Smiths Water Treatment Plant - Executive Summary

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Section 1    Executive Summary 
The Smiths Water & Sewer Authority in the Community of Smiths has developed a Risk Management Plan (RMPlan) for the Smiths Water Treatment Plant.  It is their goal to have this plan implemented at the Smiths Water Treatment Plant in an effort to protect human health, protect the environment and meet applicable federal regulations.  This plant is operated by the Smiths Water & Sewer Authority and has a capacity to process 3.4 million gallons of drinking water per day.  It is located in Section 21, Township 18 North, Range 30 East.  The plant is located at 141 Lee Road 315, Smiths, Lee County, Alabama, 36877. 
This RMPlan has been developed to meet the standards published in the 40 Code of Federal Register (CFR) part 68.  Risk Management Program regulations were promulgated by the EPA to cover the accidental release prevention provision under the Clean Air Act '112(r)(7).  These regulations require facilities that exceed the cited threshold quantities for cer 
tain chemicals to develop a RMPlan.  The goal of a RMPlan is to focus on reducing the risk of accidental releases of certain chemicals; thereby, preventing harm to employees as well as potentially catastrophic impacts on the public.  Over 60 accidental releases of RMPlan regulated chemicals at water treatment plants (WTP's) and wastewater treatment facilities in the United States were reported between 1986 and 1995.  
The chemical currently used in the water process at this site that is covered by the regulation is chlorine.  The maximum potential amount of chlorine to be present on site at any one time is 8,000 pounds.  Chlorine is stored in one ton cylinders, and although there is a potential for 8,000 pounds to be present on the site at any one time, typically, at least 2 of the cylinders are empty, usually leaving less than 4,000 pounds on site.   
A hazard analysis was performed to estimate the potential off-site consequence.  An analysis was performed for two different release sc 
enarios.  The first release scenario is the case defined by the Environmental Protection Agency (EPA) as the "worst case" scenario.  This scenario assumes that the largest vessel of each chemical is full and it releases the entire contents of the containers during a ten-minute period.  The second scenario (or alternative scenario) is based on a situation more likely to occur which will cause a release of chemicals at the facility.  The radius of impact was determined based on the guidance provided in Chapter 4: "Offsite Consequence Analysis" of the General Guidance for Risk Management Programs dated October 27, 1998 and the Compliance Guidance and Model Risk Management Program for Water Treatment Plants (American Water Works Association). 
In both release scenarios, the toxic end point concentration remains the same.  The toxic end point for chlorine is three parts per million (ppm) or 0.0087 milligrams per liter.  The American Industrial Hygiene Association (AIHA) has listed these con 
centrations as the "maximum airborne concentration", at which nearly all individuals could be exposed to for up to one hour without experiencing or developing life threatening health effects.  This concentration is referred to as the Emergency Response.  Results of the off-site consequence analyses for the EPA "worst case" scenario led to an area defined by a 2.6-mile radius for chlorine.  According to the Landview III (1990 census data) program, approximately 6,450 residents are located within the 2.6-mile radius.  The alternative off-site consequence analysis yields significantly smaller areas.  The off-site analysis for chlorine indicates a 0.48-mile radius to the end point concentration.  Based on the 1990 census data, approximately 290 residents are located within the 0.48-mile radius. 
The key to a successful risk management program is to first define hazard and undertake a comprehensive approach to prevention.  The Center for Chemical Process Safety has defined hazard as: 
A che 
mical or physical condition that has the potential for causing damage to people, property or the environment  
Once hazards are identified on the site, then, an evaluation of the risk involved will lead to a systematic identification, evaluation, and control of potential losses that may arise in operation from future events such as fires, explosions, or toxic chemical releases.  The operations and prevention plan portions of this RMP sets forth inspections and maintenance requirements of equipment, employees training and periodically reviewing readiness.  Throughout this RMPlan, the emergency readiness procedures and regular training schedules are emphasized.  One of the goals of implementing these procedures and schedules is to minimize the chance of a release occurring.  If the plant employees practice preventative maintenance and are well trained in emergency procedures, if a release occurs, they will be successful in preventing and minimizing personnel injury. 
All employees at the 
Smiths Water Treatment Plant are required to know the locations of the emergency telephone numbers and names of individuals to contact in case of a release.  If an emergency occurs, each employee will have an assigned task.  This RMPlan details which individuals will respond to the release to stop it and it outlines the agencies that will be responsible for evacuating the appropriate areas, and for sounding the "all clear" once the leak is contained.  The plan also includes procedures for the periodic review of readiness. 
No major or minor releases have occurred at the Smiths Water Treatment Plant to date.  One goal of this RMPlan is to maintain the plant's current safety record. 
This plan includes the following sections: 
7 Program Requirements 
7 Hazard Assessment 
7 Emergency Response 
7 Prevention Plan 
7 Audits 
Material Safety Data Sheets (MSDS), Tier 2 reports, employee training certificates and release confirmation and report forms will be maintained as part of this document.
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