Claremore Oklahoma Waste Water Treatment Plant - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

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 
'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.
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