K.T. Hutchinson Water Treatment Plant - Executive Summary |
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(a) Accidental Release Prevention Policy: The management and employees of this facility are very aware of the consequences of an accidental release. Accidental release prevention is, therefore, a matter of high priorty for all personnel involved in the handling, operation and maintenance of the chlorine process system and all of its components. Emergency Response Policy: The importance of immediately responding to an emergency due to an accidental release can not be over-emphasized. Failure to follow the plant emergency action plan promptly could result in major environmental damage and loss of human life. It is therefore imperative that all personnel, including management, be trained regularly on the plant emergency action plan and to ensure that it's initiation be possible any time the plant is operated. (b)Stationary Source: K.Thomas Hutchinson Water Treatment Facility 5592 Central Valley Road Murfreesboro, Tn. 37129 Regulated Substance: Chlorine Gas: CAS No. 7782-50-5 Maximum Inventory: 10,000 pounds (c) Worse Case Release Scenario: Worse case release could occur during the acceptance of delivery of full containers from the vendor. Chlorine is shipped to the facility in 1 ton containers and are delivered by truck outside the chlorine storage room. In the event that a container is dropped and a vessel rupture results, the chlorine gas would escape to the atmosphere with no containment available. This scenario predicts that the entire vessel (2000 pounds) would be released within 10 minutes. Plant employees are required to inspect the containers prior to acceptance for the following: i) Labeling and inspection markings as required by D.O.T. ii) Signs of corrosion, leakage or general lack of container maintenanc e. In addition, operators are required to perform a checklist inspection of the container lifting hoist every time it is used. This scenario estimates an End Point Distance of 3.07 miles. The estimated population is 6100 persons. Alternate Scenario: The most likely cause of an accidental release is a piping rupture. The most vulnerable spot for a piping rupture is the flexible connection used to connect the 1 ton containers to the process system. estimated release, based on container valve size and chlorine vapor/pressure characteristics, is 317 lbs in 60 minutes. (Chlorine detectors located in the area should provide enough warning to operators to isolate the containers from the flexible line within 1 hour.) In order to minimize the probability of the occurrence of this scenario, the flexible lines are tested for leaks each time a container is changed out and are replaced annually as a minimum. The containers are locate d within the facility when they are being used, therefore, in the event of such a release, employees are trained not to turn on the ventilation system, thus minimizing the rate of release to the atmosphere. (d) General description of release prevention: The release prevention program focuses primarily on the proper techniques of container handling, storage and operation and process system operation and maintenance. Operators involved in the handling, storage and operation of the containers are required to attend training on the proper techniques and the consequences of deviating from those techniques and must be authorized by the plant manager as chlorine handlers. Prior to plant certification, operators are required to train on the process system operation, its components and the maximum and minimum parameters as well as the consequences of deviating from the operating procedures or parameters. Most of the maintenance requirements of the process system (including the container hoist) have been contracted to vendors certified to perform the maintenance by the manufacturer. Maintenance performed by plant operators is minimized, and requires little or no system invasion. At any time the system must be opened, whether by operator or contractor, the plant lock-out/ tag-out program requirements must be observed. (e) Five-Year accident history: There have been NO accidents related to the chlorine process in the history of the facility. (Built in 1978). (f) General description of the emergency response program: In the event that an operator receives any indication of a release, the operator is required to perform an emergency shutdown of the plant. If the release is small and isolable, the operator will isolate it. The operator will then initiate the plant emergency action plan which includes notification of the plant manager, notification of local emergency respo nse agencies and evacuation of all personnel within the facility. (g) Planned changes for improved safety: 1) Installation of remote operators for container isolation valves. 2) Installation of cellular phone programmed to automatically initiate emergency action plan communications. 3) Installation of switch on access doors to provide automatic operation of ventilation system upon chlorine room entry. 4) Purchase of hand-held chlorine detector with digital readout. |