Valdosta Water Treatment Plant - Executive Summary

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The Valdosta Water Treatment Facility is a water facility whose primary activity is the treatment of 
potable water.  The Facility uses one regulated substance, chlorine (CAS 7782-50-5) as a disinfectant 
to treat potable water during the chlorination process.  Chlorine is also used for hydrogen sulfide 
removal in the packed towers.  The chlorination process consists of chlorine storage and the 
chlorination system.  The chlorination process begins with the withdrawal of chlorine from the 
chlorine cylinders under positive pressure.  The chlorine gas travels through black iron pipes to 
chlorinators, where the chlorine supply is regulated and measured.  At the chlorinators, the pressure 
is reduced to a vacuum by the flow of influent through the injectors.  Chlorine is mixed with effluent 
water by chlorine injectors to produce a solution which is injected into the water supply for 
disinfection.  For hydrogen removal, chlori 
ne gas is transferred to the scrubbing towers where it is 
dissolved in the scrubbing solution. 
The hazard assessment was performed on the chlorination process using the United States 
Environmental Protection Agency (USEPA) RMP*CompTM. Model.  The worst-case release scenario 
was assumed to be the release of a one ton cylinder for a duration of 10 minutes in an enclosed 
building.  The alternative release scenario selected for the Facility was a failure scenario developed 
during the process hazard review and analysis.  In this scenario, a 3/8-inch diameter whip connecting 
a one-ton cylinder to the chlorination manifold is sheared off, creating a leak in the system.  The 
Facility has the capability of responding to and stopping the leak within one hour of detection.  For 
both scenarios, the off-site consequence analysis indicated that off-site receptors could be potentially 
impacted by the release of chlorine.  Although off-site areas would be impacted, we believe that 
safety procedures a 
nd mitigation measures will reduce the potential for off-site consequences and 
subsequent risks to the surrounding community.  Our safety devices include chlorine leak detectors, 
alarms, and an automatic system shut-off feature triggered by a loss in system vacuum from the 
chlorinators to its point of application.  In addition, the chlorine cylinders are housed in a building 
with exhaust fans and vents which would dilute the chlorine gas concentration should a release 
In order to fulfill the requirements of the Risk Management Program (RMP), we have developed an 
accidental release prevention program and emergency action plan for our facility. The accidental 
release prevention program satisfies the requirements for the EPA RMP.  The prevention program 
ensures that our facility is operated under safe conditions and that any risk of an accidental release 
of chlorine is minimized.  The program has been written to reduce the potential of an accidental 
release due to human error, or  
equipment failure at our facility.  In order to prevent the release of 
chlorine due to human error, our prevention program ensures that operating procedures are current 
and reviewed annually.  Training also plays a vital part in our program.  Employees and contractors 
working near or on the chlorination process are required to be trained in the chlorination process and 
the hazards of chlorine.    
To prevent equipment failure that could result in an accidental release, our program ensures that 
equipment inspections, tests, and preventive maintenance in accordance with accepted engineering 
practices and includes manufacturer's recommendations.  All chlorine cylinders are examined upon 
delivery and are rejected if there are any signs of damage.  In addition, equipment pertaining to the 
chlorine process is visually inspected daily.  The potential for a chlorine release is greatly reduced 
from the chlorinators to the injectors in the chlorination process due to the use of a vacuum system.  
In the event of an equipment failure resulting in a loss of vacuum from the chlorinators to the point 
of application, the chlorinators will automatically shutoff (i.e. failsafe).   
All existing and proposed future chlorination equipment have been designed according to applicable 
standards and codes.  The Facility maintains records and documentation on equipment inspection 
and tests.  Precautions are taken to ensure that new equipment and processes are inspected and tested, 
that all changes on the process are authorized, and employees are informed of changes. 
The Facility performed a Process Hazard Analysis (PHA) to address the hazards in the chlorination 
process and to evaluate and control where the potential for a chlorine release exists.  Employees were 
involved in determining hazards of the process and subsequent consequences.  It was recommended 
that automatic shutoff valves be placed on the cylinders to reduce the potential for a chlorine release 
from the cylinders to the chlor 
inators.  The automatic shutoff valves will shutdown the chlorination 
system if there is a leak at the chlorine cylinders.  It is anticipated that the automatic shutoff valves 
will be installed by June 21, 1999.  
Active employee participation will ensure the success of the RMP at our facility.  Employees have 
been assigned various tasks to ensure that all elements of the RMP are implemented.  We have 
developed many different forms to assist employees in recording and documenting the various 
elements of the RMP.  
At the time of the submittal of this Risk Management Plan, there have been no accidental releases 
of chlorine at our facility in the past five years.  However, in the event that there is an accidental 
release of chlorine, an Emergency Action Plan has been written in compliance with 29 CFR 1910.38.  
The Facility is also included in the community emergency response plan.  Employees at our facility 
do not respond to accidental releases of chlorine, but coordinate with outside  
responders.  Therefore, 
in accordance with 40 CFR 68.90, an Emergency Response Program is not required for our facility.  
In the event that a chlorine release occurs, all employees are required to evacuate the process area 
and report the incident.  The emergency action plan consists of evacuation procedures, facility 
emergency numbers, and coordination with Valdosta Fire Department.  The plan also addresses 
notification procedures to the public and the local emergency response agency.    
We conducted a neighborhood open house and are willing to conduct tours of our facility for 
members of the public.
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