City of Princeton, Water Treatment Plant - Executive Summary

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Risk Management Plan Executive Summary 
1.   The Facility Policy: The owners, management, and employees of the Princeton Water Treatment Plant are committed to the prevention of any accidental release of chlorine or hydrogen fluoride by utilization of proper equipment, fire prevention, regular inspections, maintenance and training of all persons that work with the chemicals.  Should an accident occur, the facility has oriented the local fire department and local emergency planning committee so they can plan for response to any release and minimize the impact of the release to people and the environment. 
2.   Facility Information: The primary activity at the facility is Water Treatment and in conjunction with this operation, the handling, storage, and use of 1) chlorine for disinfection of water and 2) fluorosilicic acid for fluorination of water.   
Chlorine is received, stored and used for water disinfection. The maximum quantity stored in a facility "process" is 12,000 pounds (6 sto 
rage containers).  The capacities of the individual storage containers are 2000 pounds each. 
Fluorosilicic acid is received, stored and used for fluorination of water.  The maximum quantitiy stored in a facility "process" is 3,500 pounds (four 275 pound drums).  Hydrogen fluoride is a decomposition product of fluorosilicic acid at 227oF.  Based on material balance, the maximum amount of hydrogen fluoride would never exceed 2917 pounds.   
3.   The Worst-case Scenario: would be the release of the total contents of a storage container released as a gas over 10 minutes.  The maximum quantity of chlorine released would be 2000 pounds and 730 pounds of hydrogen fluoride, which represents the volume of a single storage container.  The distance to the toxic endpoint of dispersion based on the RMP*Comp V1.06 model is 1.3 miles for chlorine and 1.4 miles for hydrogen fluoride. 
The alternative case release scenario for chlorine is assumed to be a release from the rupture of container (or line) 
with a 0.2 inch diameter hole, releasing 2000 pounds of chlorine over 20 minutes.  The alternative case release scenario for hydrogen fluoride is assumed to be a release from the rupture of container  releasing 730 pounds of hydrogen fluoride over 15 minutes. Both the chlorine and fluorisilicic acid storage rooms are enclosed and the models includes mitigation by the enclosure. The distance to the endpoint of dispersion is 0.2 miles for chlorine and 0.3 miles for hydrogen fluoride. 
4.   The accidental release program: The facility complies with the Rules and Regulations as set forth under USEPA  40 CFR 68, EPCRA 302, and USDOL. 
5.   The Five-year accident history: There have been no accidental releases of chlorine for the covered process in the past five years that have caused any deaths, injuries, or significant property damage on site; nor to our knowledge, have any accidental releases resulted in offsite deaths, injuries, evacuations, sheltering in place, property damage or envir 
onmental damage. 
6.   The Emergency Response Program: The facility has a written emergency action plan in accordance with OSHA standard 29 CFR 1910.38 and provides state and local authorities the emergency planning and community right-to-know information as required under SARA Title III of EPCRA.  Our emergency response action plan has been reviewed with the local fire department and provided to the local emergency planning committee for coordination in the community response planning. 
7.   Planned changes to improve safety: Safety improvements are an on-going process at the facility.  Periodic evaluations are performed to assess the maintenance of safe practices and operations.  There are no additional specific chlorine safety recommendations for implementation at this time.
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