Cameron Municipal Water Treatment Plant - Executive Summary |
Executive Summary Risk Management Plan 40 CRF Part 68 City of Cameron Water Department Accidental release prevention policies of Cameron, Missouri Water Department This program was developed to prevent the occurrence of, or minimize the consequences of releases by stating policies and procedures necessary for effective management of process hazards. It is the policy of the Cameron Water Department to provide its employees with a safe and healthful work environment and to conduct its operations in such a manner as to have minimal impact on the environment and the surrounding community. Every effort has been made to provide the greatest degree of safety possible for city employees and the citizens of Cameron. This Risk Management Plan includes all elements of the EPA regulations. including developing a process hazard analysis, standard operating procedures for the water treatment process, employee training programs, and preventive maintenance schedules. Water Department employees will be provided full access to this document, including the process hazard analysis and all other information contained in the risk management program. Primary activities The primary activity of the Water Department is to provide the City of Cameron with a safe reliable source of drinking water. This is accomplished through the use of chlorine gas as a disinfecting agent of the water supply. Chlorine gas is stored in one ton containers and is fed to various stages of the treatment process through a chlorination system. The maximum amount of chlorine in storage at the water treatment plant is three tons, in one ton containers. Two containers are connected to the chlorination system at any one time, one container is in use while the other is on stand by. General accidental release prevention program and chemica l specific prevention steps The Cameron Water Department has in place a preventive maintenance program covering all components of chlorination system. The preventive maintenance program is intended to insure the continued integrity of process equipment and to minimize the risk of a catastrophic chlorine release. This preventive maintenance program requires regular inspection and testing of chlorination equipment by the Water Department employees. The Water Department has an employee training program which includes all topics necessary for the safe operation and maintenance of the water treatment plant. All affected personnel receive training at the time of their initial assignment and whenever there is a process modification or alteration of the operating procedures, or change in individual job duties. It is the belief of the Water Department that compliance audits would be helpful in evaluating the effectiveness of the risk management program. It is the opinion of the city o f Cameron Water Department that audits conducted at regular intervals by a multi-disciplinary employee- management team, and a review by that team of the risk management program in force at the time for effectiveness and applicability, making recommendations for changes and revisions, as necessary would be beneficial. Five-year Accident Plant History There been no chlorine releases at the Cameron Water Treatment Facility during the five-year period preceding the date of this report which resulted in death or injury to water division personnel or to the general public, significant property or environmental damage on and off-site. Worst case release scenario and alternative release scenario In the worst-case scenario, a one ton container of chlorine is dropped during delivery operations. The container ruptures upon impact with a concrete loading area and releases 2,000 pounds of chlorine gas to the atmosphere. The contents of the chlorine tank are expected to be released within ten minutes over urban terrain. The distance to the toxic end point for the worst-case scenario was determined cover an approximately 1.9 mile radius from the water treatment plant under conditions of category F (most favorable conditions) atmospheric stability and wind speed of 1.5 meters per second. This area includes most of metropolitan Cameron. In the alternate case for the chlorine gas release, a rupture or breakage occurs in the chlorination system at the chlorine storage area. The releases is assumed to have a duration of approximately 10 minutes. An estimated 2,000 pounds chlorine would be released to the atmosphere at the rate. of 200 pounds per minute. The reported amount of chlorine released during the alternate case scenario is considering all active and passive mitigation devices available at the water treatment plant. The distance to the EPA toxic end point for this scenario is 0.3 miles, using the RMP Offsite Consequence Analysis Guidance, RMP Comp version 1.06 to calculate the toxic end point. Emergency response program The scope of Water Department's emergency response and action plan includes both minor chlorine releases controllable by Water Department staff and contained within the water treatment plant, and uncontrolled, major releases requiring assistance from local emergency responder's and evacuation of plant personnel. All water treatment personnel will receive initial training in emergency response and evacuation procedures. This training includes employee duties and responsibilities in the event of a toxic chemical release, procedures for the proper use and maintenance of emergency response and protective equipment, proper use of communications equipment, pertinent telephone numbers and point of contact for emergency responders, and evacuation routes and locations of safe zones. Emergency response has been coordinated with the Cameron Fire Department, the Cameron Police Department, an d the Sheriff Departments of Dekalb and Clinton Counties. The Cameron Fire Department has responsibility for securing the area during the chlorine emergency. Notification of residents and neighboring facilities will be the responsibility of the Cameron Police Department and the Sheriff Departments of the two counties. Decontamination and cleanup efforts will be coordinated with the county hazardous material response team, and decontamination of the immediate leak area will be under the supervision of personnel from the team. In the advent of a major chlorine release, water department personnel will only offer technical assistance to emergency responders. Plan changes to improve safety The Water Department is committed to improving the quality of employee training and education programs, including training in the safe use chlorine and in appropriate emergency response. These programs are to be evaluated it regular intervals and updated and revised as necessary. Employee training will be documented to the fullest extent possible. Water Department personnel will continue to participate in drills and cooperative training with emergency responders in the local area. The chlorination system preventive maintenance program will also be evaluated, and if unsatisfactory conditions are noted or recommendations for corrective action are made, these conditions or recommendation will be promptly addressed and any outstanding problems will be resolved in a timely manner. |