Chlorine is an essential element in the provision of safe drinking water.

It is also a hazardous chemical which demands care in transport, handling and use. In response to concerns about chemical related accidents (worldwide) Congress has enacted legislation which requires users of hazardous chemicals to take steps intended to reduce risk of accidents, ensure prompt response to accidents and inform the public of these actions. These steps are:

• Hazard Assessment - Evaluation of 'Worst Case' and typical accident scenarios and compilation of 5 year accident history.
• Prevention Program - Implement a comprehensive safety program.
• Emergency Response Plan - Implement emergency action and training plans.
• Risk Management Plan - Register and submit to USEPA a formal plan detailing the above steps (Deadline June 22, 1999)
• Public Information - Hold a public meeting to share information about this Plan (deadline Feb. 01, 2000)

Highland Park's Situation
The City of Highland Park's George B. Prindle Water Treatment Plant has been in continuous operation since its commissioning in 1929. During this time no (on or off premise) chlorine related injuries have occurred. This enviable safety record is typical of the water treatment industry because safety precautions have always been an important part of water treatment facility design. Our chlorine feed system features delivery of chlorine to the point of application in a line under partial vacuum. Should this line sustain damage, it will leak air into the line instead of chlorine out to the atmosphere.

Out of concern for the recreational boating and swimming facilities abutting our Plant, we incorporated a chlorine leak scrubber system into a facility upgrade in 1986, long before the attention of the public and regulators turned to this issue. This system features a leak detection system which can contain and neutralize the contents of a full ton chlorine cylinder without human intervention. Integral to this system is automatic notification of our Fire Department.

We have also built our own leak simulator from the head of an old chlorine cylinder. This device is used for in-house and in cooperative drills with the Fire Department to simulate various types of tank and valve failures. This enables us to maintain a high level of readiness as well as familiarity with the emergency procedures and equipment.

Our concern for the public safety had led us to explore alternatives to the use of gaseous chlorine. A component of our next Plant renovation effort is the evaluation of sodium hypochlorite as a replacement.

The Highland Park Safety Plan
In compliance with the Federal 'Risk Management Plan' (RMP) law, we have performed steps required to ensure continued safe handling of chlorine.

Hazard Assessment
We have considered the highly unlikely 'worst case' accident ramifications as required by Law so that our Safety Plan is adequate for all possible scenarios.

We have examined all conceivable leak modes and determined the most likely ones. Based on this, we developed the 'alternative scenario', which serves as a basis for planning responses for more common leaks.

Prevention Program
We have reviewed all critical components of our chlorine feed system as well as our preventative maintenance (PM) programs for this equipment seeking opportunities to increase reliability and minimize the opportunity for breakdown. We also reviewed all of the manufacturer's Operation and Maintenance (O&M) manuals and contacted the manufacturers of our chlorine system components to ensure that our PM system was thorough.

This process led to incorporation of additional maintenance and testing tasks into our existing equipment PM system procedures as well as upgrading of our chlorine leak detectors.

We also reviewed our existing procedures for such activities as employee training, 'Lockout/Tagout' procedures and coordination of work by outside contractors.

Emergency Response Plan
Any chlorine leaks, either in our chlorine tank storage room or our feeder room, is simultaneously alarmed throughout the Plant and at the Highland Park Public Safety Department's alarm panel. This alarm also automatically activates the Plant's chlorine scrubber system. If necessary, this system could neutralize the entire contents of a full chlorine cylinder.

The Fire Department responds to all chlorine leak alarms.

Most chlorine leaks are trivial, caused by a loose connection and occur while Plant personnel are changing tanks.

In these cases, the amount of gas leaking is so small as to not pose a threat to occupants of the room. These are immediately remedied by shutting the gas off and tightening the fitting. In the event of a significant leak, the Plant staff and Public safety personnel will inform the Park District personnel (during Park operation season & hours) so that appropriate safety measures can be take.

Such leaks would be secured by the Fire Department personnel assisted by the Plant staff. In preparation for such occurrences, we have built a leak simulator and conducted joint training.

Risk Management Plan
In accordance with the Clean Air Act, we have completed and submitted our Risk Management Plan to the US EPA. This plan details the actions taken to reduce the risk of accidental chlorine releases and to safeguard the public from such releases.

A plan detailing these actions has been submitted to the US EPA. (Available on the EPA web site.

For additional information, see:

• American Water Works Association
• United States EPA Chemical Emergency Preparedness and Prevention Office
• US EPA Risk Management Plan Info (RMP*Info) web page
• The Chlorine Institute
• The Chemical Manufacturer's Association
• The Chlorine Chemistry Council
• USEPA Drinking Water Page
• Or, Call the Highland Park Water Plant: Don Jensen Superintendent, (847) 433-4355