City of El Dorado Water Treatment Facility - Executive Summary

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Release prevention and emergency response policies 
Personnel at this City of El Dorado (City) facility take a very active approach in maintaining and improving chemical safety.  This facility complies with industry-standard requirements for water treatment plants that use chlorine in ton containers.  The policy at this facility is to adhere to all applicable federal, state, and local laws.  If an emergency were to occur, the policy is to notify the City of El Dorado Fire Department and request that they respond to the emergency. 
Facility and regulated substance    
This facility is a water treatment plant located in the City of El Dorado, Kansas.  The facility employs a series of physical and chemical treatment operations that include: flocculation and sedimentation, disinfection, and final filtration  processes.  The covered process includes the storage and feed of chlorine for the chlorination of water.  Chlorine is the regulated substance 
The chlorine is stored in and fed from one- 
ton containers, which are delivered by truck.  The maximum intended inventory at the facility is 12,000 pounds. 
Worst-case and alternative release scenarios 
The worst-case release scenario involves the largest chlorine-containing vessel in the system, the ton container.  It can contain up to 2,000 pounds of chlorine.  The rule for worst-case release analysis assumes all of the contents are released in 10 minutes.  No mitigative measures were considered.   
The alternative release scenario was based on a methodical analysis of accident history, hazard review, experience at other similar company facilities, and industry experience.  The chosen alternative release scenario involves a break in the flexible tubing between the container and the manifold header or the tubing pulling loose accidentally. Because the release would be in the building where the ton containers are stored, an enclosure mitigation factor was considered.  No other mitigative measures were considered. 
For both analys 
es, the EPA's Risk Management Program Guidance for Wastewater Treatment Plants was used.  The results were verified using RMP*Comp, which is based on the formulae in the guidance document.  The distance to endpoint for the chlorine worst-case release is 1.3 miles and for the alternative release, the distance is 0.1 mile. 
Accidental release prevention program 
The facility's prevention program complies with the corresponding sections of EPA's 40 CFR part 68 accident prevention program rule for program level 2 processes and applicable state and local codes and regulations.  The chlorine system was designed, installed, and maintained in accordance with state and local laws.  To achieve and maintain this compliance, the City has in place procedural and technological safeguards.  The procedural safeguards include an employee training program and operating and maintenance procedures for those employees involved in operating the covered processes.  The technological safeguards include control 
s, sensors, alarms, relief valves, and industry standard systems.  All of these serve to prevent unintended releases of chlorine, or at least minimize the effects of a release. 
Five-year accident history 
This facility has not had an accident involving chlorine that caused deaths, injuries, property or environmental damage, evacuations, or shelterings in place. 
Emergency response program   
The facility has a written emergency action plan that is coordinated with local emergency responders.  The El Dorado Fire Department is the primary responder.  City employees handle incidental releases of chlorine and are trained and equipped to do so. 
The emergency action plan includes emergency situation identification, procedures for reporting emergencies, notifying the public, evacuation, system shutdown, communications directory, and a communications program flowchart.  The plan also addresses the interaction with both the police and fire departments.   
Planned changes to improve safety 
The m 
aintenance and improvement of safety is an ongoing job at this facility.  Safety training takes place throughout the year.  Safety-related recommendations from employees, whether made during formal sessions like the hazard review or made upon observation of a potential hazard, are always considered carefully for implementation.  This process is continuous and, even at times when no major process changes are anticipated, existing safety systems and procedures are fine-tuned as a matter of course.   Currently, the recommendations made at the recent hazard review are under consideration.
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