Arkansas CIty Water Treatment Plant - Executive Summary

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Release prevention and emergency response policies 
Personnel at this City of Arkansas City (City) facility take a very active approach in maintaining and improving chemical safety.  This facility complies with industry-standard requirements for water treatment plants that use chlorine in ton containers.  The policy at this facility is to adhere to all applicable federal, state, and local laws.  If an emergency were to occur, the policy is to notify the City of Arkansas City Fire Department and request that they respond to the emergency. 
Facility and regulated substance    
This facility is a water treatment plant located in the City of Arkansas City, Kansas.  The facility employs a series of physical and chemical treatment operations that include: lime softening, gravity filtration, and disinfection.  The covered process includes the storage, feed, and use of chlorine chemicals.  This chemical is used in the disinfection and chlorination process that is used to destroy pathogenic micro 
The chlorine is provided through truck-delivered one-ton containers and the maximum intended inventory at the facility is 6,000 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 mitigative measures are considered for this analysis. 
The alternative release scenario is based on a methodical analysis of accident history, hazard review, experience at other similar company facilities, and industry experience.  The alternative release scenario involves the partial release of the contents of a one-ton container of chlorine through a break in or disconnection of the flexible tubing connecting the container to the manifold header.  Chlorine gas is assumed to leak through a hole 5/16-inch in diameter.  It is also assum 
ed that personnel can stop the leak by shutting off the manual valve on the container after donning the proper personal protective equipment.  Duration of leak is assumed to be ten minutes.  Because the storage building is not a complete enclosure, the enclosure mitigation factor is not used.  No other mitigative measures are considered. 
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.  The distance to endpoint for the chlorine worst-case release scenario is 1.3 miles and for the alternative release scenario, the distance is 0.1 mile. 
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.  The chlorine system was designed, installed, and maintained in accordance with state and local laws. 
 To achieve and maintain this compliance, the City has in place procedural and technological safeguards.  The procedural safeguards include an employee training program and operating and maintenance procedures for those employees involved in operating the covered processes.  The technological safeguards include sensors, alarms, relief valves, and industry standard systems.  All of these serve to prevent unintended releases of chlorine, or at least minimize the effects of a release. 
Five-year accident history 
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 Arkansas City Fire Department is the primary responder.  City employees handle incidental releases of chlorine and are trained and equipped to do so. 
The emergency action plan includes di 
saster and emergency situation identification, procedures for reporting emergencies, notifying the public, evacuation, system shutdown, communications directory, and a communications program summary.  
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 hazard review or upon observation of a potential hazard, are always considered carefully for implementation.  This 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.
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