West Virginia - American Water Company KVTP - Executive Summary

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Risk Management Plan Executive Summary 
Accidental Release Prevention and Emergency Response Policies 
At West Virginia-American Water Company's Kanawha Valley Treatment Plant, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner.  We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees, contractors, and the public, as well as protection of the environment.  This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: 
* A description of our facility and use of substances regulated by the Environmental Protection Agency's (EPA's) risk management program (RMP) regulation 
* A summary of results from our assessment of the potential offsite consequences from accide 
ntal chemical releases 
* An overview of our accidental release prevention program 
* A 5-year accident history for accidental releases of chemicals regulated by EPA's RMP rule 
* An overview of our emergency response program 
* An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, contractors, the public, and the environment 
Kanawha Valley Treatment Plant Regulated Substances 
The Kanawha Valley Treatment Plant is a water treatment facility that takes raw river water from the Elk River in Charleston, West Virginia, and treats the river water with chlorine and other chemicals to make potable (drinking) quality water for public distribution and consumption. Sewage treatment is not a part of plant operations. The plant handles one RMP-regulated toxic substance above the EPA threshold quantity, which is chlorine. No regulated flammable substances are present at the treatment plant 
Chlorine i 
s delivered to our plant and stored in 1-ton ("ton") containers and is fed to the process from two of the containers at a time. The container storage room can hold up to 26 ton containers. Two containers are connected to the same feed piping manifold at a time. An alternate supply arrangement consists of two additional ton containers connected to a parallel, but normally isolated, feed piping manifold. Chlorine is stored as a liquefied gas under pressure, fed as a liquid to chlorine evaporators, and injected as a vapor at the outlet of the chlorinators into the water stream. The chlorine process is classified as a Program Level 3 process, and we implement a complete accident prevention program.       
Offsite Consequence Analysis 
We performed an offsite consequence analysis to estimate the potential for an accidental release of chlorine from our facility as a regulated toxic substance that could affect the public or the environment. The offsite consequence analysis consisted of evalua 
ting both a worst-case scenario (WCS) and an alternative release scenario (ARS) following identification of the appropriate ARS. We do not expect a worst-case release scenario to ever occur. An ARS represents a release that might occur during the lifetime of a facility similar to our water treatment plant. ARSs can be used to help the Kanawha Putnam (local) Emergency Planning Committee (KPEPC) improve and prepare an effective community emergency response plan. 
We have submitted release scenario analyses to EPA and have shared that information with KPEPC and other organizations involved in emergency response activities. It is also available to local residents, schools, hospitals, and businesses.  For these events, we have emergency mitigation systems that should help reduce the consequences of the events if they occur. In all cases, if such events occur, we would activate our emergency response plan to respond to the event, notify local authorities, and take appropriate actions to prot 
ect our employees, contractors, and people in the community.  The paragraphs below briefly describe the scenarios we have included in our risk management plan (RMPlan), including information about the key administrative controls and mitigation measures we have put in place to limit the exposure distances for each scenario. 
Worst-case Release Scenario for Chlorine 
The worst-case scenario at our water treatment facility involves a failure of a ton container holding approximately 2000 lbs of liquefied chlorine gas under pressure, resulting in release and vaporization of the entire contents of the container. In this scenario, the chlorine is released as a vaporizing liquid inside a completely enclosed chlorine storage room in our water treatment building. The containment provided by the building mitigates the release. Such building confinement reduces the release rate of chlorine vapor directly to the outdoors. Since this facility is located in a populated area, the toxic cloud formed b 
y the evaporating chlorine would reach offsite end points and nearby public receptors. 
A sump tank is provided with floor drains under the storage room floor to collect and contain portions of a liquid release that do not immediately vaporize. In reality, the sump could serve to reduce the vaporization rate of chlorine to the storage room air, and likewise reduce the rate at which chlorine gas is released from the room directly to the outside air. However, because we based our analysis on a very conservative approach, we did not take credit for the sump tank as a form of mitigation in reducing the end-point distance reached offsite.   
Numerous administrative controls are in place to prevent a release of this type and, should one occur, to provide for effective emergency response. Controls include container design, storage, operation, maintenance, and inspection; container repair and emergency response equipment; and personnel training conducted in accordance with regulatory requireme 
nts, chlorine industry standards and practices, and our company's corporate policies and procedures, which are strictly enforced at the water treatment plant. 
Alternative Release Scenario for Chlorine 
Our alternative release scenario for chlorine involves a chlorine release of approximately 4000 lbs through a broken flexible connection ("pigtail") between either of two connected chlorine containers and a common supply manifold in the liquid piping to our chlorine feed system. A break in a pigtail connecting one of the containers to the piping manifold will permit both connected containers to vent their respective contents (about 2000 lbs each) through the open ends of the severed pigtail. Credit is taken in accordance with EPA's simplified approach for the partial containment of chlorine vapor by the room/building enclosure, which mitigates the release. Such building confinement reduces the release rate of chlorine vapor directly to the outdoors. Since this facility is located  
in a populated area, the toxic cloud formed by the evaporating chlorine would reach offsite end points and nearby public receptors. 
As in the WCS, we have taken a very conservative approach to determining the ARS end-point distance offsite. Therefore, in determining the ARS end-point distance we have not taken credit for active mitigation provided by engineered safeguards that include chlorine monitors/detectors that automatically activate a specially designed chlorine removal and neutralization (scrubber) system. This works in tandem to (1) safely remove chlorine vapor that may be released to the chlorine storage room and (2) neutralize the chlorine before much of it can escape from the room to the outdoors. The chlorine leak detection system is calibrated to initiate alarms at very low concentrations of chlorine (i.e., lower than industry recommended settings). Some of our additional engineering safeguards are outlined in the following section of this summary and include isolation v 
alves. Isolation valves are provided in the downstream chlorine feed system to isolate downstream chlorine sources from the pigtail leak. As stated in the description of the WCS, numerous administrative controls are in place to prevent a release of this type and to provide effective emergency response should one occur. 
We are using this information to help us ensure that our site/facility emergency response plan and the community emergency response plan address all reasonable contingency cases. 
Accidental Release Prevention Program and Chemical-specific Prevention Steps for Chlorine 
We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our RMP-regulated chlorine process is also subject to the Occupational Safety and Health Administration's (OSHA's) process safety management (PSM) standard. We have extended the PSM program at this facility, where necessary, to satisfy EPA's Program Level 3 accident prevention program requirements. Our PSM  
Program and RMP Level 3 Prevention Program are designed to comply with OSHA and EPA requirements. Additionally, we adhere to chlorine industry (i.e., the Chlorine Institute) and American Water Works Association guidance and recommended practices for PSM and RMP programs, including facility and chlorine system design and safety practices.   
Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, contractors, the public, and the environment by our use of chlorine in treating drinking-quality water. We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. Our systematic, proactive management systems address each of the key features of successful prevention programs including: 
* Process safety information 
* Process hazard analysis 
* Operating procedures 
* Training 
* Mechanical integrity 
* Management of change 
* Pre-startup review 
* Compliance audits 
* Incident investigation 
* Employee participation 
* Hot work permit 
* Contractors 
As part of our prevention efforts, the following is a list of key safeguards and chlorine-specific accidental release prevention steps that we have implemented at our site: 
* A new, state-of-the-art chlorine liquid feed system 
* Instrumentation and control systems with an emergency power supply designed in accordance with current industry (recognized and generally accepted good engineering) practices 
* Corrosion-resistant equipment components and piping systems 
* Protective devices to prevent the formation of excessive pressure in chorine equipment 
* Isolation valves to permit isolation of different parts of the process   
* Chlorine monitors/detectors with alarm notification to a constantly attended control room and to other key facility locations 
* A liquid chlorine spill collection and containment system consisting of floor drains a 
nd a sump tank 
* Chlorine rooms designed to help contain a chlorine release, and building construction materials that will not support fire development, fire spread, and fire damage to equipment 
* Strict administrative controls prohibiting the entry and use of combustible materials in chlorine handling/use areas to prevent and control fire spread that may pressurize equipment 
* An automatic chlorine removal (scrubber) system that is activated by chlorine monitors/ detectors 
* Cross-trained operations and maintenance personnel who are equally trained in emergency response actions for chlorine releases to the OSHA (29 CFR 1910.120)/EPA HAZWOPER responder level  
These individual elements of our prevention program work together and in tandem with the chlorine release prevention steps to prevent accidental chemical releases. Our company, our employees, and contractors are committed to the standard that these management systems set for the way we do business, and we have specific, inter 
nal management accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. 
Five-year Accident History 
We keep records for all significant accidental chemical releases that occur at our facility. During the past 5 years we have not had any releases involving chlorine from the RMP-covered process that had any reportable onsite or offsite effects. Our facility has instituted procedures that require formal investigation of incidents involving chemical releases, regardless of chemical identity or listing by the EPA RMP rule. For each incident, we conduct formal incident investigations to identify and correct the root causes of the events. 
Emergency Response Program 
The West Virginia-American Water Company's Kanawha Valley Treatment Plant maintains an integrated contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning.  Our program provides the essential planni 
ng and training for effectively protecting workers, contractors, the public, and the environment during emergency situations. The program consists of procedures for responding to a chlorine release. The procedures address all aspects of emergency response, including (1) proper first aid and emergency medical treatment for human exposures, (2) facility evacuation plans and accounting for facility personnel after an evacuation, (3) notification of local emergency response agencies and the public if a release occurs, and (4) post-incident follow-up requirements. Procedures are in place governing the establishment of the plant's Emergency Operation Center where management personnel can direct and control emergency operations on an as-needed basis. 
In addition, we have procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment.  Employees receive training in these procedures to p 
erform their specific emergency response duties. The emergency response program is updated when necessary based on modifications made to plant facilities or to the chlorine storage and feed process, or when improvement benefits are recognized. Affected personnel are informed about, and trained on, the changes. 
The overall emergency response program for the plant is coordinated with the KPEPC - the local emergency planning committee (LEPC) having jurisdiction in Kanawha and Putnam Counties - and with Kanawha County and City of Charleston, West Virginia, emergency management officials. This coordination includes periodic meetings of the KPEPC, which includes local emergency response officials, local government officials, and industry representatives. We have around-the-clock communications capability with appropriate emergency response organizations (e.g., contracted chlorine emergency response [HAZMAT] teams, local fire department, police department). This provides a means for notifyin 
g the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to participating in periodic KPEPC meetings, we conduct periodic walk-around orientation tours of the plant facilities with key representatives of local emergency response organizations. During such tours we discuss and review the source of chlorine at our site, the hazards of a chlorine release, release mitigation features, and emergency response actions involving the chlorine system. Thus, our emergency response plan is fully coordinated with the community emergency response plan. 
Planned Changes to Improve Safety 
At the West Virginia-American Water Company Kanawha Valley Treatment Plant we constantly strive to improve the safety of our operations through periodic safety reviews, our incident investigation program, and a program for soliciting safety suggestions from our facility workers. We resolve all findings from our reviews of proposed changes to facilities, equipment, 
and operations and from analyses of process hazards. Some findings of this type can result in modifications to the process, the prevention program, or administrative controls. The following is a list of improvements that we are planning to implement at the facility during the next 5 years to help prevent and/or better respond to accidental chemical releases: 
* An engineering review of the chlorine scrubber system to determine if improvements are feasible that would ensure the system's capability to completely remove (neutralize) the entire vapor load from a release of chlorine as we postulated in our ARS 
* An engineering review of the leak-tightness of each chlorine room to more precisely determine the building (containment) mitigation factor, possibly resulting in reduced end-point distances for WCS and ARS releases of chlorine 
* An assessment of the effectiveness of each element of the Level 3 Prevention Program to ensure that the program will achieve its objectives and to strive 
for continuous program improvement
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