Albertville Water Plant - Executive Summary |
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Albertville Water Plant EPA ID: 35950LBRTV600W The Albertville Water Works facility (Albertville Water Plant (AWP)) treats on average 12 million gallons per day of water from nearby Guntersville Lake, located approximately 5 miles north of the city of Albertsville, Alabama. The AWP consists of several water purification treatment processes, including Chlorination, Filtration, Flocculation and Sedimentation. Chlorine gas has been in use for nearly a century as the choice disinfectant in the treatment of both sewage for discharge and surface and ground water for drinking. Currently the AWP maintains a maximum inventory or 8,000 pounds of Chlorine gas. Under EPA's Risk Management Program, Clean Air Act 112(r), any industry utilizing Chlorine, a regulated gas, above the threshold level of 2,500 pounds, must develop a Risk Management Plan and implement a Risk Management Program. The AWP, in implementing their Risk Management Program (RMP), is currently undergoing c hanges in both process design and operations, as well as improving on their emergency response preparedness plans. In the spirit and law of the RMP, the AWP recognizes and is pursuing optimal public involvement in response to regulated substance emergencies. The AWP acknowledges that as a result of being in compliance with the RMP Rule, the safety of the surrounding community as well as that of on-site workers is significantly enhanced. From improved record-keeping, training, operating procedures to better engineering design, the AWP is dedicated to minimizing the risk of using Chlorine gas while at the same time improving the quality of local services. Chlorine gas is required at the AWP for disinfecting surface water pumped in from nearby Lake Guntersville, as well to add a "polish of residual Chlorine" to finished drinking water leaving the facility. The AWP recognizes that Chlorine gas, if accidentally released into the environment, may cause severe injury and even dea th for a significant distance from the source. The AWP has recently adopted new policies under its RMP to prevent and prepare for the uncontrolled release of a regulated (toxic) gas from the AWP. The AWP is currently owned by Albertville Municipal Utility Board in Albertville, AL. Mr. Danny Baugh -Supervisor of Water Treatment Operations is responsible for the implementation of the RMP his contact number is ( 256.582.3780 ). Mr. Baugh's primary responsibility under the RMP will be to oversee the training and execution of the facility's health, safety and environmental programs. Additional individuals may be assigned responsibility for implementing individual requirements and will report to Mr. Baugh on delegated matters. Responsible individuals will communicate information to other employees involved in operation and maintenance of the regulated process involving Chlorine gas, as required. All responsible individuals so involved will be listed by name, title and duties, in the RMP located on site at this facility. Any material changes in the design or maintenance [except for "replacements in kind"] of the current regulated process will be introduced into the RMP by those delegated that authority under the guidelines of the RMP. The public may contact the AWP by calling (256) 878-3761or the Albertville Water Works office at (256) 582-3780 for information regarding more details about the Risk Management Plan. The AWP currently maintains up-to-date safety information related to the regulated substance, process, and equipment, including Material Safety Data Sheets for Chlorine, maximum intended inventories, and safe upper and lower temperatures, pressures and process flows for the regulated substance. Equipment specifications and process design Codes and Standards are also maintained in the RMP document on site. In the case of an uncontrolled release of Chlorine gas from the AWP, an integrated Emergency Response Plan has been adopted i nvolving the coordinated effort of several organizations, including the local Fire Department, Emergency Management Agency, local Police, Sheriff's office and local Medical Emergency services and Hospitals. The AWP is prepared to assess and repair incidental or controlled leaks of the regulated materials but is currently not authorized to respond to uncontrolled releases of Chlorine from their facility. Instead, the AWP has coordinated first response assistance from federally regulated Hazardous Materials (HazMat) specialists. Currently the Albertville, Guntersville and Albertville Fire Departments have joined together for first response action should an uncontrolled release of Chlorine gas occur on the AWP site. In coordination with local and nearby Police and Sheriffs, residents will be evacuated systematically, and as soon as decisions are made by the Emergency Coordinator (Fire Department) and others in the Emergency Chain-of-Command. EPA requires each regulated facil ity to analyze a Worst-Case Scenario release (the release of the entire contents of a regulated substance container) as well as an Alternative-Case Scenario in which the released regulated gas is brought under control at some point following uncontrolled release events. In the Worst-Case Scenario, detailed within the facility's RMP, a scenario is considered in which the uncontrolled release of the entire contents of a ton container of Chlorine gas occurs. There are no mitigation features included in this Worst-Case analysis, such as enclosed buildings or other structures, for the uncontrolled release of the regulated substance. The endpoint radius for such a release, in which injury to those exposed is potentially possible, was calculated using parameters which are facility specific as well as criteria provided by EPA. The endpoint radius was calculated to be 3.0 miles for the loss of a one ton containers of Chlorine gas. Close to the source of such a release the potential fo r serious injury is high. Of particular concern is the slough running east to west behind the AWP into Lake Guntersville. This waterway is home to a popular sand bar, where many boaters spend the day on a regular basis during the summer. Topographical features around the plant suggest that, notwithstanding a strong North to South wind, the chances are favorable for a cloud of Chlorine gas to escape downhill, move into the slough's valley, and move toward this popular beach. The AWP is preparing to post warning signs as well as install a siren which can be recognized and heard from this beach. All fire crews and other first responders are aware of, and implementing new strategy in preparation for, a possible emergency concerning this sensitive gas receptor site. The safety mechanisms in place at the AWP designed to prevent this scenario from occurring include vacuum regulator valves on the ton containers themselves. These valves release Chlorine gas only when a vacuum i s applied, hence, if a line should break in the Chlorine process manifold system the valves on the source will automatically shut off when the vacuum is lost. Although the potential for an entire ton container of the gas to escape the Plant's boundaries is unlikely, it can happen. The EPA requires all responders to such a release to coordinate with the local Emergency Management Agency, the Fire Department, HazMat specialists and other local authorities such as the Police Department and Sheriff's office, in order to effectuate the best plan for evacuation efforts, if needed, and other requirements to assure the greatest protection for those who may be exposed to the gas. As described below, recommendations have been submitted regarding improved maintenance and safety, the introduction of a community siren system, as well as initial response activities developed through coordinated efforts of the participating agencies and rescue organizations. In the analysis of the Worst-Cas e scenario release the AWP did not include mitigation features such as enclosed buildings or other physical devices which might otherwise quench or disperse the released gas and reduce the endpoint radius calculated. As part of the Worst-Case scenario Emergency Response Action the cooperating agencies considered, and is currently implementing, procedures for responding to sensitive receptors within the endpoint distance of the regulated gas. For example, local Schools, Hospitals and other sensitive receptor sites are currently being integrated into the community's Emergency Response Plan through the efforts of the Fire Department, LEPC, Police Department and others. Cooperative interaction between the various rescue organizations is enhanced under the RMP Program. An evaluation of the potential impact of released gas on the surrounding environment is also included in the RMP. USGS maps showing the effected areas within the endpoint distance are filed within the facility's RMP. The estimated population within the 3.0 mile endpoint radius is 2,200 persons. In the Alternative Release Scenario the AWP adopted conditions of uncontrolled release in which the failure of a check valve results in the release of the regulated gas for a period of approximately 30 minutes. At this time the gas is assumed to be arrested and brought under control by emergency response personnel. The endpoint radius for Chlorine was calculated to be 1.2 miles (AWP choose a scenario provided by the AWWA's Compliance Guidance and Model Risk Management Program for Water Treatment Plants. Mitigation features which impeded the dispersal of the released gases, such as an enclosed building, were integrated into the Alternative Release Scenario calculations. The population of Albertville affected within the 1.2 radius is estimated at 480 persons. Currently the regulated gases are connected to the Chlorine process within the Chlorine Building, a fire proof brick structure construc ted approximately ten years ago. This building is 150 feet from the Main Office at the AWP. The AWP maintains two Chlorine detectors which is set to activate a local and remote alarm system at 1 parts per million concentration. This detector is tested everyday for response. The Chlorine building is equipped with automatic closure of all doors and relatively tight containment of the internal atmosphere (which is environmentally controlled). In the event of a partial release of Chlorine gas it is anticipated that the bulk of the gas will be contained within the immediate vicinity of the Chlorine room. There have been no accidental releases of Chlorine gas beyond incidental events, such as minor leaks, in the last five years. During the development of the AWP's RMP Program several recommendations were made which are currently being addressed. Recommendations were introduced for windsocks, sirens, upgrading engineering process materials and instruments, and further upgr ading of AWP's standard operating procedures for all process activities which are material to the Chlorine process. From these Standard Operating Procedures training will be maintained to current industrial standards, and documented assuring that all Operators at the Albertville Filter Plant are competently trained in the design and everyday handling of Chlorine gas. |