City of Pulaski Water Treatment Plant - Executive Summary

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                      Executive Summary 
 
The City of Pulaski operates and maintains a Water Treatment Plant capable of producing a 
maximum of seven million gallons per day (MGD) of treated water to supply the City, County and 
three surrounding Utility Districts.  The Water Plant currently treats an average of 3.5 MGD and uses 
chlorine gas as a disinfectant in the treatment process.  The City uses approximately 180 pounds per 
day of chlorine in their prechlorination and postchlorination facilities.  The Water Treatment Plant 
utilizes ton chlorine cylinders manifolded in pairs with a backup pair to provide the supply chlorine.  
Additionally, the Plants stores two to four reserve non-connected cylinders to replace chlorine 
cylinders in service as they are depleted.  Typically no more than 10,000 pounds of chlorine are on 
the site at any time. 
 
The City of Pulaski Water Treatment Plant has developed this Risk Management Program in an 
attempt to identify all 
possible chemical emergencies which may occur and the best way to prevent 
the accidental release of chlorine to the atmosphere from the plant's chlorination facilities.  The City 
Personnel responsible for the daily maintenance and operation of the chlorination equipment conduct 
their work with the upmost professionalism and have a deep respect of the dangers involved with 
chlorine.  The City places chlorine safety ahead of all other matters.   
 
In addition to the Risk Management Plan, the City of Pulaski is subject to OSHA Process Safety 
Management (PSM) regulations.  The City is working with Tennessee OSHA to develop and 
implement an approved PSM plan for chlorine.  This has been coordinated with the Giles County 
Local Emergency Planning Committee and the City of Pulaski Safety Board to assure that all entities 
are aware of the possible dangers involved in a chlorine leak from the Water Treatment Plant.  The 
City has developed a written operations manual, emergency response plan and  
emergency action 
plan as a part of the OSHA PSM plan. As a part of the written operations manual, City personnel 
always conduct their work with the chlorine equipment at  a safe pace and double check all 
connections when changing tanks or adjusting the system.  Additional safety measures are installed 
in the form of ventilators and chlorine leak detectors which assist in the notification and protection 
of emergency personnel in the event of a leak. 
 
The emergency response plan outlines the proper procedures to follow in the event of a chlorine leak 
detection.  Upon detection of the leak, the plant supervisor will notify the emergency service 
coordinator as defined in the City of Pulaski's Emergency Operations Plan to coordinate assistance 
with outside emergency units.  The cause of the leak will then be determined so that appropriate 
actions may be taken to insure public safety.  The City of Pulaski Fire Department will act as 
standby rescue personnel for the plant operators while an a 
ttempt to stop the chlorine leak is made.  
The fire department personnel will be familiarized with the chlorine system so as to assure that, if 
necessary, they may be able to isolate the leak and stop it.  The Emergency Service Coordinator will 
work with the Pulaski Police Department and other personnel to alert nearby residents to remove to 
safety if the need arises.  Local radio stations may also be utilized to notify the public of the 
emergency condition and what to do. 
 
To date, the City of Pulaski has had no major accidental releases of chlorine which required action 
involving off-site receptors.  There have been no accidental releases of chlorine in the last five years. 
 
The Worst Case Scenario for the Risk Management Plan was evaluated as a rupture of a full ton 
chlorine cylinder and release of its contents to the atmosphere.  The most probable alternative release 
scenario has been determined to be a cracked and leaking supply line.  The EPA supplied 
RMPCOMP program was used to  
evaluate the area of effect for these releases.  Using this program, 
it has been determined that both scenarios will have some offsite impact.  The worst case scenario 
has an area of effect of 0.9 miles in radius and the alternate scenario has an area of effect of 0.1 miles 
in radius.  The worst case scenario could possibly affect approximately 3,700 people and public 
receptors involved include schools, hospitals, major commercial areas, churches and residences 
depending on the wind direction.  The alternate scenario could possibly affect 200 people with public 
receptors involving residences and churches.  The mitigation devices utilized in the alternative 
scenario include enclosure of the chlorine facilities and chlorine detection devices which will 
minimize the amount of the chlorine lost prior to detection and repair. 
 
The City of Pulaski is still reviewing its PSM plan to define required modifications and additions 
to improve safety.  A training session will be conducted at the end 
of the PSM review to inform plant 
personnel of the proper methods for reporting accidents and proper operational methods to minimize 
the chance of accidental release of chlorine.  Additionally the City is reviewing addition of a 
windsock to determine the wind direction in case of an emergency and a remote alarm light for the 
chlorine leak detector to improve detection response time.
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