Baumgartner Wastewater Treatment Lagoon - Executive Summary |
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I. INTRODUCTION This document contains all the information that the MSD Baumgartner Lagoon Plant (Baumgartner plant) needs in order to meet the requirements of 40 CFR 68 "Risk Management Program". II. RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The Baumgartner plant uses chlorine in their wastewater treatment process. The chlorine is used as a disinfectant. The Code of Federal Regulations (40 CFR 68) classifies chlorine as a regulated toxic substance. It can cause a potential health hazard if not handled properly. The Baumgartner plant adheres to all applicable Federal, state, and local rules and regulations to ensure a safe environment within the plant as well as for the surrounding community. Access to the chlorine systems is restricted to trained operators/mechanics, authorized contractors, and the City of Mehlville fire department (the primary responder in the event of an accidental release). The Baumgartner plant is an unmanned facility. In the event of an accidenta l release, the chlorine alarm will sound causing an automatic dialing system to contact the appropriate MSD personnel. The primary emergency responder is the Mehlville fire department. Procedures are in place for notification of the Mehlville fire department, the LEPC and the St. Louis County HAZMAT team. III. PROCESS DESCRIPTION AND REGULATED SUBSTANCES The Baumgartner plant in St. Louis, Missouri is a wastewater treatment plant. The plant has one regulated substance under 40 CFR 68: chlorine. Chlorine is used in the wastewater treatment process as a disinfectant. The chlorination process occurs during the months of April through October. The typical chlorine consumption rate is 350 - 500 lbs./day. The North American Industrial Classification System code (NAICS code) for the primary process at this facility is 22132. Typically, six 1-ton containers of chlorine are stored on site at any given time. The on-line chlorination system includes four manifolded 1-ton containers in two sets of two with manual switchover valves between the two sets. All six containers are housed inside the chlorination building. Chlorine is a regulated substance under 40 CFR 68. The chlorine threshold for triggering applicability of 40 CFR 68 is 2,500 pounds. The maximum quantity of chlorine stored on-site at any one time is 16,000 pounds. Since this exceeds the threshold limit, the Baumgartner plant is subject to 40 CFR 68 as a Program 2 facility. IV. WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS IV.1 Worst-case Scenario For the Baumgartner plant, the worst-case scenario is the loss of 2000 pounds of chlorine in ten minutes from a 1-ton container located outside the chlorination building. Since this facility is located in a populated area, the worst-case scenario would affect nearby public receptors. IV.2 Alternative Release Scenario The alternative release scenario examined involves the release of chlorine due to a flashing liquid release through a 0.28" diame ter rust hole at the liquid level of the 1-ton container. Passive mitigation is considered in this case as the 1-ton container is assumed to be housed in the chlorination building. Since this facility is located in a populated area, the alternative release scenario would affect nearby public receptors. V. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS This facility complies with EPA's Accidental Release Prevention Rule and with all Federal, state and local codes and regulations. The plant continually conducts inspections to ensure the system is intact and operating correctly. These inspections ensure that the worst-case and alternative scenarios have a minimal chance of occurring. The plant has developed a prevention program for chlorine to meet the Program 2 requirements of the RMP rule. The prevention program was developed to comply with 40 CFR 68, to ensure the safety of the employees, and to ensure the safety of the surrounding commun ity. The program covers a compilation of safety information, periodic conduct of hazard reviews, operating procedures, training, maintenance, compliance auditing and incident investigation. VI. FIVE-YEAR ACCIDENT HISTORY The review of this facility's accident history includes the following range of dates: June 22, 1994 - June 21, 1999. There have been no releases at this facility as defined by 40 CFR Part 68.42(a). VII. EMERGENCY RESPONSE PROGRAM The Baumgartner plant is not a primary emergency responder in the event of an accidental release but the plant will contact the Mehlville fire department, who are the primary responders. Procedures are in place for notification of the Mehlville fire department, the LEPC and the St. Louis County HAZMAT team. The fire department is notified by dialing 911. VIII. PLANNED CHANGES TO IMPROVE SAFETY Based on the "what-if/checklist" Hazard Review completed for chlorine, a list of action items was developed for implementation. The followin g examples briefly describe improvements occurring as a result of the Hazard Review. 1. Unsafe practices by Contractors will be reported to the Contractor's company. 2. Installation of automatic shutoff valves that will close in response to the chlorine alarm. 3. Flammable materials stored in the chlorine room will be removed. 4. Develop operating procedures specific to this location. |