Winston-Green Wastewater Treatment Facility - Executive Summary

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Winston-Green WWTF Executive Summary 
1.   Accidental release prevention and Emergency Response policies  
We at Winston-Green WWTF are committed to employee, public and environmental safety.  This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility.  It is our policy to implement appropriate controls to prevent possible releases of regulated substances.  Unforeseeably, if such a release does occur, our highly trained emergency response personnel are at hand to control and mitigate the effects of the release. We are also completely coordinated with Douglas County Fire District # 2 which provides additional emergency response expertise. 
2.  The Stationary Source and the Regulated Substances Handled 
We have 1 regulated substance present at our facility which is Chlorine. 
The maximum inventory of Chlorine 
at our facility is 8000 lbs. 
3.  The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario 
To perform the required offsite consequence analysis for our facility, we have used the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenarios. 
Toxic Worst-case analyses 
The Worst Case scenario involves a catastrophic release from Chlorination.  The scenario involves the release of 8000 lb. of Chlorine in a gaseous form over 10 minutes. The Release rate (lbs/min) is calculated to be 800. A distance to endpoint of 12 miles is obtained which affects  a residential population of 11314 within this distance. 
Toxic Alternative-case analyses 
None applicable 
Flammables Worst-case analyses 
None applicable 
Flammables Alternative-case analyses 
None applicable 
4.  Th 
e General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps 
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. A number of processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. 
Process Safety Information 
Winston-Green WWTF maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. 
Operating Procedures 
For the purposes of safely conducting activities within our covered processes, Winston-Green WWTF maintains written operating procedures.  These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations,  
normal shutdown and startup after a turnaround.  The information is regularly reviewed and is readily accessible to operators involved in the processes. 
Winston-Green WWTF has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at annually. 
Mechanical Integrity 
Winston-Green WWTF carries out highly documented maintenance checks on process equipment to ensure proper operations.  Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps.  Maintenance operations are carried out by qualified personnel with previous training in maintenance practices.  Furthermore, these personnel are offered specialized training as needed.  Any equipment deficiencies identified by the maintenance checks are corrected in a s 
afe and timely manner. 
Management of Change 
Written procedures are in place at Winston-Green WWTF to manage changes in process chemicals, technology, equipment and procedures.  Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. 
Pre-startup Reviews 
Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Winston-Green WWTF.  These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. 
Incident Investigation 
Winston-Green WWTF promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance.  These investigations are undertaken to identify the situation leading t 
o the incident as well as any corrective actions to prevent the release from reoccurring.  All reports are retained for a minimum of 5 years. 
Employee Participation 
Winston-Green WWTF truly believes that process safety management and accident prevention is a team effort.  Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements.  In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. 
On occasion, our company hires contractors to conduct specialized maintenance and construction activities.  Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Winston-Green WWTF has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes.  Contractors ar 
e also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 
5.  Five-year Accident History 
Winston-Green WWTF has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. 
6.  Emergency Response Plan 
Facility has its own written ER Plan. The ER Plan includes specific actions to be taken in response to accidental  releases of regulated substances. The ER Plan includes procedures for informing the public and local agencies for responding to accidental release. The ER Plan includes information on emergency health care. 
Date of most recent review/update of ER Plan: 4/19/99 
Date of most recent ER training of employees: 4/23/99 
The Local agency coordinating ER Plan is Douglas County Fire District # 2 which has the phone number 541-679-5503 
7.  Planned Changes to Improve Safety 
Several development 
s and findings have resulted from the implementation of the various elements of our accidental release prevention program. Chlorine cylinder containment is one of the major steps we want to take to improve safety at our facility. These changes are expected to be implemented within the next 5 years.
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