Petoskey Wastewater Treatment Plant - Executive Summary |
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EXECUTIVE SUMMARY [40 CFR 68.155] ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES [40 CFR 68.155(A)] The Petoskey Wastewater Treatment Plant (WWTP) stores chlorine on-site in quantities in excess of 2,500 pounds. Petoskey minimizes the risks associated with its chlorination system by: 1. Development and implementation of a Process Safety Management (PSM) Plan in compliance with OSHA's PSM standard (29 CFR 1910.119). 2. Planning and training for response to an emergency. The Petoskey WWTP has not had an accidental release of chlorine within the last five years. The existing procedures and policies in place make such an occurrence extremely unlikely. THE STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED [40 CFR 68.155(B)] Petoskey WWTP is a municipal wastewater treatment plant, which treats wastewater from within the City's limits and portions of surrounding townships. Chlorine is used in the disinfection process at the facility. WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS [40 CFR 68.155(C)] As required by the RMP Rule, the worst-case release for chlorine is a hypothetical situation in which the entire contents of the largest vessel is released as a gas over ten minutes. At Petoskey this is a release from a 1-ton cylinder. Petoskey WWTP minimizes the possibility of this type of release from occurring through the PSM Program that is in effect at the plant. A number of alternative release scenarios were identified. The one that appears to be the most useful is one in which a leak during hookup to a cylinder occurs, resulting in a release of chlorine gas. The building was considered a mitigating factor in the evaluation of the alternative release scenarios. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM [40 CFR 68.155(D)] The Petoskey WWTP has developed and uses routine maintenance and operational controls to prevent accidents. Prevention steps are listed in the Petoskey WWTP Process Safety Management (PSM) Plan. Specifically, Process Safety Information, Operating Procedures, Pre-Startup Safety Review, Mechanical Integrity, Hot Work Permit, Contractors, and Management of Change contribute to safe operation of the chlorination process. The process hazard analysis (PHA) conducted by the facility helps to identify potential problems before they occur. This process allows for participation of employees and identification of opportunities for improvement at the plant. The most recent PHA conducted by the plant identified no deficiencies in the chlorination system. The PHA did not identify an impending release of chlorine based on the operation or maintenance of the chlorination system. As described in the Training section of the PSM document, each employee with job responsibilities associated with the storage, handling or use of chlorine is thoroughly trained or otherwise deemed competent in the chlorine-related work procedures relevant to their responsibilities. Employee Participation is also a key component of the succes sful implementation of the PSM Plan at the Petoskey WWTP. FIVE YEAR ACCIDENT HISTORY [40 CFR 68.155(E)] Within the last five years, the Petoskey WWTP has not had an accidental release of chlorine. EMERGENCY RESPONSE PROGRAM [40 CFR 68.155(F)] The Petoskey WWTP has personnel trained to respond to the on-site effects of accidental chlorine releases. Response to the off-site effects of accidental chlorine releases at Petoskey WWTP will be coordinated with the Petoskey Public Safety Department, Tricounty LEPC and other emergency response agencies in accordance with the Petoskey WWTP Emergency Response Plan. PLANNED CHANGES TO IMPROVE SAFETY [40 CFR 68.155(G)] After consideration of the identified release scenarios, the accident history, and a review of the latest PHA for the chlorination system at Petoskey WWTP, no changes to the system are deemed necessary by the plant. |