Osage Water Treatment Plant - Executive Summary

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General Facility Information 
The Osage Water Treatment Plant, located approximately two miles southeast of downtown Amarillo within the corporate limits, is the City of Amarillo's potable water treatment plant having a current treatment capacity of 40 million gallons of water per day (mgd).  The plant is presently subject to engineering design to accommodate a 30 million gallons per day plant expansion (to 70 mgd total) in the spring of 2001.  The plant operates 24 hours a day and is enclosed by a chain-link security fence.  Thirty employees work onsite at various times during the normal business day.  At night and during irregular work hours, one or two employees oversee plant operations.  An additional 15 employees work normal business hours on the treatment plant grounds at the City's separate Environmental Laboratory.  A maximum of 18 tons of chlorine gas (Cl2) in one ton containers is stored onsite, with eight containers being connect 
ed at any one time, four online and four on standby. 
Ongoing safety training programs cover all phases of plant operation from maintenance and operations safety to safe handling of chlorine.  The Osage facility also conducts formal training as well as onsite training during normal daily operations.  Due to this safety training, this plant has not had any significant incidents in its history. 
Hazard Assessment Information 
40 CFR Part 68, Subpart B - Hazard Assessment, outlines a specific set of criteria required to be used in the modeling of worst case and most probable case release scenarios.  Worst case and most probable case scenario modeling was completed using Areal Locations of Hazardous Atmospheres (ALOHA) software.  
To complete most probable case and worst case scenario plume models, the default level of concern for chlorine was set at levels established in EPA and American Industrial Hygiene Association guidance.  The resulting plume indicates a level where individuals would 
be able to take protective actions without suffering any serious health effects from a chemical exposure during a one hour or less period.  Most probable case and worst case scenario plume analysis results are conservative estimates based on the ALOHA software, using RMP release and meteorological requirements.  
The chlorination process at the Osage Water Treatment plant is conducted in an enclosed building, with an active chlorine scrubber system.  It should be noted that in the event of a chlorine release, the passive and active mitigation measures that are in place should be more than adequate to prevent any release of product to environment outside of the chlorination building.  Due to EPA regulations and software limitations these mitigative factors could not be considered in the plume models.   
Prevention Program Information 
The written Prevention Plan for the Osage Water Treatment Plant comprehensively deals with requirements of 40 CFR, part 68, sections 68.50 through 68.60.  
Safety data has been accumulated and made available to employees.  The training program has been developed, operations and maintenance SOP's are written and have been implemented.  The hazard review has been performed and suggestions resulting from it are being implemented.  The compliance audit, which will be an internal audit, is in written procedural form; ready to be utilized and incident investigation forms are in place.  All of the above elements of the Program 2 Prevention Program are kept in a unified binder format.  Continuing requirements of the program will be carried out on the schedules required by the Risk Management Program Rule. 
Emergency Response Information 
A controlled release of the chlorine product located on the water treatment plant site shall be defined as the escape of gas to the atmosphere in small, non-reportable quantities, resulting from standard operating procedures to connect or disconnect chlorine containers and standard maintenance procedures on the w 
ater treatment plant chlorine delivery system.  Minor leaks in the system that can be promptly repaired or shut-off shall also be considered a controlled release. 
An uncontrolled release of chlorine which will require the implementation of emergency response procedures is defined as any release other than those examples defined as similar to controlled releases.  Emergency responses to the treatment plant will be made by the Amarillo Fire Department, in accordance with the community emergency response plan and Annex Q.  If uncontrolled release conditions warrant such actions, shelter-in-place, evacuation and public warning will be implemented by the Amarillo/Potter/Randall Department of Emergency Management.  Any uncontrolled release of chlorine shall be subject to an after action incident investigation by the City of Amarillo, exclusive of State and Federal agency regulatory review and oversight.
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