Keokuk Water Treatment Plant - Executive Summary
Executive SummaryExecutive Summary |
Risk Management Plan
40 C. R. F. part 68
City of Keokuk, Iowa Municipal Water Works
Accidental release prevention policies of the City of Keokuk Water Division.
This program was developed to prevent the occurrence of, or minimize the consequences of, catastrophic releases by stating policies and procedures necessary for effective management of process hazards. It is the policy of Keokuk Municipal Water Works to provide its employee with a safe and healthful work environment and to conduct it's operations in such a manner as to have minimal impact on the environment and the surrounding community. Every effort has been made to provide the greatest degree of safety possible for the employees and citizens of Keokuk. This Process Safety Management Program and Risk Management Plan includes all elements of the pertinent OSHA standards and EPA regulations, including development of a process hazard analysis, standard operating procedures for the water
treatment process, employee training programs, and preventive maintenance schedules. Water Department employees and the citizens of Keokuk will be provided full access to this document, including the process hazard analysis and all other information contained in the Process Safety and Risk Management Program.
The primary activity of the Keokuk Municipal Water Works is to provide the City of Keokuk with a safe reliable source of drinking water. This is accomplished through the use of Chlorine gas used as a disinfecting agent of the water supply. Chlorine gas is stored in one ton containers and is fed to various stages of the treatment process through the chlorination system. The maximum amount of Chlorine in storage at the water treatment plant is eight tons, in one ton containers. Only four containers are connected to chlorination system at any one time.
General accidental release prevention program chemical-specific prevention steps
The Keokuk Municipal
Water Works has a semi-structured preventive maintenance program covering all components of the chlorination system. The preventive maintenance program is intended to ensure the continued integrity of process equipment and minimize the risk of a catastrophic chlorine release. This preventive maintenance program requires regular inspection and testing of chlorination equipment by operators and maintenance personnel. The preventive maintenance program is in the process of being formalized with written procedures and schedules. Record keeping will be an integral part of the preventive maintenance program. The Water Department also has an employee education and training program which encompasses all necessary training in safe operations and maintenance of the water treatment process. All affected personnel received training at the time of their initial assignment, and whenever there is a process modification, alteration of operating procedures, or change in individual job duties.
It is the belief of the Keokuk Municipal Water Works that compliance audits are needed to evaluate the effectiveness of the Process Safety and Risk Management programs. It is a policy of the Water Department that audits should be conducted at regular intervals by a multi-disciplinary employee management team, and that this team should review the Process Safety Management Program in force at the time of the audit for it's effectiveness and applicability, and make recommendations for changes and revisions as necessary.
Five-year accident history
There have been no chlorine releases at the Keokuk Municipal Water Works during the five years prior to the date of this report which resulted in death or injury to Water Division personnel or the general public, significant property or environmental damage on and off-site.
Worst-case release scenario and alternative release.
In the worst-case scenario, a ton container of chlorine is dropped during delivery damaging the valve resulting in
the release of 2,000 pounds of chlorine gas to the atmosphere. The contents of the chlorine tank are expected to be released within 10 minutes over urban terrain. The distance to the toxic end point for the worst-case scenario was determined to be 1.3 mile radius by using the RMP Offsite Consequence Analysis Guidance, RMP, version 1.06.
In the alternate case for chlorine gas release, a rupture or breakage occurs in the chlorination system at the tank storage area. The release is assumed to have a duration of approximately 10 minutes. And estimated 3.3 pounds of chlorine would be released to the atmosphere from the total amount at the facility, at a release rate of .33 pounds per minute. The reported amount of chlorine released during the alternate case scenario is considering all active and passing mitigation devices available at the water treatment plant. The distance to the EPA toxic end point for this scenario is 0.3 miles, using the RMP Offsite Consequence Analysis Guid
ance, RMP version 1.06.
Emergency response program
The scope of the Water Department's Emergency Response Action Plan includes both minor chlorine releases controllable by Water Department staff and contained within the water treatment plant, and uncontrolled, major releases requiring assistance for local emergency responders and evacuation of plant personnel. All water treatment personnel will receive initial training in emergency response evacuation procedures and will have refresher training at least once every three years thereafter. This training includes employee duties and responsibilities in the event of a toxic chemical release, procedures for the proper use and maintenance of emergency response and protective equipment, proper use of communications equipment, pertinent telephone numbers and points of contact for emergency responders, and evacuation routes and location of safe zones.
Emergency response has been coordinated with the Keokuk Fire Department. The Fire Depar
tment has responsibility for emergency rescue and initial medical response during a chlorine emergency. Notification of residents, neighboring facilities, and the city of Hamilton, IL in the event of a major release will be the responsibility of the KuokukFire Department.
Decontamination cleanup efforts will be coordinated with the Keokuk Fire Department and decontamination of the immediate leak area will be under their supervision. In the event of a major chlorine release Water Division personnel will only offer technical assistance to emergency responders.
Planned changes to improve safety
Keokuk Municipal Water Works is committed to improving the quality of employee training and education programs, including training in the safe use of chlorine and an appropriate emergency response. These programs are to be evaluated at regular intervals and updated and revised as necessary. Employee training will be documented to the fullest extent possible. Water Department personne
l will help coordinate and participate in drills and cooperative training with emergency responders in the local area.
The chlorination system preventive maintenance program will be revised to include written procedures for inspecting equipment and record keeping. When unsatisfactory conditions are noted or recommendations for corrective action are made as a result of regular inspections, the conditions or recommendations will be promptly addressed and any outstanding problems will be resolved in a timely manner.