(RMP) would have to be prepared and submitted to the Environmental Protection Agency Risk Management Planning-Accidental Release Prevention Program.
While developing their RMP, the City staff further evaluated the chlorination facilities at one particular location -- The Ralph Brennan Water Treatment Plant -- and determined that the 25-year old system was reaching the end of its useful
life and that approximately 40 hours were spent on site-specific RMP paperwork, maintenance and operational procedures every month. Therefore, the City decided to embark on a program to replace the gaseous chlorine system at the Brennan Plant with a treatment technology that would put them in better compliance with or eliminate RMP guidelines at that location.
The City staff conducted evaluations of three treatment alternatives: rehabilitation/replacement of the existing gaseous chlorine system, bulk purchase of commercially available sodium hypochlorite solution, and on-site generation of sodium hypochlorite. The City staff decided to place a greater emphasis on trying to eliminate the use of any hazardous disinfection chemical at the plant -- a decision that accelerated the evaluation of the last two treatment alternatives; bulk and on-site sodium hypochlorite
Readily available potable grade bulk sodium hypochlorite solution ranges between a 12-15% concentration, a solution strength that is still considered a hazardous material and is subject to containment requirements. Therefore, the 0.8% solution strength produced through the use of on-site generating systems was favored by the City. Before making the final decision to install an on-site generation treatment system at the Brennan Plant, however, the City operations and engineering staff visited facilities, including plants in Vero Beach, Fl., West Palm Beach, Fla. And City of Ocoee, Fla., that were using on-site generation systems. After discussing the operational and maintenance requirements of on-site generation systems and receiving feedback on the simplicity of the process and the reliability of the operation, the City of Daytona Beach chose on-site generation as its preferred disinfection process.