Wyandotte Wastewater Treatment Facility - Executive Summary
Accidental Release Prevention and Emergency Response Policies [40 CFR 68.155(a)] |
The Wyandotte Wastewater Treatment Plant (WWTP) stores chlorine on-site in quantities in excess of 2,500 pounds. Wyandotte 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 Wyandotte 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. In addition, the Wyandotte WWTP is in the process of converting the disinfection process to one which does not require the use of chlorine. After April of 2000, it is expected that the Wyandotte WWTP will no longer store quantities of chlorine above 2,500 pounds, and therefore, will no longer be subject to the provisions of the Risk Management Progra
m (RMP) Rule.
The Stationary Source and Regulated Substances Handled [40 CFR 68.155(b)]
Wyandotte WWTP is a municipal wastewater treatment plant, which treats wastewater from all or part of thirteen municipalities within Wayne County. 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 Wyandotte this is a release from a 90-ton railcar. Wyandotte WWTP minimizes the possibility of this type of release from occurring through the PSM Program that has been in effect at the plant since 1995.
A number of alternative release scenarios were identified. The one that appears to be the most useful is one in which a fusible plug on a one-ton chlorine cylinder fails, resulting in a release of chlorine gas. No mitigating factors were consi
dered in the evaluation of the alternative release scenarios.
General Accidental Release Prevention Program [40 CFR 68.155(d)]
The Wyandotte WWTP has developed and uses routine maintenance and operational controls to prevent accidents. Prevention steps are listed in the Wyandotte WWTP Process Safety Management (PSM) Plan. Specifically, sections covering 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 did not identify a need for changes to the chlorination system. (Please note: Although no changes were deemed necessary during the most recent PHA, a
glitch in RMP*Submit shows an error for field 7.4.c. The EPA indicates that this field should be left blank when no changes are necessary.)
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 his or her responsibilities. Employee Participation is also a key component of the successful implementation of the PSM Plan at the Wyandotte WWTP.
Five Year Accident History [40 CFR 68.155(e)]
Within the last five years, the Wyandotte WWTP has not had an accidental release of chlorine.
Emergency Response Program [40 CFR 68.155(f)]
The Wyandotte 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 Wyandotte WWTP will be coordinated with the Wyandotte Fire Department and other em
ergency response agencies in accordance with the Wyandotte WWTP Contingency 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 Wyandotte WWTP, no changes to the system are deemed necessary by the plant. However, Wyandotte WWTP plans to eliminate chlorine from the treatment process by April 2000. At that time the plant will no longer be subject to the RMP Rule.