Marshall Municipal Utilities WTP - Executive Summary

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Release prevention and emergency response policies 
Personnel at this Marshall Municipal Utilities (MMU) facility are active in maintaining and improving chemical safety.  This facility complies with industry-standard requirements for water treatment plants that use chlorine in ton containers.  MMU's policy is to adhere to all applicable federal, state, and local laws.  If an emergency were to occur, our policy is to notify the City of Marshall Fire Department and request that they respond to the emergency. 
Facility and regulated substance    
This facility is a water treatment plant located north of Marshall, Missouri.  The facility employs a series of physical and chemical treatment operations that include aeration, primary and secondary clarification, disinfection, and final filtration.  The water is then transferred to one of several reservoirs and is pumped into the distribution system.  The covered process is chlorine storage and feed.  The chlorine is delivered by truck in one-to 
n containers and the maximum intended inventory at the facility is 28,000 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 passive mitigation was considered and no active mitigation could be considered.  Distance to endpoint for the analysis was 3.0 miles. 
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 alternative release scenario involved the partial release of the contents of one ton container of chlorine through a fusible plug failure.  The chlorine was assumed to be released as gas.  No mitigative measures were considered.  Distance to endpoint for the analysis was 0.2 mile. 
For both 
analyses, 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.  
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 is maintained in accordance with state and local laws and industry codes.  To achieve and maintain this compliance, MMU has safeguards in place.  These include operating and maintenance procedures, employee training, frequent checks for leaks, and a vacuum system where the chlorine pressure is cut to vacuum at the container.  All of these serve to prevent unintended releases of chlorine and, failing that, to minimize the effects of a release. 
Five-year accident history 
In the last five years, 
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 Marshall Fire Department is the primary responder.  MMU employees handle incidental releases of chlorine and are trained and equipped to do so.  Larger releases of chlorine are handled by the Fire Department. 
The emergency action plan includes emergency situation identification, procedures for reporting emergencies internally, evacuation, and responder notification.  The plan also addresses the interaction with the City Fire Department.   
Planned changes to improve safety 
The maintenance 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 h 
azard review or made upon observation of a potential hazard, are always considered carefully for implementation.  This feedback 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 during the recent hazard review are under consideration.  MMU is working with its engineer to design a major rehab of its chlorine system.  MMU is revising emergency operations plans for all of its facilities.
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