The Talladega/Shelby County Water Treatment Plant - Executive Summary |
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THE UPPER BEAR CREEK WATER FILTER PLANT EXECUTIVE SUMMARY FOR CHLORINATION PROCESS 1. Accidental Release Prevention and Emergency Response Policies The Upper Bear Creek Water Filter Plant is strongly committed to employee, public and environmental safety. This commitment is inherent to a comprehensive accidental release prevention program in place that integrates areas such as design, installation, management practices, operating procedures, maintenance, and employee training associated with the chlorination process at our facility. The chlorination system at our plant is one of the most simplified and safest chlorination systems available for disinfecting water. Appropriate controls and alarms are also in place to prevent possible releases of chlorine. Furthermore, all applicable procedures of the U.S. Environmental Protection Agency (EPA) Prevention Program Level 2 are adhered to. In the event an a ccidental release does occur, our facility is coordinated with the Marion County Emergency Management Agency, local fire and police departments, as well as, Harcross Chemicals in Muscle Shoals, Alabama. These institutions provide highly trained emergency response personnel to control and mitigate effects of the release. 2. Our Facility and the Regulated Substances Handled Our facility is a publicly owned water treatment plant. Our primary activity is treating potable water and pumping it into the distribution system for public use. We provide water to many residents, businesses, and industries in Bear Creek, Haleyville, and Phil Campbell, Alabama. We have one regulated substance, Chlorine. Chlorine is used for disinfecting the water. The maximum inventory of Chlorine at our facility is 6,500 pounds. 3. The Worst Case Release Scenario and the Alternative Release Scenario Two possible chlorine release scenarios, a "worst cas e release" and "alternative scenario" were analyzed in accordance with EPA's RMP regulations. To perform the required scenario analyses for our facility, we used reference tables for the Area Locations of Hazardous Atmospheres [ALOHA(R)] model provided by the American Water Works Association (AWWA). The following paragraphs provide details of the chosen scenarios. The worst case scenario, as required by EPA, assumes the maximum quantity of chlorine in the largest vessel is released as a gas over ten minutes due to an unspecified failure. Our largest vessel is a ton (2,000 pounds) container. Neither passive nor active mitigation was considered. At class F atmospheric stability, a 1.5 m/s windspeed, and a temperature of 101xF, a maximum distance of 3.04 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. The potentially affected residential population was estimated to be approximately 2258. Nineteen public rec eptors and no environmental receptors were identified in the toxic endpoint area. The alternative release scenario assumes the chlorine release is less severe and is more likely to occur than the worst case release scenario. The scenario chosen involves a tubing failure, bad connection, or valve failure resulting in the release of gas through the 5/16 diameter valve body opening. The total quantity released is 317 pounds with a maximum sustained release rate of 10.5 pounds per minute. At class D atmospheric stability, a 3.0 m/s windspeed, and a temperature of 101xF, a maximum distance of 0.57 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. The potentially affected residential population was estimated at 80. Five public receptors and no environmental receptors were identified in the toxic endpoint area. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps. Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA regulations. The following sections briefly describe the elements of the release prevention program that is in place at our facility. Safety Information Our facility maintains a record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with the chlorine process. Hazard Analysis Our facility conducts a comprehensive overview and analysis of our chlorination system to ensure that the associated hazards are identified and controlled efficiently. The methodology used to carry out this analysis is a hazard review checklist specifically designed for water treatment plants. This checklist was designed to meet the requirements of The Chlorine Manual published by The Chlorine Institute. The analyses are performed by qualified personnel and are revalidated at regular intervals. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our chlorination process, our facility maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, and start-up after a change. The information is regularly reviewed and is readily accessible to operators involved in the chlorination process. Training Our facility has a comprehensive training program in place to ensure that employees who are operating the chlorine process are competent in the operating procedures associated with the process. Refresher training is provided at least every three years in accordance with EPA's RMP regulations and more frequently as needed. Maintenance Our facility has established routine maintenance checks on the chlorine process equipment to ensure proper operations. Process equipment examined by these checks includes among others, ton containers, piping, chlorinators, vent systems, rotometers, and ejectors. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Compliance Audits Our facility conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. In accordance with EPA's RMP regulations we perform these audits at least every three years. Any corrective actions resulting from these audits are completed in safe and timely manner. Incident Investigation Our facility promptly investigates any inciden t which resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations provide valuable information for assessing all possible causes of the incident ranging from human error to equipment failure. In addition, possible corrective actions are identified to prevent the accident from recurring. All reports are retained for a minimum of five years as required by EPA's RMP regulations. 5. Five Year Accident History Our facility takes pride in doing everything possible to prevent accidental releases and has had an excellent record of preventing accidental releases over the last five years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response In the event of an accidental release of chlorine, we at the Upper Bear Creek Water, Sewer and Fire Protection District have opted not to implement an Emergency Response Program. Instead, in accordance with RMP regulations, we have included our facility in the community emergency response plan and have the appropriate procedures in place to notify emergency responders when there is a need to respond. 7. Planned Changes to Improve Safety As a result of preparing this Risk Management Plan, our facility will take the extra step to ensure all employees continually receive the appropriate training required to safely operate the chlorination system. We will also begin implementing a chain of command system (management system) which will ensure the proper personnel are knowledgeable of all on-going activities involving the chlorination system. In additon, we are replacing a natural gas heater, a potential fire hazard, with an electric heater. |