City of Golden Water Treatment Plant - Executive Summary

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When Congress last updated the Clean Air Act, it attempted to address public concerns about chemical related accidents. A new section of the Act required the EPA to develop reules to prevent and mitigate accidental releases of regulated substances. A Risk Management Rule (RMPR), was mandated in 1996. By June 21, 1999, industries must submit their Risk Management Plans (RMPs), which describe how their facilities will prevent or respond to chemical accidents. 
 
The RMPR affects a wide range of industries, including water and wastewater plants. A facility must develop, and submit to EPA, a Risk Management Plan if it uses and has on-site more than the threshold quantity specified. For example, Golden's water treatment plant will submit a program for chorine threshold levels over 2,500 pounds typically on hand. In general, water utility's risk management plan must contain certain basic elements that will identify hazards and help manage risks including: 
- A worst case release scenario for of 
f-site consequences and alternative release scenario(s).  
- A five-year history (1994-1999), of accidental releases of defined chemicals, if any. 
- Hazard assessment and identification of regulated substance and the source. 
- Accidental release and community-coordinated emergency response plan 
- Accidental release prevention program with specific chlorine prevention steps. 
- Planned changes to improve safety. 
 
The City of Golden has always been concerned with public safety and, in 1992 Golden installed a "chlorine scrubber" at it water plant at a cost of approximately $70,000; the scrubber collects and neutralizes any accidental release of chlorine gas. The Golden Fire Department has worked in conjunction with Golden's water plant to develop an excellent emergency response plan; the plan is coordinated with the City of Golden, Coors Brewing Company, and the Jefferson-Adams County Combined Hazardous Materials Response Team. All Water Treatment Plant self-contained breathing apparatus (S 
CBA), are compatible with the Fire Department. We are proud of Golden's five-year history that includes no releases. 
 
During the implementation of this process we made additional safety modifications. We have added a curb to the chlorine building to contain any spilled liquid chlorine inside the building and prevent it from flowing under the door. We have also installed a deluge water sprinkler-type system, as a back up, to allow operators to douse any chlorine vapors with large quantities of water, in the unlikely event of a chlorine scrubber failure. 
 
EPA regulations mandate that we model a "worst case scenario." For this to occur, all our mitigation systems (our chlorine scrubber, deluge system, and water supplies from hydrants and fire trucks), would all need to fail. In the "worst case scenario," a cloud of chlorine gas could travel as far as 0.9 miles away from the water plant. In our more likely "alternative release scenario," any chlorine release would be neutralized by our chl 
orine scrubber (the model would not let us show a zero release while using the scrubber so we showed a small release to make the model work). The model indicates that any amount released would not leave the water treatment plant site.
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