Jordan Valley Water Treatment Plant - Executive Summary

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1. Facility Description  
The Jordan Valley Water Treatment Plant (JVWTP) located at 15305 South 3200 West, Bluffdale, UT, is owned and operated by the Jordan Valley Water Conservancy District (District).  The JVWTP uses chlorine for disinfection as part of the treatment process.  Disinfection is required for all treated surface waters before being distributed for human consumption.  Liquid chlorine is shipped to the JVWTP in one-ton containers, and fed as a gas into the process.  The JVWTP is staffed 24 hours a day, 7 days a week, and the facility is equipped with appropriate chlorine detection, alarm, and scrubber systems.  All chlorine related equipment is routinely inspected. 
2. RMP Applicability 
The JVWTP normally maintains a chlorine inventory of approximately 16,000 lbs with a maximum possible inventory of 32,000 lbs.  This quantity exceeds the 2,500 lb threshold of the Risk Management Program (RMP) established by the EPA, making the JVWTP subject to RMP reg 
ulations.  The JVWTP is currently subject to the Process Safety Management (PSM) regulations established by OSHA, and complies by maintaining a chlorine leak prevention program and emergency response plan. 
3. Required RMP Elements 
Required elements of the RMP includes documentation of the management system, a hazard assessment, a leak prevention program, and an emergency response plan. 
3a. Documentation of the management system defines the staffing and organization of the JVWTP and states that the Operations/Compliance Manager has overall responsibility for the implementation of the RMP.  It also defines the delegation of responsibility for specific program elements. 
3b.In addition to the facility's five year accident history, the hazard assessment includes a determination of the off-site consequences for both the worst-case and alternate-case leak scenarios.  Using parameters specified by the EPA, the distance traveled by a release in these scenarios was determined using the EPA's 
Off-site Consequence Analysis Reference Tables in conjunction with EPA approved Dyadem RMP Pro98 and ALOHA air model programs.  The distance determined reflects the distance traveled by the release before reaching the toxic endpoint for chlorine of 0.0087 mg/L or 3 ppm as defined in 40 CFR '68.22.  The LandView III program was used for mapping, locating off-site receptors, and estimating the affected population. 
3b(1) Parameters for of the worst-case scenario were predetermined by the EPA to include the release of the single largest vessel over a ten-minute time period.  For the JVWTP this would be the release of one 2000 lb container over ten minutes resulting in a release rate of 200 lbs/minute. Using the EPA Reference Tables, the distance traveled for this scenario was determined to be 0.9 miles affecting a population of approximately 67 people. 
3b(2) Conditions of the alternate-case scenario are meant to reflect a more realistic set of release conditions specific to the facility 
.  Active mitigation factors can be considered for alternate-case scenarios.  The JVWTP is equipped with a  chlorine scrubber system designed to mitigate any release inside the chlorine room.  Therefore an alternate-case scenario involving the mishandling of a container during unloading was chosen.  This would take place outside the facility where the only mitigation would be operator intervention.  Using the ALOHA model, the  release rate was estimated at 39.1 lbs/min resulting in a 1.0 mile toxic endpoint distance affecting a population of approximately 191 people. 
3b(3) There have been zero accidents resulting in major injury, death, or damage at the JVWTP since construction of the facility including the 5 years preceding the creation of this document. 
3c. The leak prevention program is very similar to the prevention program required to comply with OSHA's PSM requirements.  The program includes the following items specific to chlorine system: process safety information; a process  
hazard analysis; operation, maintenance, and training procedures; a review of mechanical integrity; procedures regarding visitors, contractors, and tours; changes to the process; and incident investigations.  
3d. The JVWTP maintains an emergency response plan which includes evacuation/shelter procedures, notification procedures, and procedures to account for employees and visitors.  The plan also includes updated personnel information for emergency response team members and outside agencies including their duties and responsibilities.  The emergency response plan has been coordinated with the Local Emergency Planning Committee (LEPC) of Salt Lake County, and other local fire departments.  Should there be a need for outside agency assistance, these agencies are  prepared to assist with any medical needs, traffic control, or evacuation/sheltering of the public which may be required. 
3e. The procedures and policies outlined regarding the chlorine process, emergency response, and trainin 
g found in the PSM/RMP document will be reviewed regularly.  All recommendations will be evaluated, and those deemed necessary will be implemented as soon as is reasonably possible.  This is  to ensure the safest possible environment for the JVWTP employees and the public.
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