Tip H. Allen Water Treatment Plant - Executive Summary

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In this water treatment plant facility (Tip H. Allen Water Treatment Plant) we handle chlorine which is considered hazardous by EPA, OSHA, etc.  The same properties that makes chlorine valuable as a water treatment chemical, also makes it necessary to observe certain precautions in handling chlorine.  Overall, the prevention of unnecessary human exposures, reducing the threat to our own personnal health as well as our co-workers, and reducing the threat to nearby members of the communtiy is the main goal of incorporating this Risk Management Plan into our daily operations.  It is our policy to adhere to all applicable federal and state rules and regulations.  Safety depends upon the manner in which we handle and use chlorine, combined with the safety devices inherent in the design of this facility, with the safe handling procedures that we utilize, along with the training of our personnel. 
The primary purpose of this facility is to treat the water supply by utilizing chemicals such as 
chlorine.  Chlorine is received by individual one ton cylinders and stored until needed.  Chlorine is fed into the water system by automatic vacuum operated feeders.  The vacuum system will help prevent the continual operation of the chlorine feed from the cylinder if there is an increase or decrease in pressure on the feed lines (if a feed line is cut or split).  Access to the site is restricted to authorized facility employees, authorized management personnel, and authorized contractors.  The maximum amount of chlorine at this Tip H. Allen  Water Treatment Plant is 4,000 pounds. 
Our employees conduct proper cylinder change-out procedures when cylinders are changed out.  These procedures are based on the Manufacturer's recommendations.  Employees also review operating procedures and maintenance tasks daily or as need per manufacturer's recommendations.  The prevention program for this facility is a Level 2.  Lockout/Tagout procedures are used to help prevent an accidental release of 
chlorine.  When maintenance is conducted on the chlorination system, the Water Operator (Eddie Mauldin) approves the proper installation of materials, and complete installation with final approval of achnges in the system by the Mississippi State Health Department.  Any change in maintenance procedures is reviewed and approved by the same operator.  All operators at this facility are knowledgeable in the proper start-up and shut-down procedures for the water treatment operations.  All components of the chlorination system are visually inspected at least once every day. 
Our emergency response (action) plan was developed with the assistance of Environmental Data Services, Inc., Harcross Chemical Chlorine Response Team, the Canton Fire Department, and the Madison County Emergency Management Agency.  If a chlorine release occurs at the 225 Hargon St. location, the public announcement system will be used to notify plant personnel of a release.  Safety Director (Bill Davenport) will get pe 
rsonel organized for an emergency action, and if necessary, response and evacuation.  On-duty personnel have SCBA equipment that they will use to enter the confined space (due to toxic atmosphere) and determine extent of release.  They can perform an emergency action by manual shutdown of the chlorine cylinder valve.  If the release cannot be controlled by the manual valve shutdown, then evacuation procedures will then be followed.  A head count will be made of employees and the Harcross Chemical Chlroine Response Team (Hazmat Responders) will be notified, then the 911 call will be made to notify the Canton Fire Department (HazMat Responders), Madison County Emergency Management Agency, the Madison County Sheriff's Office, and the Canton Police Department of the release.  Personnel at the 225 Hargon Street location, the Harcross Chlorine Response Team, the Canton Fire Department, and Madison County Emergency Management Agency will help organize the Emergency Response activities, and wi 
ll start the evacuation of the affected population.  The release could be slowed by employees not starting the manual vent system in the chlorine room until notification to 911 system is made, and evacuation activities begin.  This will not prevent chlorine from releasing, but will allow for some time to respond. 
The worst case scenario for this facility is a one ton cylinder failure, which would be a release of 2,000 pounds of chlorine gas into the atmosphere.  Active mitigation has been considered for this scenario consisting of manual shutoffs, and automatic vacuum feed chlorine system.  Passive mitigation has also been considered for this release scenario, which would be a release into an enclosed space with little contact with outsisde air.  It is assumed that the entire contents of the cylinder are released as vapor.  The distance to endpoint of 0.087 mg/l for the worst case scenario is 2.2 miles.  The area surrounding the facility is considered to be rural due to the relatively 
flat ground, and thin vegetation.  The worst case scenarion would impact approximately 8,600 persons in approximately 3,600 households. 
An alternate release scenario was determined for the 225 Hargon Street location, the Camden Well site, the Way Road Well site, the Levi Well site, the Lake Caroline North Well site, and the Lake Caroline South site.  The chlorine cylinders operate on an automatic vacuum fedd system, so the amount of chlorine released at these locations would be minimal (approximately 10 pounds).  This release of chlorine would have a distance to toxic endpoint of less than 0.1 miles.  All sites are considered rural, and would have off-site impacts of the following numbers.  At all these locations, the number off affected population would be approximately 12 persons in 5 households  All populations were based on Landview Software. 
There have been no accidents or accidental releases of chlorine from this facility in the past five years.  The automatic vacuum feed syst 
em helps prevent/limit releases of chlorine that could escape during operational periods.  Operators of the chlorination system are required to check instruments, cylinders, feed lines, etc. on a daily basis to aid in the prevention of accidental releases.  Even though this is a Level 2 Prevention Program, Canton Municipal Utilities has chosen to utilize Level 3 Process Safety Management Program to furthur emphasize their efforts in preventing accidental releases of chlorine. 
This water treatment facility complies with EPA's Accidental Release Prevention Rule, and with all applicable state/federal regulations.
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