Bromley Pump Station - Executive Summary |
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'68.155(a) Accidental Release and Emergency Response Policies The Bromley Pump Station has documented emergency response procedures in place, as documented in the facility's Emergency Action Plan. This plan has been endorsed by the officials at the highest level of the Sanitation District No. 1. The Bromley Pump Station has procedures in place, including both onsite activities and coordination with offsite responders, that must be followed in the event of a chlorine leak. '68.155(b) Stationary Source and Substance Handled The stationary source subject to 40 CFR Part 68 is the Bromley Pump Station chlorination facility. The Bromley Pump Station chlorinatin facility is divided into two separate rooms: the Storage Room and the Chlorinator Room. The storage room houses two banks of two one-ton containers. The containers store chlorine as a pressurized liquid and feed liquid chlorine to the evaporators. A single one-ton container remains on-line at all times while the remaini ng containers are on stand-by for changeover when the contents of the on-line container are exhausted. Bromley Pump Station is equipped with chlorine leak detectors to notify staff in the event of a chlorine release. An audible alarm automatically sounds inside and outside the building when chlorine levels reach one part per million (ppm). The chlorine is fed as a gas from the chlorinators to the injectors. Feeding the chlorine as a gas under vacuum reduces the likelihood of a release into the environment. '68.155(c) Offsite Consequence Analysis As a Program 3 Process, one worst-case release scenario and one alternative release scenario have been assessed for the Bromley Pump Station. Chlorine is classified as a dense gas in the USEPA published Offsite Consequence Analysis Guidance (OCAG) dated May 24, 1996. The Sanitation District No. 1 has chosen to use the US EPA Risk Management Program Guidance for Wastewater Treatment Plants (40 CFR Part 68), US EPA 550-B-98-010, October 1998, as a source to determine off-site consequences. This guidance, developed by the USEPA and the Association of Municipal Sewerage Agencies, addresses the specific chemicals commonly found at WWTPs. '68.155(d) Accidental Release Prevention Program Prevention Program 3 elements are presented in the Process Safety Management Plan for the Bromley Pump Station. The Prevention Program required under 40 CFR Part 68 is identical to the prevention program required under OSHA PSM. Required elements include: Employee Participation, Process Safety Information, Process Hazard Analysis, Operating Procedures, Training, Contractors, Pre-startup Review, Mechanical Integrity, Hot Work Permits, Management of Change, Incident Investigation, Compliance Audits '68.155(e) Five-Year Accident History The Bromley Pump Station has had no documented accidents, as described under 40 CFR Part 68.42(a), related to the chlorination facility that have occurred in the last five years. '68.155(f) Emergenc y Response Program The Bromley Pump Station has an Emergency Action Plan in place that outlines the actions required to respond to a chlorine emergency. The facility has coordinated this plan with the Greater Cincinnati HAZMAT Response Team. Currently, the HAZMAT Response Team personnel are the designated first responders in the event of a non incidental chlorine emergency. Bromley Pump Station's Emergency Action Plan meets the exception listed in 40 CFR 68.90(b), and therefore the facility is not required to have the Emergency Response Program of 40 CFR 68.95. '68.155(g) Safety Improvements Recommendations for safety improvements were identified in the Process Hazard Analysis (PHA) which was completed per OSHA 29 CFR 1910.119(e) on June 11, 1997. Recommendations were identified for three main categories: Standard Operating Procedures, Maintenance, and Training. According to the PSM, safety improvements will be evaluated for their impacts on other systems and/or procedures pri or to implementation. Additional recommendations may be made upon review of any accidents and/or when the PHA is updated every five years. |