Nashville Water Treatment Plant - Executive Summary

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The Nashville Water Treatment Plant facility uses Chlorine, which is considered hazardous by EPA.  The same properties that make Chlorine valuable as a water treatment chemical also make it necessary to observe certain safety precautions in handling the material. 
 
The prevention of unnecessary human exposure reduces the threat to the health and safety of employees as well as nearby members of the community.  The primary goal of this Risk Management Plan is to ensure the safety of the employees of this facility and all residents that may be impacted by a release from this facility. 
 
It is the policy of the City of Nashville to adhere to all applicable federal and state rules and regulations.  Safety depends upon the manner in which Chlorine is handled, the safety devices inherent in the design of the facility, and the training of the personnel. 
 
This Risk Management Program, including the Emergency Response Program, was developed with the assistance of ALTEC Environmental Consultants, I 
nc. and NRS Consulting Engineers, Inc.  The Emergency Response Plan includes procedures for notification of the appropriate agencies and potentially affected members of the community.  In addition, it provides procedures for mitigating any releases that may cause harm to the community. 
 
The primary purpose of this facility is to produce treated water by utilizing the regulated chemical Chlorine.  The maximum amount of Chlorine stored at this plant is 8,000 pounds.  Chlorine is received in individual one-ton cylinders and stored until needed.  Chlorine is injected into the water system by automatic feeders.  The feed system uses a vacuum "shut-off" system which is designed to automatically shut the system down if a leak occurs. 
 
Access to the site is restricted to authorized facility employees, authorized management personnel and authorized contractors. 
 
A worst-case scenario for this facility involves the failure of and total release from the largest storage tank when filled to capacit 
y, resulting in a release of 2,000 pounds of Chlorine.  When Chlorine is released into the air, it creates a hazard.  Therefore, the worst-case scenario has been used.  Active mitigation has been considered for this scenario.  The Chlorine storage tanks are located in the Chlorine Cylinder Room which is constructed of a concrete wall on three sides and one side with double metal doors.  It is assumed that the entire contents are released as a vapor.  The distance to the endpoint of 0.0087 mg/l for the worst-case scenario is 2.6 miles. 
 
An alternative scenario has been developed for this facility.  The alternative scenario is based on the type of prevention system in place, and the release should be minimal.  The vacuum "shut-off" system has been determined to be effective in preventing greater than small amounts of Chlorine from being released.  Estimations based on the line capacity for the feeder lines would be approximately 10 pounds released into the atmosphere.  The amount of Chlo 
rine vapor released would result in a distance to endpoint of approximately 0.48 of a mile. 
 
This water treatment plant complies with EPA's Accidental Release Prevention Rule and with all applicable State of Arkansas codes and regulations. 
 
There have been no accidental releases of Chlorine in the last five years. 
 
The Emergency Response Program was developed for the City of Nashville and the surrounding areas with the assistance of NRS Consulting Engineers, Inc.  This program has been discussed with the Arkansas Office of Emergency Preparedness and the Nashville Fire Department.  A representative of ALTEC Environmental Consultants, Inc. visited this plant on March 5, 1999. 
 
The Chlorine feed system was constructed at this facility in 1985 and meets all design requirements for and complies with all applicable regulations for water treatment facilities.
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