City of Grand Junction Water Treatment Plant - Executive Summary

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1. Accident Release Prevention and Emergency Response Policy. 
The United States Environmental Protection Agency (USEPA) requires all facilities which have specific hazardous chemicals above a defined quantity, or threshold level, in a process, to be in compliance with the Clean Air Act, (CAA) 40 CFR 112r Part 68. The ingestion of hazardous chemicals by humans in sufficient quantity will result in loss of life or serious injury. Chlorine is on the hazardous chemical list. The City of Grand Junction Water Treatment Plant (WTP) has more than the threshold quantity of chlorine on site. The Clean Air Act, 40 CFR 112r Part 68, requires us to comply and to observe specific safety precautions in handling this chemical. Release prevention and emergency response policies are in place to help prevent exposure to facility personnel and the community, given the life, health, and safety hazards associated with this chemical. It is the policy of the City of Grand Junction to adhere to all applicable 
Federal and State ruled regulation and safety precautions. The primary purpose of the City (WTP) is to treat water for city customers. Following other water treatment processes chlorine is used as a disinfectant. 
It is in the management's opinion that the City (WTP) Emergency Action Plans is in compliance with OSHA's Employee Emergency and Fire Prevention Plan, 29 CFR Part 1910.38. The emergency action plan includes procedures for notification of the Grand Junction Hazardous Materials Team (Haz-mat) to respond to all hazardous chemical releases at this facility, and to notify all potentially affected neighbors. 
2. Stationary Source and Regulated Substances Handled. 
The City (WTP) receives chlorine by truck transport in 2,000-pound containers. These containers are stored in the chlorine room. The chemicals are in a liquid/gas form. Each full container has 2,000-pounds of chlorine in it. By standard operating policy the (WTP) has a maximum of five full containers on hand at any one ti 
me. Therefore, the maximum amount of chlorine on hand at any one time is 10,000-pounds. 
During the process two containers of chlorine are attached to the feed system at any one time. The chlorine feeds from one container until it becomes empty; at which time the automatic switching regulator starts feeding from the full tank. The remainder of the inventory is in storage in the same room. 
Access to the (WTP) is restricted to authorized personnel only. The (WTP) operations personnel are thoroughly trained regarding the hazards and risks associated with chlorine. Specific operation and maintenance procedures are in place and strictly followed. 
The chlorine building is locked after hours when personnel are not present. The fire department has a lock box at the front gate, which contains the door key for all the facility doors. 
3. Worst-Case Release Scenario. 
The worst-case scenario for a one-(1) ton container of chlorine is the catastrophic failure of  the container due to corrosion,  
impact, or construction defects. This scenario assumes a release of 2,000 pounds of chlorine in  ten (10) minutes. The estimated perimeter from the facility that that could be affected is 0.9 miles. In this and any other scenario the Grand Junction Haz-Mat team would respond to this hazardous chemical release and would notify the public of actions to take in the affected area.   
This worst - case release scenario for chlorine does not include administrative controls and mitigation measures to limit the perimeter for this reported scenario as included in the next section. "Alternative Scenario". This scenario could also happen outside the storage building while off loading the truck delivering  the chemicals. 
Alternative Scenarios. 
The alternate release scenarios include administrative controls and mitigation measures to limit the exposure perimeter for each reported scenario. This scenario would happen inside the storage room for the chlorine cylinders. The alternative scenario assu 
mes a release from a one-(1) ton chlorine cylinder through a 1/16-inch valve body opening. These assumptions would result in the release of 11.3 pounds of chlorine per minute, or the release of 678 pounds of chlorine in 60 minutes. We are assuming it would take 30 minutes to respond and another 30 minutes to stop the release. 
In all of the scenarios the Grand Junction Haz-mat team would respond to these releases and would notify the public of actions to take in the affected area. 
4. General Accidental Release Prevention Program and Specific Prevention Steps. 
It is the managements's opinion that the (WTP) is currently in compliance with USEPA's Accidental Release Prevention Rule and all Colorado State codes and Regulations. The facility was designed and constructed in 1969 in accordance with National Fire Protection Association (NFPA) and local building codes. Equipment and components related to receiving,  and the feed process, are inspected daily and maintained according to manufac 
ture guidelines.  The employees of the (WTP) have been trained to follow specific operational and maintenance procedures while handling chlorine. 
The feed process for chlorine was updated in 1999 to reduce the risk of a release. The plumbing and regulators have been replaced so now the feed system is under a vacuum, which reduces the risk of a chemical release. The flow of chlorine is  automatically shut off in the event of leak in the vacuum system. 
Plant personnel check the chlorine feed system daily and a scheduled maintenance program is in place. Chlorine detection sensors are located in the storage room that set off an alarm in the event of a chlorine release. The Alarm at the chlorine building sounds an alarm and activates a strobe light visible from the front gate. After working hours, the alarm activates an automatic  telephone dialer system to call key personnel. Specific procedures are in place for after hour's alarms, and all the operations personnel have been trained to c 
arry out these procedures. The policy and procedures manual is reviewed and updated annually. 
5. Five-year accident history 
We have had no accidental releases.  
6. Emergency Response Program. 
It is the management's opinion that the (WTP) emergency response program is in compliance with the OSHA  Employee Emergency Plans and Fire Prevention Standard,  29 CFR1910.38(a). These standards and the (WTP) program is supported by the Mesa County Local Emergency Planning Committee and Grand Junction Haz-mat Team personnel. The Grand Junction Haz-mat Team has had specific on-site training at the (WTP) to prepare for and respond to a release at this facility. 
7. Planned Changes to Improve Safety. 
It is the managements opinion that this facility is in compliance with all NFPA standards currently adopted and enforced by the Grand Junction Fire Department. The Grand Junction Fire Department does not require any modifications to the current processes to become current with the new NFPA codes unt 
il expansion of the facility takes place. Any recommended upgrades or modifications requested at that time will be addressed.  
A number of alternative processes have been considered for replacement of the chlorine. This facility will continue to evaluate safer alternative ways to disinfect water in a cost-effective manner in the future.
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