Water Treatment Plant - Executive Summary

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1. Accidental release prevention and emergency response policies: 
At the City of Punta Gorda, Florida Water Treatment Plant, chlorine is used for disinfection.  Chlorine is considered hazardous by the Environmental Protection Agency.  The same properties that make chlorine valuable as a disinfectant also make it necessary to observe certain safety precautions in handling to prevent or reduce unnecessary human exposure.  It is the Policy of the City of Punta Gorda to adhere to all Federal and state rules and regulations regarding the safe storage and process use of chlorine. 
Emergency response procedures include notification of the local fire departments and the Charlotte County Office of Emergency Management.  Access to the site is restricted to a gated entrance for authorized facility employees, management personnel, and contractors.  The chlorine system is enclosed in a room inside the operations building. 
2. The stationary source and the substance handled: 
The regulated substance is 
chlorine.  Chlorine is received in ton-cylinders and stored in the chlorine room where it is also fed to the plant process.  The maximum amount of chlorine stored at the site is 8 tons (16,000 pounds). 
3. Worst-case scenario and the alternative release scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario: 
* Worst-case scenario.  EPA has defined and specified the worst-case chlorine release scenario.  Failure of a chlorine cylinder, when filled to capacity, would release 2,000 pounds of chlorine at a rate of 200 pounds per minute, for 10 minutes, in direct contact with outside air.  The estimated distance to the toxic endpoint of 0.0087 mg/L is 3.0 miles. 
*Alternative release scenario.  A vacuum regulator washer failure at the chlorine container, resulting in a 15-minute release of chlorine gas results in a rate of 5.2 pounds per minute in an enclosed space in direct contact with outside air.  The estimated distance to th 
e toxic endpoint of 0.0087 mg/L is 0.1 miles (528 feet).  The release has the possibility of extending beyond the facility boundary onto Washington Loop Road, north of the chlorine storage room. 
4. Administrative Controls and Mitigation Measures: 
The employees responsible for overseeing and assisting in the delivery and transfer of chlorine cylinders are limited to certified Domestic Water Treatment Plant operators.  The operators are licensed by the Florida Department of Environmental Protection, and are also trained in the hazards of chlorine and the steps to be taken in an emergency situation to mitigate a release. 
5. The General Accidental Release Prevention Program and the specific prevention steps: 
The Water Treatment Plant complies with EPA's Accidental Release Prevention Rule and with applicable state codes and regulations.  The Water Plant operators and other employees are trained in safety policies and procedures that are available to all personnel.  The City has written Stan 
dard Operating Procedures (SOP's) that are followed in the daily operation of the facility.  In addition, each employee receives on-the-job training, as well as special training sessions when new pieces of equipment are installed.  The maintenance program is well established and documented to ensure the proper operation and maintenance of equipment.  Furthermore, a procedure has been established for compliance audits and incident investigations that will be implemented when necessary.  The chlorine delivery drivers have been thoroughly trained for safe chlorine  handling practices.  Facility employees oversee the delivery of each chlorine truck. 
6. Five year accident history: Since June 21, 1994, there have been no accidental releases, fires, or explosions resulting from the chlorine system. 
7. Emergency Response Program:  The Water Plant's emergency response program is based upon the management system in-place, consisting of the appropriate discovery and notification procedures to ens 
ure coordination with the local emergency planning committee and the local fire department.  The City administers an Emergency Action plan (EAP) at the Water Plant to inform employees of potential emergencies that could occur at the plant and to minimize and mitigate potential impacts to persons and property. 
8. Planned changes to improve safety: 
A hazard review of the chlorine room was conducted on April 5, 1999.  From this review, recommendations were:  
a. Develop an Emergency Action Plan (EAP) for damage caused by severe weather, heavy equipment, fire, vandalism and terrorism (an EAP was completed for severe weather and fire - May 1999) 
b. Install "no parking" signs near container storage areas 
c. Develop Standard Operating Procedures for moving cylinders (SOP was completed May 1999) 
d. Document unacceptable delivery and handling practices by chemical supplier 
e. Develop a record keeping system for regulator installation errors, to test vacuum system lines with no demand, for any pi 
pe/valve failures for Segments 2 and 3 of the PHA (The record keeping system was completed May 1999 and is a part of the Process Safety Management plan (PSM)). 
f. Consider incorporating a chemical scrubber for containment of any potential chlorine release.
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