Mountain Home Waste Water Treatment Plant - Executive Summary

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In this waste water treatment facility (Mountain Home Waste Water Plant), we handle chlorine which is considered hazardous by EPA, OSHA, etc.  The same properties that makes chlorine valuable as a water treatment chemical, aslo makes it necessary to observe certain precautions in handling chlorine.  Overall, the prevention of unnecessary human exposures, reducing the threat to our own personnal helath as well as our co-workers, and reducing the threat to nearby members of the community is the main goal of incorporating this risk management plan into our daily operations.  It is our policy to adhere to all applicable federal and state rules andd regulations.  Safety depends upon the manner in which we handle and use chlorine combined with the safety devices inherent in the design of this facility, with the safe handling procedures that we utilize, along with the training of our personnel. 
The primary purpose of this facility is to treat the waste water system by utilizing chemicals suc 
h as chlorine.  Chlorine is received by individual one ton cylinders and stored until needed.  Chlorine is fed into the waste water system by automatic vacuum operated feeders.  The vacuum system will prevent the continual operation of the system if there is an increase or decrease in operating pressure on the cylinders or feed lines.  Another prevention feature is the scrubbers system that is located inside the feed rooms that will activate upon a release of chlorine.  The scrubber systems pulls the vapors from the ground area, and neutralizes the chlorine in caustic soda.  Access to the site is restricted to authorized facility employees, authorized management personnel, and authorized contractors.  The maximum amount of chlorine at this Mountain Home Waste Water Treatment Plant , Mountain Home, AR, is 8,000 pounds of chlorine. 
Our employees conduct proper cylinder change-out procedures daily.  They also review operating procedures, and maintenance taks daily.  The prevention progra 
m for this facility is a level 2.  Lock-out/Tag-out Procedures are used to help prevent an accidental release of chlorine.  When maintenance is conducted on the chlorination system, the Plant Superintendent (Tom Hubbard), and the Plant Supervisor (Alma Clark) approve the proper installation of materials, and completed installation.  Any change in maintenance procedure is reviewed and approved by Tom Hubbard and Alma Clark.  All operators at this facility are knowledgeable in the proper start-up and shut-down procedures for the waste water treatment operations.  All guages are checked every hour, and the scrubber system goes through maintenance checks and work per manuafacturer's recommendation. 
Our emergency response program was developed with the assistance of Environmental Data Services, Inc., the Mountain Home Fire Department, and the Baxter County LEPC.  If a chlorine release occurs at the Hicks Road site, the chlorine alarm will sound, and the the scrubber system will initiate wh 
ich will neutralize any chlorine released inside the feed rooms.  Once the identification of a release is made by employees on duty, the notification to Tom Hubbard (Plant Superintendent) will be made so that determination of the extent of the release can be made.  If manual shutoff can be completed to control the release, it shall be done as soo as possible by personnel on-site.  If the release cannot be controled by active mitigation, then evacuation procedures will then be followed.  Tom Hubbard or the on-duty personnel will contact the Mountian Home Fire Department (911), and have them initiate the 911 call out service to the surrounding (affected) population.  The Mountian Home Police Department will be made aware of the evacuation emergency due to the 911 system.  Tom Hubbard will intiate the HazMat response team and initiate mitigation, response and evacutation measures. 
the worst case scenario for this facility is a one ton cylilnder failure, which would be a release of 2,000  
pounds of chlorine into the atmosphere.  Active mitigation has been considered for this scenario consisting of manual shutoffs, automatic vacuum feed chlorine system, and the scrubber system.  Passive mitigation has also been considered for this release scenario, which would be the release into an enclosed space with contact with outside air.  It is assumed that the entire contents of the cylinder are released as a vapor.  Te distance to endpoint of 0.078mg/l for the worst case scenarion is 3.5 miles.  The area surrounding the facility is considered to be urban due to the thick trees and vegetation, and the steep, hilly terrain.  This worst case release would impact approximately persons. 
An alternate release sccenario was determined for this Hicks Road location.  The cylinders operate on a vacuum feed system, so the amount of chlorie released at the Hicks Road site would be minimal (approximately 10 pounds).  This minimal amount of chlorine released would result in a distance to endp 
oint of approximatley 0.08 miles.  This relatively short distance would only impact approximately 3 persons surrounding the location (populations were based upon Landview software). 
There have been no accidental releases of chlorine from this facility in the past five years.  The automatic vacuum system, as well as the scrubber system , limits the amount (if any) of chlorine that escapes during operational periods.  Operators of the chlorination system are required to check instruments, cylinders, feed systems, etc. on a daily basis to aid in the prevention of accidental releases. 
This waste wate treatment facility complies with EPA's Accidental Release Prevention Rule, and with all applicable state/federal codes and regulations.
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