Leroy R. Summerson WWTF - Executive Summary |
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1. Accidental release prevention and emergency response policies In this wastewater treatment facility, we use chlorine and sulfur dioxide, which are both considered hazardous by EPA. The same properties that make these chemicals valuable as commodities also make it necessary to observe certain safety precautions in handling them to prevent unnecessary human exposure, to reduce the threat to our own personal health as well as that of our co-workers, and to reduce the threat to nearby members of the community. It is our policy to adhere to all applicable Federal and state rules and regulations. Safety depends upon the manner in which we handle chlorine and sulfur dioxide, the safety devices inherent in the design of this facility, the safe handling procedures that we use, and the training of our personnel. Our emergency response program is based upon the Chlorine Institute's Pamphlet 64, Emergency Response Plans for Chlorine Facilities. The emergency response plan includes procedu res for notification of the local fire authority and notification of any potentially affected neighbors. 2. The stationary source and regulated substances handled The primary purpose of this facility is to treat domestic and industrial wastewater for the protection of human health and the environment. Chlorine and sulfur dioxide are received in ton containers. It is then used in the wastewater disinfection process. This facility has equipment for unloading ton containers and equipment to utilize chlorine and sulfur dioxide in our process. Access to the site is restricted to authorized facility employees, authorized management personnel and authorized contractors. The regulated substances handled at this distribution facility are chlorine and sulfur dioxide. The total inventory of chlorine stored at this plant is 16,000 pounds. The total inventory of sulfur dioxide stored at this plant is 12,000 pounds. 3. The worst-case release scenarios and the alternative release scen arios, including administrative controls and mitigation measures to limit the distances for each reported scenario Worst-Case Scenario, chlorine - Failure of a ton container of chlorine would release 2,000 pounds of chlorine. It is assumed that the entire contents are released as vapor, which is heavier than air. The distance to the endpoint of 0.0087 mg/L (3 ppm) is calculated as 0.9 miles. Alternative Release Scenario, chlorine - A chlorine gas feed pipe fails, releasing gas into a closed room. The distance to the endpoint of .0087 mg/L (3 ppm) is 0.3 miles. Worst-Case Scenario, sulfur dioxide - Failure of a ton container of sulfur dioxide would release 2,000 pounds of sulfur dioxide It is assumed that the entire contents are released as vapor, which is heavier than air. The distance to the endpoint of 0.0087 mg/L (3 ppm) is calculated as 0.9 miles. Alternative Release Scenario, sulfur dioxide - A sulfur dioxide gas feed pipe fails, releasing gas into a closed room. The dist ance to the endpoint of .0087 mg/L (3 ppm) is 0.2 miles. 4. The general accidental release prevention program and the specific prevention steps This distribution facility complies with EPA's Accidental Release Prevention Rule and with all applicable state codes and regulations. This facility is operated in accordance with recommendations from the Chlorine Institute. 5. Five-year accident history We have had no releases of chlorine resulting in off-site consequences within the last 5 years. We have had no releases of sulfur dioxide resulting in off-site consequences within the last 5 years. 6. The emergency response program This facility's emergency response program is based upon the Chlorine Institute's Pamphlet 64, Emergency Response Plans for Chlorine Facilities. We have discussed this program with the Cortland County Local Emergency Planning Comniittee and the City Fire Department. 7. Planned changes to improve safety This facility is planning to conv ert to ton container-mounted vacuum regulators. This will eliminate any pressure piping for chlorine or sulfur dioxide. |