Withlacoochee River WPCP - Executive Summary |
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WITHLACOOCHEE RIVER WATER POLLUTION CONTROL PLANT EXECUTIVE SUMMARY The City of Valdosta's Withlacoochee River Water Pollution Control Plant 'Risk Management Plan', for Safe Chlorine Handling, involves a unified approach that integrates technologies, procedures and management practices to monitor potential chlorine hazards and minimize the risk of accidental chlorine releases. All applicable procedures of 40 CFR 68.170 are addressed in the plan, which seeks to provide for employee safety, public health and response agency interaction. The facility uses chlorine to disinfect treated wastewater prior to discharging into the Withlacoochee River. The facility services the City of Valdosta area, north of Martin Luther King Jr. Drive and west of Forrest Avenue. The chlorination process include chlorine cylinder (pressurized ), chlorination equipment, electrical equipment and process specific safety equipment. Accidental release modeling was performed for the area to determine potential consequences associated with operating failures resulting in accidental chlorine release. The 'worst case scenario', defined by EPA, states " the owner or operator shall assume that the ...maximum quantity in the largest vessel ... is released as a gas over 10 minutes". The 'alternate case scenario' is defined as "more likely to occur than the worse-case release scenario". An incident history review was performed to identify the most likely case scenario. United States Environmental Protection Agency (USEPA) RMP*CompTM. modeling was used for the area to determine the distance traveled by the chlorine released before its concentration decreases to a theoretical "toxic endpoint'. This is defined by the American Industrial Hygiene Association as " the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing life-threaten health effects". The residential popu lation within a perimeter corresponding to toxic endpoint distance was defined to estimate the population potentially affected. The worst case release scenario for Withlacoochee River WPCP involves a failure of a one-ton cylinder yielding a cumulative release of 2,000 lbs of chlorine. When atmospheric dispersion modeling for this unlikely scenario was performed using EPA RMP Comp, a distance to toxic endpoint of 0.9 miles was obtained. One receptor was identified, with a population within this radius of two (2). The alterative release scenario for Withlacoochee River WPCP involves mechanical failure of one flexible manifold connection (pigtail) allowing the accidental release of one-ton cylinder of chlorine over a one hour period. Similar atmospheric modeling per the RMP*CompTM. modeling yields a more likely figure of 0.1 mile affected radius under normal atmospheric conditions. There were no receptors identified within the radius. In support of the probability that a worst case accidental release will not occur, a review pf process history indicates that no reportable accidental release (greater than a 10 lb quantity) have occurred within the past five years. The Withlacoochee River WPCPs' Risk Management Program includes the following key elements to mitigate the effects of potential chlorine release hazards: OPERATOR TRAINING, PREVENTIVE MAINTENANCE PROGRAM, PROCESS SPECIFIC SAFETY EQUIPMENT, SAFE & EFFECTIVE STANDARD OPERATING PROCEDURES, WRITTEN WITH OPERATOR PARTICIPATION, HAZARD REVIEW OF EQUIPMENT AND PROCEDURES, AUDITING & INSPECTION PROGRAMS and COMPREHENSIVE MANAGEMENT PROGRAM Further, Withlacoochee River WPCP has an active environmental, health and safety program with the following elements specifically supporting the safe handling of chlorine and the chlorination process: RESPIRATORY PROTECTION (SCBA) PROGRAM, CHLORINE DETECTORS, CHEMICAL RIGHT - TO - KNOW PROGRAM and PERSONAL PROTECTION EQUIPMENT PROGRAM The Withlacoochee River WPCP use the Vald osta Fire Department for emergency response responsibilities, coordinated with the Lowndes Emergency Management Agency. Emergency response drills, drill evaluations, and facility tours are to be performed annually, at which time emergency operation and response procedures are also reviewed. Withlacoochee River WPCP takes a proactive approach to risk management and emergency response through continuous joint training sessions between Withlacoochee River WPCP employees and local response agencies. These preventive measures will provide for the continuous improvement if commucations and will maintain effective procedures for the safe handling of and timely emergency response to potential chlorine hazards. We conducted a neighborhood open house and are willing to conduct tours of our facility for members of the public. |