Perry Wastewater Treatment Plant - Executive Summary

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    This Risk Management Plan has been submitted for the Mason H. Kelley Drinking Water Treatment Facility which is owned and operated by the City of Perry, FL.  This facility has only one regulated substance, chlorine, in process in an above threshold quantity.  We are proud to announce that there have been no accidental releases from this stationary source in the past five years. 
    As part of assembling this plan, and our complete program, we have formalized many of our procedures, augmenting them as necessary.  Much of this effort was channeled into our level 3 prevention program which forms the backbone of our policies.  The prevention program addresses all aspects of our chlorine process in an effort to insure all accidental releases are prevented.  We have assembled process safety information, taken a fresh look at our operating and maintenance procedures, and sharpened our focus on prevention.  We have also put in place the procedures to guarantee our program is properly imp 
lemented day-to-day and updated whenever necessary. 
    We have also analyzed a two scenarios, a worst case and an alternative, to help us and the public understand what may happen if an accident occurred.  Our worst case scenario calls for the release of 2000 pounds of chlorine over a 10 minute period with no mitigation measures in place.  This is, of course, in accordance with the requirements of the regulation.  The off-site consequences and the types of receptors identified are listed in the details of this plan.  The alternative release scenario was assumed to be caused by the mishandling of a chlorine vessel and also caused the release of 2000 pounds of chlorine.  The rate of the release was less than for the worst case, 150 pounds per minute, and also considered different parameters for atmospheric stability and wind speed.  Again, no mitigation was considered.  This scenario was also modeled using the guidance published by the EPA and the results are listed in this plan. 
Because of the size of this facility and the few number of employees, we are not able to assemble a team which could reasonably be expected to respond to major accidental release,  Fortunately, we are integrated into the plan developed by our LEPC.  We have also coordinated with our local fire department for support in the event of an accident.
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