Rush Reservoir - Executive Summary
This Risk Management Program (RMPlan) has been developed for managing hazards associated with the storage and use of gaseous chlorine at the City of Rochester Rush Reservoir located in the Town of Rush, New York. The Chlorine Building is a located adjacent to the reservoir on its south side. It contains eight one-ton containers, two of which are normally hooked up. The tanks are managed by City of Rochester staff and are changed out an average of every five days.
Personnel that perform these operations have been trained in the proper procedures and safety precautions and are members of the City's Chlorine Response Team.
The total quantity of chlorine potentially present at the facility (16,000 lbs) exceeds the USEPA Risk Management Program (RMP) threshold value of 2,500 lbs for gaseous chlorine. Based on these requirements, this RMP has been developed.
The specific requirements of the RMP regulations vary, depending on conditions present at individual facilities. In the
case of the Rush Reservoir, the facility falls under the RMP Program 2 requirements due to the following:
7 Chemical inventory (chlorine) is above RMP threshold
7 Facility is not regulated by a Federal or State Process Safety Management Program.
The goal of the Risk Management Program (RMProgram) is to reduce the risk to employees and the public of injury or death from accidental release of chemicals. The City of Rochester is committed to achieving this goal. The fundamental Management Program for the Rush Reservoir RMP is the organizational structure of the City of Rochester Water Bureau. Within that framework, the responsibilities for specific tasks associated with the RMP are described below.
Program Element Responsible Employee
RMProgram Manager Dale Kriewell
Alternate RMProgram Manager Eric Carlson
Safety Information Eric Carlson
Operating Procedures Eric Carlson
Training Eric Carlson
Maintenance Eric Carlson
Compliance Audits Anne Klumpp
Incident Investigation Don Root
Emergency Planning and Response Eric Carlson
RMPlan Updates (5 Year and Changes) Anne Klumpp
Worst-Case Release Scenario
The Worst-Case Release Scenario has been developed to represent a conservative estimate of the effect on the public and environment of a release of all the contents of the largest vessel over a 10-minute period. For chlorine, it is required to determine at what distance such a release will create a chlorine concentration (a.k.a., toxic endpoint) of 3 ppm. Modeling of the release scenario was completed using the ALOHA portion of the CAMEO software program. This modeling was run with
the assistance of the Monroe County Local Emergency Planning Committee.
The model showed the radius for the Worst-Case Scenario toxic endpoint for the Rush Reservoir system to be 3.2 miles. This scenario is based on the following conditions:
7 Release of entire 2,000 lb cylinder over a ten minute period (200 lb/min)
7 Chlorine released as a gas
7 Ambient temperature of 900F and 75% relative humidity
7 Wind speed of 1.5 meters/sec
7 Meteorological stability class of F.
Based on information from the Monroe County, New York Population Distribution Map, produced by Monroe County and dated February 1999, the population within the Worst-case Scenario 3.2 mile radius is 10,350. The area is generally rural. Key receptors in the area include the following:
Receptor Direction Distance (feet).
Leary School Southeast 2,000
Burger Junior High Northwest 11,000
Vollmer School Northwest
Town of Rush Southwest 7,000
Alternate Release Scenario
The Alternate Release Scenarios was determined similar to the Worst-Case, except that it reflects a more likely release than the Worst-Case. For the Rush Reservoir, this scenario is for a tubing failure, valve failure, or bad connection in a one-ton cylinder resulting in the release of gas through a 5/16-inch diameter valve body opening. It is modeled as a release from a horizontal cylindrical tank with the release occurring through a short pipe or valve in the top of the tank. The chlorine escapes only as a gas. The American Water Works Association Research Foundation Compliance Guidance and Modeling Risk Management Program for Water Treatment Plants and the ALOHA model was used in this analysis.
The Alternate Release Scenario toxic endpoint for the Rush Reservoir system is 0.38 miles. This scenario is based on the following conditions:
7 Release of 317 lbs over a 60 minute period (10.5 lb/
7 Chlorine released as a gas
7 Ambient temperature of 850F and relative humidity of 75%
7 Wind speed of 5.4 meters/sec
7 Meteorological stability class of D.
Based on information from the Monroe County, New York Population Distribution Map, produced by Monroe County and dated February 1999, the population within the Alternative Release Scenario radius is 150.
Five Year Accident History
There have been no accidental releases of chlorine gas from the Rush Reservoir Chlorine Building within the last five years.
A review of the hazards associated with the chlorine system has been completed. The review is based on checklists from The Chlorine Manual, Chlorine Institute Pamphlet 1, 6th edition, January 1997.
Based on this review, the most serious potential chemical hazard associated with water treatment at the Rush Reservoir involves the uncontrolled release of chlorine liquid or gas from the one ton supply containers. Such releases could be in the form of a relatively
slow leak from one of the containers valves or connection to such a valve, or, in the form of a sudden and more voluminous release resulting from fail-ure of a fusable container plug, blow out of a tank valve, or a tank wall rupture. The former type of release can typically be tended to with normal maintenance procedures and generally does not pose a threat to life or property. The latter type of release, although far more likely to be catastrophic if should it occur, is extremely rare in the industry.
A second less serious, but plausible type of hazard associated with chlorine is the uncontrolled release of the highly chlorinated solution that results from the introduction of chlorine gas into the water stream passing through the venturi ejector.
Training on the management of chlorine is conducted for City of Rochester personnel by Mr. Eric Carlson on an on-going basis. The training is provided to operations staff (i.e., personnel who change out chlorine tanks) as well as
to members of the Chlorine Response Team (CRT), whose job function it is to respond to alarms of the chlorine system. The CRT team leader or their designee keeps a record of such training and keeps each CRT member appraised of their training status with respect to the team's training goals.
Since March 1998 operations and CRT personnel have been meeting on a bi-monthly basis to review chlroine handling operations, safety, maintenance, and emergency response issues. This on-going training includes the topics described in the June 5, 1996 Inter-Departmental Correspondence.
Maintenance of the chlorine equipment at the Rush Reservoir is performed on a regular basis, as a part of the facility's operations. On a daily basis the following equipment is checked:
7 Vacuum gauge
7 Suction gauge.
Based on the status of the readings and condition of this equipment, maintenance is performed by those City staff responsible for operation of the chlorine system. In conjunctio
n with this maintenance, monthly inspections are conducted of the following:
7 Chlorine B kit
7 Scott air packs
7 Building ventilation system.
As a preventative maintenance step, once per year the flexible tubing connecting the chlorine tank regulator to the chlorination system is replaced. In March 1998 the regulators and all tank hookups were inspected, repaired, or replaced.
Chlorine leaks are managed by the City's Chlorine Response Team. The procedures that are to be followed are detailed in the Chlorine Response Team Manual. The manual includes the following:
7 Chemical Spill/Leak Response Decision Trees
7 Emergency Action Checklist
7 Chlorine Response Team Roster
7 Procedures for Initial Leak Assessment
7 Correcting Non-Critical Leaks
7 Non-Critical Leak Report Form
7 Critical Leak Report Form
7 Required Hazardous Material Incident Notification and Response Procedures
7 Chlorine Institute Emergency Kit 'B' for Chlorine Ton Containers
7 First A
id and Medical Management of Chlorine Exposures
In conjunction with the above procedures, the City is coordinating with the Monroe County Local Emergency Planning Committee, to meet the requirements of their General and Technical Guidance for the Risk Management Plan Preparation for Facilities in Livingston, Genesee, Wayne, Orleans, Ontario, and Monroe Counties. This has included the following:
7 Submission of Population within Alternate Release Scenario Table
7 Submission of copy of RMP*Submit printout.
In addition, CRT personnel met with the Rush Volunteer Fire Department in October 1996 to review site conditions and the facility's response plan.