City of Gainesville Water Works - Executive Summary |
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The City of Gainesville Water Works is located at 2120 Riverside Drive in Gainesville, Georgia. The Water Works utilizes chlorine to disinfect raw water from Lake Lanier to provide drinking water to the City of Gainesville area. The plant is subject to the RMP regulations since it has greater than 2,500 pounds of chlorine on site. The maximum intended inventory of chlorine will be eighteen 1-ton cylinders. The Water Works provides a vital service to the local community. The use of chlorine to treat drinking water is a universally accepted process. The City of Gainesville recognizes the hazards associated with utilizing chlorine and has rigorous controls in place to avoid releases. The Water Works developed a RMP Program Manual that summarizes their unified approach to RMP compliance. The RMP Program integrates technology, procedures, and management practices to proactively manage the potential risks associated with chlorine storage and use. The program seeks to provide for empl oyee safety, public safety, and response agency interaction. The RMP Rule has three different levels of compliance (Programs 1-3). The required levels depend on a combination of the facility's accident history, the presence of off-site public and environmental receptors within the worst-case release scenario radius, OSHA PSM status, and SIC code. The Water Works is subject to RMP Program Level 2 because they have chlorine on-site in excess of the 2,500 pounds threshold quantity and public receptors within the worst-case release scenario circle. The Program Level 2 Prevention Program in place at the Water Works is in compliance with the RMP regulations and includes the use of equipment, buildings, and processes designed in accordance with industry codes; formal hazard review procedures; written standard operating procedures; a computerized maintenance system; and, employee training. Emergency response has been coordinated with the local fire department and Hall County LEPC. The si te also has formal incident investigation procedures and will be performing RMP Program compliance auditing periodically to ensure the Water Works remains in compliance with RMP requirements. A Worst-Case Release Scenario (WCRS) and Alternate Release Scenario (ARS) were determined for the chlorine stored on-site. The WCRS is an unrealistic scenario calculated utilizing USEPA-specified parameters. The purpose of the WCRS is to draw attention to the site. The WCRS calculated for the Water Works assumed no administrative controls or passive mitigation. The WCRS was calculated using RMP Comp and verified against the AWWA guidance for water treatment plants and the USEPA guidance document for wastewater treatment plants. The ARS was also calculated using RMP Comp. The scenario specifics were based on information provided by the AWWA guidance document and verified with information from The Chlorine Institute. The Alternate Release Scenario chosen was Scenario I.D. CLA-3 from the AWW A RMP Guidance Document (Table 5-5): Alternative Scenario for 1-ton Chlorine Container with Gas Feed: Tubing failure, bad connection, or valve failure resulting in the release of gas through the 5/16-inch-diameter valve body opening. One accident is reported in the 5-year accident history portion of the RMP Plan. This incident was minor. One employee experienced a sore throat as a result of inhaling a small amount of chlorine when changing a chlorine cylinder. The incident was reported in the plan because, as a precaution, a physician examined the employee, and a City of Gainesville Worker's Compensation Report was completed. There were no off-site impacts or other on-site impacts and no emergency responders were involved in the situation. The City of Gainesville Water Works will be a defensive responder to accidental releases of chlorine. A letter was transmitted to the local fire department and Hall County LEPC to ask that the facility be included in the community emergency response plan and inviting the fire department to visit the site to prepare for potential emergencies involving chlorine. Emergency notification and evacuation procedures are posted at facility telephones and outside the facility gate. Facility personnel will be provided emergency awareness level training at on-site monthly safety meetings. Significant upgrades to the Water Works are currently underway. Additional engineering controls are being added to the chlorine process in an effort to augment the current chlorine safety program. Although the facility has never experienced a major chlorine release, The City of Gainesville has chosen to add these controls in an effort to proactively manage environmental, health and safety risks. The chlorine process is being improved to include a scrubber in the chlorine storage area, each in-use cylinder will have automatic, remote shutoff valves, and the chlorinators will have relief valves. |