Flint Water Pollution Control Facilities - 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 Flint Water Pollution Control Facility (WPCF) stores chlorine and sulfur dioxide on-site in quantities in excess of 2,500 and 5,000 pounds, respectively. Flint minimizes the risks associated with these systems 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 existing procedures and policies in place make an event with off-site effects extremely unlikely.  
 
THE STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED [40 CFR 68.155(B)] 
 
The Flint WPCF 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, and sulfur dioxide is used for dechlorination prior to final discharge. 
 
WORST-CAS 
E AND ALTERNATIVE RELEASE SCENARIOS [40 CFR 68.155(C)] 
 
As required by the RMP Rule, the worst-case release for chlorine and sulfur dioxide are hypothetical situations in which the entire contents of the largest vessel are released as a gas over ten minutes. At Flint, this is a release from a one-ton cylinder for each chemical. The Flint WPCF minimizes the possibility of this type of release from occurring through the PSM Program that has been in effect at the plant since May 1996. 
 
A number of alternative release scenarios were identified.  The one that appears to be the most useful for both systems is one in which a failure of the transfer hose between a one-ton cylinder and the process occurs, resulting in a release. No mitigating factors were considered in the evaluation of the alternative release scenarios. 
 
The worst case and alternative releases for both chlorine and sulfur dioxide have the potential to extend off-site. 
 
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM [40 CFR 68.1 
55(D)] 
 
The Flint WPCF has developed and implemented routine maintenance and operational controls to prevent accidents. Prevention steps are listed in the Flint WPCF Process Safety Management (PSM) Plan. Specifically, sections addressing 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 and sulfur dioxide processes. 
 
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 major deficiencies in either system.  The PHA did not identify an impending release of either chemical based on the operation or maintenance of the systems.  (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 and sulfur dioxide is thoroughly trained or otherwise deemed competent in the work procedures relevant to their responsibilities. Employee participation is also a key component of the successful implementation of the PSM Plan at the Flint WPCF. 
 
FIVE-YEAR ACCIDENT HISTORY [40 CFR 68.155(E)] 
 
Within the last five years, the Flint WPCF has had one accidental release of chlorine and no reportable releases of sulfur dioxide.  The single chlorine release did not have off-site consequences. 
 
EMERGENCY RESPONSE PROGRAM [40 CFR 68.155(F)] 
 
The Flint WPCF has personnel trained to respond to the on-site effects of accidental chlorine or sulfur dioxide releases.  Response to the off-site effects o 
f accidental releases at Flint WPCF will be coordinated with Genesee County Emergency Management and other emergency response agencies in accordance with the Flint WPCF emergency response program. 
 
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 systems at the Flint WPCF, no changes to the system are deemed necessary by the plant.
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