Town of Valdese Water Treatment Plant - Executive Summary

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Town of Valdese 
RMP Executive Summary 
The Town has implemented a comprehensive program to safely manage chlorine at its water and wastewater treatment plants located adjacent to the Town. There have been no chlorine incidents in the most recent five-year history period. 
In 1994 and 1995, a Process Safety Management (PSM) program was initiated at the Plants using internal resources. A PSM Implementation Manual was developed to be site specific for each plant. Key items included in the manual were: 
- Written site-specific procedures for Employee Involvement, Management of Change, Incident Investigation, Pre-Startup Reviews and Self Audits. 
- Chlorine safety information as required by the regulations 
Next, these additional steps were implemented to complete the PSM program. 
- Training on PSM and its key components including Management of Change, Mechanical Integrity and  Incident Investigation. 
-Conducting Process Hazards Analyses for the three chlorine processes 
-Developing Sta 
ndard Operating Procedures for Chlorine Management 
-Developing an initial Emergency Response Plan 
-Training in support of the certification of operators 
The supervisor, chief operator and several plant operators are meeting several times per year to review and update procedures and to maintain compliance with all aspects of the PSM regulation. 
In addition to PSM compliance, the plants have implemented a number of programs to improve the safe handling of chlorine and other chemicals 
- The chlorine delivery systems at the plants have been upgraded to vacuum processes over the past 5 years. This process has been proven to greatly reduce leaks by reducing the amount of equipment that is exposed to pressurized chlorine.                                                                 
- Chlorine inventories are managed to maintain typi 
cally a maximum of four cylinders on site at each plant.                                                                                                                                                                        
The site's Emergency Response Plans (ERP) have been significantly upgraded. In 1997, the ERP was revised to include offsite response and communication. The County LEPC and other local response organizations have been incorporated into the ERP. Where necessary, communication plans have been developed to notify businesses or residences that may be impacted by a release. Chlorine Response Drills are being implemented on a routine basis. The next drill is scheduled for the 3Q99. 
To further understand chlorine risks, a consulting firm was contracted to conduct "Offsite Consequence" Modeling Analysis, as required by EPA's Risk Management Program. Both a "Worst Case" and an "Alternative Case" chlorine release scenarios were studied for each site. 
The "Worst Case" modelin 
g showed the potential impact of a full, 2000 pound cylinder of chlorine released in 10 minutes. This resulting chlorine plume extended 1.3 miles.  For the "Alternative Case", a more probable type of release of 180 pounds, 3 pounds/minute for 60 minutes, was modeled. The modeling indicated that a plume 0.1 mile would result. 
The results showed that the risk of chlorine exposure is low due to the favorable location of the plants. 
- The Lake Rhodhisss Wastewater Treatment Plant is located north of the town on a high hill overlooking Lake Rhodhiss. Due to the topography and location of the plant, the most likely scenario would be for the chlorine to fall to the adjacent cove in the lake and remain in the cove until the chlorine cloud disperses. Thus, the impact of a chlorine release should result in no minimum public exposure. 
-The Town's Water Treatment Plant is also located north of the town on a high hill overlooking Lake Rhodhiss. The local typography at the site also favors the co 
ntainment of any leak, with the cholorine cloud falling down the hill to the cove on the lake. Thus, most chloride releases will have little to no impact on the surrounding areas. Also, the site has a large green belt that will contain most small to medium (up to 200 pounds) leaks on site. Thus, the impact of a chlorine release from this facility would be insignificant to the public 
-In addition to Process Safety Management, the organization has an active safety program. The Town has an active Safety Committee. The committee meets monthly and its duties include reviewing new safety procedures, accident investigations, safety surveys and safety communications. The Human Resource Manager for the Town also takes an active role in supporting the Utilities Safety Program.  
Within the Utilities department, there are monthly safety meetings to review an OSHA subject or discuss a safety issue. Routine training is conducted for topics such as: 
- Hazard Communications 
- Personal Protective E 
- Lockout/Tagout 
- Confined Space 
As a result of our programs, the plants have had an excellent safety record with no recordable injuries over the past three years. As mentioned earlier, there have no reportable chlorine releases from the plants in the last five years.  The Town has worked extensively to upgrade its safety progam.                                                                                                                                                                 
Report by:   Jeffrey V. Morse                                                               
Town Manager
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