Cameron Municipal Water Treatment Plant - Executive Summary

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                     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.
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