Claremore Oklahoma Waste Water Treatment Plant - Executive Summary |
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The City of Claremore operates a Waste Water Treatment Plant (Facility) located at 1500 S. Choctaw Street in Claremore, Oklahoma. The Facility treats Claremore's residential and industrial waste waters before discharge to Dog Creek. The Facility uses one (1) regulated substance (chlorine) above the threshold quantity of the Risk Management Program rule (40 CFR 68). Facilities that use or store any toxic or flammable substances listed in 40 CFR 68.130 above the specified threshold quantities in a process, are required to develop and implement a Risk Management Program enforced by the US Environmental Protection Agency (EPA). The goal of this Risk Management Program is to prevent an accidental release of chlorine that could potentially cause harm to the public and/or the environment, and to mitigate the severity of any release that does occur. The Risk Management Program includes an analysis of the potential offsite consequences of an accidental release, a five-year accident history , a release prevention program and an emergency response program. The Facility has never had an accident involving chlorine that caused deaths, injuries, property or environmental damage, evacuations, or sheltering in place. In the event of an emergency involving the chlorine system, the Facility's emergency action plan requires an immediate evacuation of the Facility and immediate notification of the Claremore Fire Department. The Claremore Fire Department will be responsible for responding to the emergency and directing any required public evacuation or sheltering in place. The Facility has discussed this Emergency Response Plan with the Claremore Fire Department and members of the Claremore Fire Department have inspected the Facility. The Claremore Fire Department has the necessary equipment required to seal a leak in a chlorine ton-container. They are also equipped with self contained breathing apparatus (SCBA) that would enable them to enter the Chlorine Room and work to mi tigate a chlorine release. The Facility has implemented the Risk Management Program's Level 3 Release Prevention Program. Under this program the Facility has compiled process safety information and performed a process hazard analysis, developed and implemented written operating procedures and trained the employees that operate or maintain the chlorine system. The Facility has also implemented maintenance and inspection procedures to ensure the mechanical integrity of the chlorine system's equipment. Prior to implementing any change to the chlorine system, a management of change procedure will be adhered to including a pre-startup review of the chlorine system. The Facility will perform a compliance audit every three (3) years and will investigate all actual releases and any incident that could have resulted in a release. The Facility has involved its employees in the development of the Facility's Risk Management Program. The Facility requires the use of hot work permits involvin g any welding or other heat generating work either on or near to the chlorine system, and has implemented procedures for training of contractors and verifying contractors' qualifications. The maximum amount of chlorine stored at the Facility is approximately 10,000 pounds contained in the five (5) chlorine ton-containers and associated piping, valves and other miscellaneous equipment. The chlorine equipment is housed in a building. However, the ton-containers are delivered by truck and are offloaded outside of the Chlorine Room. The worst-case release scenario for chlorine would be an accident during offloading resulting in the rupture of one (1) chlorine ton-container and the release of its entire contents over a ten (10) minute period. This release would disperse in the atmosphere and the chlorine concentration would diminish with distance from the Facility. The EPA defines a 3 part per million (ppm) concentration of chlorine in the air as not having any serious long-term heal th effects on the general public. Based on the Risk Management Program Guidance for Waste Water Treatment Plants (WWTP Guidance) prepared by the EPA, the distance from the Facility to the point where the chlorine concentration has diminished to 3 ppm is 3.0 miles. This distance is known as the end-point distance. The area of potential impact is defined as a circle with its center point at the Facility and extending outward to the end-point distance, in this case 3.0 miles. 1990 census data as calculated by the LandView III program indicate that approximately 6,000 people live within this area of potential impact. The Claremore Quadrangle U.S.Geological Survey 7.5 Minute Series Topographic map (Claremore Quadrangle map), a DeLorme Street Atlas USA street map (DeLorme map), and the MARPLOT map indicate the area of potential impact contains at least one school, residence, hospital, park, jail, and commercial, office, or industrial area. A review of the Claremore Quadrangle, the DeLorme map, and the MARPLOT map failed to identify any sensitive environmental receptors with the area of potential impact. A more realistic release scenario known as the alternative-case release scenario was identified in a process hazard analysis (PHA) of the Facility's chlorine system. This release would be much smaller than the worst-case release, and it was estimated that it could be contained within one (1) hour or less by the Claremore Fire Department. This release could occur if an operator failed to properly attach the regulator to the chlorine ton-container's valve, and then opened the valve. This would cause a release of chlorine through the open valve at an estimated rate of 15 lb/min. This would immediately cause a very high concentration of chlorine in the Chlorine Room requiring the operator to immediately evacuate the Chlorine Room and implement the Facility's emergency action plan. As noted above, the Claremore Fire Department be notified under the Facility 's emeregency action plan and all employees would evacuate the Facility. It is anticipated that the Claremore Fire Department would use SCBA to enter the Chlorine Room and close the valve. Using the WWTP Guidance for a 15 lb/min chlorine release over a 60 minute time period, the endpoint distance was determined to be 0.2 miles. LandView III census data indicate that approximately 21 people live within this area of potential impact. A review of the Claremore Quadrangle, the DeLorme map, and the MARPLOT map failed to identify any sensitive environmental receptors with the area of potential impact. |