Town of Normal (Water Department) - Executive Summary

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Executive Summary of Risk Management Plan for The Town of Normal Water Department 
1.  The Facility Policy:  The owners, management, and employees of The Town of Normal Water Department 
are committed to the prevention of any accidental releases of chlorine by utilization of proper equipment, 
regular inspections and maintenance and training of all persons that work with chlorine.  Should an accident occur, the facility has oriented the local fire department and local emergency planning committee so they can plan for response to any release and minimize the impact of the release to people and environment. 
2.  Facility Information:  The primary activity at the facility is potable water treatment and in conjunction with this operation, the handling, storage, etc. of chlorine for use in disinfection.  Chlorine is received, stored and used in the chlorination of the treated water to maintain a disinfection residual through out the storaged and distributed water.  The maximum quantity stored 
would be 12,000 pounds in the facility process.  The capacity of the individual containers is 2000 pounds. 
3.  The Worst-case Scenario:  The total release of the contents of a holding container, in the form of a gas and liquid mixture, over a 10 minute period.  The maximum quantity released would be 2000 pounds, which represents the volume of the storage containers or as limited by design standards and company procedures. Tthe distance to endpoint of disperson based on the model used is .9 mile. 
   The Alternative- case Scenario:  The assumed release of 1050 pounds from a holding container, in the form of a gas, over a 15 minute period.  The distance to the endpoint of dispersion based on the model used is .1 mile.  
4.  The Accidental Release Program:  The facility complies with the Rules and Regulations as set forth in SARA Title III / EPCRA Subtitle A Sections (302, 303, 304, 311, and 312), CERCLA Sections (101, 102, and 103), Title 40 CFR Subchapter C Part 68, and  Title 40 CFR 
Subchapter J Parts (302,355, and 370). 
5.  The Five-year Accident History:  There has been one accidental release of chlorine in the past five years that has occured from the covered process.  On August 24, 1997, there was a release of approximately five pounds of chlorine gas.  The release occured during reconnection of piping after the change over of containers.  The cause was human error.  One of the valves in the system was not completely closed before a closed loop was secured.  The fire department was called and responded within in three minutes and proceeded to secure all valving, stopping the release.  There were no injuries or property damages.   
6.  The Emergency Response Program:  The facility has a written emergency action plan coordinated with the Town of Normal E.S.D.A (Emergency Services and Disaster Agency) and in accordance with OSHA Standard 29CFR 1910.38 and provide state and local authorities the emergency planning and community right-to-know information as requi 
red under SARA Title III of EPCRA.  Our emergency response action plan has been reviewed with the local fire department and provided to the local emergency planning committee for coordination in the community response planning. 
7.  Planned Changes to Improve Safety:  Safety improvement is an on-going process at the facility.  Periodic evaluations are performed to assess the maintenance of safe practices and operations.   We have recently installed an emergency shut off system for chlorine ton container valves.  The system is activated in the event of a leak detection by a monitor and by manual panic buttons located strategically through out the facility in the event a leak is detected by facility personnel.  We are investigating alternative disinfection options to reduce or eliminate our use of chlorine gas.
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