K.T. Hutchinson Water Treatment Plant - Executive Summary
(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.
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.
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
(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.