Kurt Keene Water Treatment Plant - Executive Summary

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Section 1    Executive Summary  
The Madison Water & Wastewater Board has developed a Risk Management Plan (RMPlan) for the Kurt Keene Water Treatment Plant in an effort to protect human health, to protect the environment and meet applicable federal regulations.  This plant is operated by the Madison Water & Wastewater Board and has a capacity to process 4 million gallons of drinking water per day.  Currently, the plant is treating approximately 1.5 million gallons per day.  It is located in Section 5, Township 4 North, Range 2 West.  The plant is located at 590 Gillespie Road, Madison, Madison County, Alabama. 
This RMPlan has been developed to meet the standards published in the 40 Code of Federal Register (CFR) part 68.  The EPA to cover the accidental release prevention provision under the Clean Air Act '112(r)(7) promulgated these regulations.  These require facilities that exceed the cited threshold quantities for certain chemicals to develop a RMPlan.  The goal of a RMPlan is to f 
ocus on reducing the risk of accidental releases of certain chemicals; thereby, preventing harm to employees as well as potentially catastrophic impacts on the public.  Over 60 accidental releases of regulated chemicals at water treatment plants (WTP's) and wastewater treatment facilities in the United States were reported between 1986 and 1995.  
Chlorine is currently used in the water treatment process at this facility and the quantity stored on site exceeds the 2,500-pound threshold for coverage under the RMP Program.  Currently, the maximum potential amount of chlorine to be present on site at any one time is 4,000 pounds.  Chlorine is stored at the site in one ton cylinders, and although there is potential for 4,000 pounds to be present on the site at any one time, typically, at least one of the cylinders is empty.  Typically, less than 2,000 pounds is on site.  Except during delivery, all of the chlorine is stored within an enclosed building. 
In order to illustrate the areas tha 
t could be impacted from a release of the chemicals into the atmosphere, a hazard analyses was conducted to determine the offsite consequences.  Two analyses were performed in order to estimate the offsite consequences from two release scenarios.  The first release scenario is the case defined by the Environmental Protection Agency (EPA) as the "worst case" scenario.  This scenario assumes that the largest vessel is full and it releases the entire contents of the containers during a ten-minute period.  The second scenario (or alternative scenario) is based on a situation more likely to occur which will cause a release of chemicals at the facility.  The radius of impact was determined based on the guidance provided in Chapter 4: "Offsite Consequence Analysis" of the General Guidance for Risk Management Programs dated October 27, 1998 and the Compliance Guidance and Model Risk management Program for Water Treatment Plants.  The distance to the end point concentration was determined with  
the aide of the Computer Program Aerial Locations of Hazardous Atmospheres, version 5.2.1 (ALOHA).  The National Safety Council developed this program for emergency planners.  ALOHA works in conjunction with the Computer-Aided Management of Emergency Operations (CAMEO) database and Mapping Operation for Response, Planning and Local Operational Task (MARPLOT) program. 
In all release scenarios, the toxic end point concentration remained the same.  The toxic end point for chlorine is three parts per million (ppm) or 0.0087 milligrams per liter (mg/l) which is the endpoint concentration published in the CFR Part 68.  The American Industrial Hygiene Association (AIHA) has listed these concentrations as the "maximum airborne concentration", at which nearly all individuals could be exposed to for up to one hour without experiencing or developing life threatening health effects.  This level is referred to as the Emergency Response Planning Guideline (ERPG-2) concentration.  Results of the haz 
ard analyses for the EPA "worst case" scenario led to an area defined by a 2.6-mile radius for chlorine.  This 2.6-mile radius encompasses 21.36 square miles and includes a population of approximately 5,300 people (according to 1990 census data).  The alternative off-site consequence analysis yields significantly smaller areas.  The off-site analysis for chlorine indicates a 0.60-mile radius to the end point concentration.  Based on the 1990 census data from the Landview III Program, the estimated population inside the area is 500.  
The key to a successful risk management program is to first define hazard, risk and undertake a comprehensive approach to prevention.  The Center for Chemical Process Safety has defined hazard as: 
A chemical or physical condition that has the potential for causing damage to people, property or the environment  
Once hazards are identified on the site, then, an evaluation of the risk involved will lead to a systematic identification, evaluation, and contro 
l of potential losses that may arise in operation from future events such as fires, explosions, or toxic chemical releases.  Currently, the Kurt Keene Water Treatment Plant is operating in accordance with the procedures outlined in the plant's Operation and Maintenance Manual.  The manual sets forth inspections and maintenance requirements of the equipment.  Throughout this RMPlan, the emergency readiness procedures and regular training schedules are emphasized.  One of the goals of implementing these procedures and schedules is to minimize the chance of a release occurring.  If the plant employees practice preventative maintenance and are well trained in emergency procedures, if a release occurs, they will be successful in preventing and minimizing personnel injury. 
All employees of the Water Works are required to know the locations of the emergency telephone numbers and names of individuals to contact in case of a release.  If an emergency occurs, each employee will have an assigned 
task.  This risk management plan enhances the standard operating procedures because it provides a clear checklist that identifies predetermined individuals and agencies that require notification and coordination in case of an emergency.  This RMPlan details which individuals will respond to the release to contain it and it outlines the agencies that will be responsible for evacuating the appropriate areas, and for sounding the "all clear" once the leak is contained.  The plan also includes procedures for the periodic review of readiness. 
The Kurt Keene Water Treatment Plant has been operational since February 1999 and to date, there have not been any major or minor reported releases from this facility.  One of the goals of this Risk Management Plan is to maintain the plant's current high level of safety and safety record. 
This plan includes the following sections: 
7 Program requirements 
7 Hazard Assessment 
7 Emergency Response Plan 
7 Prevention Plan 
7 Audit Schedules 
Material Safet 
y Data Sheets (MSDS), Tier 2 reports, employee training certificates and release confirmation and report forms will be maintained as part of this document.
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