Verona Pumping Station - Executive Summary

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City of Battle Creek-Verona Pumping Station 
RMP Executive Summary  
1. Accidental Release Prevention and Emergency Response Policies 
We at the Verona Pumping Station (Water Treatment Plant) are strongly committed to 
employee, public and environmental safety. This is demonstrated, by an accidental release 
prevention program that covers such areas as design, installation, operating procedures, 
maintenance and employee training associated with the process at our facility. It is our 
policy, through the use of appropriate controls, to prevent the release of the regulated 
substance used in our operation. If such a release should occur, we are completely 
coordinated with the HAZMAT unit of the Battle Creek Fire Department. They would 
provide the highly trained emergency response personnel to control the effects of any 
The Source and Regulated Substance Handled 
The primary activity of the Verona Pumping Station is Municipal Water Supply and 
Treatment. We have 1 regulated substance 
at our facility. That substance is Chlorine. It is 
used in the treatment process for oxidation and disinfection. 
The maximum inventory at the Verona Pumping Station is 24,000 lbs. It is stored in 1 
location in 2,000 lb. cylinders. 
3. The Worst Case Release Scenario and the Alternative Release Scenario, including 
administrative controls and mitigation measures to limit the distance for each scenario. 
To evaluate the worst case scenario, we have used the AWWA Compliance Guidance and 
Model Risk Management Program for Water Treatment Plants. We have used the same 
reference book for the alternative scenario. The details are as follows. 
The worst case scenario submitted is CLW-2. This is for a program 3 toxic substance and 
involves a catastrophic release of Chlorine. The scenario involves a direct release of 2,000 
lbs. of Chlorine in a gaseous form over 10 minutes. At Class F atmospheric stability and 
1.5 m/s wind speed, a maximum distance of 2.63 miles is needed in an urban setting to 
reach a toxic endpoint of 0.0087 mg/L. 
The Alternative release scenario submitted is CLA-3 for a 1 ton Chlorine Container with 
gas feed. This scenario involves the release of Chlorine gas through a 5/16 diameter valve 
body opening due to tubing, connection or valve failure. It has a 317lb total release at a 
rate of 10.5 lb/min over a 60 minute duration. This scenario assumes a stability class D, 
relative humidity of 50%, temperature of 77 degrees F and wind speed of 3.0 m/s. This 
scenario has a distance to its toxic endpoint of 0.48 miles in an urban setting. 
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4. General Accidental Release Prevention Program and the Chemical-Specific Prevention 
Our facility has taken all the necessary steps to comply with the accidental release 
prevention requirements set out under 40 CFR part 68. The Chlorination process at our 
facility is subject to the OSHA PSM standard under 29 CFR 1910.119. The following 
sections briefly describe the elements of the program that is in place at t 
he Verona 
Pumping Station. 
Process Safety Information 
The Verona Pumping Station maintains a detailed record of safety information on the 
chemical hazards, operating parameters and equipment designs associated with the 
Chlorination process. 
Process Hazard Analysis 
Our facility conducts comprehensive studies to ensure that the hazards associated with the 
Chlorination process are identified and controlled. We use the Check List" analysis 
method, conducted by a team of qualified personnel, to evaluate the process every 3 years 
or whenever there is a change to the process. Any problems are addressed in a timely 
Operating Procedures 
The Verona Pumping Station maintains written operating procedures. These procedures 
cover the modes of operation such as start up, normal operations, emergency operations 
and shutdown procedures. These procedures are reviewed regularly and are available to 
anyone involved with the process. 
The Verona Pumping Station has a training program 
in place to ensure that employees 
operating the process are competent in the operating procedures associated with the 
process. Refresher training is provided at least every 3 years. 
Mechanical Integrity 
Verona Pumping Station carries out documented maintenance checks on all the 
chlorination equipment to ensure proper operation. Maintenance checks are performed by 
qualified  personnel and factory trained service people. Any problems are corrected in a 
timely manner.  
Management of Change 
Written procedures are in place at the Verona Pumping Station to manage any change in 
the Chlorination process. This includes changes in equipment, technology or procedures. 
All employees involved with the maintenance or operation of the process are notified 
promptly of any changes and offered training on the changes. 
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Pre-start up Review 
Pre-start up, safety reviews are conducted on any new equipment or changes to existing 
equipment in the Chlorination process. These reviews are conducted to 
confirm that 
construction, operating and maintenance procedures are correct and understood by all 
employees involved in the process prior to the start up of any new equipment. 
Compliance Audits 
The Verona Pumping Station will conduct audits on a regular basis to determine if the 
provisions under the PSM rule are being carried out. These audits are to be done at least 
every 3 years. Any corrective actions required, as a result of these audits, will be promptly 
taken care of. 
Incident Investigation 
The Verona Pumping Station promptly investigates any incident that results in or could 
result in a chlorine release. These investigations are to identify the causes leading to the 
incident as well as any corrective actions necessary to prevent its recurrence. 
Employee Participation 
The staff, of the Verona Pumping Station, believes that process safety management and 
accident prevention are a team effort. Employees are encouraged to express their views on 
accident prevention and to recommen 
d improvements. Employees actively serve on the 
Process Safety Management Team. 
Sometimes we hire contractors to conduct maintenance and construction activities. These 
contractors are required to adhere to all safety regulations and policies. Verona Pumping 
Station has a strict policy of coordinating safety issues with contractors and employees on 
any potential hazards involved with the contractors work. Contractors are also informed 
of all emergency response procedures, should an accidental release occur. 
5. Five year Accident History 
The Verona Pumping Station has an excellent record of preventing accidental releases 
over the years. In the past 5 years we have had no releases of chlorine that resulted in any 
deaths, injuries, damage on site or off site consequences.  
6. Emergency Response Plan 
The Verona Pumping Station has a written emergency response plan to deal with the 
release of any hazardous materials. This plan requires the notification of the Battle Creek 

ire Department. It relies on their HAZMAT team for all aspects of emergency response 
including first aid, medical treatment, evacuations, notification of local emergency 
agencies and the public.  
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To ensure proper operation, our emergency equipment is inspected and serviced according 
to the manufacturers recommendations. 
The Calhoun County LEPC is the Local Emergency Planning Committee. 
                                                                                                                                                                 7. Planned Changes to Improve Safety 
There are no current plans to change any of our operating equipment or procedures. We 
are constantly reviewing changes in our industry and new technologies for anything we 
can do to make the operation of our Chlorination Process safer. 
8. Certification Statement 
The undersigned certifies that to the best of my knowledge, information and belief, formed 
after reasonable inquiry, the information is 
true, accurate and complete. 
David L. Rich 
Water Production Superintendent 
City of Battle Creek 
Date: 6/10/99
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