Graves-Foster Water Treatment Plant - Executive Summary |
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In this water treatment facilty (Graves-Foster Water Treatment Plant), we handle chlorine which is considered hazardous by EPA, OSHA, etx. The same properties that makes chlorine valuable as a water treatment chemical, also makes it necessary to observe certain safetu precautions in handling chlorine. Overall, the prevention of unnecessary human exposures, reducing the threat to our own personnal health as well as our co-workers, and reducing the threat to nearby members of the community is the amin goal of incorporating this risk management plan into our daily operations. It is our policy to adhere to all applicable federal and state rules and regulations. Safety depends upon the manner in which we handle and use chlorine combined with the safety devices inherent in the design of this facility, with the safe handling procedures that we utilize, along with the training of our personnel. The primary purpose of this facility is to treat the water system by utilizing chemicals such a s chlorine. Chlorine is received by individual one ton cylilnders and stored until needed. chlorine is fed into the water system by automatic vacuum operated feeders. The vacuum system will prevent the continual operation of the system if there is an increase or decrease in operating pressure on the cylinders or feed lines. Access to the site is restricted to authorized facility employees, authorized management personnel, and authorized contractors. The maximum amount of chlorine at this Graves-Foster Water Plant in Fulton, AR is 4,000 pounds. There are other wells and booster location located throughout the Hope, AR area which also contain chlorine in 150 pound cylinders. There are normally only 300 pounds at any of these locations. The Old Wel #'s 3 & 5 are storage locations where the maximum amount on hand would be 2,500 pounds in 150 pound cylinders. The wells and booster location also operate on vacuum feed systems. Our employees conduct proper cylinder change-out proced ures daily. They also review operating procedures, and maintenance tasks daily. The prevention program for this facility is a level 2. Lock-out/Tag-out Procedures are used to help prevent in accidental releases of chlorine. When maintenance is conducted on the chlorination system, the Plant Production Manager (Russell Cornelius), and the Water manager (Lesslie Patterson II) approve the proper installation of the materials. Any change in maintenance procedure is reviewed and approved by Leslie Patterson II. All operators at this facility are knowledgeable in the proper start-up and shut-down procedures for the water treatment operations. Our emergency response program was devloped with the assistance of Environmental Data Services, Inc., the Hempstead County LEPC (Steve Smith), the Fulton, AR Volunteer Fire Department, and the Hope Fire Department. If a chlorine release occurs at the Fulton Site, the chlorine alarm will sound to notify plant personnel of the release. The exaust fans will be activated manually after a period which will allow for time needed to evacuate the affected population. The emergency response plan includes the proper notification procedures by person (s) on duty, who call the Plant Superintendent (Russell cornellius), who wil then call Les Patterson (Water Manager/Safety Coordinator). The extent of the hazard will be determined, and mitigation measures will be started. If the degree of the chlorine release requires evacuation, the 911 system will be used to notify on-duty fire department personnel to assist in the response and the evacuation of the surrounding population. Employees at the Fulton site are Haz-Mat triained, and will be the responders for this facility. They have the proper PPE necessary to respond to a release of chlorine at this location. Thw worst case scenario for this facility is a one tone chlorine cylinder failure, which would be a release of 2,000 pounds of chlorine gas into the atmospheere. Active mitigati on has been considered for this scenario consisting of manual shutoffs, as well as the vacuum system. Passive mitigation has also been considered for this release scenario, which would be the release into an enclosed space with contact with outside air. It is assumed that the entire contents of the cylinder are released as vapor. The distance to endpoint of 0.087mg/l for the worst case scenario is 4.8 miles. Alternate releases were determined for the Fulton location, as well as the well locations, booster locations, storage loactions, etc. All chlorine cylinders operate on a vacuum feed system, so the amount of chlorine released at the fulton site would be minimal (approximately 10 pounds). However, if a 150 pound cylinder at any other location were to have a vessel problem, such as a valve, the locations of these sites could allow for a release of the entire contents of the cylinderin a short period of time. The result of a 150 pound release typically would allow for a distance to endpoint of 0.43 miles. There have been no accidental releases of chlorine from this facility in the paast five years. The automatic vacuum feed system limits the amount (if any) of chlorine that escapes during operational periods. Operators of the chlorination system are requird to check instruments, cylinders, feed systems, etc. on a daily basis to aid in the prevention of accidental releases. This water treatment facility complies with EPA's Accidental Release Prevention Rule, and with all applicable state/federal codes and regulations. |