Town of Tonawanda Wastewater Treatment Plant - Executive Summary

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This RMP submission applies to the Town of Tonawanda Wastewater Treatment Facility located at 779 Two Mile Creek road in the Town of Tonawanda, New York.  The facility treats sanitary wastewater from the Town of Tonawanda, the Village of Kenmore, and the City of Tonawanda.  In order to disinfect the treated effluent, liquid  chlorine is utilized.  This type of system is commonly used at most wastewater treatment plants.  The facility has a maximum capacity of 21 one-ton chlorine cylinders (42,000 pounds) although, at most 4,000 pounds of chlorine are connected to the process (two one-ton cylinders).   Following are the required seven elements for the wastewater Treatment Plant: 
 
Accidental release prevention and emergency response policies-  
The wastewater treatment plant complies with all Federal, state, and local requirements for chlorine processes.   The facility was designed and constructed in accordance with applicable industry standards and codes.  In an emergency the facility wi 
ll call 911 and the local volunteer fire department will respond.  The facility has a written set of emergency response procedures that describes who to call under what conditions. 
 
Stationary source and regulated substances handled - 
The facility is a municipal  wastewater treatment plant.  The facility has 42,000  pounds of chlorine on-hand at any one time. 
 
Worst case release scenario and alternative release scenario including administrative controls and mitigation measures to limit the distance for each reported scenario- 
The worst case release scenario is a rupture of a one-ton cylinder which is the largest vessel in the system.  A release from the cylinder would include 2,000 pounds of chlorine.  The release would be a liquid spilled onto the floor in the chlorine cylinder room.   The cylinder  room doors and windows are kept closed which will help mitigate the release.   The liquid will vaporize and form a vapor cloud.  The cloud will be released from the building either via le 
akage, and/or by exhausting from the building, over a period of time, by the ventilation system in the cylinder room.   The alternate scenario would consist of a release from a broken vacuum regulator  at a pressure of 40 psi (downstream of the pressure reducing valve) through a 3/8 inch tube.  The relief would be to the outdoors via a 1/2 inch PVC vent line.   For both the worst case and alternate release scenarios, chlorine detectors are in place that will detect the release and notify the treatment plant operator, which is on-duty 24 hours per day, seven days per week.  The operator  will in turn follow written procedures for notification of emergency personnel.  Note that this facility is equipped with a caustic scrubber system that is capable of removing the chlorine from the air within the cylinder storage room so that no chlorine is released.  However, the regulations do not allow for a consideration of the scrubber in determining the offsite impacts. 
 
General accidental release 
prevention program and chemical specific prevention steps. 
The facility complies with EPA's Risk Management Program requirements and all applicable state and local codes and standards in effect at the time the facility was constructed. 
 
Five year accident history- 
There have not been any releases from this facility in the past 5 years. 
 
Emergency response program- 
In the event of an emergency the facility will call 911 and request that the local fire department/hazmat team respond to the emergency.   Several members of the Tonawanda wastewater plant have appropriate training on the use of personal protective equipment and may assist the fire department with rescue, isolation, and shut-off of the release .  Written emergency response procedures are provided in the facility's Response Procedure. 
 
Planned changes to improve safety- 
Several recommendations were made during the facility's recent process hazard  analysis.  These recommendations are scheduled to be implemented by December 19 
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