Manitowoc Wastewater Treatment Facility - Executive Summary

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Executive Summary 
 
 
At the Manitowoc Wastewater Treatment Facility, chlorine is stored in ton containers and used to provide disinfection for the plant discharge.  Chlorine is stored at the site in a quantity greater than 2,500 pounds, the applicability threshold for the Accidental Release Prevention Rules set forth in 40 CFR Part 68. The City of Manitowoc designed this Risk Management Program to achieve the following objectives: 
 
-  Reduce the potential of an accidental release of chlorine, 
- Minimize the impacts should a release occur, and 
- Comply with the environmental regulations 
 
The Compliance Guidance and Model Risk Management Program for Water Treatment Plants, prepared by the American Water Works Association and the AWWA Research Foundation, and sponsored by EPA and the AWWA Research Foundation, provided the backbone of this Risk Management Plan. The City of Manitowoc has determined that the chlorine storage and handling operation at the wastewater plant is a Program 3 pro 
cess.  Although Federal OSHA requirements are not applicable to municipal facilities, the wastewater treatment plant is subject to the OSHA standards under the Wisconsin Department of Commerce rules in COMM 32.27.   The results of a Hazards Assessment (or Off-Site Consequence Analysis) of chlorine conducted for the site suggests that public receptors could be impacted in the event of a "worst-case" release of chlorine.  
 
The Risk Management Plan contains a management program that details the persons responsible for implementing and updating the RMP and the results of a Hazards Assessment, which was conducted to estimate the potential environmental and public receptors that could be impacted by a worst-case and alternative release scenarios.  A Program 3 Prevention Program was prepared that documents a management program, safety information on the chlorine process, the results of a hazards review, written operating and maintenance procedures, mechanical integrity program, descriptions o 
f training, compliance audit and incident investigation procedures, and other information designed to help ensure safe operation of the chlorine system. 
 
The staff at the wastewater treatment plant works closely with the Manitowoc Fire Department and Manitowoc County Emergency Government to ensure that proper emergency response procedures are in-place to quickly and effectively respond should a chlorine release occur.
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