Charles M. Bolton Plant - Executive Summary |
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The Cincinnati Water Works, Charles M. Bolton Plant (CMBP) utilizes more than a threshold quantity of chlorine (2,500 pounds) in their process. Therefore, this facility is required to submit a Risk Management Plan (RMP) as defined in '68.150 by June 21, 1999 (three years after publication of the final rule). Public employees are covered under the State of Ohio's Public Employee Risk Reduction Program (PERRP), which has adopted by reference the requirements of OSHA's (PSM) Standard. Based on the March 1999 revised USEPA RMP Guidance for Wastewater Treatment Plants (WWTPs) (EPA 550-B-98-010), the Charles M. Bolton Plant is subject to the OSHA Process Safety Management (PSM) Standard and is therefore subject to Program 3 requirements of the RMP Regulation. '68.155(a) Accidental Release and Emergency Response Policies The Charles M. Bolton Plant has documented emergency response procedures in place, as documented in the facility's Emergency Action Plan. This plan has been endorsed by the City staff responsible for the operation and maintenance of the CMBP. The CMBP has procedures in place, including both onsite activities and coordination with offsite responders, that must be followed in the event of a chlorine leak. All personnel involved in handling chlorine are trained with regard to chlorine safety and accident prevention. '68.155(b) Stationary Source and Substance Handled The stationary source subject to 40 CFR Part 68 is the Charles M. Bolton Plant Chlorination Facility. The CMBP has a design capacity of 40 million gallons of water per day (MGD) and treats groundwater to drinking water standards. The CMBP Chlorination Facility is divided into two rooms dedicated to specific tasks: the Storage/Unloading Room and the Chlorine Feed Room. The Storage/Unloading Room houses a maximum of ten (10) one-ton containers that store chlorine as a pressurized liquid. For normal operating conditions, there are four one-ton containers of chlorine connected to the main header system. There is a fifth one-ton container connected to a separate manifold for use if the main header system is inoperable. The remaining five one-ton containers are stored in the room for use when the on-line containers are exhausted. Chlorine gas is fed from the containers through the automatic changeover system and is then feed under a vacuum to the chlorinators in the Chlorine Feed Room. Three vacuum chlorinators and five water operated injectors are provided for solution chlorine feed at various process locations. Vacuum chlorine feed reduces the likelihood of a release into the environment. The Chlorination Facility is equipped with many safety features to prevent public exposure in the event of a chlorine leak. One chlorine leak detector is located in the Storage/Unloading Room and one in the Chlorine Feed Room. To allow safety personnel time to respond to emergencies, an audible warning alarm sounds inside and outside of the building when chlorine levels r each 0.5 ppm. At 1 ppm at high level alarm is sounded and the normal building ventilation system automatically shuts down to contain the chlorine. In addition, the chlorine detector alarms are connected to the CMBP control panel and the Richard Miller Water Treatment Plant SCADA system. This alerts the staff at both plants in the event of a chlorine release. '68.155(c) Offsite Consequence Analysis As a Program 3 Process with one toxic gas, one worst-case release scenario and one alternative release scenario has been assessed for the Chlorination Facility. The Charles M. Bolton Plant 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, (WWTP Guidance), as a guide to determine off-site consequences. This guidance specifically addresses the chemicals commonly found at WWTPs. The chlorination process for WTPs is similar to the chlorination process at WWTPs. Therefore, this guidance docume nt is applicable to the Charles M. Bolton Plant's chlorination process. The worst-case release scenario was determined in accordance with the requirements provided in 40 CFR 68.22 and 40 CFR 68.25(b,c). The worst case release scenario for chlorine is the loss of 2,000 lbs (largest vessel) in 10 minutes. This results in a release rate of 200 lb/min and does have offsite impacts. The facility is also required to complete at least one alternative release scenario that reaches an endpoint offsite. The alternative release scenario was evaluated in accordance with the guidelines provided in 40 CFR 68.22 and 40 CFR 68.28. The most likely release scenario is identified based on the results of the Process Hazard Analysis (PHA). The alternative release scenario for chlorine is a vapor release through a 3/16 inch opening from a leaking valve, gasket, union, flexible tubing, or piping. This scenario incorporates the passive mitigation of the building and results in an endpoint offsite. '68.155(d) Accidental Release Prevention Program The Charles M. Bolton Plant facility has a documented Prevention Program for the Chlorination Facility that documents release prevention measures. These prevention measures include elements such as 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, and compliance audits. CMBP is equipped with many safety features to prevent any public exposure in the unlikely event of a chlorine leak. One chlorine leak detector is located in the Storage/Unloading Room and one in the Chlorinator Room. To allow safety personnel time to respond to emergencies, an audible warning alarm sounds inside and outside of the building when chlorine levels reach 0.5 ppm. At 1 ppm at high level alarm is sounded and the normal building ventilation system automatically shuts down to conta in the chlorine. In addition, the chlorine detector alarms are connected to the CMBP control panel and the Richard Miller Water Treatment Plant SCADA system. This alerts the staff at both plants in the event of a chlorine release. CMBP employees who are involved in chlorine operations are trained in specific procedures regarding handling and storage of chlorine at the facility. '68.155(e) Five-Year Accident History The Charles M. Bolton Plant has had no accidental releases of chlorine in the last five years that have resulted in on-site injuries or off-site injuries or other impacts. '68.155(f) Emergency Response Program The Charles M. Bolton WTP has developed an Emergency Action Plan to ensure employee safety as allowed by 40 CFR 68.90(b). The Bolton WTP facility Emergency Action Plan outlines actions required to respond to a chlorine emergency and has coordinated this plan with the City of Fairfield Fire Department. Fire Department personnel are the designated first respond ers in the event of a non incidental chlorine emergency. Charles M. Bolton WTP employees are not designated first responders to a serious or unplanned chlorine release. As specified in 40 CFR 68.90(b), Charles M. Bolton WTP's Emergency Action Plan meets the exception listed, 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 November 6, 1996. Recommended improvements were identified in three main categories: Standard Operating Procedures, Maintenance, and Training. According to the PSM, any safety improvements will be investigated concerning their impacts on other systems and/or procedures prior to implementation. Additional recommendations may be made upon review of any accidents and/or when the PHA is updated every five years. |