Bluffton Wastewater Treatment Facility - Executive Summary

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Bluffton Wastewater Treatment Plant 
City of Bluffton, Wells County, Indiana 
Risk Management Plan 
Executive Summary 
The City of Bluffton's Wastewater Treatment Plant Risk Management Plan (RMP) has been established in accordance with the Environmental Protection Agency (EPA) 40 CFR Part 68.  The wastewater treatment plant utilizes chlorine to meet Indiana Department of Environmental Management (I.D.E.M.) and National Pollution Discharge Elimination System (N.P.D.E.S.) effluent disinfection requirements.  The Bluffton wastewater treatment plant maintains an inventory of 2,000 to 4,000 pounds of chlorine, stored on-site in one (1) ton cylinders, in order to meet disinfection requirements.  Chlorine cylinders are stored and used inside a building.  The wastewater treatment plant serves the City of Bluffton, treating residential, commercial, institutional, and industrial wastewater flows.  The average daily treated wastewater flow is 2.3 million gallons per day (MGD).  Chlorine is the only  
regulated chemical utilized by the Bluffton Wastewater Treatment Plant. 
The purpose of the Risk Management Plan is to reduce the risk to employees and to the public of injury or death from accidental release of chlorine.  The Risk Management Program is designed to prevent the accidental release of chlorine, and also to define a plan for management in the event that accidental release occurs.  The Bluffton wastewater treatment plant has had no accidental release of chlorine in the past five (5) years, due to excellent employee handling safety.   
Operational safety has been in the past, and will continue in the future to be a primary focus for Bluffton wastewater treatment plant operation and management staff.  Chemical handling is a particularly important safety concern for both employees, and the public.  Treatment plant employees perform quarterly equipment maintenance inspections on all plant facilities, including chlorine process equipment.  Visual inspection of chlorine cylinders u 
pon delivery is the first step in safe handling of chlorine at the treatment plant.  Chlorine cylinders are stored inside a building, both cylinders contained in a single room.  Enclosure of the chlorine cylinders serves as a means of passive mitigation to contain accidental chlorine release. 
Scenarios were modeled for worst-case release and alternative release conditions for accidental release of chlorine at the wastewater treatment plant.  The chlorine release model was based on the E.P.A.'s RMP*COMPf Model, to determine potential offsite impacts of a chlorine release.  The worst case scenario was modeled for the most severe release circumstances that could occur.  The model defined a distance to endpoint of 1.5 miles, including an estimated residential population of 7,200.  The alternative release model resulted in a distance to endpoint of 0.10 miles, including a residential population of approximately 1,800.   
The wastewater treatment plant's chlorine emergency response includes i 
mmediate reporting to the City of Bluffton Fire Department HAZMAT team, City of Bluffton Police Department, and the Wells County Local Emergency Plan Committee (LEPC).  Detailed information concerning the wastewater treatment plant chlorination system and storage facility is provided to each of the potential responders, along with modeled distance to endpoint for chlorine release.  Public notification and alerts for all emergency responses are organized to be performed in accordance with the criteria set up by the Wells County Local Emergency Plan Committee, and are subject to periodic review and updating by the LEPC and groups of jurisdiction.  The City of Bluffton Wastewater Treatment Utility will continue in efforts to maintain and improve chlorine safety at the plant and for the surrounding community, and will update their Risk Management Plan with the E.P.A. as improvements are made.  Annual training will be held to assist employees in understanding and implementing the facility R 
isk Management Plan.
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