District 3A Water Treatment Plant - Executive Summary

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1.  Accidental release prevention and emergency response policies: 
 
At the District 3A Water Treatment Plant (WTP) located in Broward County, Florida, chlorine is stored for use for drinking water disinfection.  Chlorine is considered hazardous by the United States Environmental Protection Agency (USEPA).  It is management's commitment to safety and adherence to Federal, State, and local rules and regulations that reduce the threat to our employees and nearby members of the community.  Our safety procedures involve the training of our employees in the safe handling of chlorine and the safety devices inherent in the design of this facility. 
 
Our facility's specific Emergency Action Plan includes notification of the local fire authority.  In addition, access to the site is restricted to authorized facility employees, management personnel, and contractors.  At the District 3A WTP, the chlorine system is currently in an unenclosed building on our property. 
 
2.  The stationary source and re 
gulated substances handled: 
 
The regulated substance handled at this facility is chlorine. 
 
The primary purpose of the District 3A WTP is to provide safe and high quality drinking water to the customer base.  A large part of the purification of the water includes disinfection, of which chlorine plays a major part.  Disinfection is a necessary step to kill bacteria and other microorganisms that can harm human health.  Therefore, disinfection is accomplished by the addition of chlorine.  A residual level of disinfectant is maintained throughout the distribution system in order to control unwanted microbial activity.  The storage capacity of each cylinder is 2,000 pounds of chlorine.  We have a total capacity for 10 cylinders, therefore the maximum amount of chlorine that is stored at our plant is 20,000 pounds.  
 
3.  The worst-case release scenario(s) and the alternative release scenario(s):  
 
A.  Worst-Case Scenario - After careful review of potential worst-case scenario, we feel that t 
he largest quantity of a cylinder (2,000 pounds) released outside, during a cylinder unloading accident that causes rupture of the cylinder, with no building passive mitigation effects, is our worst-case. 
 
The distance to the EPA established endpoint of 3 ppm for the worst-case scenario is approximately 1.3 miles. 
 
B.  Alternative Scenario - The connection from the chlorine cylinder to the delivery piping breaks causing a flashing liquid release through a small hole approximately 1/4-inch diameter.  The liquid chlorine flashes immediately to vapor and liquid droplets, and is carried downwind. 
 
The distance to the EPA established endpoint of 3 ppm for the alternative scenario is estimated to be 0.2 miles.  This release has the possibility of extending beyond the facility's boundary. 
 
4.  The general accidental release prevention program and the specific prevention steps: 
 
This facility's complies with EPA's Accidental Release Prevention Rule and with applicable state codes and regulatio 
ns including OSHA's Process Safety Management Standard.  This facility was designed and constructed in accordance with professional engineering practices to ensure a safe system for our employees as well as our neighbors and environment.  The delivery drivers have been thoroughly trained in regard to chlorine hazards.  Our employees monitor each delivery of chlorine on our site.  In addition, we contract out to chlorine system professionals to periodically inspect our chlorine system, and make any necessary adjustments to either equipment or procedures to continue to ensure safe handling and use of chlorine.  We maintain a computer generated preventative maintenance schedule of the chlorine process equipment. 
 
5.  Five-year accident history: 
 
There have been no accidental releases, injuries, or environmental damage resulting from our chlorine system in the last five years. 
 
6.  The emergency response program: 
 
This facility's Emergency Action Plan is based upon the appropriate discover 
y and notification procedures to ensure coordination with our local emergency responders.  We have discussed this program with the Broward County Fire Station. 
 
7.  Planned changes to improve safety: 
 
The safety items that are in place have been deemed adequate and the system is maintained on a regular basis.
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