Metal Finishing Technologies, Inc. - Executive Summary

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Metal Finishing Technologies (MFT), operates a metal finishing job shop in Forestville, Connecticut.  The MFT facility, which occupies approximately 3.6 acres, is situated north of the Pequabuck River and south of Camp Street.  Chlorine is stored on-site at the facility and used for water treatment in the cyanide reactors.  Because the quantity of chlorine stored on-site in a single process exceeds the threshold quantity of 2,500 pounds, the facility is subject to the Risk Management Program (RMP) provisions under Section 112 of the Clean Air Act Amendments (40 CFR Part 68), also known as the "Chemical Accident Prevention Provisions."  Because MFT is subject to OSHAs Process Safety Management (PSM) standard, MFT is subject to "Program 3" in the tiered RMP approach. 
The primary chlorine storage facility consists of four one-ton chlorine cylinders located near the northwest corner of the building.  The chlorine gas system consists  
of four one-ton chlorine storage tanks (two of which are used at one time), a vacuum regulator, a "V-Notch" control valve, an Eductor, a 2.0HP centrifugal pump, a "Y" strainer, and associated appurtenances (flexible tubing, valves, controls, pvc piping etc).  The chlorine system is surrounded on the north, south and east by concrete block walls and to the west by an overhead door.  Chlorine is transferred to the chlorinator via 1/2" flexible teflon tubing and then to the cyanide reactor via PVC tubing.  The chlorine gas system described above comprise the "covered process" under this RMP. 
The one-ton chlorine containers are delivered to the MFT facility by truck.  The chlorine containers are unloaded outside the chlorine building using a hydraulic boom.  The boom lifts the containers from the truck and enters the chlorine storage room through an overhead door. The "covered process" under this RMP includes chlorine storage, handling, and transfer activities prior to the introduction of 
chlorine into the chlorine contact basin or mixed sludge well. 
MFT complies with accidental release prevention requirements for a Program 3 facility in accordance with 40 CFR 68.  The facilitys chlorine storage, handling, and distribution system is designed and operated in accordance with state and local laws.  Emergency response procedures for the MFT facility, including the chlorine storage area, are described in MFTs Contingency Plan (CP).  In general, outside responders and the local fire department are notified of all chlorine releases other than incidental releases that can be controlled at the time of the release (i.e., shutting a valve) by personnel in the immediate release area.   
The worst-case release scenario for the MFT chlorine facility consists of the release of the single greatest capacity storage vessel within the process.  For MFT this comprises one 2,000 
pound chlorine cylinder being released over a period of 10 minutes.  The resulting distance to the endpoint extends 0.9 miles from the release.  Portions of industrial developments, surrounding residences, schools, recreation areas (campgrounds), and  the Pequabuck River are within this region.   
The alternative release scenario for the MFT chlorine system consists of one chlorine tank leaking from an accident during the cylinder delivery process outdoors.  The resulting distance to the endpoint extends 0.1 miles from the release, and the potentially impacted region includes industrial developments and surrounding residences. 
The MFT chlorine storage, handling, and transfer facilities addressed in this RMP comply with EPAs accident prevention rule as well as applicable state and local codes and regulations. The chlorine system is designed, installed, maintained, and operated in accordance with good engine 
ering practice and industry-specific guidance developed by the Chlorine Institute, and MFTs current chlorine cylinder supplier, Jones Chemicals. 
No accidents involving chlorine that caused deaths, injuries, property or environmental damage, evacuations, or shelterings in-place have occurred at MFT in the five-year period prior to the submittal date of this plan (June 1, 1994 to June 1, 1999). 
Emergency procedures described in MFTs CP will be followed in the event of an emergency involving the chlorine gas distribution system.  If the chlorine leak is manageable and the emergency coordinator determines that the chlorine leak is minor, then MFT may elect to stop the leak themselves using trained employees with the appropriate personal protective equipment (PPE).  However, if a chlorine leak is beyond the capabilities of MFT employees, all employees shall immediately evacuate the building.  The Fire Department and other appropria 
te agencies shall be immediately notified.  An outside contractor would likely be contacted who is trained in the handling of such a release.  In a actastrophic release of chlorine, MFT shall, to the extent feasible, directly inform nearby local businesses, schools, and othe rpotential receptors to warn them of the impending danger of the chlorine gas release.  This effort will focus on receptors within the worst-case scenario distance to endpoint (0.9 miles surrounding the building).  A copy of MFTs CP has been provided to the local fire department and Local Emergency Planning Committee (LEPC).   
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