City of Kingsport - Water Treatment Plant - Executive Summary |
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The City of Kingsport's Water Treatment Plant has a comprehensive risk management program. Trained plant personnel acting in conjunction with the Fire Department's Hazardous Materials Response Team ensures the local citizenry of optimum attention to accident prevention and hazard consequence response and mitigation. In the water treatment process for potable supply, chlorine is used as a disinfectant. Other technologies and chemicals are available to achieve disinfection, but all have shortcomings compared to the feasibility of chlorine. The plant can store up to 10 one-ton cylinders or 20,000 pounds of chlorine at any given time, exceeding the threshold of 2,500 pounds as established by the EPA, thereby qualifying this facility to comply with the elements of EPA's Risk Management Plan (RMP). The worst-case chlorine release scenario involves the rupture of a one ton cylinder whereby all 2,000 pounds of gaseous chlorine are released at a rate of 200 pounds per minute for 10 minutes . Other predetermined factors affecting the release are a wind speed of 1.5 meters per second and an "F" atmospheric stability class. Using EPA's Offsite Consequence Analysis (OCA) guidelines for urban topography, the resultant plume radius is 2.6 miles or a circle of influence 5.2 miles in diameter. Under this scenario, certain public and environmental receptors could be affected, depending upon wind direction, including schools, residences, one hospital, a state park, recreation areas, major commercial, office and industrial areas, and a bird sanctuary. The alternative or most-likely case scenario involves the failure of a transfer pipe from 4 chlorine cylinders, a typical arrangement with 2 cylinders in use and 2 on stand-by. Again using EPA's OCA guidance 1,268 pounds of chlorine would be released at a rate of 46.8 pounds per minute for 27.1 minutes. Also, the wind speed for this scenario would be 3.0 meters per second with a "D" atmospheric stability class. The resultant d istance to the endpoint of the radius would be 1.0 mile for an urban setting or a circle of influence 2 miles in diameter. The receptors affected by this scenario would be schools, residences, major commercial and industrial areas, and a bird sanctuary. The Water Treatment facility is in compliance with the Occupational Safety and Health Administration's (OSHA) complimentary regulation to EPA's RMP, or Process Safety Management (PSM) rule. The elements of the PSM that constitute the RMP's accidental release prevention program are described as follows: Management System - establishment of a management team headed by the Environmental Manager responsible for developing, implementing and integrating the risk management program elements; Employee Participation Plan - reflects the involvement of employees necessary to implement the RMP program; Process Safety Information - the compilation of written material to enable the employees involved in process operation to identify and understan d the hazards posed by the use of chlorine and how it correlates to the technology and equipment used in the process; Process Hazard Analysis - identifies, evaluates and controls the hazards involved in the process; Operating Procedures - development and implementation of written operating procedures that provide clear instructions for safely conducting activities involved in each process; Training - each employee presently or to be involved in operating a process is trained in an overview of the process and in the operating procedures including emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work pracitices applicable to the employee's job tasks; Contractors - those performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process, shall be knowledgable, trained and responsible in matters concerning PSM as it pertains to chlorine; Mechanical Integrity - development and implementat ion of a maintenance plan, inspection and testing procedures, deficiency correction plan, and a quality assurance program designed to ensure that equipment used to process, store, or handle chlorine is designed, constructed, installed, and maintained to minimize the risk of hazardous chemical release; Hot Work Permits - to document that fire prevention and protection requirements are met; Management of Change - development and implementation of procedures to manage changes in process chemicals, technology, equipment, procedures, and changes to facilities that affect a covered process; Incident Investigation - development and implementation of procedures necessary to thoroughly investigate each incident which resulted in, or could reasonably have resulted in a significant release of chlorine; Compliance Audits - provides assurance that compliance has been evaluated at least every three years, verifying that the PSM procedures and practices are adequate, observed, and reported. The City of Kingsport's Water Treatment Plant has not had a reportable incident during the past five years. The development and implementation of the PSM and RMP programs have increased employee awareness to the hazards of chlorine and the processes and procedures necessary to minimize the probability of a release and, if an event occured, minimize the associated risks. Continued improvement in the integrity of both programs will allow employees and the community to feel secure that all precautions are being taken to ensure their health and safety. The Emergency Response Program (ERP) has been tailored specifically to address the consequences of a chlorine release from this particular facility. Employees at the Water Treatment Plant have been trained in Personal Protective Equipment and Respiratory Protection as defined by OSHA requirements. This allows them to safely handle changing out chlorine cylinders and responding to incidental releases of gas sometimes experienced during routine procedures or taking immediate action to prevent a significant release from occuring. In the event of a significant release, a chlorine detector automatically activates an alarm and ventillation system. Simultaneously, plant personnel will notify the City's Fire Department (Hazardous Materials Response Team) via Central Dispatch, which will then promptly respond to the incident. Plant personnel will immediately evacuate the site according to procedure, with a designated coordinator(s) to rendezvous with the Hazmat Team at a predeterminded site outside the affected perimeter to discuss appropriate response procedures . The Hazmat Team is fully trained in hazard response and communication and will represent the Fire Department as the lead agency determined by the Kingsport Emergency Preparedness Plan. They also have access to a pre-programmed computer located in their van that enables them to predict the nature of the site-specific release. This was accomplished as part of a pre-pl an of the facility by the Hazmat Subcommittee of the Local Emergency Preparedness Council. With this information available, the responders can efficiently mitigate risk and inform the affected community about proper response action. Other Departments involved in the response include Police for traffic control, site security and assistance in evacuation, if necessary; TEMA (Tennessee Emergency Management Agency) for information, equipment and to notify the EPA; and Sullivan County EMS and the Kingsport Life Saving Crew to provide medical aid and transport of victims. A full-scale training exercise was previously conducted at the facility, resulting in invaluable experience and knowledge in responding to a significant release scenario. Continued training of personnel, updating of PSM and RMP programs, and mock demonstrations of release scenarios will assure the public, personnel, and responders that their health and safety are of highest priority should a significant release of chlo rine occur at the City of Kingsport's Water Treatment Plant. This will continue to be our philosophy as we seek to alleviate this hazard through the installation of mitigation or control equipment or using different technology. |