Burton Creek Wastewater Treatment Plant - Executive Summary

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Executive Summary 
It is the policy of the City of Bryan, Texas, to operate safe water and wastewater treatment facilities, reducing to the greatest extent possible any hazards associated with our processes, and reducing any subsequent risk to the surrounding community, our employees, and the environment. It is also our policy to work with the surrounding community and local emergency response agencies, and promote a spirit of cooperation and teamwork, to orchestrate an effective contingency plan in the unlikely event that a process incident occurs at one of our plants. 
Primary Activity 
The primary activity at the Burton Creek Wastewater Treatment Plant is Municipal Wastewater Treatment. 
Use of Regulated Substances 
Chlorine is used primarily as a disinfectant to kill pathogens prior to discharge of treated water. 
Sulfur Dioxide is used in the dechlorination process to remove residual chlorine from the treated water prior to discharge to the local creek. 
Quantities Handled or Stored 
rine: 16,000 pounds 
Sulfur Dioxide: 16,000 pounds 
Worst-Case Release Scenario 
Failure of a ton container of  2,000 pounds of sulfur dioxide; 10 minute release mitigated by a factor of 0.55 because the process is sheltered by a building.  Under worst case weather, sulfur dioxide could travel 1.85 miles before dispersing enough to no longer pose a hazard to the public. 
Alternative Release Scenarios (ARS) 
Rupture of a flexible connection due to corrosion or fatigue.  The release would be mitigated by an enclosure, resulting in a release rate of 5.8 pounds per minute, and an offsite distance of 0.31 miles.  This is about the most realistic release that would ever be expected to occur.  However, the plant policy is to replace the flexible connections quarterly, four times more frequent than the manufacturer's recommendations. 
Accidental Release Prevention Program and Chemical-Specific Prevention Steps 
Burton Creek WWTP is in compliance with the RMP Rule, 40 CFR 68. Burton Creek WWTP has con 
ducted a comprehensive review of all systems, as well as administrative, technical, operating and maintenance procedures, in addition to the other required program elements of the Rule. As a result of a Hazard Review at this plant, recommendations were developed to install or upgrade some safety items.  
Five Year Accident History 
Burton Creek WWTP has never had a significant release of a hazardous substance as defined by this Rule. 
Emergency Response Program 
This facility has an Emergency Response Program that is coordinated with the community plan. 
Planned Changes to Improve Safety 
The following recommendations were made as a result of the Burton Creek WWTP Risk Management Program. Some of the recommendations are currently being implemented. Others are being prioritized and budgeted accordingly. 
Because Burton Creek WWTP is within close proximity to a moderately populated urban area, the City of Bryan is considering commissioning a study to investigate either emergency scrubbing syste 
ms or non-chlorine alternatives to disinfection.  In the meantime, the following steps will be taken based on the results of a detailed hazard review at the plant. 
' We will apply high grade bright yellow paint on all chlorine pressure pipe to facilitate early leak detection 
' We will begin to specifically look for leaks during 2 hour inspections  
' We will develop log sheets / checklists, and use once per shift.  We will note problems in logbook, and these procedures will be formalize in our SOP 
' We will require each operator to be trained on the plant's  SOP. 
' We will endeavor to develop and implement a chlorine and sulfur dioxide supplier audit program.  For example, do they have emergency container repair kits? Do they maintain their equipment?   
' We will formalize our Buddy System for hazardous substance work at the plant.   
' We will train employees recurrently on B-kits and SCBAs.  We will show B-kit videos, & drill annually (with air packs). 
' We will perform maintenance on  
defective vacuum regulator heating units, and cease use of any space heaters to facilitate sulfur dioxide feed. 
' We will begin a preventive maintenance program on pressure relief valves, and document each valve's service history.
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