Caqon City Water Treatment Plant - Executive Summary

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Executive Summary 
 
1.   Accidental release prevention and Emergency Response policies  
 
We at Caqon City Water Treatment Plant are committed to employee, public and  
environmental safety.  This commitment is demonstrated by our comprehensive 
accidental release prevention program that covers areas such as design,  
installation, operating procedures, maintenance, and employee training  
associated with the processes at our facility.  It is our policy to implement  
appropriate controls to prevent possible releases of regulated substances.   
Unforeseeably, if such a release does occur, our highly trained emergency  
response personnel are at hand to control and mitigate the effects of the release.  
We are also completely coordinated with Caqon City Fire Protection District 
which provides additional emergency response expertise. 
 
2.  The Stationary Source and the Regulated Substances Handled 
We have 1 regulated substance present at our facility which is Chlorine. 
 
The maximum inventory of C 
hlorine at our facility is 6000 lbs. 
 
 
3.  The Worst Case Release Scenario and the Alternative Release Scenario,  
including administrative controls and mitigation measures to limit the  
distances for each reported scenario 
 
To perform the required offsite consequence analysis for our facility, we 
have used the look-up tables and equations provided by the EPA in the RMP  
Offsite Consequence Analysis Guidance. The following paragraphs provide  
details of the chosen scenarios. 
 
Toxic Worst-case analyses 
 
The Worst Case scenario involves a catastrophic release from Disinfection.   
The scenario involves the release of 2000 lb. of Chlorine in a gaseous form over  
10 minutes. The Release rate (lbs/min) is calculated to be 200. A distance to  
endpoint of 5.4 miles is obtained which affects  a residential population of 26577  
within this distance. 
 
 
Toxic Alternative-case analyses 
 
The Alternative Case scenario involves a catastrophic release from Disinfection.  
The scenario involves the rele 
ase of 0.6 lb. of Chlorine in a gaseous form. 
Active mitigation controls such as sprinkler and scrubbers are also taken into  
account to calculate the scenario. The Release rate (lbs/min) is calculated to be 
0.3 and a Distance to endpoint of 0.1 miles is obtained which affects  a  
residential population of 2.  
 
 
Flammables Worst-case analyses 
None applicable 
 
Flammables Alternative-case analyses 
None applicable 
 
4.  The General Accidental Release Prevention Program and the Chemical-Specific  
Prevention Steps 
 
Our facility has taken all the necessary steps to comply with the accidental release  
prevention requirements set out under 40 CFR part 68 of the EPA. Our facility is also  
subject to EPCRA Section 302 notification requirements. The following sections  
briefly describe the elements of the release prevention program that is in place at our  
stationary source. 
 
Process Safety Information 
Caqon City Water Treatment Plant maintains a detailed record of safety information 
that descri 
bes the chemical hazards, operating parameters and equipment designs  
sociated with all processes. 
 
Process Hazard Analysis 
Our facility conducts comprehensive studies to ensure that hazards associated with  
our processes are identified and controlled efficiently.  The methodology used to 
carry out these analyses is  the What-If/Checklist method.  The studies are  
undertaken by a team of qualified personnel with expertise in engineering and  
process operations and are revalidated periodically.  Any findings related to the  
hazard analysis are addressed in a timely manner. 
 
Operating Procedures 
For the purposes of safely conducting activities within our covered processes,  
Caqon City Water Treatment Plant maintains written operating procedures.  These  
procedures address various modes of operation such as initial startup, normal  
operations, temporary operations, emergency shutdown, emergency operations,  
normal shutdown and startup after a turnaround.  The information is regularly  
rev 
iewed and is readily accessible to operators involved in the processes. 
 
Training 
Caqon City Water Treatment Plant has a comprehensive training program in place  
to ensure that employees who are operating processes are competent in the  
operating procedures associated with these processes. New employees receive  
basic classroom training in process operations followed by on-the-job supervision 
until they are deemed competent to work independently. Refresher training is  
provided anually as needed. 
 
Mechanical Integrity 
Caqon City Water Treatment Plant carries out highly documented maintenance  
checks on process equipment to ensure proper operations.  Process equipment  
examined by these checks includes among others; pressure vessels, storage tanks, 
piping systems, relief and vent systems, emergency shutdown systems, controls  
and pumps.  Maintenance operations are carried out by qualified personnel with 
previous training in maintenance practices.  Furthermore, these personnel are  
offe 
red specialized training as needed.  Any equipment deficiencies identified 
by the maintenance checks are corrected in a safe and timely manner. 
 
Compliance Audits 
Caqon City Water Treatment Plant conducts audits on a regular basis to  
determine whether the provisions set out under the RMP rule are being  
implemented.  These audits are carried out at least every 3 years and any 
corrective actions required as a result of the audits are undertaken in a safe 
and prompt manner. 
 
Incident Investigation 
Caqon City Water Treatment Plant promptly investigates any incident that has  
resulted in, or could reasonably result in a catastrophic release of a regulated  
substance.  These investigations are undertaken to identify the situation leading  
to the incident as well as any corrective actions to prevent the release from  
reoccurring.  All reports are retained for a minimum of 5 years. 
 
Employee Participation 
Caqon City Water Treatment Plant truly believes that process safety management  
and ac 
cident prevention is a team effort.  Company employees are strongly  
encouraged to express their views concerning accident prevention issues and to 
recommend improvements.  In addition, our employees have access to all 
information created as part of the facility's implementation of the RMP rule, 
including information resulting from process hazard analyses in particular. 
 
 
5.  Five-year Accident History 
 
Caqon City Water Treatment Plant has had an excellent record of preventing  
accidental releases over the last 5 years. Due to our stringent release prevention  
policies, there has been no accidental release during this period. 
 
6.  Emergency Response Plan 
 
Caqon City Water Treatment Plant has its own written ER Plan. The ER Plan  
includes specific actions to be taken in response to accidental  releases of  
regulated substances. The ER Plan includes procedures for informing the  
public and local agencies for responding to accidental release.The ER Plan  
does not include information on em 
ergency health care. 
 
Date of most recent review/update of ER Plan: 4/27/99 
Date of most recent ER training of employees: 6/9/99 
 
The Local agency coordinating ER Plan is Caqon City Fire Protection  
District which has the phone number 719-275-8666 
 
7.  Planned Changes to Improve Safety 
Several developments and findings have resulted from the implementation  
of the various elements of our accidental release prevention program.
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