Town Creek Water Treatment Facility - Executive Summary |
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Executive Summary The Town Creek Water treatment Facility maintains a Risk Management Plan and Program for safe chlorine handling that involves an approach that integrates technologies, procedures, and management practices to monitor potential hazards and minimize the risk of accidental release. 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 Town Creek Water Treatment Facility disinfects water pumped from the Ocmulgee River. Chlorination processes include liquid chlorine cylinders, chlorination equipment, instrumentation, electrical equipment, and process specific safety equipment. The chlorination process accidental release modeling was performed for the respective area to determine potential consequences associated with operating failures resulting in accidental chlorine release. The first "worst case" scenario, defined by the EPA, states that "the owner or operator will assume that the . . . maximum quantity in the largest vessel . . . is released as a gas more than ten (10) minutes." The "alternative scenario" is "more likely to occur than the worst-case release scenario." The Town Creek Water Treatment Facility has no accident history, since it is a new facility. In each case, atmospheric dispersion modeling was performed to determine the distance traveled by the chlorine released before its concentration decrease 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-threatening health effects." The residential population within a perimeter corresponding to the toxic endpoint distance was defined to estimate the population potentially affected. The worst-case release scenario for the Town Creek Water Treatment Facility involves a failure of a one-ton cylinder yielding a cumulative release of 2000 lbs. of chlorine. When atmospheric dispersion modeling for this unlikely scenario was performed using the RMP* Comp Version 1.06, a distance to toxic endpoint 2.2 rural miles was obtained. The alternative release (more likely) scenario for all chlorination processes involves tubing failure, bad connection, or valve failure resulting in the release of 630 lbs. of chlorine. When atmospheric dispersion modeling for this scenario was performed using the RMP* Comp Version 1.06, a distance to a toxic endpoint of .1 rural miles was obtained. The Town Creek Water Treatment Facility 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 Continue with Key Elements to mitigate the effects of potential chlorine release . . . Safe and Effective Standard Operating Procedures Hazard Review of Equipment and Procedures Auditing and Inspection Programs Comprehensive Management Program The Town Creek Water Treatment Facility has an active environmental, health, and safety program with the following elements specifically supporting the safe handling of chlorine. Respirator Protection (SCBA) Program Chlorine Detectors Chemical Right-To-Know Program Personal Protective Equipment Program The Town Creek Water Treatment Facility has a written Emergency Response Plan, which has been coordinated with the City of Macon and Bibb County Fire Department which is a member of the Local Emergency Planning Committee (LEPC). Emergency response drills, drill evaluations, and facility tours will be conducted annually, at which time emergency operation and response procedures are also reviewed. The Town Creek Water Treatment Facility takes a pro-active approach to risk management and em ergency response through continuous joint training sessions between plant employees and local response agencies. These preventive measures will provide for the continuous improvement of communications and will maintain effective procedures for the safe handling of and timely emergency response to potential chlorine incidents. |