Mena Wastewater Treatment Facility - Executive Summary

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RISK MANAGEMENT PLAN 
THE ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE AT YOUR FACILITY.        The number one priority at the Wastewater Treatment Facility is safety!   It is the Managements and Supervisors intention to handle and dispense all Toxic Hazardous Chemicals with the utmost care.   Strict precautionary measures are implemented by all personel.   Prevention is the key to safety and preventing an accidental release.   All chlorine equipment is inspected on a regular basis for wear, cracking, seal failures, etc..equipment is updated and replaced when needed.   The Wastewater Supervisor is committed to the health safety and welfare of his employees and the public, who may be affected by an unintentional release of Chlorine Gas. 
THE FOLLOWING SAFETY PRECAUTIONS WILL BE IMPLEMENTED; 
1.  An SBCA Unit will be donned whenever a tank is to be changed or minor repair is being made.  Then in the event of malfunction, the operator has the ability to correct it before it escalates 

2.   A semi-annual inspection of the "B" Kit to familiarize the operators with the repair methods and various repair tools.   New gasket kits will be ordered every fourth year as advised by the Chlorine Institute. 
3.   All SCBA's will be inspected quarterly to insure porper working order, along with gaskets, seals and cleanliness.   All employees will at that time don a SCBA Unit and use up one tank of air each. 
4.   Chlorine safety meetings will be held semi-annually by the water & wastewater Supervisors, along with local and rural fire fighters to stay abreast of the hazasrdous potential of Chlorine.   Representatives from the Sheriffs Department and The Office Of Emergency Services will also be on hand to see the sites and familiarize themselves with the facility locations and evacuation areas. 
5.   An inhouse first responders team will be assembled by plant operators, supervisors, and maintenance employees.   They will be responsible for the containment, and chlorine leak elimina 
tion.   They will work inconjunction with the Mena City Fire Department which has a first responders team trained in hazardous chemical emergencies.   However, the Mena Fire Department will not be responsible for the containment and leak elimination.   Their presence will be only to assist the men working on the leak, I.E. first aid, extraction, radio communications. 
YOUR FACILITY AND THE REGULATED SUBSTANCES HANDLED 
The wastewater facility is situated on a 160 acres with 55 acres of lagoon surface.   The main lift station receives its flows from three sublift stations and gravity mains in the city of Mena.   Water that is stabilized from the lagoons, then enters the filter building for final clarification by upflow sand filtration.   The filters remove the algae from the water before release to the stream bed.   The regulated substance that is used is chlorine.   Primarily used for disinfection and to keep the filters free from filementeous alge buildup.   Chlorine range from one to t 
hree tons.   A one ton cylilnder may last one to three months depending on demand and flow. 
THE WORST CASE RELEASE SCENARIO(S) AND THE ALTERNATIVE RELEASE SCENARIO(S) 
The worst case  and the alternative release scenarios would be treated identically until the operator would have time to assess the situation and make sure the shut-off valve is completely closed.   At that time the operator would with the assistance of the supervisor, determine if the emergency response plan would be initiated.  OUR WORST CASE SCENARIO INVOLVED;  One full cylinder (2000) with full release in ten minutes @ a 110 pounds per minute.   The release is in an enclosed space in direct  contact with outside air.   The topography is in a rural surrounding with wind speed at 3.4 mph @ 77 degrees F.  Offsite impact is critical because of the number of homes, schools, and industry in the toxic endpoint of the radius, which is 2.2 miles.   Severity of the release would be determined mainly by prevailing wind, which di 
rection they are blowing.   We seriously doubt whether the entire radius would be evacuated.   Most likely a quadrant of that circle would be evacuated depending on wind direction.   FOR THE ALTERNATIVE RELEASE SCENARIO;   
A half full cylinder would be in an enclosed space in contact with ourside air, with a partial release only.   The release rate is 35 pounds per minute for 60 minutes.   The topography is of course the same with the wind speed at 6.7 mph @ 77 degrees F  The toxic endpoint is 0.2 miles and the impact considered minimal because of sparse receptor sites.   No schools or industries are involved in this scenario. 
THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL SPECIFIC PREVENTION STEPS.    The wastewater facility complies with the OSHA Hazard Communications Standard (29 CFR 1910.1200), and always make MSDS information to the employees.   We also abide by the rules and regualtions of the Arkansas Department of Envoronmental Quality,  the Arkansas Department  
of Health,  and the Environmental protection agency.   The practices we believe that are important for a solid prevention program are common sense and hands on training exercises.   Operators are instructed on the proper methods of loading and unloading the ton cylinders.   They have also attended training classes on Chlorine Safety and are well versed on action needed to contain a major and a minor leak.   They are also schooled on visual inspection of hoses and apparatus constantly checking for worn or cracked material.   A chlorine alarm sounds when levels of chlorine rise above 10 ppm.   The first responder team is trained semi-annually in the "B" repair kit, along with the proper donning of the hazmat suits/SCBA's. 
FIVE YEAR ACCIDENT HISTORY - There have been no accidental releases of chlorine for the past five years of any magnitude. 
THE EMERGENCY RESPONSE PROGRAM - The emergency response program for the wastewater facility is as follows:   
1.   Should an operator find a leak, or 
be in response to an alarm, he should evaluate the severity and notify the supervisor and management immediately.   If leak is minor with no visible cloud or vapor, the operator should donn a SCBA and turn the main control valve of tank off.   If this action remedies the leak, then responders should be put on standby until the repair is made.   No attempt to repair the minor leak shall be done by one person alone.   Two operators will fix the leak, both checking each others work before resuming chlorination.   If the turning of the shut off valve did not remedy the situation, then the operator or supervisor will notify the water department first responder team to the site.   No risks shall be taken. 
2.   The supervisor or management would then contact 911 and brief them on the situation.   The first responders from the Mena Fire Department would also be summoned, along with the Sheriffs Department and Rural Fire Department. 
3.   In the event that the leak is from a puncture or missing 
fusible plug, then action should be taken to roll the tank so that the hole is at the highest point possible to avoid a liquid leak. 
4.   When the first responders team arrives, they should be informed by the operators on site of the location of the leak, and prepare for the repair immediately.   Mena Fire Department will assist for extraction of first aid if needed. 
5.   The O.E.S. and the local and rural Fire Departments will be responsible for the evacuation process.   Quadrants will have to be determined according to wind direction and speed.   The local radio station will advise via broadcastings in conjunction with O.E.S. all emergency information. 
6.   In the event of a major catastrophe, such as earthquake or tornado, and the tank is not accessible because of debris or rubble, then the above steps should be suspended until equipment can arrive.   Efforts should be made to evacuate the areas affected by the release immediately.   When equipment arrives, all efforts shall be mad 
e to expose or extract the tank into an open area for leak eradication. 
7.   All releases must be classified by the operators for severity.   To classify the severity of the leak, the wastewater facility has adopted the following guide line: 
a)  LEVEL #1 RELEASE - Defined as a minor hint or smell of chlorine. 
b)  LEVEL #2 RELEASE - Defined as a strong smell of chlorine gas. 
c)  LEVEL #3 RELEASE - Defined as overbearing smell, with the presence of a cloud from gas. 
d)  LEVEL #4 RELEASE - Defined as unapproachable, most likely liquid with massive vaporisation. 
e)  LEVEL #5 RELEASE - Same as #3 or #4 above, except leak cannot be reached because of debris or rubble. 
It is important that all personel and first responders learn these levels of release so that unnecessary emergency calls are not made, and to avoid panic. 
PLANNED CHANGES TO IMPROVE SAFETY - Changes planned to improve safety will stem from increased communications and expanded information to both the local emergency response pl 
an and the public.   The public will be inofrmed of the hazard potential by means of radio interviews, newspaper articles, and public forums for those interested.   Training should be semi-annually to keep procedures and evacuation routes fresh in the minds of those involved.   Cross training of all fire department personnel with the water department first responders team in case of fatalities within the water department.   Training education programs should be: 
1.   Hands on training and cross training with Mena Fire Department and the First Responder Team from the Water Department.   Training on an empty tank with a hazmat suit, and an SCBA Unit in an open area for observation by all. 
2.   Meeting should be held with O.E.S., Sheriffs Office, Police, and Rural Fire Departments to discuss evacuation procedures and who will cover that area. 
3.   Document and finalize all plans and evacuation routes and put into brochure form for all personnel involved so that they can read and be inform 
ed on their roll or position, should a emergency occur. 
4.   Conduct mock training exercises using the Worst Case Scenario so that everyone has the feel of the potential hazard that is possible in the event of a major storm or earthquake. 
5.   Keep it up.  Everyone remembers the precautions taken by Civil Defense, which have long gone by the wayside.   Be vigilant.
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