Rome Water Treatment Plant - Executive Summary

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EXECUTIVE SUMMARY 
 
A Risk Management Program is designed to prevent serious chemical accidents that could affect the public health and the environment and to improve the response to any accidents that may occur.  All applicable procedures of 40CFR68 are addressed in the plan.  The Water Treatment Plant (WTP) for the City of Rome located at 1 Blossom Hill Rd, Rome Georgia.  The WTP uses chlorine (regulated substance # 7782-50-5 in its water treatment disinfection process.  The City Water Dept serves  customers for all of the City of Rome and some areas of Floyd County.  The City withdraws water from the Oostanaula and Etowah Rivers. 
 
The City's Risk Management Program addresses specific actions the City will take to prevent accidental releases of chlorine into the atmosphere and reduce the potential impact on the public health and the environment.  The specific actions includef the development and implementation of a program containing the following key elements: 
 
*  Worse Case Scenario 
 
*  Alternative Scenario 
*  5 Year Accident History 
*  A Management system to oversee and implement the program. 
*  A Prevention Program that includes: 
  Chlorine safety information 
  Operating Procedures 
  Employee Training 
  Preventive Maintenance 
  Incident Investigation 
  Compliance Audits 
  An Emergency Response Program 
 
Accidental release modeling (40CFR68.22) was performed to determine the potentail consequences of an accidental chlorine release.  Two accidental release scenarios were developed for the facility.  The "Worse Case" scenario assumes that the enrire contents of a one ton cylinder (2000 pounds) are released over a period of ten minutes (a scenario defined and required by the EPA).  The "Alternative " scenario is site specific and is considered more likely to occur than the worse case scenario.  The alternative scenario is determined by reviewing the accident history and uning reasonable judgement and knowledge of the systsem.  The EPA's RMP*Comp program was us 
ed to determine the estimated distance to the toxic endpoint during releases. 
 
The worse case release scenario for the Rome WTP assumes failure of a one ton chlorine cylinder and the release of 2000 pounds of chlorine over a  ten minute period.  Usint RMP*Comp and considering the Rome WTP urban surroundings (EPA defined many obstacles in the immediate area), the distance to toxic endpoint were 2332 Persons, 4 Schools, 2 Hospitals, 1 Correctional facility, 1 Recreation area, 21 Businesses,   1 Industry, 7 Churches, and 1 Union hall. 
 
The alternative , or most likely, release  scenario for the Rome WTP was determined to be a complete break of the 3/8 inch I.D. pigtail that connects the cylinder to the manifold.  The release rate determined usiing RMP*Comp would be 20.9 pounds per minute.  Assuming that the entire contents of a one ton cylinder would be released at this rate, the release would ocur over a period of about 96 minutes.  The Five-Year accident  history was considered in deter 
mining the scenario.  There were no reportabale accidents at the WTP during the last five years.  For RMP purposes, assuming a pigtail was sheared and a valve failed, the entire contents would be releases. 
 
The distance to toxic endpoint for the Rome WTP alternative scenario, assuming its urban terrain and the release fo the complete contents of a one ton cylinder over 96 minute period, was calculated by RMP*Comp to be .1 miles ( .2 Kilometers ) There were 9 Residences and 18 persons as receptors for the most likely or alternative release scenario. 
 
The City of Rome has developed a Prevention Program that addresses basic, sound prevention practices. 
Safety Information Includes: 
*  General chlorine Properties 
*  General Chlorine Hazards 
*  MSDS Information 
*  Build and operate Equipment specifications including the Codes and Standards uses to design, process. 
*  Hazard review process including what-if-questions 
 
Operational Procedures Including: 
*  Startup 
*  Shutdown 
*  Temporary Shutd 
own 
*  Emergency Shutdown 
Training Program Covering 
*  Chlorine Safety 
*  Responder Notification 
*  SCBA Use 
Operational procedures have been outlined and implemented. 
Preventive Maintenance 
Incident Investigation 
Compliance Audits 
 
The Rome WTP has an emergency response plan coordinated with the Rome-Floyd County  Fire Department.  The RMP includes a procedure to notify emergency responders, emergency drills, and operator training.
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