Rome Water Pollution Control Plant - Executive Summary
EXECUTIVE SUMMARY |
The Rome Water Pollution Control Plant (Rome WPCP) is an 18 MGD wastewater treatment facility, located at 212 Blacks Bluff Road, Rome, Georgia. The Rome WPCP is owed and operated by the City of Rome, Georgia and is subject to the requirements of 40 CFR part 68 ("Chemical Accident Prevention Provisions"). The Rome WPCP utilizes chlorine to disinfect treated wastewater and stores chlorine above the EPA Threshold Quantity of 2,500 pounds. The facility is subject to the "Program 2" requirements of the rule. The facility employs the use of one-ton chorine cylinders that are trucked to the plant site.
The goal of the City's risk management program is to prevent accidental releases of chlorine and mitigate the severity of releases that do occur. The program addresses specific actions the City will take to prevent accidental releases of chlorine into the atmosphere and reduce the potential impact on the public and the environment. The specific actions include the deve
lopment and implementation of a program containing the following key elements:
* Off-site consequence analysis (Worst-case and Alternative scenarios)
* 5-year accident history
* A management system to oversee and implement the program
* A Prevention Program that includes:
* Chlorine safety information
* Operating Procedures
* Employee Training
* Preventive Maintenance
* Incident Investigation
* Compliance Audits
* An Emergency Response Program
Accidental release modeling was performed to determine the potential consequences of an accidental chlorine release. Two accidental release scenarios where developed for the facility. The "Worst-case" scenario assumes that the entire contents of a one-ton cylinder (2,000 pounds) are released over a period of ten minutes (a scenario defined and required by EPA). The "Alternative" scenario is site specific and considered more likely to occur than the worst-case scenario. The alternative scenario is determined by reviewing the accident histor
y and using reasonable judgement and knowledge of the system. The EPA's RMP*Comp program was used to determine the estimated distance to the toxic endpoint during releases.
The worst-case release scenario for the Rome WPCP assumes failure of a one-ton chlorine cylinder and the release of 2000 pounds of chlorine over a ten-minute period. Using RMP*Comp and considering the Rome WPCP's urban surroundings (many obstacles in the immediate area), the distance to toxic endpoint was determined to be 1.3 miles.
The alternative, or more likely, release scenario for the Rome WPCP was determined to be a complete break of the inch I.D. pigtail that connects the cylinder to the manifold. The release rate determined using RMP*Comp would be 20.9 pounds per minute. Assuming that the entire contents of a one-ton cylinder would be released at this rate, the release would occur over a period of about 96 minutes. The five-year accident history was considered in determining this scenario. The only
reportable accident occurring at the facility in the past five years involved a valve that failed to seal on an empty one-ton cylinder. Assuming a pigtail was sheared and a valve failed, the entire contents would be released.
The distance to toxic endpoint for the Rome WPCP alternative scenario, assuming its urban terrain and the release of the complete contents of a one-ton cylinder over a 96 minute period, was calculated by RMP*Comp to be 0.1 miles (528 feet).
There was only one receptor within the radius of the alternative (more likely) release scenario for the facility, the Coosa River. Receptors for the Rome WPCP worst-case scenario include 2,170 persons, 822 residences, 5 schools, 1 nursing home, 1 prison, 2 recreation areas, 23 businesses, 11 other public receptors, and 2 wildlife sanctuaries.
A review of the accident history indicated only one reportable release at the Rome WPCP in the past five years. An employee inhaled some residual chlorine gas from an empty cylinder
during the process of changing cylinders. The employee was monitored at a local hospital for a short period and returned to work the same day. There was no appreciable amount of chlorine released. During a review of the incident it was determined that the valve on the cylinder did not completely close.
The City of Rome has developed a Prevention Program that addresses basic, sound prevention practices. Safety information includes general chlorine properties and hazards, a MSDS, a established maximum intended inventory of 32,000 pounds, safe upper and lower parameters for piping and equipment, and equipment specifications including the Codes and standards used to design, build, and operate the process. A hazard review process that is intended to prevent malfunctions or errors that may cause an accidental release has been established. A hazard review checklist and what-if questions are used to assist in the hazard review process. Operational procedures for startup, shutdown, tempor
ary, emergency, and normal operations have been developed. A training program covering chlorine safety, responder notification, SCBA use, and operation procedures has been outlined and implemented. The Prevention Program also includes preventive maintenance and incident investigation procedures, and a method of conducting compliance audits.
The City of Rome's senior management is strongly committed to safety. The City of Rome's existing Loss Prevention Program requires that all accidents be reported as to the cause, and the corrective action taken to prevent future accidents. Accidents are reviewed by the supervisor, safety officer and department head to ensure that all accidents are addressed appropriately. Unsafe conditions reports are also available to all employees to ensure that all safety related matters, including chlorine, are given the highest priority. Any accident involving chlorine requires a chlorine specific investigation in addition to the requirements of the Loss
During the initial hazard review for the Rome WPCP, only one major hazard was identified. The chlorine process area is located in a flood-plane, protected by the treatment facility's levee system. In the event of a catastrophic flood, and/or the failure of emergency power generators, the chorine process could become flooded. Procedures are in place to deal with such an event. Other items addressed in the hazard review included the need for warning signs, a wind sock, better labeling of equipment and controls, continued training in chlorine safety, and training to make sure that the recently written operational procedures are being implement properly. Training has already begun and the signs and labels are expected to be in place no later than July 31, 1999.
The Rome WPCP is by definition a "non-responding" facility. A response to a chlorine release at the Rome WPCP was previously developed by Rome-Floyd County Emergency Management Agency with the Rome-Floyd
County Fire Department designated as the first responder. The Rome WPCP's emergency response has therefore, changed very little. The Rome-Floyd County Fire Department, once notified, shall coordinate all release mitigation procedures and public notification. The risk management program includes a procedure to notify emergency responders, emergency response drills, and operator training.