Redstone Arsenal Water Treatment Plant #3 - Executive Summary
Executive Summary |
Redstone Arsenal (RSA) is located in Madison County, southwest and adjacent to the city of Huntsville, Alabama (Figure 1-1). RSA currently comprises 37,910 acres (including special-use permit land) located on an approximately six-mile wide by ten-mile long site (U.S. Army Missile Command, 1995). Approximately 29,000 government and contractor personnel are employed at RSA. Prior to acquisition by the Army, the land comprising the present day Arsenal was primarily used for producing cotton, corn, hay, small grain crops, and livestock.
The primary activity at the RSA water treatment plants (covered processes) is to treat water collected from the Tennessee River to industrial and Federal and State drinking water standards. Collection operations include pumping, storage, solids reduction, and bacteria and virus removal. Water is drawn from the Tennessee River at Plant #1 through intakes located approximately fifteen feet below the surface and treated to industrial
standards. The industrial water then pumped to Water Treatment Plant #3 where it is to domestic standards. Plant #3 uses rapid sand filters to treat the industrial water. The water flows into a 360,000 gallon clear well. Fluoride and chlorine are added to the water before it is pumped to storage tanks. There are 10 domestic and 2 industrial storage tanks that store water from Plant #3. Plant #3 has a capacity of 4.6 million gallons per day with an average flow of 3 million gallons per day.
This Risk Management Program (RMP) plan was prepared to cover one regulated chemical (chlorine) at Water Treatment Plant #3 located on Redstone Arsenal (RSA). Chlorine is used to treat the water to drinking water standards by reducing the quantities of bacteria and viruses in the water to acceptable levels.
Water Treatment Plant #3 has a maximum inventory of 8,000 pounds of chlorine stored on site in one-ton cylinders. This is above the threshold quantity of 2,500 pounds and 1,500 pounds u
nder OSHA Process Safety Management (PSM) program. This requires that the RMP meet Program Level 3 requirements. The chlorine cylinders are stored on their side in an open area where they are easily accessible, but covered to reduce the amount of rainfall that might reach them.
These processes were determined by conducting a thorough review of RSA's Tier II reports and a site inspection of each site where we expected to find RMP chemicals. A table was prepared and is included in the written RMP plan that details the results of this inspection.
Accident records were reviewed for the covered process. No known accidents have occurred in the past five years from operations involving the covered process.
An off-site consequence analysis was conducted of the process. The layout of the chlorine cylinders is such that when one cylinder is emptied, the second comes on line. It was therefore determined that the maximum amount that could be released was 2 one-ton cylinders, or 4,000
pounds. The worst-case scenario was modeled using the RMP-Comp program. The model assumed that the processes were in a rural setting. The modeling reveals that an evacuation radius of 4.2 miles results around Water Treatment Plant #3.
The release radii were drawn on USGS 7.5-minute topographic maps and the census data compared.
A worst-case release from Water Treatment Plant #3 would impact a population of 27,000. The release would impact an industrial area on Redstone Arsenal, including NASA's Marshall Space Flight Center, US Army Aviation and Missile Command, Chugach's support operations, and a commercial area along Montgomery Highway (US Highway 231). The southwestern portion of Huntsville would be impacted, including subdivisions referred to as McDonnell, Chelsea, Parkway Estates, Whitesburg Estates, Fleming Hills, Haysland Estates and English Village. The following schools would be impacted: Chaffee School and McDonnell School. The release would impact Wheeler National
Wildlife Refuge, the Huntsville Municipal Golf Course, Byrd Spring Lake and the Byrd Spring Rod and Gun Club.
Alternative release events were modeled based upon the document "Compliance Guidance and Model Risk Management Program for Water Treatment Plants" published by the American Water Works Association Research Foundation and the USEPA, ISBN No. 0-89867-965-6. Release scenarios CLA 3, CLA-4 and CLA-5, as described in Table 5-5 of the above referenced guidance document, were modeled using RMP-Comp. The scenario that resulted in the largest release radius was scenario I.D. CLA-5. The resulting radius was 0.6 miles.
Because of the determination that the process is subject to Program 3 prevention plan requirements, the site's OSHA PSM program was reviewed and modified to comply with the Program 3 requirements. When completely implemented, the installation will be in complete compliance with the OSHA PSM requirements and as a result, the EPA RMP requirements.
The prevention plan
consists of the following documents:
? Risk Management Procedures Manual
? PSM/RMP Program Manual
The Risk Management Procedures Manual establishes the RMP management system, the requirements for controlling documents, controlling records, and developing documents and procedures and the controlling confidentiality. Subsections of this document include the following:
? RMP Management System
? RMP Management Responsibility
? Numbering and Indexing
? Controlling Confidentiality
? Developing Policies, Procedures and Instructions
? Controlling Documents
? Controlling Records
? Establishing and Maintaining Libraries
? Controlling Nonconforming Conditions
? Managing Corrective & Preventive Action
The PSM/RMP Procedure Manual presents the specific procedures for the RMP program, such as the process hazard analysis procedures, training, employee participation, mechanical integrity, etc. The subsection headings include the following:
? Employee Participation Procedure
? Process Safety I
? Process Hazard Analysis Procedure
? Operations Personnel Training Procedure
? Operating Procedures
? Contractor Procedures
? Pre-startup Safety Review Procedure
? Mechanical Integrity Procedure
? Hot Work Permit Procedure
? Management of Change Procedure
? Incident Investigation Procedure
? Compliance Audits Procedure
RSA's emergency response plans and programs were reviewed and modified to comply with the RMP requirements. A section was added that specifically addresses releases of chlorine. This section was added as an addendum to RSA's Spill Prevention, Containment and Countermeasure (SPCC) plan and the Installation Spill Contingency Plan (ISCP). Where possible, references to existing sections of the SPCC and ISCP were made and new information was added and has been incorporated into the site-training program.