Ass. Chief Operator)   (Maintenance Foreman) 
                   *            *                 
                   *            * 
                 Operators            Mechanics 
 
 
 
 
 
Prevention Program 
 
"EPA developed the Program 2 prevention program by identifyin 
g the basic elements that are the foundation of sound prevention practices- safety information, hazard review, operating procedures, training, maintenance, compliance audits, and accident investigation.  By meeting other Federal regulations, state laws, industry codes and standards, and good engineering practices, you probably have already met most of the Program 2 prevention elements requirements." (6-1) 
 
 
       Sections of the Program 2 Prevention Program: 
 
1. Safety Information 
2. Hazard Review 
3. Operating Procedures 
4. Training 
5. Maintenance 
6. Incident Investigation 
7. Compliance Audits 
 
 
(1) Safety Information 
    
* Material Safety Data Sheet (MSDS) for chlorine is included with this report. 
* The Maximum Intended Inventory is 10 full one ton cylinders of Chlorine. 
* Safe upper and lower for chlorine storage - Ideal storage temperature is 10-27oC (50-80oF).  Do not expose sealed containers to temperatures above 40oC (104oF).  The Chlorine Institute recommends that chlorine tanks not  
be filled beyond 95 percent at a maximum temperature of 122oF. 
* Equipment specifications used in the design of the chlorination system are included with this plan. 
* Codes and standards used to design the chlorination system are also included with the RMP. 
 
"The purpose of this requirement is to ensure that you understand the safety-related aspects of the equipment and processes you have, know what limits they place on your operations, and adopt accepted standards and codes where they apply.  Having up-to-date safety information about your process is the foundation of an effective prevention program." (6-1) 
 
The chlorination facility was designed and built in conformance with the National Electric Code (NEC), American National Standards Institute (ANSI), American Society for Testing Materials (ASTM), and the National Fire Protection Association (NFPA). 
 
The following table contains the equipment used within the chlorination process.  For each piece of equipment, specifications pertain 
ing to that equipment's construction, design, and tolerances are noted.  Documentation for the RMP is achieved by having the specifications and safety information for the chlorination process contained within.  
 
 
CHORINATION EQUIPMENT 
 
   Maximum Flow Rate: 400 lb/day per cylinder(depends on storage conditions) 
   Flexible Piping- 3/8" OD Cadmium Plated Copper Tubing;  500 psi maximum 
   Rigid piping- 1" Schedule 80 high temperature seamless carbon steel (ASTM A106 GR. C) 1" Schedule 80 PVC (ASTM D1785) 
    Fittings- 1" 3000 lb CWP Forged Carbon Steel (ASTM A105-ANSI B16.11)2,000 psi 1" Schedule 80 ( ASTM F439, latest revision) 
   Chlorinator- Wallace & Tiernan 2000 lb/day chlorinator; 160 psi max. pressure at point of application Capitol Controls 1000 lb/day chlorinator;   
   Chlorine Ejector- Capitol Controls ; 150 lb PVC 
   Vacuum Regulator- Capitol Controls 2000 lb/day; 3/4" and 1" schedule 80 PVC 
 
 
(2) Hazard Review 
 
"For a Program 2 process, you must conduct a hazard review.  EPA has streamlin 
ed the process hazard analysis (PHA) requirement of OSHA's PSM standard to create a requirement that will detect process hazards for processes in Program 2.  The hazard review will help you determine whether you are meeting applicable codes and standards, identify and evaluate the types of potential failures, and focus your emergency response planning efforts." (6-9) 
 
   Hazard Review Requirements 
 
(1) Conduct a review 
   - hazards 
   - opportunities that could create a release 
   - safeguards 
   - detecting minor releases 
(2) Document results & resolve problems 
(3) Update your hazard review 
   - every five years 
   - before processes are changed 
 
 
There are three different hazard evaluation methods that can be used in the RMP.   
* Checklist 
* What-If / Checklist 
* Hazard and operability (HAZOP) Review 
    
After the hazard review is complete, the person or persons conducting the review should report a list of findings and recommendations.  Plant personnel will review these findings and implement a pro 
gram to address the deficiencies.   
    
"You must ensure that problems identified are addressed in a timely manner.  EPA does not require that you implement every recommendation.  It is up to you to decide which recommendations are necessary and feasible.  You may decide that other steps are as effective as the recommended actions or that the risk is too low to merit the expense.  You must, however, document your decision on each recommendation.  If you are implementing a recommendation, you should document the schedule for implementation.  If you are taking other steps to address the problem or decide the problem does not merit action, you should document the basis for your decision." (6-13) 
 
"You must update the review every five years or whenever a major change in a process occurs." (6-13) 
Exhibit 6A-1, 6A-2, and 6A-3 were reviewed and found to be an appropriate checklists for the chlorination operation the Lancaster WWTP.  The checklist was distributed to key personnel in April 1999  
for completion.  Based on the responses, operational changes and equipment purchases will be made.  All changes will be documented.  
 
   The most recent hazard review was completed on April 7, 1999.  
 
The hazard review will be updated at least once during the next five years.  A hazard review will also be conducted whenever a major operational change occurs. 
 
It is important to note that two chlorine leak detectors are used in the chlorination process.  One Chloralert leak detector is located in the chlorine cylinder room and the other is located in the chlorinator room.  If these sensors detect a leak, a highly visible light located outside the building is triggered to alert personal of a leak.  These leak detectors are also connected to the WWTP's computer system.  When the sensors are triggered, an alarm message will display on the operations computers and digital display located in the control room.  
 
Two self contained breathing apparatuses (SCBA) are located outside the chorine cyl 
inder room.  Each SCBA has an oxygen supply time of thirty minutes. 
 
Aorespro Escape Artist chemical cartridge respirators are provided to each operator that controls the chlorination process.  These respirators are required to be used during any chlorine handling activities.    
 
 
(3)Operating Procedures 
 
"Written operating procedures describe in detail what tasks a process operator must perform, set safe operating parameters that must be maintained, and set safety precautions for operations and maintenance activities." (6-14) 
 
"You must prepare written operating procedures that give workers clear instructions for safely conducting activities involving a covered process.  You may use standardized procedures developed by industry groups or provided in industry-specific risk management program guidances as the basis for your operation procedures, be sure to check that these standard procedures are appropriate for your activities."  (6-14)     
 
At the Lancaster WWTP Operators move chlorine c 
ylinders, connect new cylinders, and disconnect empty cylinders.  All other procedures and problems encountered with the chlorination system are handled by supervisory staff.  Written standard operating procedures were developed for the safe handling of chlorine for the given circumstances mentioned above. 
 
Additional safety and operating procedures were taken from the Operation of Wastewater Treatment Plants; Volume 2.  This training manual contains pertinent information pertaining to the operations at the Lancaster WWTP, and pages of this manual are included with the RMP. 
 
Safety and training videos published by The Chorine Institute are used to help educate the WWTP operators. 
 
Standard operating procedures were reviewed and revised on April 16, 1999. 
 
 
    
   Standard Operating Procedures for the Safe Handling of Chlorine 
               April-1999 
 
Chlorine is an extremely toxic chemical and must be handled with extreme care and caution. 
 
1) Storage 
 
   a) Temperature in the chlorine cylinder stora 
ge room should be approximately 600F or slightly warmer. 
 
   b) Temperature in the chlorinator room should be maintained at a normal indoor temperature of about 680F. 
 
   c) A maximum of six cylinders can be stored inside the chlorination building and eight cylinders can be stored in the outside storage area. 
 
   d) The maximum administrative limit for full chlorine cylinders is 10 full cylinders. 
 
       i) Of the 10 cylinders, 6 full cylinders are stored inside the chlorination building and four full cylinders will be stored outside.  As cylinders are used, the empties are moved from the inside to the outside, and the full cylinders are moved from the outside to the inside.   
 
   e) Eight chlorine cylinders are ordered when the final two full cylinders are connected and in use.   
 
   f) Full cylinders must be brought into the chlorination building approximately 24 hours or more before using so that the temperature of the contents can become equalized with the room temperature. 
 
   g) All storage area 
s must be kept clean so that trash does not accumulate and present a fire hazard. 
 
2) Cylinder Handling 
 
   a) Before chlorine handling is commence, the employees performing the activities must verify that the safety equipment is present and in good working order. 
 
   b) The moving of chlorine ton cylinders must be done by two or more employees. 
 
   c) The valve protective hood must be in place on all containers not in use so the valves are protected from damage.  
 
   d) Cylinders must be moved with the electric hoist and monorail system.  The ventilation fan to the building must be on, and the doors to the cylinder building must be securely fastened in the open position. 
 
   e) When an empty container is removed from service the valve must be closed, valve end cap replaced, and the valve protective hood reinstalled to prevent moisture form entering the container. 
 
3) Cylinder Use 
 
   a) Before chlorine handling is commenced, the employees performing the activities must verify that the safety equi 
pment is present and in good working order. 
 
   b) Ton cylinders must be chocked in a horizontal position and the valves must be in a vertical line.  Gas is withdrawn from the upper valve. 
 
   c) Never use containers that are warmer than the room in which the chlorinator is located.  If the cylinder is warmer than the room, gas can condense into a liquid in the gas supply piping and this liquid could possibly enter the chlorinator.  Liquid chlorine will damage equipment, cause faulty operation, and possible cause failure of the process. 
 
   d) The ventilation fans to the cylinder room and the chlorinator room should be on during any periods in which either room is occupied. 
 
   e) Due to the amount of chlorine consumed, it is necessary to manifold two chlorine cylinders together and discharge them simultaneously. 
 
   i) The temperature of all containers connected to the header must be equal and remain equal during use.  If containers are of unequal temperatures, gas will flow from the warmer con 
tainer and condense in the cooler container. 
 
4) Connection of Chlorine Cylinders 
 
   a) Before chlorine handling is commenced, the employees performing the activities must verify that the safety equipment is present and in good working order.  The Aorespro Escape Artist supplied to each operator must be present. 
 
   b) Ventilation fans to the cylinder room and chlorinator room must be turned on if the room is to be occupied at any time. 
 
   c) All cylinder valves and header valves must be closed before connecting new cylinders. 
 
   d) Remove the cylinder's protective housing that covers the valves. 
 
   e) The cylinder should be rotated so that the valves are in a vertical line. 
 
       i) Gas is removed from the upper valve. 
       ii) Liquid is removed from the lower valve. 
 
   f) Remove the outlet cap on the upper valve for gas withdraw. 
 
   g) Connect the two new cylinders to the header with the flexible copper tubing. 
 
       i) A new lead gasket should be used each time a connection is made between a cylinde 
r and the flexible connection tubing. 
 
   h) Open the header valves 1 1/2 turns in the counter-clockwise direction. 
 
   i) Open the cylinder valves 1 full turn in the counter-clockwise direction. 
 
       i) One full turn of the stem permits maximum discharge. 
       ii) If the valve will not open, do not use excessive force.  Notify the supervisor of the problem. 
       iii) Leave the square box wrench on each cylinder valve so that once the valve is opened the valve can be closed quickly. 
 
   j) Once all the connections have been made the system can be pressurized and tested for leaks with ammonia.  
 
5) Disconnecting Chlorine Cylinders 
 
   a) Before chlorine handling is commenced, the employees performing the activities must verify that the safety equipment is present and in good working order.  The Aorespro Escape Artist supplied to each operator must be present. 
 
   b) When the cylinders become empty, close the outlet valves on both cylinders. 
 
   c) After several minutes, close both header valves when the ch 
lorine pressure at the vacuum regulator is zero psi. 
 
   d) Disconnect the flexible copper connecting hose and throw away the old lead gasket. 
 
   e) Replace the outlet cap on the upper valve and the valve protective housing. 
 
   f) Place empty cylinders in the outside storage area. 
 
   g) If two cylinders are located within the chlorination building cylinder storage location, rotate these cylinders into the previous locations of the empty cylinders that were placed outside. 
 
   h) Place two full cylinders in the chlorination building storage location from the outside storage area. 
 
6) Emergency Shutdowns 
 
   a) Ventilation fans to the cylinder room and chlorinator room must be turned on. 
 
   b) Employees performing the activities must verify that the safety equipment is present and in good working order.  The Aorespro Escape Artist supplied to each operator must be present. 
 
   c) If a problem develops in the chlorination system immediately turn the chlorine off. 
 
       i) Close the cylinder valve in the 
clockwise direction until it is closed. 
       ii) Check all equipment, pipes, and cylinders for leaks. 
 
 
(4)Training  
 
"You must train all new workers in your operating procedures developed under the previous prevention program element;  if any of your more experienced workers need training on these procedures, you should also train them.  Any time the procedures are revised, you must train everyone using the new procedures.  At least once every three years, you must provide refresher training on the operating procedures even if they have not changed.  The training must cover all parts of the operating procedures, including information on the consequence of deviations and steps needed to address deviations." (6-16) 
 
"You need not provide initial training for workers already operating a process as of June 21, 1999, if you in writing that the employees have the "required knowledge, skills, and abilities to safely carry out the duties and responsibilities as provided in the operating procedu 
res" (68.54(a)).  This certification should kept in your files; you do not need to submit it to EPA." 
 
Workers at the Lancaster WWTP have the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as provided in the operating procedures.  All operators are trained by the management staff and are accompanied during all chlorine handling activities until they demonstrate they are competent in all aspects of the process.  Observation by the Operations Supervisors is the method used to determine if an operator understands and has the ability to operate the process safely.  Additional refresher training is provided by the Operations Staff on a yearly basis. 
 
Additional safety, operating, and training procedures were taken from the Operation of Wastewater Treatment Plants; Volume 2.  This training manual contains pertinent information pertaining to the operations at the Lancaster WWTP, and pages of this manual are included with the RMP. 
 
Safety and trai 
ning videos published by The Chorine Institute are used to help educate the WWTP operators. 
 
The last overview of the training program, completed on April 26, 1999, was performed as a part of the development of the RMP. 
 
 
(5)Maintenance 
 
"Preventive maintenance, inspection, and testing of equipment is critical to safe operations.  Waiting for equipment to fail often means waiting for an accident that could harm people and the environment.  Further, a thorough maintenance program will save you money by cutting down-time caused by equipment failures." (6-21) 
 
"You must prepare and implement procedures for maintaining the mechanical integrity of process equipment, and train your workers in the maintenance procedures.  For most of the equipment in a WWTP, the manufacturer will have supplied maintenance instructions.  These can be used to fulfill the requirement for maintenance procedures.  Where such instructions are not available, you will need to develop them." (6-22) 
 
Contained in this  
RMP are manufacturers' recommended maintenance procedures for equipment used in the chlorination process.  Inspection and testing information was also obtained from the Operation of Wastewater Treatment Plants; Volume 2.   
 
At the Lancaster WWTP, procedures used to maintain the mechanical integrity of the chlorination process are followed.  Maintenance procedures are based on manufacturers' recommendations, prior operating experience, and industry standards. 
 
"In the RMP, you are required to report on the date of the most recent review or revision of your maintenance procedures and the date of the most recent equipment inspection or test and equipment inspected or tested.  You must keep on site your written procedures and schedules as well as any agreements you have with contractors."  (6-24) 
 
At the Lancaster WWTP, the Maintenance Supervisor has a computer system that automatically generates work orders.  These work orders are completed by the maintenance staff and are stored on file. 
 A maintenance log will be developed to document work performed on the chlorination system.   
 
The last overview of the maintenance program was completed in April 1999. 
 
Along with the manufacturers' maintenance procedures, documents published by The Chlorine Institute will be purchased to supplement the maintenance information.   
 
"You must establish a schedule for inspecting and testing equipment associated with covered processes.  The frequency of inspections and tests must be consistent with manufacture's recommendations, industry standards or codes, good engineering practices, and your prior operating experience." (6-24) 
 
 
(6)Incident Investigation  
 
"You must investigate each incident which resulted in, or could have resulted in, a catastrophic release of a regulated substance.  A catastrophic release is one that presents an imminent and substantial endangerment to public health and the environment.  Exhibit 6-10 briefly summarizes the steps you must take for investigation incid 
ents.  You should also consider investigating minor accidents or near misses because they may help you identify problems that could lead to more serious accident; however, you are not required to do so under part 68."    (6-29) 
 
The Lancaster WWTP will investigate all incidences that result in the release of chlorine within 48 hours.  All findings will be summarized in a report that will include the following information: 
* Factors contributing to the incident 
* Recommendation for corrective actions 
 
Modifications, if applicable, will be made to the chlorination system and RMP to prevent further incidents.  All incident investigation reports will be kept on file for five years. 
 
The Lancaster WWTP will use an Incident Investigation Report to document each incident that occurs. 
 
 
(7)Compliance Audits 
 
"Any risk management program should be reviewed periodically to ensure that employees and contractors are implementing it properly.  A compliance audit is a way for you to evaluate and mea 
sure the effectiveness of your risk management program.  An audit reviews each of the prevention program elements to ensure that they are up-to-date and are being implemented and will help you identify problem areas and take corrective actions." (6-26) 
 
During the months of  January 1999 to May 1999, the RMP for the Lancaster WWTP was developed.  All information pertaining to the RMP was collected, organized, and revised. 
 
All aspects of the fully developed RMP will be reevaluated within two years by supervisory staff knowledgeable in the chlorination process.  
 
"You must keep a written record of audit findings and your response to those findings and documents that deficiencies have been corrected.  You must keep the two most recent audit reports, but you need not keep a report that is more than five years old.  You may also want to keep a record of who conducted the audit, but you are not required to do this." (6-27) 
 
Exhibit 6-9 was reviewed and found to be an appropriate checklist f 
or completing an audit of the safety information and hazard review contained in the RMP.  Based on the responses, operational changes and equipment purchases will be made.  All changes will be documented.   
 
The Lancaster WWTP will keep the two most recent audit reports within the prior five-year period. 
 
 
 
 
Emergency Response Program 
 
"If you have at least one Program 2 or Program 3 at you facility, then part 68 may require you to implement an emergency response program, consisting of an emergency response plan, emergency response equipment procedures, employee training, and procedures to ensure the program is up-to-date.  This requirement applies if your employees will respond to some releases involving regulated substances." (8-1) 
 
What is a response? 
 
"EPA interprets "response" to be consistent with the definition of response specified under OSHA's HAZWOPER Standard.  OSHA defines emergency response as "a response effort by employees from outside the immediate release area or by ot 
her designated responders... to an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous substance."  The key factor here is that responders are designated for such tasks by their employer.  This definition excludes "responses to incidental releases of hazardous substances where the substance can be absorbed, neutralized or otherwise controlled at the time of release by employees in the immediate release are, or by maintenance personnel"  as well as " responses to releases of hazardous substances where there is no potential safety or health hazard (i.e., fire, explosion, or chemical exposure)."  Thus, if you expect your employees to take action to end a small leak (e.g., shutting a valve) or clean up a spill that does not pose an immediate safety or health hazard, this action could be considered an incidental response and you would not need to develop an emergency response program if your employees are limited to such activities." (8-2) 
 
Due to the 
fact that employees at the Lancaster WWTP will only respond to small leaks that can be contained by shutting a valve, the WWTP is not required to develop a full blown Emergency Response Program in the RMP. 
 
Under the RMP requirements, the WWTP is required to coordinate with local response agencies to ensure that they will be prepared to respond to an emergency at the facility. 
 
Coordination with local responders entails the following steps: 
 
* Ensure that you have set up a way to notify emergency responders when there is a need. 
* If you have a covered process with a regulated toxic, work with the local emergency planning entity to ensure that the facility is included in the community emergency response plan prepared under EPCRA regarding a response. 
 
The Local Emergency Planning Committee (LEPC) of Lancaster County is currently has an Off-Site Response Plan in place for the chlorination operation at the Lancaster WWTP.  This plan is updated each year by both the LEPC and the City of  
Lancaster.   
 
The latest update of the LEPC's Off-Site Response Plan is enclosed. 
Introduction 
 
The following Risk Management Program (RMP) information is taken directly from Environmental Publication (EPA) 550-B-98-010.  This publication has specific guidance requirements and calculation procedures for Wastewater Treatment Plants regulated under section 112 of the Clean Air Act. 
 
It has been determined that the City of Lancaster Advanced Wastewater Treatment Facility has to comply with Part 68 of Title 40 of the Code of Federal Regulations (CFR). 
 
"The phrase "risk management program" refers to all of the requirements of part 68, which must be implemented on an on-going basis.  The phrase "risk management plan " refers to the document summarizing the risk management program that you must submit to EPA." 
 
Due to the fact that the WWTP is covered under this regulation, the following activities must be undertaken: 
    
"Covered facilities must develop and implement a RMP and maintain docum 
entation of the program at the site.  The RMP will include and analysis of the potential offsite consequences of an accidental release, a five-year accident history, a release prevention program, and an emergency response program."  
 
"Covered facilities also must develop and submit a Risk Management Plan, which includes registration information, to EPA no later than June 21, 1999, or the date on which the facility first has more than a threshold quantity in a process, whichever is later.  The Risk Management Plan provides a summary of the Risk Management Program.  The RMP will be available to federal, state, and local government agencies and the public." 
 
"Covered facilities also must continue to implement the RMP and update their RMPs periodically or when processes change, as required by the rule." 
 
 
The WWTP is covered because it is a stationary source that stores chlorine above the threshold quantity of 2,500 pounds in a single process. 
 
   Process:    Any group of vessels that are inter 
connected, or separate vessels that are located such that a regulated substance could be involved in a potential release, shall be considered a single process.  
 
   Vessel:    Any container, from a single drum or pipe to a large storage tank or sphere. 
 
The WWTP stores one (1) ton chlorine cylinders for the purpose of disinfecting wastewater before it enters the Conestoga River.  The maximum quantity stored on site is ten (10) full cylinders.  Of these ten (10) cylinders, six (6) full cylinders are stored inside and four (4) are stored outside.  The maximum amount of chlorine stored outside is four (4) full cylinders.  Once cylinders become empty, they are moved from inside the chlorination building to the outside storage area. 
 
"In general, if you have two or more vessels containing a regulated substance that are connected through piping or hoses for the transfer of the regulated substance, you must consider the total quantity of a regulated substance in all the connected vessels and pipin 
g when determining if you have a threshold quantity in a process." (1-6) 
 
If only one cylinder was used at a time, the City's WWTP would not be required to develop a Risk Management Program because they would be under the 2,500 pound threshold quantity.  Due to the amount of wastewater chlorinated at the Lancaster WWTP, it is necessary to manifold two chlorine cylinders together.  
 
 
   Flow Diagram:  Two cylinders---> vacuum regulator --->  chlorinator ---> chlorine ejector 
 
As the diagram above shows, two cylinders are connected together resulting in a threshold quantity over the 2,500 pound limit.  Interconnecting the two vessels together creates a single process.  Thus, the WWTP must develop a Risk Management Program. 
 
"The third possibility you must consider is whether you have separate vessels that contain the same regulated substance that are located such that they could be involved in a single release.  If so, You must add together the total quantity in all such vessels to determi 
ne if you have more than a threshold quantity." (1-7) 
 
The possibility of an accident effecting two or more full chlorine cylinders stored outside is nonexistent.  The outside storage area is a brick and steel structure capable of withstanding fire, earthquake, and collision hazards.  Pillions made of steel and cement protect the area from collisions and the escape of cylinders.  A release from one chlorine cylinder would not lead to a release from another cylinder located next to it. 
It has been determined that the two cylinders connected together are considered to be a single process.  The associated piping is also considered to be a part of that process. 
 
    
When does the process end?    
 
   "The process ends when the concentration of chlorine in the wastestream is no longer above one percent, unless other regulated substances are present above their threshold quantities or the vessel is otherwise considered part of the process because it could cause a release of the covered vessels ho 
lding regulated substances or hinder a response to such a release." 
 
   Process ends when the Cl2 mixes with the process water. 
   * 150 gal/min of process water 
   * 1000 LB/day maximum Cl2 input 
 
1.8 million LB/day of process water to 1000 LB/ day Cl2 creates a .05 % chlorine solution.   
 
 
"If your process consists of two or more interconnected vessels, you must determine the maximum quantity for each vessel and the connecting pipes or hoses.  The maximum for each individual vessel and pipe is added together to determine the maximum for the process." 
 
Standard operating procedure at the Lancaster WWTP directs personnel to only change chlorine when all chlorine is removed from the network by vacuum.  After all chlorine is drained for the system, two new cylinders are connected to the manifold.  At no time is there more than 4,000 pounds of chlorine within the process. 
 
Since it has been determined that the Lancaster WWTP has to develop a RMP and it falls under the classification of a Progra 
m 2, the following is required: 
 
 
(1) Hazard Assessment 
   (a) Worst-case analysis 
   (b) Alternative releases 
   (c) 5-year accident history 
(2) Management Program 
   (a) Document management system 
 
(3) Prevention Program 
   (a) Safety information 
   (b) Hazard review 
   (c) Operating procedures 
   (d) Training 
   (e) Maintenance / Mechanical integrity 
   (f) Incident investigation 
   (g) Compliance audit 
(4) Emergency Response Program 
   (a) Develop plan and program 
(5) Risk Management Plan Contents 
   (a) Executive summary 
   (b) Registration 
   (c) Worst-case data 
   (d) Alternative release data 
   (e) 5-year accident history 
   (f) Prevention program data 
   (g) Certification 
 
 
 
 
Offsite Consequence Analysis 
 
"You are required to conduct an offsite consequence analysis to provide information to the government and the public about the potential consequences of an accidental chemical release at your facility.  The offiste consequence analysis (OCA) consists of two elements:  
 
* A worst-case release scenario  
* Alternati 
ve release scenario 
 
"To simplify the analysis and ensure a common basis for comparisons, EPA has defined the worst-case scenario as the release of the largest quantity of a regulated substance from a single vessel or process line failure that results in the greatest distance to an endpoint." (4-1) 
 
   Estimating Offsite Receptors 
 
"The rule requires that you estimate residential populations within the circle of your worst-case and alternative release scenarios.  In addition, you must report in the RMP whether types of public receptors and environmental receptors are within the circles." 
    
Population estimates were obtained from the United States Bureau of Census.  Landview III software was downloaded off of the Internet and used to determine the population within the release area.  The rule requires that you estimate the population to two significant digits. 
 
The RMP also states that you must identify what types of receptors are located within the release area.  Receptors are classified 
by the following terms: 
 
Public receptors: residences, schools, hospitals, prisons, public recreation areas, and major commercial or industrial areas 
 
   Recreational areas: public swimming pools, public parks 
 
Environmental receptors: National or State Parks, forests, monuments, wildlife sanctuaries, Federal wilderness areas 
 
 
(1)Development of the Worst-Case Scenario 
 
The worst-case release quantity Q (lb) was determined to be the contents of one cylinder of chlorine. 
 
    
"For vessels, you need only consider the largest amount in the vessel, regardless of interconnections with pipes and other vessels. ... You may be able to think of scenarios in which a quantity greater that Q as defined above can be released, but EPA does not require you to model such scenarios as worst-case (you may want to consider modeling them as alternative scenarios)." (4-3) 
 
From this definition, the worst-case release quantity (Q), would be that of a one ton cylinder of chlorine, 2,000 lbs.  The worst-case sce 
nario also assumes that this quantity would be released over a period of 10 minutes.  The worst-case release rate would then be 200 lb/min. 
 
The worst-case scenario is assumed to take place at ground level under specific default weather conditions. 
 
   Default weather conditions: 
       * 1.5 m/s Wind Speed  
       * F Atmospheric Stability 
       * 25oC (77oF) Ambient Temperature 
       * 50 percent Humidity   
 
The toxic endpoint for chlorine is 0.0087 mg/L (3ppm). 
    
"These airborne concentrations are the maximum airborne concentrations below which it is believed that nearly all individuals can be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ability to take protective action." 
 
Both the worst-case and alternative-case release will take place under urban conditions.  Urban conditions are modeled because the Lancaster WWTP is located amongst hills, trees, and numerous buildings.  The release modeled f 
or the RMP can only occur within the chlorination building due to the threshold quantity of 2,500 pounds only being located inside the building.  If a cylinder would release chlorine outside the building, it would be a single vessel under the 2,500 pound threshold. 
 
The worst-case scenario will be modeled as if it where to occur outside.  This scenario is used to represent an event in which the building doors are open, the building in not leak-tight, or the ventilation system is on. 
EPA Guidance 550-B-98-010 Exhibit 4-3 was used to determine the distance to toxic endpoint. 
    
Worst-case scenario distance to toxic endpoint - 1.3 miles 
 
"Note that the release rate estimated by the method above is conservative.  As the release proceeds, chlorine continuously evaporates from the liquid surface in the cylinder.  This causes the liquid to cool, the vapor pressure to decrease, and the rate of release to decline.  However, the equations for calculating this effect are rather complex and not inc 
luded in this guidance." (4-26) 
 
Landview III software was used to determine the population within the release radius. 
    
The population affected by a release with a radius of 1.3 miles would be 15,000 people. 
 
   Public and Recreational receptors would be affected. 
 
 
(2)Development of the Alternative Release Scenario 
 
"Your alternative scenario for a covered process must be one that is more likely to occur than the worst-case scenario and that reaches an endpoint offsite, unless no such scenario exists.  You do not need to demonstrate greater likelihood of occurrence or carry out and analysis of probability of occurrence; you only need to use reasonable judgement and knowledge of the process." (4-20) 
 
The alternative release scenario for the Lancaster Advanced Wastewater Treatment Facility is modeled under the average weather conditions for Lancaster, Pennsylvania.  These conditions were obtained from the National Climatic Data Center on March 11, 1999.     
   * 10.9oC (51.7oF) Average Ambien 
t Temperature 
   * D Atmospheric Stability 
   * 3.7 m/s Wind Speed 
   * 50 percent Humidity 
 
A break or crack in the flexible connection between the cylinder and the header could easily be stopped by closing the cylinder valve.  If a chlorine leak were to occur, it would most likely occur during the hookup of new cylinders.  For the Lancaster WWTP, the most probable incident resulting in a chlorine release would be the shearing of the cylinder valve. Other scenarios were examined but determined to be less likely of ever occurring.  The outside diameter of the chlorine cylinder valve is one inch.  The actual opening inside the valve for chlorine to escape is only 3/8 inch.   
 
The alternative scenario will be modeled as if it where to occur outside.  This scenario is used to represent an event in which the building doors are open, the building in not leak-tight, or the ventilation system is on.  The release takes place in an urban environment. 
 
EPA Guidance 550-B-98-010 Exhibit 4-15 was used t 
o determine the distance to toxic endpoint.  The atmospheric stability and wind speed for the WWTP's location is the closest available.  Exhibit 4-15 uses an atmospheric stability of  D and a wind speed of    3 m/s.  A hole of 5/16 resulted in a release rate of 15 lbs/min. 
 
Alternative scenario distance to toxic endpoint - 0.1 miles 
 
"Note that the release rate estimated by the method above is conservative.  As the release proceeds, chlorine continuously evaporates from the liquid surface in the cylinder.  This causes the liquid to cool, the vapor pressure to decrease, and the rate of release to decline.  However, the equations for calculating this effect are rather complex and not included in this guidance." (4-26) 
 
 
Landview III software was used to determine the population within the release radius. 
    
The population affected by a release with a radius of 0.1 miles would be 25 people. 
 
   Public and recreational receptors would be affected. 
 
 
 
 
Five Year Accident History 
 
The City of L 
ancaster Advanced Wastewater Treatment Facility had no reportable releases during the past five years. 
 
 
 
 
Management System 
 
The management system was developed to oversee the coordination and implementing of the Risk Management Program element. 
 
The Plant's Utility Engineer will have the overall responsibility for the Risk Management Program elements.    
 
"Remember that the only element of your management system that you must report in the RMP is the name of the qualified person or position with overall responsibility." (5-2) 
 
 
 
 
Lines of Authority for RMP purposes: 
 
 
 
                 William Horst 
       (Superintendent of Wastewater Operations) 
                   * 
      ********************************************** 
   Bryan Harner          Gary Bowers        Edward Mastromatteo 
(Utility Engineer)     (Chief Operator)     (Maintenance Supervisor) 
                   *            * 
                   *            * 
                 Terry Dickel             Jim Csoka 
              (Ass. Chief Operator)   (Maintenance Foreman) 
                   *            *                 
                   *            * 
                 Operators            Mechanics 
 
 
 
 
 
 
Prevention Program 
 
"EPA developed the Program 2 prevention program by identifying the basic elements that are the foundation of sound prevention practices- safety information, hazard review, operating procedures, training, maintenance, compliance audits, and accident investigation.  By meeting other Federal regulations, state laws, industry codes and standards, and good engineering practices, you probably have already met most of the Program 2 prevention elements requirements." (6-1) 
 
 
       Sections of the Program 2 Prevention Program: 
 
1. Safety Information 
2. Hazard Review 
3. Operating Procedures 
4. Training 
5. Maintenance 
6. Incident Investigation 
7. Compliance Audits 
 
 
(1) Safety Information 
    
* Material Safety Data Sheet (MSDS) for chlorine is included with this report. 
* The Maximum Intended Inventory is 10 full one ton cylinders of Chlorine. 
* Safe upper and lower for chlorine storage - Ideal storage temperature is 10-27oC (50-80oF).  Do not expose sealed containers to temperature 
s above 40oC (104oF).  The Chlorine Institute recommends that chlorine tanks not be filled beyond 95 percent at a maximum temperature of 122oF. 
* Equipment specifications used in the design of the chlorination system are included with this plan. 
* Codes and standards used to design the chlorination system are also included with the RMP. 
 
"The purpose of this requirement is to ensure that you understand the safety-related aspects of the equipment and processes you have, know what limits they place on your operations, and adopt accepted standards and codes where they apply.  Having up-to-date safety information about your process is the foundation of an effective prevention program." (6-1) 
 
The chlorination facility was designed and built in conformance with the National Electric Code (NEC), American National Standards Institute (ANSI), American Society for Testing Materials (ASTM), and the National Fire Protection Association (NFPA). 
 
The following table contains the equipment used with 
in the chlorination process.  For each piece of equipment, specifications pertaining to that equipment's construction, design, and tolerances are noted.  Documentation for the RMP is achieved by having the specifications and safety information for the chlorination process contained within.  
 
 
CHORINATION EQUIPMENT 
 
   Maximum Flow Rate: 400 lb/day per cylinder(depends on storage conditions) 
   Flexible Piping- 3/8" OD Cadmium Plated Copper Tubing;  500 psi maximum 
   Rigid piping- 1" Schedule 80 high temperature seamless carbon steel (ASTM A106 GR. C) 1" Schedule 80 PVC (ASTM D1785) 
    Fittings- 1" 3000 lb CWP Forged Carbon Steel (ASTM A105-ANSI B16.11)2,000 psi 1" Schedule 80 ( ASTM F439, latest revision) 
   Chlorinator- Wallace & Tiernan 2000 lb/day chlorinator; 160 psi max. pressure at point of application Capitol Controls 1000 lb/day chlorinator;   
   Chlorine Ejector- Capitol Controls ; 150 lb PVC 
   Vacuum Regulator- Capitol Controls 2000 lb/day; 3/4" and 1" schedule 80 PVC 
 
 
(2) Hazard Revie 

 
"For a Program 2 process, you must conduct a hazard review.  EPA has streamlined the process hazard analysis (PHA) requirement of OSHA's PSM standard to create a requirement that will detect process hazards for processes in Program 2.  The hazard review will help you determine whether you are meeting applicable codes and standards, identify and evaluate the types of potential failures, and focus your emergency response planning efforts." (6-9) 
 
   Hazard Review Requirements 
 
(1) Conduct a review 
   - hazards 
   - opportunities that could create a release 
   - safeguards 
   - detecting minor releases 
(2) Document results & resolve problems 
(3) Update your hazard review 
   - every five years 
   - before processes are changed 
 
 
There are three different hazard evaluation methods that can be used in the RMP.   
* Checklist 
* What-If / Checklist 
* Hazard and operability (HAZOP) Review 
    
After the hazard review is complete, the person or persons conducting the review should report a list of findings and 
recommendations.  Plant personnel will review these findings and implement a program to address the deficiencies.   
    
"You must ensure that problems identified are addressed in a timely manner.  EPA does not require that you implement every recommendation.  It is up to you to decide which recommendations are necessary and feasible.  You may decide that other steps are as effective as the recommended actions or that the risk is too low to merit the expense.  You must, however, document your decision on each recommendation.  If you are implementing a recommendation, you should document the schedule for implementation.  If you are taking other steps to address the problem or decide the problem does not merit action, you should document the basis for your decision." (6-13) 
 
"You must update the review every five years or whenever a major change in a process occurs." (6-13) 
Exhibit 6A-1, 6A-2, and 6A-3 were reviewed and found to be an appropriate checklists for the chlorination operation t 
he Lancaster WWTP.  The checklist was distributed to key personnel in April 1999 for completion.  Based on the responses, operational changes and equipment purchases will be made.  All changes will be documented.  
 
   The most recent hazard review was completed on April 7, 1999.  
 
The hazard review will be updated at least once during the next five years.  A hazard review will also be conducted whenever a major operational change occurs. 
 
It is important to note that two chlorine leak detectors are used in the chlorination process.  One Chloralert leak detector is located in the chlorine cylinder room and the other is located in the chlorinator room.  If these sensors detect a leak, a highly visible light located outside the building is triggered to alert personal of a leak.  These leak detectors are also connected to the WWTP's computer system.  When the sensors are triggered, an alarm message will display on the operations computers and digital display located in the control room.  
 
Tw 
o self contained breathing apparatuses (SCBA) are located outside the chorine cylinder room.  Each SCBA has an oxygen supply time of thirty minutes. 
 
Aorespro Escape Artist chemical cartridge respirators are provided to each operator that controls the chlorination process.  These respirators are required to be used during any chlorine handling activities.    
 
 
(3)Operating Procedures 
 
"Written operating procedures describe in detail what tasks a process operator must perform, set safe operating parameters that must be maintained, and set safety precautions for operations and maintenance activities." (6-14) 
 
"You must prepare written operating procedures that give workers clear instructions for safely conducting activities involving a covered process.  You may use standardized procedures developed by industry groups or provided in industry-specific risk management program guidances as the basis for your operation procedures, be sure to check that these standard procedures are appropriat 
e for your activities."  (6-14)     
 
At the Lancaster WWTP Operators move chlorine cylinders, connect new cylinders, and disconnect empty cylinders.  All other procedures and problems encountered with the chlorination system are handled by supervisory staff.  Written standard operating procedures were developed for the safe handling of chlorine for the given circumstances mentioned above. 
 
Additional safety and operating procedures were taken from the Operation of Wastewater Treatment Plants; Volume 2.  This training manual contains pertinent information pertaining to the operations at the Lancaster WWTP, and pages of this manual are included with the RMP. 
 
Safety and training videos published by The Chorine Institute are used to help educate the WWTP operators. 
 
Standard operating procedures were reviewed and revised on April 16, 1999. 
 
 
    
   Standard Operating Procedures for the Safe Handling of Chlorine 
               April-1999 
 
Chlorine is an extremely toxic chemical and must be handled with extr 
eme care and caution. 
 
1) Storage 
 
   a) Temperature in the chlorine cylinder storage room should be approximately 600F or slightly warmer. 
 
   b) Temperature in the chlorinator room should be maintained at a normal indoor temperature of about 680F. 
 
   c) A maximum of six cylinders can be stored inside the chlorination building and eight cylinders can be stored in the outside storage area. 
 
   d) The maximum administrative limit for full chlorine cylinders is 10 full cylinders. 
 
       i) Of the 10 cylinders, 6 full cylinders are stored inside the chlorination building and four full cylinders will be stored outside.  As cylinders are used, the empties are moved from the inside to the outside, and the full cylinders are moved from the outside to the inside.   
 
   e) Eight chlorine cylinders are ordered when the final two full cylinders are connected and in use.   
 
   f) Full cylinders must be brought into the chlorination building approximately 24 hours or more before using so that the temperature of t 
he contents can become equalized with the room temperature. 
 
   g) All storage areas must be kept clean so that trash does not accumulate and present a fire hazard. 
 
2) Cylinder Handling 
 
   a) Before chlorine handling is commence, the employees performing the activities must verify that the safety equipment is present and in good working order. 
 
   b) The moving of chlorine ton cylinders must be done by two or more employees. 
 
   c) The valve protective hood must be in place on all containers not in use so the valves are protected from damage.  
 
   d) Cylinders must be moved with the electric hoist and monorail system.  The ventilation fan to the building must be on, and the doors to the cylinder building must be securely fastened in the open position. 
 
   e) When an empty container is removed from service the valve must be closed, valve end cap replaced, and the valve protective hood reinstalled to prevent moisture form entering the container. 
 
3) Cylinder Use 
 
   a) Before chlorine handling is co 
mmenced, the employees performing the activities must verify that the safety equipment is present and in good working order. 
 
   b) Ton cylinders must be chocked in a horizontal position and the valves must be in a vertical line.  Gas is withdrawn from the upper valve. 
 
   c) Never use containers that are warmer than the room in which the chlorinator is located.  If the cylinder is warmer than the room, gas can condense into a liquid in the gas supply piping and this liquid could possibly enter the chlorinator.  Liquid chlorine will damage equipment, cause faulty operation, and possible cause failure of the process. 
 
   d) The ventilation fans to the cylinder room and the chlorinator room should be on during any periods in which either room is occupied. 
 
   e) Due to the amount of chlorine consumed, it is necessary to manifold two chlorine cylinders together and discharge them simultaneously. 
 
   i) The temperature of all containers connected to the header must be equal and remain equal during u 
se.  If containers are of unequal temperatures, gas will flow from the warmer container and condense in the cooler container. 
 
4) Connection of Chlorine Cylinders 
 
   a) Before chlorine handling is commenced, the employees performing the activities must verify that the safety equipment is present and in good working order.  The Aorespro Escape Artist supplied to each operator must be present. 
 
   b) Ventilation fans to the cylinder room and chlorinator room must be turned on if the room is to be occupied at any time. 
 
   c) All cylinder valves and header valves must be closed before connecting new cylinders. 
 
   d) Remove the cylinder's protective housing that covers the valves. 
 
   e) The cylinder should be rotated so that the valves are in a vertical line. 
 
       i) Gas is removed from the upper valve. 
       ii) Liquid is removed from the lower valve. 
 
   f) Remove the outlet cap on the upper valve for gas withdraw. 
 
   g) Connect the two new cylinders to the header with the flexible copper tubing. 
 
       i)  
A new lead gasket should be used each time a connection is made between a cylinder and the flexible connection tubing. 
 
   h) Open the header valves 1 1/2 turns in the counter-clockwise direction. 
 
   i) Open the cylinder valves 1 full turn in the counter-clockwise direction. 
 
       i) One full turn of the stem permits maximum discharge. 
       ii) If the valve will not open, do not use excessive force.  Notify the supervisor of the problem. 
       iii) Leave the square box wrench on each cylinder valve so that once the valve is opened the valve can be closed quickly. 
 
   j) Once all the connections have been made the system can be pressurized and tested for leaks with ammonia.  
 
5) Disconnecting Chlorine Cylinders 
 
   a) Before chlorine handling is commenced, the employees performing the activities must verify that the safety equipment is present and in good working order.  The Aorespro Escape Artist supplied to each operator must be present. 
 
   b) When the cylinders become empty, close the outlet valves on 
both cylinders. 
 
   c) After several minutes, close both header valves when the chlorine pressure at the vacuum regulator is zero psi. 
 
   d) Disconnect the flexible copper connecting hose and throw away the old lead gasket. 
 
   e) Replace the outlet cap on the upper valve and the valve protective housing. 
 
   f) Place empty cylinders in the outside storage area. 
 
   g) If two cylinders are located within the chlorination building cylinder storage location, rotate these cylinders into the previous locations of the empty cylinders that were placed outside. 
 
   h) Place two full cylinders in the chlorination building storage location from the outside storage area. 
 
6) Emergency Shutdowns 
 
   a) Ventilation fans to the cylinder room and chlorinator room must be turned on. 
 
   b) Employees performing the activities must verify that the safety equipment is present and in good working order.  The Aorespro Escape Artist supplied to each operator must be present. 
 
   c) If a problem develops in the chlorinatio 
n system immediately turn the chlorine off. 
 
       i) Close the cylinder valve in the clockwise direction until it is closed. 
       ii) Check all equipment, pipes, and cylinders for leaks. 
 
 
(4)Training  
 
"You must train all new workers in your operating procedures developed under the previous prevention program element;  if any of your more experienced workers need training on these procedures, you should also train them.  Any time the procedures are revised, you must train everyone using the new procedures.  At least once every three years, you must provide refresher training on the operating procedures even if they have not changed.  The training must cover all parts of the operating procedures, including information on the consequence of deviations and steps needed to address deviations." (6-16) 
 
"You need not provide initial training for workers already operating a process as of June 21, 1999, if you in writing that the employees have the "required knowledge, skills, and abilities to safe 
ly carry out the duties and responsibilities as provided in the operating procedures" (68.54(a)).  This certification should kept in your files; you do not need to submit it to EPA." 
 
Workers at the Lancaster WWTP have the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as provided in the operating procedures.  All operators are trained by the management staff and are accompanied during all chlorine handling activities until they demonstrate they are competent in all aspects of the process.  Observation by the Operations Supervisors is the method used to determine if an operator understands and has the ability to operate the process safely.  Additional refresher training is provided by the Operations Staff on a yearly basis. 
 
Additional safety, operating, and training procedures were taken from the Operation of Wastewater Treatment Plants; Volume 2.  This training manual contains pertinent information pertaining to the operations at the Lan 
caster WWTP, and pages of this manual are included with the RMP. 
 
Safety and training videos published by The Chorine Institute are used to help educate the WWTP operators. 
 
The last overview of the training program, completed on April 26, 1999, was performed as a part of the development of the RMP. 
 
 
(5)Maintenance 
 
"Preventive maintenance, inspection, and testing of equipment is critical to safe operations.  Waiting for equipment to fail often means waiting for an accident that could harm people and the environment.  Further, a thorough maintenance program will save you money by cutting down-time caused by equipment failures." (6-21) 
 
"You must prepare and implement procedures for maintaining the mechanical integrity of process equipment, and train your workers in the maintenance procedures.  For most of the equipment in a WWTP, the manufacturer will have supplied maintenance instructions.  These can be used to fulfill the requirement for maintenance procedures.  Where such instructi 
ons are not available, you will need to develop them." (6-22) 
 
Contained in this RMP are manufacturers' recommended maintenance procedures for equipment used in the chlorination process.  Inspection and testing information was also obtained from the Operation of Wastewater Treatment Plants; Volume 2.   
 
At the Lancaster WWTP, procedures used to maintain the mechanical integrity of the chlorination process are followed.  Maintenance procedures are based on manufacturers' recommendations, prior operating experience, and industry standards. 
 
"In the RMP, you are required to report on the date of the most recent review or revision of your maintenance procedures and the date of the most recent equipment inspection or test and equipment inspected or tested.  You must keep on site your written procedures and schedules as well as any agreements you have with contractors."  (6-24) 
 
At the Lancaster WWTP, the Maintenance Supervisor has a computer system that automatically generates work orders.  
These work orders are completed by the maintenance staff and are stored on file.  A maintenance log will be developed to document work performed on the chlorination system.   
 
The last overview of the maintenance program was completed in April 1999. 
 
Along with the manufacturers' maintenance procedures, documents published by The Chlorine Institute will be purchased to supplement the maintenance information.   
 
"You must establish a schedule for inspecting and testing equipment associated with covered processes.  The frequency of inspections and tests must be consistent with manufacture's recommendations, industry standards or codes, good engineering practices, and your prior operating experience." (6-24) 
 
 
(6)Incident Investigation  
 
"You must investigate each incident which resulted in, or could have resulted in, a catastrophic release of a regulated substance.  A catastrophic release is one that presents an imminent and substantial endangerment to public health and the environment. 
 Exhibit 6-10 briefly summarizes the steps you must take for investigation incidents.  You should also consider investigating minor accidents or near misses because they may help you identify problems that could lead to more serious accident; however, you are not required to do so under part 68."    (6-29) 
 
The Lancaster WWTP will investigate all incidences that result in the release of chlorine within 48 hours.  All findings will be summarized in a report that will include the following information: 
* Factors contributing to the incident 
* Recommendation for corrective actions 
 
Modifications, if applicable, will be made to the chlorination system and RMP to prevent further incidents.  All incident investigation reports will be kept on file for five years. 
 
The Lancaster WWTP will use an Incident Investigation Report to document each incident that occurs. 
 
 
(7)Compliance Audits 
 
"Any risk management program should be reviewed periodically to ensure that employees and contractors are i 
mplementing it properly.  A compliance audit is a way for you to evaluate and measure the effectiveness of your risk management program.  An audit reviews each of the prevention program elements to ensure that they are up-to-date and are being implemented and will help you identify problem areas and take corrective actions." (6-26) 
 
During the months of  January 1999 to May 1999, the RMP for the Lancaster WWTP was developed.  All information pertaining to the RMP was collected, organized, and revised. 
 
All aspects of the fully developed RMP will be reevaluated within two years by supervisory staff knowledgeable in the chlorination process.  
 
"You must keep a written record of audit findings and your response to those findings and documents that deficiencies have been corrected.  You must keep the two most recent audit reports, but you need not keep a report that is more than five years old.  You may also want to keep a record of who conducted the audit, but you are not required to do t 
his." (6-27) 
 
Exhibit 6-9 was reviewed and found to be an appropriate checklist for completing an audit of the safety information and hazard review contained in the RMP.  Based on the responses, operational changes and equipment purchases will be made.  All changes will be documented.   
 
The Lancaster WWTP will keep the two most recent audit reports within the prior five-year period. 
 
 
 
 
Emergency Response Program 
 
"If you have at least one Program 2 or Program 3 at you facility, then part 68 may require you to implement an emergency response program, consisting of an emergency response plan, emergency response equipment procedures, employee training, and procedures to ensure the program is up-to-date.  This requirement applies if your employees will respond to some releases involving regulated substances." (8-1) 
 
What is a response? 
 
"EPA interprets "response" to be consistent with the definition of response specified under OSHA's HAZWOPER Standard.  OSHA defines emergency response as 
"a response effort by employees from outside the immediate release area or by other designated responders... to an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous substance."  The key factor here is that responders are designated for such tasks by their employer.  This definition excludes "responses to incidental releases of hazardous substances where the substance can be absorbed, neutralized or otherwise controlled at the time of release by employees in the immediate release are, or by maintenance personnel"  as well as " responses to releases of hazardous substances where there is no potential safety or health hazard (i.e., fire, explosion, or chemical exposure)."  Thus, if you expect your employees to take action to end a small leak (e.g., shutting a valve) or clean up a spill that does not pose an immediate safety or health hazard, this action could be considered an incidental response and you would not need to develop an emergency resp 
onse program if your employees are limited to such activities." (8-2) 
 
Due to the fact that employees at the Lancaster WWTP will only respond to small leaks that can be contained by shutting a valve, the WWTP is not required to develop a full blown Emergency Response Program in the RMP. 
 
Under the RMP requirements, the WWTP is required to coordinate with local response agencies to ensure that they will be prepared to respond to an emergency at the facility. 
 
Coordination with local responders entails the following steps: 
 
* Ensure that you have set up a way to notify emergency responders when there is a need. 
* If you have a covered process with a regulated toxic, work with the local emergency planning entity to ensure that the facility is included in the community emergency response plan prepared under EPCRA regarding a response. 
 
The Local Emergency Planning Committee (LEPC) of Lancaster County is currently has an Off-Site Response Plan in place for the chlorination operation at the  
Lancaster WWTP.  This plan is updated each year by both the LEPC and the City of Lancaster.   
 
The latest update of the LEPC's Off-Site Response Plan is enclosed.
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