Courtney Bend Water Treatment Plant - Executive Summary |
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City of Independence, Missouri Water Department Risk Management Plan Executive Summary The purpose of this document is to inform interested persons, including the public, that our facility is complying with the Environmental Protection Agency (EPA) Accidental Release Prevention Requirements: Risk Management Programs under the Clean Air Act Section 112 (r)(7). We fall into the Program 2 Prevention Program. We have liquid chlorine in quantities above the threshold quantity as specified in Section 68.115 of 40 CFR Part 68, and therefore must comply with the RMP program. This program provides our facility with an integrated approach to identifying and managing the hazard posed by regulated substances. Under this program, our facility has assessed and continues to assess hazards to determine how accidental releases can impact the public health and environment. Because we are committed to the succe ss of our written risk management program, we encourage all suggestions. We strive for a comprehensive, integrated prevention system, which obtains clear understanding, safe behavior, and involvement in the program from every level of our facility, as well as the general public. The City of Independence Water Department's Courtney Bend Water Treatment Facility has been treating well water at its current location since 1955. The plant is located on the south side of the Missouri River, about 1/4 mile west of M-291 Highway. The plant is capable of treating 42 million gallons of water per day. Chemicals used to treat the well water are stored at the plant. Liquid chlorine is stored in an elevated rack outside the operations building in 15 1-ton containers. Anhydrous ammonia is stored inside the building in 150-pound cylinders, for a total of 2,250 pounds. Our ammonia storage falls below the threshold quantity for 40 CFR Part 68. Also used in the treatment process is lime (ca lcium oxide), which is stored inside the operations building, in quantities as great as 550,000 pounds. Lime requires special handling due to its hydro-thermic nature, but is not listed on the EPA's list of hazardous chemicals. Worst-case and Alternative Release Scenarios The Water Department used RMP*Comp to determine the affected area of our worst-case and alternative release scenarios. For our worst-case scenario, we used the parameters specified in the regulation (40 CFR Part 68.22). RMP*Comp determined that our area of impact if releasing one ton of liquid chlorine under these parameters would be an area within a 3-mile radius. Although we left the area as a circle in our risk management plan, we believe that an actual release will not follow a perfect circle. The water treatment plant sits below the river bluff. About = mile south of the plant, the topography rises considerably. Since chlorine gas is heavier than air, it is unlikely that chlorine would travel 3 miles to the south of the treatment plant. Landview was used to estimate population residing within the 3-mile radius. We consider Landview's computation of 6900 people to be high. We counted the population within a 1.5-mile radius at 55 persons, using property owner information. For our alternative release, we selected a scenario that would be more likely to occur than the release specified in the worst-case scenario. We prepared a model based on a twenty-pound chlorine release. The model did not show any chlorine would leave plant property. This scenario is based on a possible leak in the piping that runs from the chlorine storage rack to the treatment building. This area is the most unprotected area, and might be the most likely place for a leak to occur. Our facility is required to comply with state and federal Emergency Planning and Community Right-to-Know laws, which require that we notify local and state emergency planning committees of the ty pe and amount of chemicals we store. In addition, we comply with the National Fire Prevention Association 704 marking system, the Federal Hazard Communication Standard, and the OSHA Chemical Hygiene Plan. We developed our emergency response plan with assistance from the City of Independence Emergency Management Coordinator, and representatives of the Sugar Creek, Independence, and Kansas City Fire Departments. All our plant staff have been trained at the Operations Level of Hazwoper (8 hours). Staff members who will assist in chlorine leak response have been trained at the Technician Level (24 hours). Five-Year Accident History We have had no accidental releases of chlorine in the last five years. In addition, the Courtney Bend Water Treatment Plant has had no significant chlorine releases in its 45-year history. Emergency Response Plan As stated previously, our emergency response plan was developed with assistance from our City of Independence Emergency Management Coordinator, and several local fire departments. Trained water plant staff members will respond to small chlorine releases, such as a leak in piping. In the unlikely event of a major chlorine release (such as a ruptured ton container), emergency response personnel will be contacted. Sugar Creek, Independence, and Kansas City Fire Departments will respond as needed. In such a case, water department trained staff will be available to provide assistance as needed. Provisions are made for notifying the public, as may be appropriate. Planned Changes to Improve Safety Although the water plant has not had a major chlorine release in its history, we are making improvements to enhance our plant safety. Currently, an enclosure and scrubber system is being designed for the chlorine storage rack. We anticipate construction to begin in late 1999. This enclosure will increase plant worker safety, and will significantly red uce the risk of offsite impacts from chlorine releases. The enclosure will include the piping running below the rack that was used in our alternative release scenario. The City of Independence Water Department considered all procedures and equipment in the chlorine process as part of our hazard review. Several procedures were revised as a result, including preventative maintenance procedures, contractor safety orientation, additional staff training, and chlorine delivery procedures. All of these revisions were designed to decrease the possibility of a chlorine release. |