Walnut Creek WWTP - Executive Summary |
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The Walnut Creek Waste Water Treatment Plant (WWTP), which is owned and operated by the City of Troy, Alabama, is about 0.5 mile southeast of Troy and about 0.3 mile south of U.S. Highway 231 South. Operations at the Walnut Creek WWTP include disinfection of the wastewater through chlorination. The chlorination operation at the Walnut Creek WWTP utilizes about 90 pounds of chlorine per day. The chlorine is fed to the process from 1-ton containers. In order to ensure a sufficient supply of chlorine is available, about 6,000 pounds of chlorine are typically stored on site. Because chlorine is stored on site in excess of the 2,500 pound threshold quantity, the City of Troy is required to prepare a Risk Management Plan (RMP) for the Walnut Creek WWTP. As required in 40 CFR Part 68, an off-site consequence analysis, including consideration of a worst case scenario and an alternative case scenario, was conducted for the facility. Based on the worst case scenario defined by the r egulations, the distance to the toxic endpoint for a release of 2,000 pounds of chlorine gas was determined to be 1.3 miles. In the event of a worst case release, residences, commercial areas, schools and churches would be affected. The alternative case defined for the facility assumed that the gas valve was sheered off of a 1-ton container leaving a 1 inch diameter hole in the container and allowing the entire contents of the container to be released. Based on this scenario, the distance to the toxic endpoint would be about 0.2 mile. Review of the off-site consequence analysis results and the definition of the program levels indicates that the Walnut Creek WWTP is subject to the Program 2 Prevention Program requirements because the Walnut Creek WWTP is not in the classifications for Program 3 facilities, and there has not been a release of a regulated substance at the facility in over 5 years. In order to meet the Program 2 Prevention Program requirements, updated safety inform ation was compiled, a Hazard Review was conducted, and new procedure for employee training, equipment maintenance, compliance audits and incident investigations were prepared. All of this information was summarized in a written plan prepared for the facility. The City of Troy tried to review operating procedure for the facility. However, to date, written operating procedures for the facility cannot be located. The City of Troy is attemtpting to obtain written operating procedures from the engineering firm that designed the WWTP. If written operating procedures cannot be obtained from engineering firm, new operating procedures will be prepared for the facility. The RMP regulations in 40 CFR 68, require that each facility subject to the regulations have emergency response procedures in place. The City of Troy has established procedures with the Troy Fire Department to respond to emergency situations at the Walnut Creek WWTP. The Troy Fire Department has personnel trained in haz ardous materials response procedures. The City of Troy will provide the equipment necessary to resond to a release of chlorine to the Troy Fire Department. In addition, the City of Troy has reported the presence of chlorine at the Walnut Creek WWTP to the Pike County LEPC and has requested that the Walnut Creek WWTP be included in the community emergency response plan. Because emergency responses at the Walnut Creek WWTP will be handled by outside responders, an emergency response plan was not prepared for the facility. However, an emergency action plan was prepared for the facility. The emergency action plan outlines procedures for ensuring that personnel at the Walnut Creek WWTP are evacuated and accounted for in the event of an emergency. The City of Troy is commited to establishing and maintaining safe operating procedures at the Walnut Creek WWTP. Where necessary and appropriate, the City or Troy will invest capital into equipment and training required to ensure the safe operation of the facility. Currently, the City of Troy is working to implement a number of recommendations to improve safety at the facility. Mr. Mike Davis, Project Manager with the City of Troy Utilities Department, bears the overall responsibility for the implementation of the RMP at the Walnut Creek WWTP. Questions regarding the implementation of the RMP should be directed to Mr. Davis. Mr. Davis can be reached at (334) 670-6031. |