Ketchikan Chlorination Plant - Executive Summary |
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EXECUTIVE SUMMARY Ketchikan Public Utilities (KPU) presently uses gaseous chlorine to disinfect the municipal water system. We generally have two 1-ton cylinders of chlorine stored on-site, one full and the other in service. Consequently, this can exceed the threshold limitation of 2500 pounds and by 40 CFR 68, KPU must have a Risk Management Program (RMP) completed by June 21, 1999. KPU has been preparing for this forthcoming regulation beginning in the fall of 1997. We included into our 1998 Budget request which was approved by the Ketchikan City Council, funds for a thorough study of alternative disinfection methods to eliminate the use of gaseous chlorine. CH2M-Hill completed the study in July 1998 recommending that the most cost-effective alternative for KPU was to switch to on-site generation of a weak solution of sodium hypochlorite (bleach). After review of the study, in August, 1998, the City Council authorized KPU to solicit proposals for the design of this facility. During September, 1998, proposals were sent to 6 qualified engineering firms and responses were received from two of them. After review of the proposals, Contract 98-43 was awarded to a local engineering firm, Southeast Engineering, on Ocotber 26, 1998. The contract schedule called for delivery of preliminary design phase plans with 42 days after the notice to proceed and envisioned completion of the entire design project by early March 1999. In KPU's Budget request for 1999, funds for the estimated cost of construction of this facility were approved. We intended to have the construction contract awarded by April, 1999 and the facility fully constructed and operational before a RMP plan was required. Southeast Engineering is a small firm and severely behind schedule on this project. The principal in the firm, George Lybrand, estimates that he will have preliminary drawings for review by mid-June, 1999. The completed bid-ready specifications and drawings will be completed by l ate July, 1999. On that estimated schedule, KPU will be able to advertise the construction contract for bid, August, 1999 and award it during September, 1999. Assuming that there are no long delivery items incorporated into the design, KPU estimates that the new disinfection facility will be constructed and fully operational by December, 1999. However, starting construction in Alaska this late in the year makes weather a critical factor as we have to pour a foundation and erect a new building. We receive 160 - 180 inches of rain a year, much of that in the fall months. Sub-freezing weather may start as early as late October/ early November. Depending upon when sub-freezing weather begins, the startup date may be delayed into the spring of 2000. Despite the delay, we believe that this document demonstrates that KPU has been proceeding since 1997 with all due diligence in preparation for the forthcoming Clean Air Act Amendments which go into effect on June 21, 1999. Had South east Engineering not encountered difficulties preparing the design documents, we would have made the change to sodium hypochlorite disinfection by that date and not be affected by the RMP requirements as we would no longer be using gaseous chlorine. During the remaining months before we make the changeover, KPU's accidental release prevention program is based upon the following key elements: 1. A High level of training of the operators including refresher chlorine handling courses conducted by Wallace & Tiernan, an industry leader in the manufacture of chlorine disinfection equipment. 2. Thorough preventative maintenance program. 3. Use of state-of-the art process and safety equipment. 4. Use of accurate and effective operating procedures, written with participation of the operators. 5. Daily inspection program of all operating chlorination equipment to ensure everything is in proper condition. 6. Periodic training in the donning and operation of self-contain ed breathing apparatus (SCBA) and training in the assembly and usage of the specialized equipment necessary for the gagging of 1-ton cylinders. 7. Each operator's awareness of the hazaradous and toxic properties of chlorine, and the presence of a chlorine detector which automatically alarms through our 24-hour monitiored SCADA system. 8. There have been no accidental releases of chlorine at this facility for over 30 years. 9. The facility has an emergency response plan which is coordinated with the other members of the Local Emergency Response Planning Committee. This program includes an emergency response decision tree and a notification plan. |