NC0024911_Report_19980907

NPDES DOCIMENT SCANNIN`i COVER SHEET
NPDES Permit:
NC0024911
MSD Buncombe County WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
•
Report ,''n
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
September 7, 1998
Thia document iisc printed on reuse paper - ignore any
content on the rezrerae side

N(O0Zy9/)
EVALUATION OF CHLORINATION ALTERNATIVES
METROPOLITAN SEWERAGE DISTRICT OF
BUNCOMBE COUNTY, NORTH CAROLINA
HARRY B. BUCKNER, P.E.
McGill
ASSOCIATES
Engineering • Planning • Finance
Asheville, North Carolina
SEPTEMBER, 1998
98715.00
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SEAL 9rt 22541
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Section I Introduction and Background
Section II Chlorination Chemistry
Section III Existing Disinfection System
Section IV Alternative Disinfection System
Section V Safety and Compliance Issues
Section VI Summary and Conclusions
Appendix A Bibliography
Appendix B OSHA Process Safety Management Plan Information
Appendix C EPA Risk Management Plan Information
Appendix D Catastrophic Failure Scenario Descriptions
1
3
7
13
19
24
1

The Metropolitan Sewerage District of Buncombe County (MSD) currently owns and operates a
40 million gallon per day (MGD) wastewater treatment facility located on the French Broad
River just north of Asheville, North Carolina. This facility serves the majority of the
incorporated areas of Buncombe County and a portion of northern Henderson County, and treats
waste collected by approximately 1000 miles of collection sewers in those areas. The waste is
comprised of approximately 70 percent domestic waste and 30 percent industrial waste,
primarily from textile industries.
One of the most important processes at the facility is the disinfection of the final effluent prior to
its discharge into the French Broad River. Currently liquid -gas chlorine is fed into solution and
then added to the final effluent to eliminate harmful bacteria and viruses prior to discharge. This
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method of disinfection has been utilized in the United States since the late 1800's and has been
almost exclusively used since the middle part of this century because of its cost effectiveness,
ease of use, and reliability. Today, chlorine is the most widely used disinfectant in the world at
water and wastewater treatment plants.
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Due to recent promulgation of safety regulations governing the safe transport, storage, and use of
liquid -gas chlorine, publicly owned treatment works (POTW's) are being forced to evaluate
their use of the product. Many POTW's are realizing that significant health and safety concerns
exist as the population near once rural water and waste treatment facilities increases.
1

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P.A.
of Asheville, North Carolina, with
recent developments, McGill Associates, e
In light of these report to evaluate and compare
the assistance and at the dire
ction of MSD staff, has pTepared this rep
' ne as a disinfectant for the District. In
sodium hypochlorite to liquid -gas chlorine the use of liquid however, the
testingof ultraviolet light disinfection,
the staff of the District underwent pilot resent in the
1997
due to the significant amount of colorp
res
ults of this process were unacceptablealternative disinfection
logprogression in the search for
wastewater. This report is the next g
processes for the District.
in this report the Metropolitan Sewerage
By carefully evaluating the information contained capital
in the two processes,
' ct will be able to understand the differences and evaluate both the understand the
District rocesses,
and ongoing operations and
maintenance costs associated with the p
potential safety implications
of choosing one process over the other.
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2

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A. BASIC CHLORINE CHEMISTRY
The most common chlorine compounds used in wastewater treatment plants are liquid -gas
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chlorine (C12), calcium hypochlorite [Ca(OC1)21, sodium hypochlorite (NaOC1) and chlorine
MI dioxide (C102). Both calcium and sodium hypochlorite are most often used at very small
wastewater treatment plants, where simplicity and safety are much more important than cost.
Sodium hypochlorite is also often used at large facilities primarily for reasons of safety as
m' influenced by local conditions. Chlorine dioxide, because of its unusual properties (it does not
react with ammonia), is used at some treatment facilities. Regardless of the form of chlorine
used, however, the basic reactions and effectiveness of each of the compounds is essentially the
' same. For the purposes of this report, only liquid -gas chlorine and sodium hypochlorite will be
considered.
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When chlorine compounds are added to water, two reactions take place: hydrolysis and
ionization.
For chlorine gas, hydrolysis may be defined as
C12+H20aHOC1+H++Cl"
Ionization is defined as
HOCI a H+ OCl"
3

The quantities of HOC1 and OC1' that is present in water is called the free available chlorine.
1.1
The distribution of these two species is very important because the killing efficiency of HOC1 is
about 40 to 80 times that of OC1
When free chlorine is added to water in the form of sodium hypochlorite salts, the pertinent
reaction for hydrolyses is as follows:
NaOC1 + H2O HOCI + NaOH
I1
and the reaction for ionization is the same as for liquid -gas chlorine
`an HOC1 a Ht OC1"
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The hydrolyses reaction of chlorine gas tends to lower the overall pH, while the hydrolyses
reaction of sodium hypochlorite tends to raise overall pH. This becomes important because the
1.1 ratio of HOCI to 0C1" is directly related to the pH of the water. This can become a factor in
poorly buffered water since the concentration of the more effective HOC1 is higher in lower pH
1.1
water and lower in higher pH water. The table below shows the distribution of HOC1 and OC1'
r., with pH.
I1
pH
Percentage of Total Free Chlorine as:
HOCI
ocr
6.0
96.8
3.2
7.0
75.2
24.8
7.5
49.1
50.9
8.0
23.2
76.8
9.0
2.9
97.1
Because of this dependency on pH to determine the amounts of each form of free chlorine,
depending on the buffering capacity of the wastewater, the results of liquid -gas chlorine
application can be more effective than that of sodium hypochlorite application.
4

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B. FACTORS THAT AFFECT THE DISINFECTION EFFICENCY OF CHLORINE
In addition to the buffering capacity of the water, the following items are some of more
important factors that affect the disinfection efficiency of chlorine: (1) the importance of initial
mixing, (2) the contact time, (3) the characteristics of the wastewater, and (4) the characteristics
of the microorganisms.
(1) Mixing: According to "Wastewater Engineering: Treatment, Disposal, and Reuse" by
Metcalf and Eddie, the importance of initial mixing cannot be overstressed. Testing data has
conformed that when chlorine is added in a highly turbulent manner, the resulting bacteria kill
levels will be on the order of two (2) magnitudes greater than when when chlorine is added
separately to a complete mix reactor. Mixing times on the order of one second are desirable.
(2) Contact Time: Because of all of the various forms of chlorine that can. exist in wastewater,
each compound with its own disinfection efficiencies, the amount of contact time is very
important to ensure optimization of the entire process. A well designed plug -flow reactor is
critical in the overall disinfection process.
(3) Characteristics of the Wastewater: The BOD, COD, TSS, and nitrogen levels in the effluent
can impact the chlorine disinfection efficiency. Generally, the higher these levels are, the more
chlorine it will take to achieve suitable results. There is also the possibility that there can exist
5

certain interfering organic compounds that either make the total residual chlorine measurement
unreliable, or otherwise reduce the overall effectiveness of the chlorine.
(4) Characteristics of the Microorganisms: Testing data has shown that microorganisms that
9.0
are relatively young (1 day old or less) may only require a 2 mg/1 chlorine dose with 1 minute of
contact time to destroy. Microbes that are older (10 days or more) approximately 30 minutes
were required at the same dosage level. As the microorganisms age, they develop more resistant
sheaths that protect them from the chlorine. The age of the microorganisms is directly related to
'"' the type of wastewater treatment process used and is somewhat controllable by adjusting recycle
rates, mixed liquor concentrations, and return sludge flow rates.
C: AQUATIC TOXICITY
One of the other factors that must be considered when using chlorine as a disinfectant in
wastewater is aquatic toxicity. Chlorine has been proven to be toxic to some aquatic life at levels
as low as 11 micrograms per milliliter. Also, the reaction of chlorine with naturally occurring
organic matter in the receiving stream may form chlorinated compounds that can be toxic. These
compounds may have long term adverse effects on the beneficial uses of the receiving waters.
1119 To minimize these effects, some applications have found it necessary to dechlorinate wastewater
treated with chlorine. While the evaluation of dechlorination options is not a portion of this
study, it is mentioned here so that further consideration of a dechlorination program may be
evaluated in the future if improvements to the chlorination process are implemented.
6

1101
cm II
SECTION III
EXISTING DISINFECTION SYSTEM
A. GENERAL
The Metropolitan Sewerage District currently utilizes a Fischer -Porter liquid -gas chlorine feed
system to disinfect the effluent discharged to the French Broad River. The system was last
improved in the early 1990's and has performed without major problems since the original
facility was constructed. The system is in generally good condition, is functional and adequately
disinfects the flows generated at the plant. Figure III-1 shows the general plant layout and
location of the major chlorination facilities.
B. METHOD OF OPERATION AND EQUIPMENT
Liquid -gas chlorine is delivered to the plant in ton cylinders, ten at a time, via truck from Jones
Chemical in Charlotte, North Carolina. Bulk tanks are stored outdoors under a covered shed and
0.1
lifted indoors to the chlorine tank room two at a time for connection to the chlorination
equipment. Two tanks are ganged together and connected with an automatic switchover device
to another pair of tanks. The cylinders are placed on load cells and the weight is monitored and
recorded to determine the amount of chlorine fed to the system. When one pair of tanks empty,
P., the automatic switchover device automatically converts to the second pair of cylinders, and the
first pair that is empty can then be switched with full tanks.
The gas is withdrawn from the ganged cylinders to an evaporator that converts the liquid
�► chlorine to a gas. The gas is then fed into a chlorinator that meters out the appropriate amount of
7
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1 1 1 1 1 1 1 1 1 1 1 1 1
SZU;F LAC
OVERFLOW
R.4 NERN OR
5EUDGE
HANDLING
!M7FliL 47E
PUSER BUILDING
PARALLEZ ASH/SLtiWCE
70 LAGOON
•
•
•
•
0.1 MOD
nuArE7t7 MSO
FRENCH BROAD RIVER
NOT TO SCALE
CHLORINATION BUILDING
jFSFND
FILTRATE/
DECANT
FLOW
GREASE
GRIT
SLUDGE
7 r;
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FIGURE Ii-1
PtETROPOUTAN SEWERAGE DISTRICT
OVERALL RANT FLOW DIAGRAM
0 McGill
ASSOCIATES
mUCnRRIENc•PILAR NO•►RURCI
iR+EV*?a, NORiE CAROM&

'� chlorine to the injector. Effluent water enters the injector and then becomes the vehicle by which
the chlorine gas is converted into solution. The resulting chlorine solution is then fed into the
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head of the chlorine contact basin. The solution is mixed through a diffuser in the chlorine
MI contact basin and then flows through the plug flow reactor (chlorine contact chamber) to achieve
contact time. Finished effluent is then sampled and discharged to the French Broad River.
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Figure III-2 shows the basic liquid gas chlorination system diagram.
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Chlorine is also dosed into the feed of each of the secondary microscreens to provide some
additional contact time as well as prevent growth on the microscreen surface.
See Figure III-1 for a schematic of the current chlorine feed system.
C. FEED RATES AND ESTIMATED COSTS
PMCurrently the plant uses an average of 600 pounds of chlorine per day at an average daily flow of
23 million gallons per day. This equates to a feed rate of approximately 3.1 milligrams of
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chlorine per liter of wastewater (mg/1). The year ending July 1998 price for chlorine was $347
,as, per ton cylinder. Therefore the projected annual chemical cost for disinfection is estimated as
follows:
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0.9 600 lbs per day x $347 / 2000 lbs = $104.10 per day
$104.10 per day x 365 days = $38,000 per year.
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COMPRESSED LIQUID -GAS EVAPORATOR
CHLORINE CYLINDERS
LEGEND
LIQUID CHLORINE
GAS CHLORINE
EFFLUENT WATER
CHLORINE SOLUTION .
UNDISINFECTED WASTEWATER
FKE IF-2
P ETROPOLITAN SEWERAGE DSTFICr
LIQUID -GAS CHLORINATION SYSTEM DIAGRAM
011180CI•TES
IN 013013627t a • rux7[17V a • TOO1ms
1U11ETR1S. NORTH CABIIIINA
McGill
INJECTOR
CHLORINATOR
0
JJ
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L
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0
DISCHARGE TO RECIEVING STREAM
CHLORINE CONTACT CHAMBER

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Extrapolated to plant design flow, the annual chemical cost is estimated as follows:
600 lbs per 23 MGD x 40 MGD x $347 / 2000 lbs = $181.04 per day
$181.04 per day x 365 days = $66,100 per year.
In addition to the direct cost of liquid gas chemical, there are several additional annual
operational costs that are unique to the use of liquid gas chlorine. A summary of these additional
annual costs is summarized below.
Estimated Annual Operational, Maintenance, and Compliance Costs
Liquid Gas Chlorine System
Metropolitan Sewerage District of Buncombe County
- Description
.Estimated Costs
Cost of coordination with Bucombe County
Hazardous Materials Response Team
$5,000
Internal Safety Training
$5,000
Chlorinator Service Contract
$5,000
Estimated Total Annual Compliance Costs
$15,000
�+ B. ESTIMATED COST FOR COMPLIANCE IMPROVEMENTS
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There are several improvements that may be required at the existing liquid -gas chlorine system if
improvements are ever made to the system. In evaluating a similar system at a separate
municipal installation, the addition of an air scrubber to the existing system was required to bring
the facility into compliance. The project cost estimate for the required improvements is below.
11

Construction Cost Estimate
Liquid Gas Chlorination System Improvements
►trnnnlitan Sewerage District of Buncombe Coun
Enclosure of Ton Cylinder Storage Shed
$50,000
Chlorine Scrubber and Enclosure
$98,000
Total Estimated Construction Costs
- _-
. $148,000
Design Fee
$22,200
Construction Administration
$11,840
Total Estimated Project Costs -_ _
--
L$182,040
Project Contingency
$36,400
Total Estimated Project Budget
=
_S218 440
rawl
Note that the above estimated project costs may require modification based on the results of a
'o' full analysis of the existing safety equipment, code requirements, and evaluation of best available
technology.
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ON
ALTERNATIVE DISINFECTISYSTEM
SECTION IV
S 11 a sodium hypochlorite feed
A.GENErequired to install describes the necessary
This section ecessary components required capital costs as well as
treatment plant and estimates the q e
system at MSD's wastewater analysis of this system,
Y system. To assist in the analy
annual chemical costs for the proposedY sodium hypochlorite
estimated arin visited three
vied by MSD operations staff,
McGill Associates, accompanied plant and two at water
treatment plants). Additionally, several printed
Tina (one at a wastewater treatment
feed systems in Concord, North CEO (see attached
Y sources were consulted
ine the proposed layout of the system.
bibliography) to determ
B.
EQUIPMENT REQUD Company in Charlotte, North
available from Jones Chemical 'on.
Sodium hypochlorite is also a 15
all shipped in 6600 gallon tankers
at percent concentration solution.
Carolina. It is traditionally One of the disadvantages of using
C re IV-l.
feed diagram is shown in Figure AtYP
typical system presence of heat and light. The
that is degrades over time in the pre
sodium hypochlorrte is of sodium hypochlorite.
are generally accepted for the storage
following decay ratesTemperatures
' es of Various Solution Concentrations when Stored at Ambient Temp
Salf-Lives
id decay rate, it is standard practice
Because of the rap
imately 5 to 8 percent immediately.
dilute it to approx
to unload the chemical from the tanker and
This increases the amount of required
13

1 I 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
DILUTION WATER
15% SODIUM
HYPOCHLORITE SOLUTION
DELIVERED IN BULK
0
Lil CE
h-- w
U
U
Z W
TRANSFER U' ~
PUMP z
LEGEND
15% SODIUM HYPOCHLORITE SOLUTION
DILUTION WATER
DILUTE SODIUM HYPOCHLORITE SOLUTION
UNDISINFECTED WASTEWATER
FIGURE IV-1
METROPOUTAN SEWERAGE DISTRCT
SOOILM HYPOCHL ORffE SYSTEM DIA(1AM
McGill
ASSOCIATES
ENCINEEHING• PLOIONG •FINANCE
IEFIEVILIB, NORTH CAROLINI
BULK STORAGE
TAN K
DISCHARGE TO RECIEVING STREAM
CHLORINE CONTACT CHAMBER

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SW
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storage, but ultimately saves money by retaining the chlorine in solution where it can be utilized.
The system calculations are as follows:
Assumptions: Loads are estimated to be 6,600 gallons each at 15% concentration
Specific Gravity of Sodium Hypochlorite = 1.14
Desire to store chemical at 7.5% concentration
Desire to store 15 days of chemical at plant design capacity
Current chlorine demand is 600 lbs of chlorine to treat 23 MGD
First, calculate the pounds of chlorine required per day per million gallons of flow per day.
M+ 600 lbs / 23 MGD = 261bs/MGD
Extrapolate to design capacity of 40 MGD, and the total pounds of chlorine required is:
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261bs/MGD x 40 MGD = 1040 lbs per day
'"' Now calculate the required amount of sodium hypochlorite required. First, the concentration
must be corrected for specific gravity:
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15%/ 1.14= 13.16%
Then calculate pounds of chlorine per gallon of NaOC1:
8.34 lbs/gal x 0.1316 = 1.10 lbs chlorine per gallon NaOC1 delivered.
At plant design flow rate, the total gallons of sodium hypochlorite needed per day is
1040 lbs chlorine / 1.10 lbs chlorine per gal NaOC1= 950 gpd (at 15% solution)
Therefore, one tanker load of NaOC1 will last
6600 gallons / 950 gallons / day = approximately 7 days.
15

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MIN
For operational flexibility, it is proposed to provide four (4) 15,000 gallon bulk storage tanks to
store the sodium hypochlorite and allow the concentration to be cut in half. Upon startup, all
four tanks will be filled with one tanker full of sodium hypochlorite. Two tanks will be fed to
the system, and when empty, the system will be switched to the other two tanks. At that point,
two additional tanker loads will be ordered to fill the empty tanks, and the process will proceed
accordingly, switching between the pair of tanks as necessary. Additional equipment necessary
for the system includes metering pumps, yard piping, and a new building to house the storage
tanks in a controlled environment out of direct sunlight. Figure IV-2 shows the preliminary
layout and configuration of the proposed Sodium Hypochlorite Feed System Control Building.
The estimated costs associated with this system are summarized below:
Construction Cost Estimate
Sodium Hypochlorite Feed System
Metropolitan Seweraie District of Buncombe Coun
Sodium Hypochlorite Control Building
$96,000
Metering Pumps
$7,500
Yard Piping
$4,000
Bulk Tanks
$90,000
Automatic Control System
$25,000
Site Development
$20,000
Total Estimated. Construction Costs
$242,500
Design Fee
$36,375
Construction Administration
$19,400
Total Estimated Project Costs
S298,275
Project Contingency
$60,000
Total Estimated Project Budget
=
S358,275
Note that the above cost estimate does not include surveying services that may be required, nor
does it include dechlorination equipment that may be required to be added at a later date. The
proposed Control Building, however, can accommodate the installation of a dechlorination
system in the future.
16

I 1 1 l 1 1 l 1 1 1 1 1 1 1 1
Dilution
40'-0"
Water Piping
0' 0"
Roll —Up Door
Standard
3-0 Door
Storage Tank Fill
Piping (Typ 4)
15,000 Gallon
Storage Tank
#1
Roll —Up Door
I ,Sodium
Hypochlorlte
Transfer Pumps
(Typ 4)
Standard
3-0 Door
Pump Discharge Piping
LEGEND
Suction Piping
Discharge Piping
Dilution Water Piping
Fill Piping
FIGURE IV-2
METROPOLITAN SEWERAGE DISTRICT
PRELMNARY SODIUM HYPOCHLORITE
CONTROL BULDING LAYOUT
McGill
ASSOCIATES
ENGINEERING • PLANNING •FINANCE
ASHEVILLE, NORTH CAROLINA

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C. FEED RATE AND ESTIMATED CHEMICAL COSTS
At the current plant flows, the plant utilizes approximately 600 lbs of chlorine per day. At an
equivalent chlorine dosage of 1.10 lbs of chlorine per gallon of sodium hypochlorite, this equates
to a sodium hypochlorite usage of 550 gallons per day. The estimated current pricing for sodium
hypochlorite (From Jones Chemical Company) is estimated to be $0.54 per gallon. Therefore,
550 gpd x $0.54 / gallon = $297 per day
$297 per day x 365 days per year = $108,500 per year at current flows
Extrapolated to plant design flow, this equates to
950 gpd x $0.54 / gallon = $513 per day
$513 per day x 365 days per year = $187,250 per year at design flow
full
While for planning purposes the price of $0.54 per gallon was tentatively confirmed with Jones
Chemical, it is anticipated that a slightly improved price will be obtained in a competitive
bidding situation.
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11
18
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A. BACKGROUND
As communities continue to grow and cities and towns begin to encroach upon once rural water
and wastewater treatment plants, the potential for mass injuries and property damages due to the
release of process chemicals increases greatly. Regulatory agencies were reminded of this fact
during a major accident in Yougstown, Ohio in 1978, when a liquid -gas chlorine release killed
eight people and injured almost 250 more during a railcar accident. Public concern regarding the
release of process chemicals intensified again in 1984 when following the release of methyl
isocyanate in Bhopal, India, which killed more than 2,000 people. A subsequent release in
Institute, West Virginia sent more than 100 people to the hospital and made Americans aware
that such incidents can and do happen in the United States.
B. APPLICATION TO WASTEWATER TREATMENT AND POTW's
In the early 1990's, both the Environmental Protection Agency (EPA) and the Occupational
Health and Safety Administration (OSHA) began to evaluate programs that could be
implemented to help avoid, or at least minimize the dangers associated with accidental chemical
releases. OSHA was the first agency to implement a program, called the Process Safety
Management Standard which was issued February 24, 1992. This program established chemical
usage and storage thresholds for approximately 140 hazardous chemicals, which, if exceeded,
required the user to prepare and keep on file a Process Safety Management Plan (PSMP). The
program was designed primarily to regulate industrial users, however, specifically in regard to
19

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;;;1
chlorine (which has an action level of 1500 pounds connected) the impact to POTW's was also
felt. Basically all facilities that utilize ton cylinders for liquid -gas chlorine disinfection were
required to have a PSMP in place by May 26, 1997.
PRI
More recently, the Environmental Protection Agency's (EPA) Risk Management Program
rim (RMP) was promulgated on June 20 of 1996. This program has three levels of compliance, each
one requiring higher levels of analysis and record keeping. Program 1 applies to processes for
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which a worst -case release, as evaluated in a hazard assessment, would not affect the public.
ram Remotely located sources using listed flammables are primarily those that are eligible for this
program. It is required that Program 1 compliance facilities have no previous releases with
run
serious offsite consequences.
Program 2 plans apply to less complex operations that do not involve chemical processing and
those that are not currently covered under OSHA PSM standards. It includes retailers, non-
'"' chemical manufacturers, and propane users, as long as they are not eligible for Programs 1 or 3.
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Program 3 compliance includes the major industrial processes, including those that are higher
risk, with complex chemical processing operations. Processes already regulated under OSHA
PSM fall into this category as well as other major industries such as petroleum refineries,
industrial organic producers, agricultural chemicals, and pulp mills.
A list of the threshold quantities of compounds under EPA RMP is included in the appendix. It
is important to note that the threshold quantities do vary between the OSHA rule and the EPA
20

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rule, specifically with regard to chlorine. The difference, however, is that OSHA rules apply to
connected quantities, while EPA thresholds apply to total quantities stored on site. Nonetheless,
the Metropolitan Sewerage District, with it's current liquid -gas chlorine system, does fall under
the requirements of both the PSM and RMP rules.
RMP rule requirements are comprised of six basic elements of risk management planning:
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• An offsite consequence analysis that evaluates specific potential release scenarios,
including worst case and alternative scenarios.
• A 5-year history of certain accidental releases of regulated substances from covered
processes.
• An integrated prevention program to manage risk.
• An emergency response plan.
• An overall management system to supervise the implementation of these program
elements.
• A risk management plan (RMP) revised at lease once every five years, that summarizes
and documents these activities for all covered processes.
The current deadline for facilities to be in compliance with the RMP requirements of EPA is
June 20, 1999. Compliance with the rule means that the RMP must be submitted to an as yet
unnamed "implementing agency" to be designated by EPA where the plan can be evaluated and
kept on file in a central location in case of an emergency
More information on both OSHA's PSMP rule and EPA's RMP are included in the appendices
of this report.
21

C. PRACTICAL IMPLICATIONS
In light of the recent and upcoming regulatory events, many publicly owned treatment works
have begun to formally evaluate their current processes, particularly liquid -gas chlorine use, and
to evaluate alternatives. Several similar sized POTW's in North Carolina municipalities have
already abandoned their liquid -gas chlorination systems in favor of sodium hypochlorite,
including, Greensboro, Burlington, Charlotte, Concord, and, locally, The Regional Water
Authority of Asheville, Buncombe and Henderson. The dilemma of how to achieve the
reliability and cost effectiveness of liquid -gas chlorine without the potential risk to workers and
the public has forced POTW's to closely investigate their chosen disinfection methods and their
available options. It is also important to note that the risk of using liquid -gas chlorine not only
comes form the chemical's use at the plant, but also from the potential dangers of transporting
materials from the supplier to the end user.
Pail
Because of the chemical similarities of sodium hypochlorite and liquid -gas chlorine, a
fm.' comparison of the two chemicals is almost always a part of any disinfection process evaluation.
As a disinfectant, it behaves almost identically as liquid -gas chlorine, however, it is not as
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corrosive and does not volatilize rapidly if released. In general, liquid sodium hypochlorite is
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much safer to transport, handle and use than liquid -gas chlorine. It is not currently subject to the
OSHA Process Safety Management rule or the EPA Risk Management Plan rules.
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Because of these benefits, many POTW's have accepted the higher operating costs and replaced
,., their liquid -gas chlorine systems with sodium hypochlorite feed systems. The general consensus
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22

in the industry is that the risk of one loss of life is well worth the increased operational costs of
switching to sodium hypochlorite.
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23

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A. INTRODUCTION
The Metropolitan Sewerage District is currently evaluating its disinfection process and the
potential impacts of the use of liquid -gas chlorine on the surrounding area in the event a
catastrophic release were to occur. Sodium hypochlorite is a viable alternative that has many of
the benefits of liquid -gas chlorine without the extreme safety concerns of a possible chlorine gas
release. By evaluating this process, the District is proactively evaluating the safety of the
ro, treatment plant and its operations and its potential impact on the communities that it serves. By
carefully evaluating the information contained in this report, the Metropolitan Sewerage District
will be able to understand the differences in the two processes, evaluate both the capital and
rwri ongoing operations and maintenance costs associated with the processes, and understand the
potential safety implications of choosing one process over the other. Based on the data in this
report, the following conclusions are made.
B: CHLORINATION CHEMISTRY
rim
Sodium hypochlorite functions essentially identical as a disinfecting agent as liquid -gas chlorine.
'""' The primary differences include a tendency for sodium hypochlorite to increase effluent water
pH, while liquid gas chlorine decreases effluent water chlorine. This can reduce the
effectiveness of sodium hypochlorite in poorly buffered water.
mei
24

C: LIQUID -GAS CHLORINATION CONSTRUCTION AND OPERATIONS COST
The following table summarizes the estimated chemical costs associated with the continued use
fw, of liquid gas chlorine
IND
P•,
fml
floR
Estimated Annual Chemical Costs
Liquid Gas Chlorine System
Metropolitan Sewerage District of Buncombe County
Flow Treated
.Estimated Annual
Chemical Cast
Current Demand (23 MGD)
$38,000 per year
Design Capacity Demand (40 MGD)
$66,100 per year
Additionally, there are additional operational costs associated with the use of liquid -gas
chlorination systems. These are summarized below:
Estimated Annual Operational, Maintenance, and Compliance Costs
Liquid Gas Chlorine System
Metropolitan Sewerage District of Buncombe County
Description
Estimated Costs
Cost of coordination with Buncombe County
Hazardous Materials Response Team
$5,000
Internal Safety Training
$5,000
Chlorinator Service Contract
$5,000
Estimated Total Annual Compliance Costs
$15,000
In addition to the annual operational costs associated with the system, there are several
improvements that may be required to help the system comply with current best management
practices for safety. The costs are estimated as follows:
25

rFmR
{
fun
RIM
Construction Cost Estimate
Liquid Gas Chlorination System Improvements
Metropolitan Sewerage District of Buncombe County
Enclosure of Ton Cylinder Storage Shed
$50,000
Chlorine Scrubber and Enclosure
$98,000
Total Estimated Construction Costs-
$148,000
Design Fee
$22,200
Construction Administration
$11,840
Total: Estimated Project Costs
=
. $182,040
Project Contingency
$36,400
Total Estimated Project Budget
$218,440
D: SODIUM HYPOCHLORITE CONSTRUCITON AND OPERATIONS COST
Before the sodium hypochlorite can be used as the disinfecting agent, a storage and handling
ram
facility must be constructed to provide bulk storage and application equipment for the solution.
The following cost estimate summarizes the estimated total project costs for the facility.
fmt
IMM
MIR
Construction Cost Estimate
Sodium Hypochlorite Feed System
Metropolitan Sewerage District of Buncombe County
Sodium Hypochlorite Control Building
$96,000
Metering Pumps
$7,500
Yard Piping
$4,000
Bulk Tanks
$90,000
Automatic Control System
$25,000
Site Development
$20,000
Total -Estimated Construction Costs -
-:
- :.
$242,500 =
.
Design Fee
$36,375
Construction Administration
$19,400
Total Estimated Project Costs _ - :_
-
:
=-
,$298,275
$60,000
- _-.: ,_ -
Project Contingency
Total Estimated Project Budget -
$358,275 -
- _
26

FRI
PRI
See Chapter IV for more detail regarding the proposed feed system and cost estimate.
In addition to the capital costs associated with the installation of the facility, the following table
summarizes the estimated chemical costs associated with the use of sodium hypochlorite as the
disinfecting agent.
Estimated Annual Chemical Costs
Sodium Hypochlorite Feed System
Metropolitan Sewerage District of Buncombe County
Flow Treated
Estimated Annual
Chemical Cost
Current Demand (23 MGD)
$ 108,500 per year
Design Capacity Demand (40 MGD)
$187,250 per year
D: SAFETY AND COMPLIANCE ISSUES
With the implementation of OSHA's Process Safety Management Program, and, more recently,
EPA's Risk Management Program, POTW's have been forced to evaluate the potential impact of
a catastrophic failure of their chemical processes on their plant and the surrounding communities.
Fon
With the District's plant located so close to several institutional facilities, including a
FRI Department of Corrections prison facility, Woodfin Elementary School, Town of Woodfin, and
Riverside Business Park, the potential impact of a major release of chlorine gas could be quite
FRI
severe.
The PSMP's and RMP's are designed to make state and local safety and emergency officials
aware of the potential hazards that exist at the facility, however, it is conceivable that there could
still be significant damage to property or possible loss of life if a release occurred. While it is
possible to place a value on the capital costs and increased operational costs associated with the
27

switch to sodium hypochlorite, it is impossible to quantify the potential damage, not only direct,
,..,
but also indirect through potential liability, that may occur during a release.
Mt
The information contained in this study can be used to educate the District to one available
mil
disinfection alternative and help to explain the complex issues surrounding safety at the
'm District's POTW. By utilizing, this information, the District can make informed decisions about
the operations of the plant while providing its members with the most environmentally sound and
rm
cost effective wastewater treatment available.
WI
WI
WM
rINI
,r
MI
MI
WI
MIPI
PM
Foil
28
PM

APPENDIX: A BIBLIOGRAPIY-
,ir U.S. Environmental Protection Agency: Design Manual, Municipal Wastewater Disinfection,
EPA/625/1-86/021, October 1986.
Metcalf & Eddie, Inc.: Wastewater Engineering: Treatment, Disposal, Reuse, Third Edition,
,., McGraw Hill, New York, NY, 1991.
Owl
I1
Pal
Water Pollution Control Federation: Sewage Treatment Plant Design, Manual of Practice 8,
Washington DC, 1977.
McGhee, Terence J.: Water Supply and Sewerage, Sixth Edition, McGraw Hill, New York, NY,
1991.

fln
PROCESS- MANAGEMENT -
-I 71- - -PtAN INFORMAflCT

04/01/1993 - Process Safety Management of Hi... Page 1 of 3
OSHA - Occupational Safety and Health Administration
rl
OSHA Fact Sheets
Process Safety Management of Highly Hazardous Chemicals
JOSHA ?SH \ Fact Sheer9 - Table :ii Ci-mtent3
T.wnt
f++l
• Record Type: Fact Sheets
• Subject: Process Safety Management of Highly Hazardous Chemicals
1.9 • Information Date: 01 /01 / 1993
• Fact Sheet: 93-45
U.S. Department of Labor
Program Highlights
rim Fact Sheet No. OSHA 93-45
PROCESS SAFETY MANAGEMENT
OF HIGHTLY HAZARDOUS CHEMICALS
Introduction -The Process Safety Management(PSM) of Highly Hazardous
run Chemicals(HHC's) standard, 29 CFR 1910.119 is intended to prevent or minimize the
consequences of a catastrophic release of toxic, reactive, flammable or explosive HHC's from
a process. A process is any activity or combination of activities including any use, storage,
manufacturing, handling or the on -site movement of HHC's. A process includes any group of
vessels which are interconnected and separate vessels which are located such that a HHC
could be involved in a potential release.
Application -The standard applies to a process which contains a threshold quantity or greater
amount of a toxic or reactive HHC as specified in Appendix A. Also, it applies to 10,000
'o`' pounds or greater amounts of flammable liquids and gases and to to the process activity of
manufacturing explosives and protechnics.
Exceptions -The standard does not apply to retail facilities, normally unoccupied remote
facilities and oil or gas well drilling or servicing activities. Hydrocarbon fuels used solely for
work place consumption as a fuel are not covered, if such fuels are not part of a process
'm' containing another HHC covered by the standard. Atmospheric tank storage and associated
transfer of flammable liquids which are kept below their normal boiling point without benefit
of chilling or refrigeration are not covered by the PSM standard unless the atmospheric tank
run is connected to a process or is sited in close proximity to a covered process such that an
incident in a covered process could involve the atmospheric tank.
AEI
Process Safety Information -Requires compilation of written process safety information
(PSI) including hazard information on HHC's, technology information and equipment
information on covered processes.
Employee Involvement -Requires developing a written plan of action regarding employee

01/01/1993 - Process Safety Management of Hi...
rAFI
participation; consulting with employees and their representatives on
development of process hazard analyses and on the development of of
safety management required under the rule; providing to employe.: —
access to process hazard analyses and to all other informal'
the rule. Employees include work site and contractor employees.
fm' Process Hazard Analysis -Specifies that process h7.,z7-:
as soon as possible for each covered process using comic:
required considerations. At least twenty-five percent o:
be completed by May 26, 1994; 50 percent by May 26,
and 100 percent by May 26, 1997. Process hazard analyses mu<-.
at least every five years and must be retained for the life of tile
Operating Procedures -Must be in writing and provide
conducting activities involving covered process consistent v.
each operating phase, operating limits, safety and
and their functions; be readily accessible to employees who v,
process, and be reviewed as often as necessary to ass'!7e •pti
practice; and must implement safe work practices to p,.o
as lockout/tagout and confined space entry.
Training -Employees operating a covered process must b:; t.; .. .
process and in the operating procedures addressed previ ^t." a- . -
,., specific safety and health hazards, emerge-.:. :
training must occur before assignment
the process as of May 26, 1992, have required knov.'1�
refresher training is required at least ev ,_7 : •
Contractors -Identifies responsibilities of work site cmj-:.
,:, respect to contract employees involved in maintenance. repair
or specialty work, on or near covered proce .
their employees to safely perform their jobs, . .
understood training, and assui ti tut c
hazards and the work site employer's emergency action p
safety rules of the facility, and advise the work site emn'.?..
poses or hazards identified by contract employees.
Pre -startup Safety Review -Mandates a safety review fo
modified work sites to confirm that the construction a nu tic
accordance with design specifications; to assure that a degt :.
and emergency procedures are in place; and to assure process c),
completed. Also, for new facilities, the PHA must be performed a-�
resolved and implemented before start up. Modified facilities rr:,.
change requirement.
Mechanical Integrity -Requires the on -site employer to csta'., .
procedures for the ongoing integrity of process equipment particu
which contain and control a covered process.
I1
rwr
Hot Work -Hot work permits must be issued for hot work operation, ;,1

01/01/1993 - Process Safety Management of Hi... Page 3 of 3
Pin
covered process.
Management of Change -The work site employer must establish and implement written
procedures to manage changes except "replacements in kind" to facilities that effect a covered
process. The standard requires the work site employer and contract employers to inform and
train their affected employees on the changes prior to start-up. Process safety information and
operating procedures must be updated as necessary.
Incident Investigation -Requires employers to investigate as soon as possible (but no later
than 48 hours after) incidents which did result or could reasonably have resulted in
catastrophic releases of covered chemicals. The standard calls for an investigation team,
including at least one person knowledgeable in the process involved, (a contract employee
when the incident involved contract work) and others with knowledge and experience to
investigate and analyze the incident, and to develop a written report on the incident. Reports
must be retained for five years.
Emergency Planning and Response -Requires employers to develop and implement an
emergency action plan. The emergency action plan must include procedures for handling
small releases.
Compliance Audits -Calls for employers to certify that they have evaluated compliance with
process safety requirements at least every three years. Prompt response to audit findings and
documentation that deficiencies are corrected is required. Employers must retain the two
most recent audit reports.
Trade Secrets -Sets requirements similar to trade secret provisions of the 1910.1200 Hazard
Communication standard requiring information required by the PSM standard to be available
to employees (and employees representatives). Employers may enter into confidentiality
agreement with employees to prevent disclosure of trade secrets.
ran
This is one of a series of fact sheets highlighting U.S. Department of Labor programs. It is
intended as a general description only and does not carry the force of legal opinion. This
information will be made available to sensory impaired individuals upon request. Voice
phone: [phone]. TDD message referral phone: [phone].
run JOSHA OST-TA Fact Sheets - Table of Contents

List of Highly Hazardous Chemicals, Toxics an...
Page 1 of 5
"'OSHA - Occupational Safety and Health Administration
OSHA Regulations (Standards - 29 CFR)
List of Highly Hazardous Chemicals, Toxics and Reactives (Mandatory). - 1910.119 App A
"'OSHA i_1jHRe(ruiations ; Ctanuard - CFR) R) - :ble of (Tontents
• Standard Number: 1910.119 App A
ram • Standard Title: List of Highly Hazardous Chemicals, Toxics and Reactives
(Mandatory).
• SubPart Number: H
• SubPart Title: Hazardous Materials
Purl
This Appendix contains a listing of toxic and reactive highly hazardous chemicals which
present a potential for a catastrophic event at or above the threshold quantity.
CHEMICAL NAME
Acetaldehyde
Acrolein (2-Propenal)
Acrylyl Chloride
Allyl Chloride
Allylamine
Alkylaluminums
Ammonia, Anhydrous
Ammonia solutions (greater
than 44% ammonia by weight)
Ammonium Perchlorate
Ammonium Permanganate
Arsine (also called
Arsenic Hydride)
Bis(Chloromethyl) Ether
Boron Trichloride
Boron Trifluoride
Bromine
Bromine Chloride
Bromine Pentafluoride
Bromine Trifluoride
3-Bromopropyne (also
called Propargyl Bromide)
Butyl Hydroperoxide
(Tertiary)
Butyl Perbenzoate
(Tertiary)
Carbonyl Chloride
1
CAS*
75-07-0
107-02-8
814-68-6
107-05-1
107-11-9
Varies
7664-41-7
I 7664-41-7 I
I 7790-98-9
I 7787-36-2
7784-42-1 I
542-88-1
10294-34-5
7637-07-2
7726-95-6
13863-41-7
7789-30-2
7787-71-5
I 106-96-7 1
75-91-2 I
614-45-9 I
TQ**
2500
150
250
1000
1000
5000
10000
15000
7500
7500
100
100
2500
250
1500
1500
2500
15000
100
5000
7500
Poll

List of Highly Hazardous Chemicals, Toxics an... Page 2 of 5
(see Phosgene)
Carbonyl Fluoride
Cellulose Nitrate (concentration
greater than 12.6% nitrogen
Chlorine
Chlorine
Chlorine
Chlorine
Dioxide
Pentrafluoride
Trifluoride
Chlorodiethylaluminum
mil (also called
Diethylaluminum Chloride)
1-Chloro-2,4-Dinitrobenzene
wq Chloromethyl Methyl Ether
Chloropicrin
Chloropicrin and Methyl
MR Bromide mixture
Chloropicrin and Methyl
Chloride mixture
rum Commune Hydroperoxide
Cyanogen
Cyanogen Chloride
Cyanuric Fluoride
Diacetyl Peroxide
ran
i
PoR
(concentration greater
than 70%)
Diazomethane
Dibenzoyl Peroxide
Diborane
Dibutyl Peroxide
(Tertiary)
ram Dichloro Acetylene
Dichiorosilane
Diethylzinc
Diisopropyl Peroxydicarbonate
Dilauroyl Peroxide
Dimethyldichlorosilane
Dimethylhydrazine, 1,1-
Dimethylamine, Anhydrous
2,4-Dinitroaniline
Ethyl Methyl Ketone Peroxide
(also Methyl Ethyl Ketone
Peroxide; concentration
greater than 60%)
Ethyl Nitrite
Ethylamine
Ethylene Fluorohydrin
Ethylene Oxide
Ethyleneimine
Fluorine
Formaldehyde (Formalin)
Furan
Hexafluoroacetone
Hydrochloric Acid, Anhydrous
Hydrofluoric Acid, Anhydrous
75-44-5 I
353-50-4
9004-70-0 I
7782-50-5
10049-04-4
13637-63-3
7790-91-2
96-10-6 I
97-00-7
107-30-2
76-06-2
None
None I
80-15-9
460-19-5
506-77-4
675-14-9
110-22-5 I
334-88-3
94-36-0
19287-45-7
110-05-4 I
7572-29-4
4109-96-0
557-20-0
105-64-6
105-74-8
75-78-5
57-14-7
124-40-3
97-02-9
100
2500
2500
1500
1000
1000
1000
5000
5000
500
500
1500
1500
5000
2500
500
100
5000
500
7500
100
5000
250
2500
10000
7500
7500
1000
1000
2500
5000
1338-23-4 I 5000
109-95-5 5000
75-04-7 7500
371-62-0 100
75-21-8 5000
151-56-4 1000
7782-41-4 1000
50-00-0 1000
110-00-9 500
684-16-2 5000
7647-01-0 5000
7664-39-3 1000

List of Highly Hazardous Chemicals, Toxics an... Page 3 of 5
Hydrogen Bromide
Hydrogen Chloride
Hydrogen Cyanide, Anhydrous
Hydrogen Fluoride
Hydrogen Peroxide (52% by
weight or greater)
mm Hydrogen Selenide
Hydrogen Sulfide
Hydroxylamine
Iron, Pentacarbonyl
min Isopropylamine
Ketene
Methacrylaldehyde
Methacryloyl Chloride
mm Methacryloyloxyethyl Isocyanate
Methyl Acrylonitrile
Methylamine, Anhydrous
Methyl Bromide
mm Methyl Chloride
Methyl Chloroformate
Methyl Ethyl Ketone Peroxide
(concentration greater
than 60 0 )
Methyl Fluoroacetate
Methyl Fluorosulfate
Methyl Hydrazine
Methyl Iodide
Methyl Isocyanate
Methyl Mercaptan
Methyl Vinyl Ketone
Methyltrichlorosilane
Nickel Carbonly (Nickel
Tetracarbonyl)
Nitric Acid (94.5% by
weight or greater)
Nitric Oxide
Nitroaniline (para
Nitroaniline
Nitromethane
Nitrogen Dioxide
Nitrogen Oxides (NO; NO(2);
N204; N203)
Nitrogen Tetroxide (also
called Nitrogen Peroxide)
Nitrogen Trifluoride
Nitrogen Trioxide
Oleum (65% to 80% by weight;
also called Fuming Sulfuric
Acid)
Osmium Tetroxide
Oxygen Difluoride (Fluorine
Monoxide)
Ozone
Pentaborane
10035-10-6
7647-01-0
74-90-8
7664-39-3
7722-84-1 I
7783-07-5
7783-06-4
7803-49-8
13463-40-6
75-31-0
463-51-4
78-85-3
920-46-7
30674-80-7
126-98-7
74-89-5
74-83-9
74-87-3
79-22-1
1338-23-4 I
453-18-9
421-20-5
60-34-4
74-88-4
624-83-9
74-93-1
79-84-4
75-79-6
13463-39-3 I
I 7697-37-2 I
110102-43-9
I 100-01-6 I
75-52-5
110102-44-0
110102-44-0 I
110544-72-6 I
7783-54-2
110544-73-7
8014-94-7 I
20816-12-0 I
7783-41-7
10028-15-6 I
19624-22-7 I
5000
5000
1000
1000
7500
150
1500
2500
250
5000
100
1000
150
100
250
1000
2500
15000
500
5000
100
100
100
7500
250
5000
100
500
150
500
250
5000
2500
250
250
250
5000
250
1000
100
100
100
100
Poll

List of Highly Hazardous Chemicals, Toxics an... Page 4 of 5
Peracetic Acid (concentration
greater 60o Acetic Acid; also I
called Peroxyacetic Acid)
Perchloric Acid (concentration
greater than 60% by weight)
Perchloromethyl Mercaptan
Perchloryl Fluoride
Peroxyacetic Acid (concentration
mm greater than 60o Acetic Acid;
also called Peracetic Acid)
Phosgene (also called Carbonyl
Chloride)
Phosphine (Hydrogen
Phosphide)
Phosphorus Oxychloride (also
called Phosphoryl Chloride)
Phosphorus Trichloride
Phosphoryl Chloride (also called
Phosphorus Oxychloride)
Propargyl Bromide
Propyl Nitrate
Sarin
Selenium Hexafluoride
Stibine (Antimony Hydride)
Sulfur Dioxide (liquid)
Sulfur Pentafluoride
�n Sulfur Tetrafluoride
Sulfur Trioxide (also called
79-21-0 I 1000
I I
7601-90-3 I 5000
594-42-3 I 150
I 7616-94-6 I 5000
I I
79-21-0 I
75-44-5
7803-51-2 I
10025-87-3 I
7719-12-2
10025-87-3 I
106-96-7
627-3-4
107-44-8
7783-79-1
7803-52-3
7446-09-5
5714-22-7
7783-60-0
Sulfuric Anhydride) I 7446-11-9 I
mm Sulfuric Anhydride (also
called Sulfur Trioxide)
Tellurium Hexafluoride
Tetrafluoroethylene
Tetrafluorohydrazine
Tetramethyl Lead
Thionyl Chloride
m" Trichloro (chloromethyl)
ran
Silane
Trichloro (dichlorophenyl)
Silane
Trichlorosilane
Trifluorochloroethylene
Trimethyoxysilane
I 7446-11-9
7783-80-4
116-14-3
10036-47-2
75-74-1
7719-09-7
I 1558-25-4 I
127137-85-5 I
110025-78-2
( 79-38-9
I 2487-90-3
Footnote* Chemical Abstract Service Number
1000
100
100
1000
1000
1000
100
2500
100
1000
500
1000
250
250
1000
1000
250
5000
5000
1000
250
100
2500
5000
10000
1500
Footnote** Threshold Quantity in Pounds (Amount necessary to be
covered by this standard.)

List of Highly Hazardous Chemicals, Toxics an... Page 5 of 5
[57 FR 7847, Mar. 4, 1992]
JOSHA ;;;i-ik Psawiations (Standards - FR': Vole of Contents
D m1I mot;
rot
Pal
�9

OM
WI
Mil
Ail
WI
MR
MI
WI
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Pr
PM
Pull
Mr

MOM
*Pi EPA
United States
Environmental Protection
Agency
Office of Solid Waste
and Emergency Response
(5101)
550-F-96-002
May 1996
RISK MANAGEMENT PLANNING:
ACCIDENTAL RELEASE PREVENTION
Final Rule: Clean Air Act section 112(rj
FACTSHEET
MANAGING
CHEMICALS
SAFELY
Section 112(r) of the
amended Clean
Air
Act (CAA), signed into
law on 15 November
Preventing accidental releases of hazardous chemicals is the shared
responsibility of industry, government, and the public. The first steps
toward accident prevention are identifying the hazards and assessing the
risks. Once information about chemicals is openly shared, industry, gov-
ernment, and the community can work together toward reducing the risk
to public health and the environment. Important new provisions in the
Clean Air Act advance the process of risk management planning and pub-
lic disclosure of risk. These requirements will affect facilities that pro-
duce, handle, process, distribute, or store certain chemicals. The final rule
for risk management planning was promulgated on 20 June 1996.
1990, mandates a new federal focus on the preven-
tion of chemical accidents. The objective of section
112(r) is to prevent serious chemical accidents that
have the potential to affect public health and the
environment. Under these requirements, industry
has the obligation to prevent accidents, operate
safely, and manage hazardous chemicals in a safe
and responsible way. Government, the public, and
many other groups also have a stake in chemical
safety and must be partners with industry for acci-
dent prevention to be successful.
The risk management planning requirements of
CAA section 112(r) complement and support the
Emergency Planning and Community Right -to -
Know Act of 1986 (EPCRA). A milestone in federal
actions, EPCRA helps local communities prepare
for and respond to chemical accidents. It requires
communities to develop emergency response
plans, based on information from industry con-
- cerning hazardous chemicals. Under the new
CAA requirements, stationary sources (facilities)
must identify and assess their chemical hazards
and carry out certain activities designed to reduce
the likelihood and severity of accidental chemical
releases. Information summarizing these activities
will be available to state and local governments,
the public. and all other stakeholders. Using this
information, citizens will have the opportunity to
work with industry to reduce risks to the commu-
nity from chemical accidents.
In the broadest sense, risk management planning
relates to local emergency preparedness and
response, to pollution prevention at facilities, and
to worker safety. In a more focussed sense, it forms
one element of an integrated approach to safety
and complements existing industry codes and
standards. The risk management planning require-
ments build on OSHA's Process Safety
Management Standard, the chemical safety guide-
lines of the Center for Chemical Process Safety of
the American Institute of Chemical Engineers, and

2
Risk Management Planning Final Rule May 1996
similar standards of the American Petroleum
Institute and Chemical Manufacturers
�—, Association, as well as the practices of many
other safety -conscious companies.
IT'S THE LAW...
kAA section 112(r) mandates that EPA pub-
ilish rules and guidance for chemical acci-
dent prevention. These rules must include
`i' requirements for sources to develop and imple-
ment risk management programs that incorpo-
rate three elements: a hazard assessment, a pre-
vention program, and an emergency response
program. These programs are to be summarized
in a risk management plan (RMP) that will be
• made available to state and local government
agencies and the public.
Pon
WHO'S COVERED
ny source with more than a threshold quan-
rttity of a listed "regulated substance" in a
single process must comply with the regulation.
"Process," in terms of the regulation, means
manufacturing, storing, distributing, handling,
or using a regulated substance in any other way.
• Transportation, including pipelines and vehicles
under active shipping orders, is excluded. On 31
January 1994, EPA promulgated a final list of 139
i regulated substances: 77 acutely toxic sub-
stances, 63 flammable gases and volatile liquids,
and Division 1.1 high explosives as listed by
▪ DOT. The final list rule established threshold
quantities for toxics ranging from 500 to 20,000
pounds. For all listed flammables, the threshold
quantity is 10,000 pounds. EPA proposed modifi-
foa' cations to the final list on 15 April 1996. These
modifications would exclude facilities handling
explosives, exploration/production facilities for
�•, oil and gas, and gasoline.
EPA estimates that approximately 66,000 sources
▪ will be covered by the rule, assuming the pro-
posed list amendments are adopted. The uni-
verse includes chemical manufacturers, other
manufacturers, certain wholesalers and retailers,
drinking water systems, wastewater treatment
works, ammonia refrigeration systems, utilities,
and federal facilities. Sources with at least one
covered process must comply with the rule by
June 20,1999.
THREE LEVELS OF
COMPLIANCE
Ttionhe final risk management planning regula-
CFR (40 part 68) defines the activities
sources must undertake to address the risks
posed by regulated substances in covered
processes. To ensure that individual processes
are subject to appropriate requirements that
match their size and the risks they may pose,
EPA has classified them into three categories
("Programs").
Program 1 requirements apply to processes for
which a worst -case release, as evaluated in the
hazard assessment, would not affect the public.
These are sources or processes that have not had
an accidental release that caused serious offsite
consequences. Remotely located sources and
processes using listed flammables are primarily
those eligible for this program.
Program 2 requirements apply to less complex
operations that do not involve chemical process-
ing (e.g., retailers, propane users, non -chemical
manufacturers. and other processes not regulat-
ed under OSHA's PSM Standard).
Program 3 requirements apply to higher risk,
complex chemical processing operations and to
processes already subject to the OSHA PSM.
RMP BASICS
ources with processes with a regulated sub-
b.../stance above a threshold quantity will be
required to carry out the following elements of
risk management planning
• An offsite consequence analysis that
evaluates specific potential release scenar-
ios, including worst -case and alternative

3 a
Risk Management Planning Final Rule May 1996
Fal
scenarios
1'4 • A 5-year history of certain accidental
releases of regulated substances from covered
processes
1101
• An integrated prevention program to man-
age risk
rm
• An emergency response program
Er
• An overall management system to supervise
the implementation of these program elements
• A risk management plan (RMP), revised at
least once every five years, that summarizes
and documents these activities for all covered
processes
IR
Based on their limited potential for serious offsite
consequences, sources are not required to imple-
W , ment a prevention program, an emergency
response program, or a management system for
Program 1 processes. Sources with processes in
Program 2 and Program 3 must address each of
p'" the above elements.
PM
PM
WI
PEI
ran
MR
Min
lug
LINKS
The OSHA PSM Standard (29 CFR 1910.119)
reflects the key elements that the petrochemical
industry, trade associations, and engineering soci-
eties have deemed essential to safe management of
hazardous substances for complex, chemical -pro-
cessing operations. EPA has adopted OSHA's PSM
requirements as the Program 3 prevention pro-
gram, with only minor changes in terminology.
With few exceptions, processes assigned to
Program 3 are already subject to the OSHA PSM
Standard; the remaining Program 3 processes are in
industry sectors that have a significant accident
history.
EPA has also worked closely with other regulatory
programs that focus on risk management issues for
hazardous chemicals in order to foster co-ordina-
tion and reduce burden. EPA and the National
Response Team have prepared Integrated
Contingency Plan Guidance to assist sources sub-
ject to multiple regulations in preparing a consoli-
dated emergency response plan. Further, EPA
believes that many of the prevention program
requirements for Program 2 processes and the
emergency response program requirements can be
satisfied without additional effort because of exist-
ing compliance with other federal and state regula-
tions, industry standards and codes, and good
engineering practices.
MAKING IT WORK
To document compliance with the rule and pro-
vide risk information, all sources must submit
to a central location a risk management plan that
includes a registration, an executive summary, a 5-
year accident history, and offsite consequence
analysis information. Sources with Program 2 and
3 processes also must submit information in the
RMP regarding compliance with requirements for
the prevention program and the emergency
response program.
EPA is developing a reporting mechanism and
form to collect RMPs in a way that encourages elec-
tronic submission. This will make risk management
planning information available far more widely to
the public and at a far lower cost than would tradi-
tional reporting. To support electronic submission
and reduce the reporting burden, EPA has stan-
dardized the RMP requirements. With the excep-
tion of the executive summary, data elements will
be primarily check -off boxes, yes/no answers, or
numerical entries.
An "implementing agency" will oversee these
requirements and receive the RMPs. It will audit
and inspect a percentage of sources each year and
require whatever revisions to the RMPs are neces-
sary. Under CAA section 112(1), states may request
that EPA delegate the authority to serve as the
implementing agency to a state or local agency
with the appropriate expertise, resources, and
authority. States may implement their own pro-
grams, although the law demands that program
requirements must be as stringent as EPA's and
must include all EPA -regulated substances and
processes. Approximately 30 per cent of the
sources subject to the risk management program

Risk Management Planning Final Rule May 1996
requirements must also comply with Title V of the
Clean Air Act, which requires permits for emis-
-
sions of air pollutants. Section 112(r) is an applica-
ble requirement for Title V permits.
HELP FOR SMALL
BUSINESS
Small and medium-sized enterprises may receive
information about CAA section 112(r) through
the Small Business Assistance Program in each
state, through the Federal Small Business
Assistance Program, through the network of Small
Business Development Centers across the country,
— through the EPCRA Hotline, and through a range
of electronic outlets.
— To make compliance easier for small businesses,
EPA is working with industry groups to develop
model risk management programs. Initially, these
model programs will be developed for ammonia
refrigeration, propane handling, and water treat-
ment operations. The RMP Offsite Consequence
Analysis Guidance will eliminate the need for cov-
ered small operations to invest in computer model-
ing programs and to answer complex technical
questions (e.g., how to model liquefied gases) relat-
- ed to this element of the hazard assessment.
LOOKING AHEAD...
A s this final rule is implemented, EPA plans to
publish general technical guidance, guidance
for states on implementation, guidance for Local
Emergency Planning Committees on ways to use
RMP information in the community, and additional
model plans for certain industry sectors and regu-
lated substances. In addition, the Agency will pro-
- duce training packages and disseminate training
through a variety of educational outlets.
Workshops, in co-operation with industry and
engineering societies, will also be presented around
the country, as well as teleconferences to introduce
the new risk management planning requirements
to a diversity of stakeholders.
♦..
With risk management planning as the basis for
accident prevention, everybody wins.
Industry has an opportunity to demonstrate excel-
lence in safety. Government can show effective,
efficient leadership in developing sensible require-
ments. And communities will have a powerful
right -to -know tool, as citizens work together
toward reducing chemical risks to public health
and the environment.
FOR MORE INFORMATION...
CONTACT THE EMERGENCY PLANNING AND
COMMUNITY RIGHT -TO -KNOW HOTLINE
[phone] OR [phone]
TDD [phone]
MONDAY-FRIDAY, 9 AM TO 6 PM, EASTERN TIME
♦•♦
VISIT THE CEPPO HOME PAGE ON THE WORLD
WIDE WEB AT:
http://www.epa.gov/swercepp/
01.1
Chemical Emergency Preparedness and Prevention Office

& EPA
cEi i *
United States
Environmental Protection
Agency
Office of Solid Waste and
Emergency Response
(5101)
May 1996
550-F-96-003
LIST OF SUBSTANCES FOR
ACCIDENTAL RELEASE
PREVENTION
CLEAN AIR ACT section 112(r)
FACTSHEET
The purpose of the
CAA provisions
for accident prevention
is to ensure that facili-
ties reduce the likeli-
hood and severity of
accidental chemical
releases that could
harm the public and
the environment. These
provisions also ensure
that the public and state
and local governments can receive facility -specific
information on potential hazards and the steps
being taken to prevent accidents.
REGULATORY BACKGROUND
In 1986 the Emergency Planning and Community
Right -to -Know Act (EPCRA) became law.
EPCRA improves the ability of communities to
prepare for and respond to chemical accidents.
Under EPCRA, communities must develop
emergency response plans, based on information
that facilities must provide on the hazardous
chemicals they handle. In the 1990 amendments to
the Clean Air Act, Congress included requirements
for accidental release prevention regulations in
section 112(r). Congress also mandated that the
Occupational Safety and Health Administration
(OSHA) adopt a process safety management
standard to protect workers from the workplace
effects of chemical accidents; the standard was
issued on 24 February 1992.
On 31January 1994, EPA promulgated a final rule under provisions of the Clean
Air Act (CAA) Amendments s.112(r) for the prevention of accidental releases of
hazardous substances. The rule establishes a list of chemicals and threshold
quantities that identify facilities subject to subsequent accident prevention
regulations. The listed substances have the potential to pose the greatest hazard
to public health and the environment in the event of an accidental release. On 15
April 1996, EPA proposed several amendments to the final rule. The list
constitutes the first of two necessary elements for the prevention of chemical
accidents under EPA's CAA mandate. The second element is the requirement for
risk management planning. A facility that handles more than a threshold quantity
of a listed substance in a process is subject to the risk management planning
requirements of CAA section 112(r).
CHARACTERISTICS OF
THE FINAL RULE
Under the CAA, EPA must develop an initial
list of at least 100 substances that, in the event
of an accidental release, could cause death, injury,
or serious adverse effects to human health or the
environment.
If a facility has more than a threshold quantity
of these substances in a process, then it must
develop and implement a risk management
program. That program must include a hazard
assessment, prevention program, and an
emergency response program. Summary risk
management plans will be submitted to a central
location and will be made electronically available to
state and local authorities as well as the public. The
final rule for risk management planning was
promulgated on 20 June 1996.
The statutory criteria EPA considered in selecting
substances for the list include severity of acute
adverse health effects, likelihood of release, and

2 List of Substances for Accidental Release Prevention May 1996
potential magnitude of human exposure. EPA
set threshold quantities for each regulated
substance based on its toxicity, reactivity,
volatility, dispersibility, and flammability, as well
as the amount known or anticipated to cause
effects of concern.
The list EPA promulgated in 1994 includes 77
acutely toxic chemicals, 63 flammable gases and
volatile flammable liquids, and Division 1.1 high
explosive substances as listed by DOT in 49 CFR
172.101. The final rule establishes threshold
quantities for toxic substances ranging from 500
— to 20,000 pounds. For all listed flammable
substances, the threshold quantity is 10,000
pounds, while all explosive substances have a
threshold quantity of 5,000 pounds. The rule sets
forth the procedures for determining whether a
threshold quantity of a regulated substance is
present at a stationary source. Specific
exemptions to the threshold determination are
also included for mixtures, articles, and certain
uses and activities. The rule also specifies the
requirements for petitions to the Agency to add
substances to, or delete substances from, the list.
PROPOSED CHANGES
ollowing EPA's promulgation of the final list
rule, some members of the regulated
community raised questions about certain
provisions they felt were inconsistent with the
intent EPA expressed in the preamble and other
documents supporting the final rule. In response,
EPA published proposed amendments to the
final rule on 15 April 1996.
The first proposed modification would be to
delete the category of Division 1.1 explosives.
The Agency also proposes to exempt from
threshold quantity determinations regulated
flammable substances in gasoline used as fuel
and in naturally occurring hydrocarbon mixtures
prior to initial processing. Further, the Agency
proposes clarification of the provision for
threshold determination of flammable
substances in a mixture. Modifications to the
definition of "stationary source" are proposed to
clarify the exemption of transportation and
storage related to transportation and to clarify
that naturally occurring hydrocarbon reservoirs
are not stationary sources or parts of stationary
sources. In addition, EPA proposes to clarify that
40 CFR part 68 does not apply to sources located
on the Outer Continental Shelf. EPA believes
these proposed changes will focus accident
prevention more appropriately on stationary
sources with high hazard operations and reduce
duplication with other similar requirements.
For those provisions of the list rule that EPA is
proposing to amend, the Agency has finalized a
stay of effectiveness until it takes final action on
the proposed modifications. Thus, owners and
operators of processes and sources that EPA has
proposed not be subject to risk management
planning requirements would not have to
comply with CAA section 112(r) until EPA has
determined whether to finalize the proposed list
rule amendments.
AFFECTED UNIVERSE
EPA estimates that approximately 66,000
facilities will be affected by the list and risk
management planning rules, if the proposed list
amendments are adopted. The facilities include
chemical and many other manufacturers, cold
storage facilities with ammonia refrigeration
systems, public water treatment systems,
wholesalers and distributors of these chemicals,
propane retailers, utilities, and federal facilities.
CONCLUSION
Ncording to the risk management planning
equirements of the Clean Air Act, facilities
that handle certain hazardous substances must
act to prevent chemical accidents. They must also
share information about their prevention efforts
with the public, workers, and government. EPA
expects these new partnerships among
stakeholders in prevention activity to prove a
dynamic force in reducing the number and
severity of chemical accidents.
FOR MORE INFORMATION...
CONTACT THE EMERGENCY PLANNING AND
COMMUNITY RIGHT -TO -KNOW HOTLINE
[phone] OR [phone]
TDD [phone]
MONDAY-FRIDAY, 9AM TO 6PM, EASTERN TIME
VISIT THE CEPPO HOME PAGE
http://www.epa.gov/swercepp/

44 EPA
coP
United States
Environmental Protection
Agency
Office of Solid Waste 550-F-96-004
and Emergency Response May 1996
(5101)
CHEMICAL ACCIDENT PREVENTION
AND THE CLEAN AIR ACT
AMENDMENTS OF 1990
The Clean Air Act
(CAA) makes it
clear that facilities that
handle hazardous
substances bear the
primary responsibility
for ensuring their safe
use. The CAA section
112(r)(1) general duty
clause outlines the basic
statutory principle that
facilities are responsible
for designing and
maintaining a safe plant,
identifying their hazards, and minimizing the
consequences of accidental chemical releases. This
clause applies to any facility that handles any
hazardous substance, regardless of the quantity
on site.
CAA SECTION 112 (r) :
BASIC REQUIREMENTS
Under nder CAA s.112(r), EPA must:
• Publish a list of at least 100
substances and associated threshold
quantities that determine who must
comply with the new regulations
Preventing accidental releases of hazardous chemicals is the shared
responsibility of industry, government, and the public. The first steps toward
prevention are identifying the hazards and assessing the risks. Once information
about chemicals is openly shared, stakeholders can work together toward
reducing chemical risks to public health and the environment. Important new
provisions in the Clean Air Act of 1990 advance the process of risk management
planning and public disclosure of risk. The amendments, which cover a wide
range of air pollution issues, include specific provisions addressing accidental
releases of hazardous chemicals. These requirements will affect facilities that
produce, handle, process, distribute, or store certain chemicals.
• Develop regulations and guidance for the
response, prevention, and detection
of accidental releases associated with these
regulated substances.
Certain facilities must:
• Prepare risk management plans that
include a hazard assessment, accident
prevention program, and emergency
response program
• Comply with other accidental release
regulations that EPA may adopt.
One of the other key provisions of section 112(r) is
a mandate for OSHA to establish a chemical
process safety management standard for the
workplace.

.4
2 Chemical Accident Prevention and the Clean Air Act Amendments of 1990 May 1996
The CAA, under s.507, also requires that each
state set up programs to provide small
mm
businesses with technical assistance on the CAA
and to help them comply with the Act's
regulations. By statute, these small business
'" programs must include assistance related to
accidental release prevention and detection.
These programs provide information on
cal alternative technologies, process changes,
products, and methods of operation that help
reduce air pollution.
PM
MEI
BACKGROUND: CHEMICAL
ACCIDENT PREVENTION
BEFORE 1990
ublic awareness of the potential danger
from accidental releases of hazardous
substances has increased over the years as
serious chemical accidents have occurred around
MR the world. Public concern intensified following
the 1984 release of methyl isocyanate in Bhopal,
India, which killed more than 2,000 people. A
r..i subsequent chemical release in Institute, West
Virginia, sent more than 100 people to the
hospital and made Americans aware that such
incidents can and do happen in the United
w' States.
rm EPA's RESPONSE TO BHOPAL
n response to this public concern and the
Iiii hazards that exist, EPA began its Chemical
Emergency Preparedness Program (CEPP) in
1985. CEPP was a voluntary program to
encourage state and local authorities to identify
m^ hazards in their areas and to plan for potential
chemical emergencies. This local planning
complemented emergency response planning
rim carried out at the national and regional levels by
the National Response Team and Regional
Response Teams.
im The following year, Congress enacted many of
the elements of CEPP in the Emergency Planning
and Community Right -to -Know Act of 1986
,,., (EPCRA), also known as Title III of the
Superfund Amendments and Reauthorization
Act of 1986 (SARA). This law requires states to
establish State Emergency Response
1•1' Commissions and Local Emergency Planning
Committees to develop emergency response
plans for each community. EPCRA also requires
facilities to make information available to the
public on the hazardous chemicals they have on
site. EPCRA's reporting requirements foster a
valuable dialogue between industry and local
communities on hazards to help citizens become
more informed about the presence of hazardous
chemicals that might affect public health and the
environment. According to OSHA requirements,
workers on site also have a right to know about
the hazardous chemicals to which they could be
exposed.
MILESTONE REPORT ON
SYSTEMS FOR PREVENTION
EPCRA did not require facilities to
establish accident prevention programs.
However, under EPCRA section 305(b), EPA was
required to conduct a review of emergency
systems to monitor, detect, and prevent chemical
accidents at facilities across the country. The
final report to Congress, Review of Emergency
Systems (EPA, 1988), concluded that the
prevention of accidental releases requires an
integrated approach that considers technologies,
operations, and management practices, and it
emphasized the importance of management
commitment to safety.
EPA's PREVENTION
PROGRAM TAKES SHAPE
EPA recognized that prevention,
preparedness, and response form a safety
continuum. Therefore, in 1986, EPA established
its Chemical Accident Prevention Program,
integrating it with the Chemical Emergency
Preparedness Program. The first initiative was to
begin collecting information on chemical
accidents. Then EPA began working with other
stakeholder groups to increase knowledge of
prevention practices and encourage industry to
improve safety at facilities.
Under the Chemical Accident Prevention
Program, EPA developed the Accidental Release
Mel

May 1996 Chemical Accident Prevention and the Clean Air Act Amendments of 1990 3
NMI
Information Program (ARIP) to collect data on
the causes of accidents and the steps facilities
„m take to prevent recurrences. EPA also
developed its Chemical Safety Audit Program to
gather and disseminate information on
successful practices to mitigate and prevent
chemical accidents. The audit program also
points out problematic practices and ways to
improve them. Through the program, EPA has
trained its regional staff as well as state officials
on process safety and auditing techniques.
Another significant component of EPA's
Chemical Accident Prevention Program
involves outreach to small and medium-sized
enterprises, which the section 305(b) study
indicated are generally less aware of risks than
larger facilities. EPA has worked with a broad
spectrum of stakeholder groups to determine
the best ways to reach these smaller operations.
PEI
All these efforts are based on the premise that
while industry bears the primary responsibility
for preventing and mitigating chemical
accidents, many other groups also have a role to
play. Workers, trade associations, environ-
mental groups, professional organizations,
public interest groups, the insurance and
financial community, researchers and academia,
the medical profession, and governments at all
levels can help facilities that use hazardous
chemicals identify their hazards and find safer
ways to operate. A number of stakeholder
groups have now developed programs and
guidance to assist facilities in the management
of chemical hazards. Many of these safety
measures can make businesses more efficient
and productive.
CLEAN AIR ACT
REQUIREMENTS:
WHAT CHEMICALS ARE
COVERED?
Under
CAA 112(r)(3)(5), EPA must develop
and publish an initial list of at least 100
substances that, in an accidental release, could
cause death, injury, or serious adverse effect to
human health or the environment.
To build its list, EPA considered the severity
of any acute adverse health effects, the
likelihood of an accidental release, and the
potential magnitude of human exposure. The
threshold quantities for each chemical (which
determine the facilities subject to the RMP
requirements) reflect toxicity, reactivity,
volatility, flammability, explosivity, and
dispersibility as well as the amount known or
anticipated to cause effects of concern.
On January 31,1994, EPA promulgated a final
rule on the substances and thresholds: 77
acutely toxic chemicals, 63 flammable gases and
volatile flammable liquids, and Division 1.1
high explosive substances as listed by DOT. On
April 15, 1996, based on concerns raised by the
regulated community, EPA proposed
modifications to the final rule. The
modifications would clarify "flammables" so
that gasoline and crude oil would not be
covered; clarify "stationary source": and make
clear the exclusion of facilities handling
explosives, exploration and production facilities
for oil and gas, and gasoline.
It is important to note that the threshold
quantity is determined by the maximum
amount of a substance in a proccess, not the
maximum quantity on site. The list rule also sets
forth the requirements for petitions to the
Agency to add substances to, or delete
substances from, the list.
RISK MANAGEMENT
PLANNING
For industry, chemical accident prevention
has become an important way of doing
business. More and more plant managers,
whether they are subject to regulation or not,
recognize chemical safety management as an
integral part of running an efficient operation.
At the same time, new CAA regulations ensure
that the public can be properly informed about
chemical risks in their neighborhoods, and
community organizations, states, and the
federal government all have become active
players in helping to lower these risks.
RMP Basics
EPA proposed its regulation on risk
management planning on October 20, 1993. Its

4 Chemical Accident Prevention and the Clean Air Act Amendments of 1990
May 1996
requirements apply to facilities that have more
than a threshold quantity of a regulated
substance in a process. As mandated by the
CAA, the final rule requires facilities to develop
and implement a risk management program that
includes a hazard assessment of the off site
consequences of releases under worst case and
alternate scenarios, a prevention program, and
an emergency response program. Information
about the program must be documented in a risk
management plan that is submitted to a central
location and made available electronically to
▪ states and local planning agencies as well as the
public.
Building on Chemical
Process Safety Management
These new risk management planning
requirements are not unique. Rather, they form
one element of an integrated approach to safety
▪ and complement closely related industry
standards and practices. In the broadest sense,
risk management planning relates to local
Sol emergency preparedness and response, to
pollution prevention at facilities, and to worker
safety. In a more focussed sense, these
requirements build on OSHA's Process Safety
Management Standard (issued on February 24,
1992). They also draw from the chemical safety
guidelines of the Center for Chemical Process
Safety of the American Institute of Chemical
Engineers and similar standards of the American
Petroleum Institute and Chemical Manufacturers
Association, as well as the practices of safety -
fun
conscious chemical companies. In addition, four
states --New Jersey, California, Nevada, and
Delaware --also have regulations on accidental
release prevention.
For facilities to comply with the new risk
management planning rule, EPA is encouraging
them to incorporate these existing industry
standards and approaches that many already
practice for chemical safety management.
rign
Prevention Program Requirements
The elements of the
prevention program include the
following:
• Review and documentation
of the plant's chemicals,
processes, and equipment
• Detailed process hazard
analysis to identify hazards,
assess the likelihood of
accidental releases, and
evaluate the consequences
of such releases
• Development of standard
operating procedures
• Training of employees on
procedures
• Implementation of a
preventive maintenance
program
• Management of changes in
operation that may impact
the safety of the system
• Reviews before initial start-
up of a process and before
start-up following a
modification of a process
• Investigation and
documentation of accidents
• Periodic safety audits to ensure
that procedures and practices
are being followed

May 1996 Chemical Accident Prevention and the Clean Air Act Amendments of I990 5
POI
Affected Universe
EPA estimates that approximately 66,000
facilities will be affected by the risk
management planning requirements, if
proposed amendments to the list rule are
adopted. These facilities include manufacturers
in the chemical and petrochemical and refining
industries, other manufacturers in many
manufacturing sectors (e.g., manufacturers of
pulp and paper; organic and inorganic
chemicals; manufacturers and handlers of chlor-
alkalis, plastics and resins, nitrogen fertilizers,
and agricultural chemicals), cold storage
facilities that use ammonia as a refrigerant
including food processors and distributors and
refrigerated warehouses, public water treatment
systems, chemical retailers, federal facilities, and
"Er some service industries.
Many other stakeholder groups will also be at
ru•r least indirectly affected by the new 112(r)
requirements. These include federal agencies
and departments (especially OSHA, DOT, DOD,
DOE, SBA, FEMA , and Coast Guard) and state
and local representatives (particularly State
Emergency Response Commissions and Local
Emergency Planning Committees, state air
fir offices, local fire departments, emergency
management agencies, environmental protection
and public health departments, land use
planning officials, and natural resource planning
and management offices).
Other interested stakeholders will be public
interest groups and the environmental
community, insurance companies, labor
organizations, and international bodies such as
the Organisation for Economic Co-operation and
Development.
fur
RMP Registration and
Submittal
Facilities covered by the rule will comply by
submitting to a central location a registration
form along with a risk management plan that
describes their risk management program.
Facilities will submit their plans electronically,
selecting options to be spelled out in guidance.
The information will be available immediately
to state and local authorities as well as to the
general public and all other stakeholders who
may be interested.
The final rule with the requirements for risk
management planning was promulgated on
June 20, 1996. Submittals of registration forms
and risk management plans are due from
facilities by June 20, 1999, with updates required
every five years.
Should EPA add to the list of regulated
substances, the regulations would take effect for
newly covered facilities three years after the
date on which a substance is first listed.
OTHER CAA PROVISIONS
Presidential Review
The CAA requires the President to conduct a
review of the current authority of various
federal agencies regarding chemical release
prevention, mitigation, and response and to
report the findings to Congress. The purpose of
the review is to clarify and co-ordinate
responsibilities and to identify any gaps and/or
overlaps that may exist. The President delegated
this authority to the EPA Administrator in 1993.
Hydrofluoric Acid Study
As required by the CAA, EPA conducted a
study on the potential hazards of hydrofluoric
acid (HF). Transmitted to Congress in the fall
of 1993, the study investigates the physical and
chemical properties of HF, its hazards in
commercial and industrial use, and the types
and numbers of facilities in which HF is
handled. The document also describes accidents
that have resulted in the release of HF, as well as
any public and environmental impacts that
resulted from these releases. An analysis of
scenarios using atmospheric dispersion models
investigates potential impacts on the public
from a range of worst -case accidental releases.
The study also describes the current industry
and government controls to prevent accidental
releases of HF and to mitigate the potential
consequences of accidents through emergency
preparedness and response efforts.

6 Chemical Accident Prevention and the Clean Air Act Amendments of 1990 May 1996
Research Programs
Under the CAA, EPA must establish a
program of long-term research on methods
and techniques for conducting detailed hazard
assessments. The CAA also requires EPA to
test substances at the Liquefied Gaseous Fuels
Spill Test Facility in Nevada. These tests
would develop and validate improved
predictive models for atmospheric dispersion,
evaluate existing dispersion models, and
evaluate technology for mitigation and
— emergency response.
119
New OSHA Standard
On February 24, 1992, OSHA adopted a
standard for chemical process safety
management in the workplace as required
under the CAA 1990 amendments. Just as
CAA s.112(r) protects public health and the
environment, the OSHA standard is designed
to protect workers from accidents involving
hazardous chemicals. The OSHA standard
applies to facilities that handle certain acutely
toxic, highly flammable, and reactive
substances.
Requirements of the standard cover safety
information on chemicals and processes, a
workplace process hazard analysis, periodic
audits, standard operating procedures,
training, maintenance, pre -startup safety
reviews, management of change, emergency
response, and accident investigation.
In formulating the regulatory requirements for
risk management planning, EPA incorporated
OSHA's Process Safety Management Standard
nearly verbatim into the prevention program
requirements of CAA s.112(r) for higher risk
facilities.
NATURAL EVOLUTION
Sonce the mid-1980s, EPA has been
working closely with the whole gamut of
prevention stakeholders to help reduce the
likelihood and severity of chemical accidents.
Beginning with the voluntary Chemical
Emergency Preparedness Program in 1985,
extending to the SARA Title III regulations in
1986, and now culminating in the new Clean
Air Act, these efforts address the entire safety
continuum from emergency response to
preparedness to prevention. In this way, a new
partnership involving government, business,
and the public is being forged. Working
together, each of these groups is playing a key
role in preventing accidental releases of
hazardous chemicals.
FOR MORE INFORMATION...
CONTACT THE EMERGENCY PLANNING AND COMMUNITY RIGHT -TO -KNOW HOTLINE
[phone], OR [phone], OR TDD [phone]
MONDAY THROUGH FRIDAY, 9:00 AM TO 6:00 PM, EASTERN TIME
ON THE WORLD WIDE WEB, VISIT TILE HOME PAGE OF EPA's CHEMICAL EMERGENCY PREPAREDNESS
AND PREVENTION OFFICE AT:
http://www.epa.gov/swercepp/

MIER
United States
Environmental Protection
Agency
Office of Solid Waste
and Emergency Response
(5101)
550-F-96-005
May 1996
CLEAN AIR ACT
SECTION 112(r)
Excerpts from Statute
FACTSHEET
CLEAN AIR
ACT
SECTION 112 (r)
EXCERPTS
(r) Prevention of
Accidental
Releases
Section 112(r) of the amended Clean Air Act deals with the preven-
tion and detection of accidental releases of hazardous chemicals.
EPA has promulgated the two regulations that the Act calls for con-
cerning risk management planning. As a reference document to
accompany those rules, this fact sheet sets forth relevant portions
excerpted from the statute.The Clean Air Act is codified in the U.S.
Code at 42 U.S.C. 7401 et seq.; section 112(r) may be found at
U.S.C. 7412.
(1) Purpose and General Duty
It shall be the objective of the regulations and pro-
grams authorized under this subsection to prevent
the accidental release and to minimize the conse-
- quences of any such release of any substance listed
pursuant to paragraph (3) or any other extremely
hazardous substance. The owners and operators
of stationary sources producing, processing, han-
dling, or storing such substances have a general
duty in the same manner and to the same extent as
section 654 of Title 29 to identify hazards which
may result from such releases using appropriate
hazard assessment techniques, to design and main-
tain a safe facility taking such steps as are neces-
_, sary to prevent releases, and to minimize the con-
sequences of accidental releases which do occur.
For purposes of this paragraph, the provisions of
section 7604 of this title shall not be available to
—
any person or otherwise be construed to be applic-
able to this paragraph. Nothing in this section
shall be interpreted, construed, implied or applied
to create any liability or basis for suit for compen-
sation for bodily injury or any other injury or prop-
erty damages to any person which may result from
accidental releases of such substances.
(2) Definitions
(A) The term "accidental release" means an unan-
ticipated emission of a regulated substance or
other extremely hazardous substance into the
ambient air from a stationary source.
(B) The term "regulated substance" means a sub-
stance listed under paragraph (3).
(C) The term "stationary source" means any build-
ings, structures, equipment, installations or sub-
stance emitting stationary activities (i) which
belong to the same industrial group, (ii) which are
located on one or more contiguous properties, (iii)
which are under the control of the same person (or
persons under common control), and (iv) from
which an accidental release may occur.

2
CAA s./12(r) Excerpts
May 1996
Pin
(3) List of Substances
The Administrator shall promulgate not later
than 24 months after enactment of the Clean Air
Act Amendments of 1990 an initial list of 100
substances which, in the case of an accidental
release, are known to cause or may reasonably
be anticipated to cause death, injury, or serious
adverse effects to human health or the environ-
ment. For purposes of promulgating such list,
ray' the Administrator shall use, but is not limited to,
the list of extremely hazardous substances pub-
lished under the Emergency Planning and
Community Right -to -Know Act of 1986 [42
U.S.C. B 11001 et seq.], with such modifications
as the Administrator deems appropriate. The
initial list shall include chlorine, anhydrous
ammonia, methyl chloride, ethylene oxide, vinyl
chloride, methyl isocyanate, hydrogen cyanide,
ammonia, hydrogen sulfide, toluene diiso-
cyanate, phosgene, bromine, anhydrous hydro-
gen chloride, hydrogen fluoride, anhydrous sul-
fur dioxide, and sulfur trioxide. The initial list
shall include at least 100 substances which pose
the greatest risk of causing death, injury, or seri-
ous adverse effects to human health or the envi-
ronment from accidental releases. Regulations
▪ establishing the list shall include an explanation
of the basis for establishing the list. The list may
be revised from time to time by the
• Administrator on the Administrator's own
motion or by petition and shall be reviewed at
least every 5 years. No air pollutant for which a
national primary ambient air quality standard
r"`' has been established shall be included on any
such list. No substance, practice, process, or
activity regulated under subchapter VI of this
chapter shall be subject to regulations under this
subsection. The Administrator shall establish
procedures for the addition and deletion of sub-
stances from the list established under this para-
graph consistent with those applicable to the list
in subsection (b) of this section.
111,11
Pol
PEI
Fag
(4) Factors to be Considered
In listing substances under paragraph (3), the
Administrator shall consider each of the follow-
ing criteria ,
(A) the severity of any acute adverse health
effects associated with accidental releases of the
substance;
(B) the likelihood of accidental releases of the
substance; and
(C) the potential magnitude of human exposure
to accidental releases of the substance.
(5) Threshold Quantity
At the time any substance is listed pursuant to
paragraph (3), the Administrator shall establish
by rule, a threshold quantity for the substance,
taking into account the toxicity, reactivity,
volatility, dispersibility, combustibility, or flam-
mability of the substance and the amount of the
substance which, as a result of an accidental
release, is known to cause or may reasonably be
anticipated to cause death, injury or serious
adverse effects to human health for which the
substance was listed. The Administrator is
authorized to establish a greater threshold quan-
tity for, or to exempt entirely, any substance that
is a nutrient used in agriculture when held by a
farmer.
(7) Accident Prevention
(A) In order to prevent accidental releases of
regulated substances, the Administrator is
authorized to promulgate release prevention,
detection, and correction requirements which
may include monitoring, recordkeeping, report-
ing, training, vapor recovery, secondary contain-
ment, and other design, equipment, work prac-
tice, and operational requirements. Regulations
promulgated under this paragraph may make
distinctions between various types, classes, and
kinds of facilities, devices and systems taking
into consideration factors including, but not lim-
ited to, the size, location, process, process con-
trols, quantity of substances handled, potency of
substances, and response capabilities present at
any stationary source. Regulations promulgated
pursuant to this subparagraph shall have an
effective date, as determined by the
Administrator, assuring compliance as expedi-
tiously as practicable.
(B) (i) Within 3 years after November 15, 1990,
the Administrator shall promulgate reasonable
AMR

3
CAA s.112(r) Excerpts May 1996
PEP
regulations and appropriate guidance to provide,
!w, to the greatest extent practicable, for the prevention
and detection of accidental releases of regulated
substances and for response to such releases by the
owners or operators of the sources of such releases.
w The Administrator shall utilize the expertise of the
Secretaries of Transportation and Labor in promul-
gating such regulations. As appropriate, such reg-
ulations shall cover the use, operation, repair,
replacement, and maintenance of equipment to
monitor, detect, inspect, and control such releases,
including training of persons in the use and main-
tenance of such equipment and in the conduct of
periodic inspections. The regulations shall include
procedures and measures for emergency response
after an accidental release of a regulated substance
in order to protect human health and the environ-
ment. The regulations shall cover storage, as well
as operations. The regulations shall, as appropri-
ate, recognize differences in size, operations,
processes, class and categories of sources and the
voluntary actions of such sources to prevent such
rim
releases and respond to such releases. The regula-
tions shall be applicable to a stationary source 3
years after the date of promulgation, or 3 years
riml after the date on which a regulated substance pre-
sent at the source in more than threshold amounts
is first listed under paragraph (3), whichever is
,.R, later.
(ii) The regulations under this subparagraph shall
require the owner or operator of stationary sources
m, at which a regulated substance is present in more
than a threshold quantity to prepare and imple-
ment a risk management plan to detect and prevent
or minimize accidental releases of such substances
"1 from the stationary source, and to provide a
prompt emergency response to any such releases in
order to protect human health and the environ-
ment. Such plan shall provide for compliance with
the requirements of this subsection and shall also
include each of the following:
' (I) a hazard assessment to assess the potential
effects of an accidental release of any regulated
substance. This assessment shall include an esti-
mate of potential release quantities and a determi-
nation of downwind effects, including potential
exposures to affected populations. Such assess-
ment shall include a previous release history of the
past 5 years, including the size, concentration, and
duration of releases, and shall include an evalua-
tion of worst case accidental releases;
W' (II) a program for preventing accidental releases of
regulated substances, including safety precautions
and maintenance, monitoring and employee train-
ing measures to be used at the source; and
(III) a response program providing for specific
actions to be taken in response to an accidental
release of a regulated substance so as to protect
human health and the environment, including pro-
cedures for informing the public and local agencies
responsible for responding to accidental releases,
emergency health care, and employee training
measures.
At the time regulations are promulgated under this
subparagraph, the Administrator shall promulgate
guidelines to assist stationary sources in the prepa-
ration of risk management plans. The guidelines
shall, to the extent practicable, include model risk
management plans.
(iii) The owner or operator of each stationary
source covered by clause (ii) shall register a risk
management plan prepared under this subpara-
graph with the Administrator before the effective
date of regulations under clause (i) in such form
and manner as the Administrator shall, by rule,
require. Plans prepared pursuant to this subpara-
graph shall also be submitted to the Chemical
Safety and Hazard Investigation Board, to the State
in which the stationary source is located, and to
any Iocal agency or entity having responsibility for
planning for or responding to accidental releases
which may occur at such source, and shall be avail-
able to the public under section 7414(c) of this title.
The Administrator shall establish, by rule, an
auditing system to regularly review and, if neces-
sary, require revision in risk management plans to
assure that the plans comply with this subpara-
graph. Each such plan shall be updated periodical-
ly as required by the Administrator, by rule.
(C) Any regulations promulgated pursuant to this
subsection shall to the maximum extent practica-
ble, consistent with the subsection, be consistent
with the recommendations and standards estab-
lished by the American Society of Mechanical
Engineers (ASME), the American National
Standards Institute (ANSI) or the American Society
of Testing Materials (ASTM). The Administrator
shall take into consideration the concerns of small
business in promulgating regulations under this
subsection.
(D) In carrying out the authority of this paragraph,
the Administrator shall consult with the Secretary
of Labor and the Secretary of Transportation and
shall coordinate any requirements under this para-
graph with any requirements established for com

4 CAA s. I I L(r) Excerpts
WWI
May 1996
MIMI
parable purposes by the Occupational Safety and
Health Administration or the Department of
Transportation. Nothing in this subsection shall be
interpreted, construed or applied to impose
requirements affecting, or to grant the
Administrator, the Chemical Safety and Hazard
'— Investigation Board, or any other agency any
authority to regulate (including requirements for
hazard assessment), the accidental release of
. , radionuclides arising from the construction and
operation of facilities licensed by the Nuclear
Regulatory Commission.
. , (E) After the effective date of any regulation or
requirement imposed under this subsection, it shall
be unlawful for any person to operate any station-
ary source subject to such regulation or require-
-
ment in violation of such regulation or require-
ment. Each regulation or requirement under this
subsection shall for purposes of sections 7413, 7414,
um 7416, 7420, 7604, and 7607 of this title and other
enforcement provisions of this chapter, be treated
as a standard in effect under subsection (d) of this
▪ section.
(F) Notwithstanding the provisions of subchapter
V of this chapter or this section, no stationary
.. source shall be required to apply for, or operate
pursuant to, a permit issued under such subchap-
ter solely because such source is subject to regula-
tions or requirements under this subsection.
me
(G) In exercising any authority under this subsec-
tion, the Administrator shall not, for purposes of
section 653(b)(1) of Title 29, be deemed to be exer-
cising statutory authority to prescribe or enforce
standards or regulations affecting occupational
safety and health.
(9) Order Authority
(A) In addition to any other action taken, when the
Administrator determines that there may be an
•. imminent and substantial endangerment to the
human health or welfare or the environment
because of an actual or threatened accidental
release of a regulated substance, the Administrator
may secure such relief as may be necessary to abate
such danger or threat, and the district court of the
United States in the district in which the threat
▪ occurs shall have jurisdiction to grant such relief as
the public interest and the equities of the case may
require. The Administrator may also, after notice
to the State in which the stationary source is locat-
ed, take other action under this paragraph includ-
ing, but not limited to, issuing such orders as may
be necessary to protect human health. The
Administrator shall take action under section 7603
of the title rather than this paragraph whenever the
authority of such section is adequate to protect
human health and the environment.
(B) Orders issued pursuant to this paragraph may
be enforced in an action brought in the appropriate
United States district court as if the order were
issued under section 7603 of this title.
(C) Within 180 days after enactment of the Clean
Air Act Amendments of 1990, the Administrator
shall publish guidance for using the order authori-
ties established by this paragraph. Such guidance
shall provide for the coordinated use of the author-
ities of this paragraph with other emergency pow-
ers authorized by section 9606 of this title, sections
311(c), 308, 309 and 504(a) of the Federal Water
Pollution Control Act, sections 3007, 3008, 3013,
and 7003 of the Solid Waste Disposal Act, section
1445 and 1431 of the Safe Drinking Water Act, sec-
tion 5 and 7 of the Toxic Substances Control Act,
and section 7413, 7414, and 7603 of this title.
FOR MORE INFORMATION...
CONTACT THE EMERGENCY PLANNING AND
COMMUNITY RIGHT -TO -KNOW HOTLINE
[phone] OR [phone]
TDD [phone]
MONDAY-FRIDAY, 9 AM TO 6 PM, EASTERN TIME
♦•♦
VISIT TIIE CEPPO HOME PAGE ON TIIE WORLD
WIDE WEB AT:
http://www.epa.gov/swercepp/
Chemical Emergency Preparedness and Prevention Office

Threshold Quantities of Compounds Under EPA Risk Management Program'
"1" Pollutant •
ran
Threshold Pollutant
(Ibs)
Threshold
(Ibs)
1,1-Dimethylhydrazine (Hydrazine, 1,1-dimethyl-]
1,3-Butadienc
1,3-Pentadiene
1-Butene
1-Chloropropylene (1-Propene, 1-chloro-]
1-Pentene
2,2-Dimethylpropane [Propane, 2,2-dimethyl-]
2-Butene
2-Butene-cis
2-Butene-trans (2-Butene, (E)]
2-Chloropropylene (1-Propene, 2-chloro-]
2-Methyl-l-butene
Fan 2-Methylpropene (1-Propene, 2-methyl-]
2-Pentene, (E)- -
2-Pentene, (Z)-
rm 3-Methyl-l-butene
Acetaldehyde
Acetylene (Ethyne]
1.9 Acrolein (2-Propenal)
Acrylonitrde (2-Propenenitrile]
Acrylyl chloride (2-Propenoyl chloride]
Allyl alcohol (2-Propen-l-ol]
ram
Allylarnine (2-Propen-l-amine]
Ammonia (anhydrous)
Ammonia (conc 20% or greater)
Arsenous trichloride
Arsine
Boron trichloride (Borane, trichloro-]
Boron trifluoride (Borgne, trifluoro-]
Boron trifluoride compound w/methyl ether (1:1)
Brom inc
Bromotrifluorethylene (Ethene, bromotrifluoro-]
Butane
Butene
Carbon disulfide
Carbon oxysulfide (Carbon oxide sulfide (COS)]
Chlorine
Chlorine dioxide (Chlorine oxide (C102)]
Chlorine monoxide (Chlorine oxide]
Chloroform (Methane, trichloro-]
Chlorom ethyl ether (Methane, oxybis[chloro-]
Chlorom ethyl methyl ether (Methane, chloromethoxy-]
Crotonaldehyde (2-Butenal) •-
15,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
5,000
20,000
5,000
15,000
10,000
10,000
20,000
15,000
1,000
5,000
5,000
15,000
10,000
10,000
10,000
10,000
• 20,000
10,000
2,500
1,000
10,000
20,000
1,000
5,000
20,000
Cyclopropane
Diborane
Dichlorosfane (Slane, dichloro-]
Difluoroethane [Ethane, 1,1-difluoro-]
Dimethylamine (Methanamine, N-methyl-]
Dimethyldichlorosilane [Slane, dichlorodimethyl-]
Epichlorohydrin (Oxirane, (chloromethyl)-j
Ethane
Ethyl acetylene (1-Butyne]
Ethyl chloride (Ethane, chloro-]
Ethyl ether [Ethane, 1, 1'-oxybis-]
Ethyl mercaptan [Ethanethiol]
Ethyl nitrite [Nitrous acid, ethyl ester]
Ethylamine (Ethanamine]
Ethylene [Ethane]
Ethylene oxide (Oxirane)
Ethylenediamine (1,2-Ethanediaminej
Ethyleneimine (Aziridine]
Fluorine
Formaldehyde (solution)
Furan
Hydrazine
Hydrochloric acid (conc 30% or greater)
Hydrocyanic acid
Hydrogen
Hydrogen chloride (anhydrous) (Hydrochloric acid]
Hydrogen fluoride/Hydrofluoric acid
(cone 50% or greater)
Hydrogen selenide
Hydrogen sulfide
Iron, pentacarbonyl- (Iron carbonyl
(Fe(CO)5), (TB-5-11)-]
Isobutane[Propane, 2-methyl]
Isobutyronitrlle [Propanenitrile, 2-methyl-]
Isopentanc (Butane, 2-methyl-]
Isoprene (1,3-Butadiene, 2-methyl-]
Isopropyl chloride [Propane, 2-chloro-]
Isopropyl chloroformate (Carbonochloridic acid,
1-methylethyl ester]
Isopropylamine (2-Propanamine]
Methacrylonitrile (2-Propenenitrile, 2-methyI-]
Methane
Methyl chloride [Methane, chloro-]
Methyl chloroformate
(Carbonochloridic acid, methylescer]
Methyl ether [Methane, oxybis-]
Methyl formate [Formic acid, methyl ester]
10,000 • ..
2,500
10,000
10,000
10,000
5,000
20,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
20,000
10,000
1,000
15,000
5,000
15,000
15,000
2,500
10,000
5,000
1,000
500
10,000
2,500
10,000
20,000
10,000
10,000
10,000
15,000
10,000
10,000
10,000
10,000
5,000
10,000
10,000
t From Federal Register List 59 FR 4478.

4
Threshold Quantities of Compounds Under EPA Risk Management.Program' (continued)
rum
Mel
Pollutant
Threshold Pollutant
(Ibs)
Crotonaldehyde, (E)- (2-Butenal, (E)-)
Cyanogen (Ethanedinitrile]
Cyanogen chloride
Cyclohexyla,mine (Cyclohexanamine]
Methylamine (Methanamine]
Methyltrichlorosilane (Shane, crichloromethyl-]
Nickel carbonyl
Nitric acid (cone 80% or greater)
Nitric oxide (Nitrogen oxide (NO)]
Oleum (Fuming Sulfuric acid) (Sulfuric acid,
mixture with sulfur trioxide]
Pentane
Peracetic acid (Ethaneperoxoic acid]
Perchloromethylmercaptan
(Methanesulfenyl chloride, trichloro-]
Phosgene (Carbonic dichloride)
Phosphine
Phosphorus oxychloride (Phosphoryl chloride]
Phosphorus trichloride (Phosphorous trichloride]
i Piperidine
Propadiene (1,2-Propadiene]
Propane
Propionitrile (Propanenitrile)
Propyi chloroformate
(Carbonochloridic acid, propylescer]
min Propylene (I -Propene]
Propylene oxide (Oxirane, methyl-)
Propyleneirnine (Aziridine, 2-methyl-]
Propyne (L-Propyne)
Shane
PEI
PER
20,000
10,000
10,000
15.000
10,000
5,000
1,000
15,000
10,000
10,000
10,000
10,000
10,000
500
5,000
5,000
15,000
15,000
10,000
10,000
10,000
15,000
10,000
10,000
10,000
10,000
10,000
Methyl hydrazine (Hydrazine, methyl-)
Methyl isocyanate (Methane, isocyanato-]
Methyl meraptan (Methanethiol]
Methyl thiocyanate (Thiocyank acid, methyl ester]
Sulfur dioxide (anhydrous)
Sulfur tetrafluoride (Sulfur fluoride (SF4), (T-4)-]
Sulfur trioxide
Tetrafuoroethylene (Ethene, tetrafluoro)
Tetramethyllcad (Plumbane, tetramethyl-]
Tetramethylsiiane (Shane, tetrarnethyl-)
Tetranitromethane (Methane, tetranitro-]
Titanium tetrachloride
(Titanium chloride (TiCI4) (T-4)-)
Toluene 2,4-diisccpnate (Benzene,
2,4-diisocyanato-l-methyl-)1
Toluene 2,6-diisocyanace (Benzene,
1,3-di socyanato-2-methyl-]1
Toluene dusocyanate (unspecified isomer)
(Benzene, l,3-diisocyanatomethyl-]
Trichlorosilane (Slane, trichloro-]
a ifluorochlotoethylene (Ethene, chlorotrifluoro-]
Trirnethylamine (Methanamine, N,N-dimechyl-]
Trirnedtylchlorosilane (Silane, chlorotrimethyl-)
Vinyl acetate monomer (Acetic acid ethenyl ester]
Vinyl acetylene (I-Buten-3-yne]
Vinyl chloride (Ed ene, chloro-)
Vinyl ethyl ether (Echene, ethoxy-)
Vinyl fluoride (Ethene, fluoro-)
Vinyl methyl ether (Ethene, methoxy-]
Vinylidene chloride (Ethene, 1,1-dichloro-]
Vinylidene fluoride (Ethene, 1,1-difIuoro-]
Program 3 Source industrial Classification (SIC) Codes2
SIC Code
2611
2812
2819
2821
2865
2369
2373
2379
2911
Industrial Process Description
Pulp Mills
Alkali and Chlorine Manufacturing
Industrial Inorganic Chemicals Manufacturing
Plastic Materials and Resins Manufacturing
Cyclic Crudes and intermediates Manufacturing
Industrial Organic Chemicals Manufacturing
Nitrogenous Fertaizer Manufacturing
Agricultural Chemicals Manufacturing
Petroleum Refining
Thresho.
(Ibs)
15,000
10,000
10,000
20,000
5,000
2,500
10,000
10,000
10,000
10,000
10,000
2,500
10,000
10,000
10,000
10,000
10,000
10,000
10,000
15,000
10,000
10,000
10,000
10,000
10,00C
10,000
10,00C
' From Federal Register List 61 FR 31717.

APPENDIX D CATASTROPHIC L
SCENARIO DESCRIPTIONS

69:ZT Q3,H 86/Z0/60
(LLC9 ON Xh/XZ]
0
7 • Stability Class B
(1)
Morning Morning - Clear, Low Winds
0 Y Axis Distance in Feet
17.
n
Dart shading Concecaration Excmds 25 ppm
0 Light shading Ccmoectration Exceeds 10 ppm
Scenario Description:
a. A 1-on cylinder is struck and its liquid valve is sheared off. Liquid
chlorine is released from a 3/8-inch hole.
b. The container is full 2,000 pounds C12.
c. The valve body has a 3/8-inch hole.
d. Release height is 3 feet. The container is on a concrete slab.
1
1 1 1 1 1 i 1 1 1
1
1 1
1 1
1 1 1
1
1
1 1
1 1
1 1
1 1
1 i 1
1 1
1 1
11 11�
340•
O.
...
mo•+--�i
aR :¢
v x$=a=s
,Y. " . 71'.xS).,
' `
_
' ; J'K
1 1 1 1 1 1) 1 i
1
1 1
11
11 1
1, 1
1 1
1 1
1 1
11111
.w
11
1 1
1 1•
AI f•fL•
0.
6000.
DISTANCE (FEET)
•
Stability Class D
All other Conditions
art
x Y-Axis Distance in Feet
0
1
O f-j
3
part shading Concentration Exooabs 25 ppm
Light shading Cassoraar oo Exceeb 10 ppm
680
L
r,11 ,1 i •
-
- 340.
x
ti, Sri.•'•.. -
n•`
.
{ t �:5, ,�}tip, •-.
r
1IJIlllljl
_
11J111111 111111111_ t11111111
_-
0.
haw.
12000.
DISTANCE (FEET)
Stability Class F
Nighttime - Mostly Clear Skies, Low Winds
Q Y Axis Distance in Feet
0
Dut shading
ng
Light shading
C000mtrtrion Exceeds 25 ppm
Cooamlrstim Exceeds 10 ppm
11 1 i i i 1 1 1 I i 1 1 I i l i i i l I I 11 1 1 1 1 1 1 1 1 1 1 i e 1 i
II 680.
r> > , •..� Sao
•
r•�.�'•s. atz -2}q%: tiRj%?tyt v`t;•
r� rr.;,''' • —:�. ,�RV ?...�r••r:, ^ajt:t '..
• Q���
:Y-', �`,.-'.• -ttc l dy "“Zt.:,i•, r; •.1slit;L;. =
— k~�fT•:•7qz• %a�xH:. 7`::xi§�: X. t3E e
l i 34a•w--=
x3Dx
i
1 1 1 1 1 1 1 1 1 i i l i l l l l l l l l l l i l l l 1 1 1 1 1 1 1.680.--.,
0. 6000. 12000. 18000. 24000.
DISTANCE (FEET)
cT
1'
c
1:
t
1
r•

69:ZT (MA 86/Z0/60
800 Ej [LLC9 ON 121/XZ
Scenario Description:
a. Half -inch, type-K copper tubing is sheared off. Chlorine gas is
released (modeled with infinite supply).
b. Release height is 3 feet.
(� Stability Class B
Morning _ Clear, Low Winds
Y-Axis Distance in Feet
7
0
N
a)
Dnk shading CAocestrasiao Exceeds 25 ppm
Light shading C000tensticn Exceeds 10 ppm
1 1 1 1 1 1 1 1
111111111
ftiili111
FEIN
WEB
"11111 1111i'
160.
•
WNW
11.1
0.
1 1 I 1 1 1 1 1 1
111111111.
IU00.
111111111
2000.
DISTANCE (FEET)
80.
-80:
-160.
1 11.11 1 111
3000.
4000.
B '� Stability Class D
3 Alt other Conditions
to Q Y-Axis Distance in Fat
? x
8C)
n
g
to
D n shaft
Licht thaw
Conne nation Exceeds 25 ppm
Ca oeatrstion Exceeds 10 ppm
Stability Class F
Nighttime - Mostly Clear Skies, Low Winds
Y Axis Distance is Feet
Ds k shading
litbi
s6sdi�
Concentration Exceeds 23 ppm
Ceoeatta600 Excoofb 10 ppm
l i 1 1 1 1 i I 1 I l till 1 1 11 it tilt 1 1 1
NINO
C
111111111
1111111111111111111
1000.
2000.
DISTANCE (FEET)
1111111+1
160.—�
80.--
1
-80.
160.
._11 1 1 1 1 1 1 1
3000.
4000.
1 1 1 1 _
4000.
:`?
C
U
•
G
•
0
U

1 1 1
•
(EA 86/ZO/60
[LLC9 ON XdI/XI]
0
3
a .0
46 3
3
0
W
r
1
Scenario Description
a. A 1-inch, schedule-80 pipe is sheared off. Chlorine gas is
released (modeled with infinite supply).
b. Release height is 3 feet.
Stability Class B
Morning - Clear. Low Winds
• Y-Axis Distance in Feet
Dort sliding
ld stud
Coocentrmico pxr odds 25 ppm
Ccumeatratioa Exceeds 10 ppm
YON
1 1 1 1 1 1 1 1 1 I 1 1 1 1 1 i 1 1 1 l
'tit till I
11111i111
320.
x by
111111111 111111111
0. 2000. 4000.
DISTANCE (FEET)
111111111
160.
•
OEM
-160.
•320.
111111111
6000. 8000.
Stability Class D
All other Conditions
Y Axis Distance in Feet
Dolt abaft
Lied shodieg
Coot mosian Exceeds 25 ppm
Commotion Exceeds 10 ppm
1iii11111
iil lrlill'1111111i1‘
i l Iliil3f
20.—i
`
,
IIIIII1.12`�y
8000.
IM
111111111
1 1I III I I I
111111111_
6000.
n 2000. 4000.
DISTANCE (FEET)
Stability Class F
Nighttime - Mostly Clear Skies, Low Winds
Y-Axis Distance in Feet
Dui shoring
Wit shbill
Comentrnfico Exceeds 25 ppm
Cooeaocnbao Exceeds 10 ppm
11141i1I1i111111111111111111
4000.
DISTANCE (FEET)
I t 1 1 1 1 1 1 i 1 1
320.
-320.
8000.
assaI

65:ZT UM 96/Z0/60
(LLE9 ON XH/Xl)
w.
so
8 13
0
70
0�
O X.
3 0
v
�-A
C
ZT
to
Soamrio Description
a. Half-incb, type -IC copper tubing is sheared off. Liquid chlorine is
released (modeled with infinite supply).
b. Release height is 3 feet.
Stability Class B
Morning - Clear, LOW Winds
Y-Axis Distance in Feet
Datk iodine
Veit labdict
Caocca tsioo Eiseeds 25..
Caoccu raoco Eucoods lappet
1 1
1 1 1 1
1 1
1 1 1 1 1
1 1
1 1 1:
1 1 1 1
1 1
1 1
1
1111111
Vic.
.0.. 4.
k .
3,/,,0„,..,.:.s.
11
1 1 1 1
1 1
1
11 1 1
1 1
1 1 l
t 1 1 1
1 1
1 1
1_
1
1 1 1 1 1 1
0.
2500.
5000.
7500.
DISTANCE (FEET)
10000.
Stability pass D
All other Conditions
Y Axis Distance in Feet
Dart kaki
Liibt abldbe
Coeoad*atiaio Weeds Xi rpm
Gaoccustias Exceeds 10 *pm
I I I 1 1 1 1 1 1 l 1 1 1 1 1 1 f l i`
mmilr
,r.
11Tti1i11
S00.
9.
111111 11111.1
2500.
1111111 1111111_1 1,_l1
5000. 7500.
DISTANCE (FEET)
O••
•
1111111
10000.
Stability Class F
Nighttime - Mostly Clear Skies. Law winds
Y•Axis Distance in Fed
tht iodic(
Comotritioa Exceeds u»
Com ore= Bute& 10 ppm
2500.
So®.
DISTANCE (FEET)
1/
c
.n
0
2
c
c
c
1,
c

l 1 1 1 t1 1 1 1 1 1 1 1 1 1
6S:ZT Q3M 86/Z0/60
[LL£9 ON X3/XL]
r
so
a
O
2.?;
8 2
lD
ox
3 n
—Ui
5
A
to
K.
1Q
Q
Scenario Description:
a. A 1-inch, schedule-80 pipe is sheared off. Liquid chlorine is
released (modeled with infinite supply).
b. Release height is 3 feet.
Stability Class B
Morning - Clear, Low Winds
Y Adis Distance in Feet
Did ihadia
C ic1s sit
r
Cooccatrtiea Eacccas 10 ppm
Stability Class D
All other Conditions
Y Axis Distance in Feet
Dirt shading
L% & dig
Cooemtratian Eacaeds 2.5 pro
Sao ExaoeEs 10 ppca
11111 rl 11j11111 1 11 f
111111111�
111111111
760:
.: ;_
v,.•+'till
N. • $:•• i
_
1 1 1 1 1 1 1 11 1 1 1 1 1 1 1 1 1 1
1 1 1 t 1 1 1 1 1
1 1 1 1 1 1 1 t i
l
O.
5000.
100 0.
DISTANCE (FEET)
•
Stability Class F
Nighttime - Mostly Clear Skies, Low Winds
Y Axis Distance in Feet
Deit*
ibadig
000trstioo Exceeds 23 ppa
Ccocmwic* Eueeas 10 ppm
111
760.
380..
t.
. x.,y , ; - r s:•.Sr`+ a % 110011i ..wi, ..w•
xG • ii •9C:w 4E$ 4 ? w .� ��4rgu� g£ggXt A� jj. qX•t'','
= ^^n iiulivL JYw. 7GwZ�`:vww vv v 60. �
l 1 1 t I l 11 1 I 1 I 1 1 I 1 l t I1 l 1 1 1 1 t 1 t t 1 1 1 1 1 1 1 .-t371 I
0. 5000. 10000. 15000. 20000.
DISTANCE (FEET)

1
Table 2. Summary of Dispersion Distances and Downwind Concentrations
for Chlorine Release Scenarios
Scenario
Stability Class B
Stability Class D
Stability Class F
Description
Distance in
Distance in
Distance in
feet and miles
feet and miles
feet and miles
.
25 ppm
10 ppm
25 ppm
10 ppm
25 ppm
10 ppm
1) 1-ton cylinder
Is struck and the
valve is sheared
3,600
5,400
5,400
9,600
10,800
18,000
off. Liquid
chlorine Is
released from a
0.7
1.0
1.0
1.8
2.0
3.4
3/8 inch hole.
1-
2) Half -Inch
copper tubing Is
sheared off.
800
1,200
1,200
2,100
1,800
3,300
Chlorine gas is
0.2
0.2
0.2
0.4
0.3
0.6
released
(modeled with
_
Infinite supply).
3) A 1-inch pipe is
sheared off.
chlorine gas is
1,600
2,800
2,600
4,400
4,200
7,400
released
(modeled with
infinite supply).
0.3
0.5
0.5
0.8
0.8
1.4
4) Half -inch
copper tubing is
sheared off.
2,000
3,750
3,000
5,500
5,250
9,250
Liquid chlorine Is
released
(modeled with
infinite supply).
0.4
0.7
0.6
1.0
1.0
1.8
5) A 1-inch pipe Is
sheared off.
Liquid chlorine is
4,000
7,000
7,000
7,000
11,000
18,500
released
(modeled with
infinite supply),
0.8
1.3
1.3
1.3
2.0
3.5
•
Isopleths, indicating the plume of the chlorine from the release point Is
shown in Appendix C.
09/02/98 WED 12:59 [TX/RX NO 6377] Q]007

Appendix E
Area Location of Metropolitan Sewerage District
During a release under Stability Class B, the chlorine concentration can reach
a concentration of greater than 10 ppm at a distance of approximately one mile.
During a release under Stability Class F, the chlorine concentration can reach
a concentralon of greater than 25 ppm at a distance of approximately two miles.
(Predominant wind direction is from North to South)
09/02/98 WED 12:59 (TX/RX NO 6377] 0008