Perryville Wastewater Treatment Plant - Executive Summary

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   Executive Summary 
 
Release Prevention and Response Policy 
 
   In compliance with the provisions of Title 40 of the Code of Federal Regulations Part 68, and OSHA Regulations Title 29 CFR Part1910.119, and in an on-going effort to be prepared for emergencies, the Town of Perryville Department of Public Works is preparing an Integrated Process Safety and Risk Management Plan for  the Waste Water Treatment Plant.  It is the policy of the Department of Public Works to operate all of the facilities within its jurisdiction in the safest and most efficient manner possible, with due regard for the health and safety of Department of Public Works employees, the Public, and our environment. 
 
Stationary Source and Chemicals 
 
   The Wastewater Treatment Plant (WWTP) of the Town of Perryville , Maryland employs chlorine as a disinfectant for the effluent and sulfur dioxide as a dechlorination prior to discharge to Mill Creek and subsequently to the Chesapeake Bay.  The chlorine is delivered, stored, an 
d drawn from one-ton containers.  The containers are stored in a dedicated room in the Control Building.  The maximum inventory is 8,000 pounds of chlorine in 4 containers on site. The maximum inventory of sulfur dioxide is 8,000 pounds in four one-ton containers.  The chlorine and sulfur dioxide are delivered by truck and stored in the Control Building. 
 
The Perryville Wastewater Treatment Plant is operated by the Plant Manager and one operator.  There are two operators on-site during all gas related operations.  The Plant is operated for one shift per day with chlorine and sulfur dioxide flowing during non-duty periods.  The WWTP is currently secured by building door and chain-link fence gate locks when the plant is not in operation. 
 
Release Scenarios 
 
   For the Wastewater Treatment Plant, a worst case assumed an accidental release of two containers of chlorine (4,000 pounds) during 10 minutes at 0 feet elevation and 77 degrees Fahrenheit, with an atmospheric stability class F, in ac 
cordance with the EPA mandated scenario. 
 
   The Alternative scenario for the facility assumes a break in the gas withdrawal tubing at a single cylinder connection, a temperature of 102xF (the maximum temperature, at the closest reporting station), a wind speed of 7.8 miles per hour(mean wind speed at the closest reporting station) and an atmospheric stability class of D.  Procedures have only one cylinder in use at a time,  which reduces the likelihood of breaking multiple lines and having releases greater than 2,000 pounds. 
 
Release Prevention 
 
   The general release prevention program is based on training, Standard Operating Procedures,  and material selection.  Two operators are on-site during periods of operation, and particularly when gas-related operations (container receipt and change-over) are performed.  The operating personnel are trained in the proper operation, maintenance, connection-disconnection, and emergency response for the chemicals employed at the Wastewater Treatment  
Plant.  The two chemicals are present in quantities greater than RMP threshold, and Process Safety Management and Risk Management procedures have been performed in compliance with the Regulations of both OSHA and the EPA 
 
   All gas-containing tubing and control devices are selected for specific material compatibility and compliance with appropriate Codes and Standards.  The systems are regularly and routinely inspected, and maintenance or replacement is performed as appropriate.  Process monitoring equipment is regularly tested by built-in circuit testing, and by actual sensor exposure to chlorine. 
 
Accident History 
 
   To date, there have been no accidental chlorine releases from the Wastewater Treatment Plant resulting in either on-site or off-site consequences. 
 
Emergency Response Program 
 
   The Emergency Response Program is based on the use of Department of Public Works WWTP employees who are trained to respond to and control an accidental release of chlorine.  The employees are traine 
d in the use of Personal Protective Equipment (SCBA) and specialized container repair kits (Chlorine Institute Kit B).  Emergency Response planning has existed in some form since 1982.
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