K.T. Hutchinson Water Treatment Plant - Executive Summary

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(a) Accidental Release Prevention Policy: 
         The management and employees of this facility are very aware of the consequences of an  
     accidental release.  Accidental release prevention is, therefore, a matter of high priorty for all   
     personnel involved in the handling, operation and maintenance of the chlorine process system and all  
     of its components.   
 Emergency Response Policy: 
         The importance of immediately responding to an emergency due to an accidental release can not be 
     over-emphasized.  Failure to follow the plant emergency action plan promptly could result in major  
     environmental damage and loss of human life.  It is therefore imperative that all personnel, including  
     management, be trained regularly on the plant emergency action plan and to ensure that it's initiation be 
     possible any time the plant is operated. 
(b)Stationary Source:  
                  K.Thomas Hutchinson Water Treatment Facility 
5592 Central Valley Road 
                  Murfreesboro, Tn. 37129 
Regulated Substance: Chlorine Gas:   
       CAS No.  7782-50-5                Maximum Inventory: 10,000 pounds 
(c) Worse Case Release Scenario:   
          Worse case release could occur during the acceptance of delivery of full containers from the  
    vendor.  Chlorine is shipped to the facility in 1 ton containers and are delivered by truck outside the  
    chlorine storage room.  In the event that a container is dropped and  a vessel rupture results, the  
    chlorine gas would escape to the atmosphere with no containment available. This scenario predicts that  
    the entire vessel (2000 pounds) would be released within 10 minutes.   Plant employees are required to  
    inspect the containers prior to acceptance for the following:  
                     i)  Labeling and inspection markings as required by D.O.T.   
                    ii)  Signs of corrosion, leakage or general lack of container maintenanc 
    In addition, operators are required to perform a checklist inspection of the container lifting hoist  every 
    time it is used. 
   This scenario estimates an End Point Distance of 3.07 miles.  The estimated population is 6100 persons. 
  Alternate Scenario:  
            The most likely cause of an accidental release is a piping rupture.  The most vulnerable spot for a  
  piping rupture is the flexible connection used to connect the 1 ton containers to the process system.         
  estimated release, based on container valve size and chlorine vapor/pressure characteristics, is 317 lbs 
  in 60 minutes. (Chlorine detectors located in the area should provide enough warning to operators to 
  isolate the containers from the flexible line within 1 hour.)   In order to minimize the probability of the 
 occurrence of this scenario, the flexible lines are tested for leaks each time a container is changed out 
 and are replaced annually as a minimum.  The containers are locate 
d within the facility when they are 
 being used, therefore, in the event of such a release, employees are trained not to turn on the ventilation 
 system, thus minimizing the rate of release to the atmosphere. 
(d) General description of release prevention: 
            The release prevention program focuses primarily on the proper techniques of container handling, 
   storage and operation and process system operation and maintenance.  Operators involved in the  
   handling, storage and operation of the containers are required to attend training on the proper  
   techniques and the consequences of deviating from those techniques and must be authorized by the 
   plant manager as chlorine handlers.  Prior to plant certification, operators are required to train on the  
   process system operation, its components and the maximum and minimum parameters as well as the  
   consequences of deviating from the operating procedures or parameters.  Most of the maintenance 
of the process system (including the container hoist) have been contracted to vendors 
   certified to perform the maintenance by the manufacturer.  Maintenance performed by plant operators is 
   minimized, and requires little or no system invasion.  At any time the system must be opened, whether by 
   operator or contractor, the plant lock-out/ tag-out program requirements must be observed. 
(e)  Five-Year accident history:  
          There have been NO accidents related to the chlorine process in the history of the facility. (Built in 1978). 
(f)  General description of the emergency response program:  
          In the event that an operator receives any indication of a release, the operator is required to 
  perform an emergency shutdown of the plant.  If the release is small and isolable, the operator will  
  isolate it.  The operator will then initiate the plant emergency action plan which includes notification of the  
  plant manager, notification of local emergency respo 
nse agencies and evacuation of all personnel within  
  the facility. 
(g)  Planned changes for improved safety:  
                  1)  Installation of remote operators for container isolation valves. 
                  2)  Installation of cellular phone programmed to automatically initiate emergency action plan   
                  3)  Installation of switch on access doors to provide automatic operation of ventilation system 
                       upon chlorine room entry.  
                  4)  Purchase of hand-held chlorine detector with digital readout.
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