City of Danville Water Treatment Facility - Executive Summary

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This document presents City of Danville's Water Treatment Facility (Facility) strategy to comply with the Clean Air Act requirements of Section 112(r)(7), Accidental Release Prevention Requirements: Risk Management Program.  It is City of Danville's intent to enforce the policies and procedures presented in this document to prevent accidental releases of regulated substances or reduce the severity of those releases that do occur. 
The City of Danville Water Treatment Facility complies with Clean Air Act and Occupation Safety and Health Administration (OSHA) air emissions regulations and has policies in place to ensure continued compliance. 
The Facility is responsible for treating water for the City of Danville (SIC Code 4941). Chlorine Chemical Abstracts Services (CAS Number 7782-50-5) is used to destroy pathogens in the water prior to distribution. The Facility can store a total of seventeen (17) 1-ton cylinders, on site.  The Chlor 
ine Feed room can store a total of six (6) 1-ton cylinders including the three (3) cylinders connected to the chlorine feed system.  Approximately eleven (11) 1-ton cylinders can be stored on trunnions outside underneath a covered walkway.  The maximum number of 1-ton cylinders normally maintained on-site at the facility is approximately seven (7), six cylinders in the chlorine feed room and a maximum of one outside. 
The worst case release scenario involves the failure of one 1-ton container releasing approximately 2,000 lbs of chlorine.  In this scenario, the entire amount is released over a ten-minute period at a rate of 110 pounds per minute (lbs/min).  The distance to the toxic endpoint the chlorine would travel, before dispersing enough to no longer pose a health hazard, is 0.9 miles. 
The alternate release scenario involves the release of chlorine through a 5/16  inch diameter hole. The release rate is approximately 15 lbs/min. The distance to the toxic en 
dpoint is 0.1 miles.  This release would simulate failure of a cylinder valve. 
The facility is in compliance with the OSHA Process Safety Management (PSM) rule and, with this document, the Clean Air Act Accidental Release Prevention Program regulations.  The City of Danville Water Treatment Facility relies on a system of employee training, equipment maintenance and periodic testing to prevent accidental releases.  
To date, the City of Danville Water Treatment Facility has had no off-site impact caused by the release of chlorine.  The only releases of chlorine at the facility have been minor and have been associated with leaky valves on the 1-ton cylinders.  The facility has started purchasing 1-ton cylinders from a new supplier which has reduced the occurrences of these minor leaks.  There has only been one injury associated with the chlorine system, within the past five years.  This was a result of an improper seal i 
n the personal breathing apparatus used by an operator during the cylinder change over.  The operator was moved to fresh air and taken to the hospital for minor chlorine inhalation.     
The City of Danville Water Treatment Facility does not have an individual emergency response plan.  The facility has coordinated with the local community emergency response team to address releases at the facility. 
The City of Danville Water Treatment Facility has an ongoing maintenance training and operational training program to continuously update operator knowledge of systems within their facility.  Yearly training is provided on personal protection equipment and cylinder repair kit.
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