Lackawanna Sewage Treatment Plant - ECSD #6 - Executive Summary

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1.  The Accidental Release Prevention and Emergency Response Policies at the Stationary Source 
At the Lackawanna Sewage Treatment Plant - Erie County Sewer District No. 6 (ECSD #6), personnel are continually concerned with the safety of employees, the public, and the environment.  The Accidental Release Prevention Program we have covers areas including operating procedures, maintenance, and employee training associated with the process at this facility.  To prevent possible releases of regulated substances, appropriate controls and techniques are used.  If such a release does occur, personnel at ECSD #6, through the Division of Sewerage Management (DSM), are fully coordinated with the Erie County Department of Emergency Services and the Lackawanna Fire Department, whom all commit highly trained emergency response crews to help control and ease the effects of the release. 
2.  The Stationary Source and Regulated Substances Handled (primary activities, use of regulated substances, & q 
uantities handled or stored) 
7 This facility's primary activity involves the treatment of wastewater at a Sewage Treatment Plant.  Presently, there is one (1) regulated toxic substance above threshold quantity at this facility, which is Chlorine (Cl2).   
7 Chlorine is used for the disinfection of wastewater, primarily to destroy and/or deactivate pathogenic organisms. 
7 The maximum inventory of Chlorine at this facility is 12,000 lbs., which is broken down into six (6) one-ton (2,000 lb.) containers.  There are two (2) containers on each of the two (2) scales, and the remaining two (2) containers on the floor, with only one (1) container in use at any given time. 
3.  The Worst Case Release Scenario and the Alternative Release Scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario (include scenario & distance to endpoint). 
The ALOHA (Areal Locations of Hazardous Atmospheres) modeling program, version 5.2.1, was used to 
attain the required offsite consequence analysis for this facility.  The following provides a summary of the Worst Case and Alternative Scenarios: 
The WORST CASE RELEASE SCENARIO submitted for Program 3 toxic substances involves a disastrous release from one of the chlorine containers and assumed to be a puncture at the bottom of the container.  In this particular scenario, 2,000 lbs. (the entire mass of the container) of Chlorine was released and resulted in a liquid spill, with vaporization, over a ten (10) minute span.  Under worst case weather conditions being Class F atmospheric stability, 250C (770F), 50% humidity, no cloud cover, and 1.5 m/s (3.35 mph) windspeed, the maximum threat zone distance for a level of concentration (LOC) of 0.0087 mg/L is 2.9 miles. 
The ALTERNATIVE RELEASE SCENARIO for Chlorine involves a release from a single chlorine container and assumed to be a failure at the transfer hose, due to over pressurization or human error.  In this scenario, 800 lbs. o 
f Chlorine will be released in a gaseous form over a six (6) minute span.  The contents that remain in the tank after the pressurized gas is released will be of liquid chlorine.  This liquid will be at a level lower than the release point and therefore, the contents would remain in the tank.  Under neutral weather conditions (taken from Local Climatological Data 1995-1997 for Buffalo, NY) being Class D stability, 47.40F (8.560C), 73% humidity, 5/10 cloud cover, and 10.3 mph (4.61 m/s) windspeed, the maximum threat zone distance for a level of concentration (LOC) of 0.0087 mg/L is 2.0 miles. 
4.  The General Accidental Release Prevention Program and Chemical-Specific Prevention Steps 
At the Lackawanna Sewage Treatment Plant - Erie County Sewer District No. 6 (ECSD #6), personnel have taken all the steps needed to comply with the accidental release prevention requirements, found in 40 CFR Part 68.  This facility is subject to the OSHA PSM and EPCRA section 302 standards.  A brief descr 
iption of the elements in the Release Prevention Program follows: 
Safety Information 
This facility keeps a written record of safety information that includes information on the chemical hazards, operating procedures, and all equipment used within the process.  
Process Hazard Analysis 
This facility has conducted a thorough analysis to ensure that hazards associated with the process are identified and responded to efficiently.  The methodology used to determine and evaluate the hazards of the process in this analysis is What If/Checklist.  The Process Hazard Analysis will be updated and revalidated every five (5) years.  Any changes resulting from the hazard analysis are completed in a timely manner. 
Operating Procedures 
To safely conduct activities involved within the process, Lackawanna Sewage Treatment Plant - ECSD #6 personnel maintain written operating procedures.  These procedures address each operating phase including initial startup, normal operations, temporary operations, em 
ergency shutdown, emergency operations, normal shutdown, and startup after an emergency shutdown.  Each year, the Chief Wastewater Treatment Plant Operator reviews the operating procedures and certifies in the annual report that all current operating practices are reflected.  In addition, all operating procedures are readily accessible to employees who work in or maintain the process. 
This facility has an extensive training program in place to ensure that employees involved with the processes are completely knowledgeable about the operating procedures and hazards associated with them.  Refresher training is provided at least every three (3) years and more often if necessary, to each employee involved with the processes.  Currently, training is ongoing throughout the year in many areas. 
Mechanical Integrity 
At the Lackawanna Sewage Treatment Plant - ECSD #6, personnel carry out routine maintenance checks, inspections, and testing on all process equipment to ensure proper fun 
ctioning.  Process equipment that is covered includes but is not limited to pressure vessels, storage tanks, piping systems, relief and vent systems and devices, emergency shutdown systems, controls, and pumps. Any equipment deficiencies that are not acceptable are corrected in a safe and timely manner to assure safe operation. 
Management of Change 
Written procedures are established at this facility to manage changes to process chemicals, technology, equipment, and procedures.  Any employee whose job tasks are affected by a change in the process are informed and trained. 
Pre-startup Reviews  
Pre-startup safety reviews related to modifications in the established process are conducted as needed.  These reviews shall confirm that construction, equipment, safety, operations, and maintenance procedures are in place and adequate prior to startup. 
Compliance Audits 
This facility evaluates compliance at least every three (3) years.  Any corrective actions required as a result of the audits  
are undertaken in a safe and prompt manner. 
Incident Investigation 
During the past five (5) years, there have not been any incidents at the Lackawanna Sewage Treatment Plant - ECSD #6.  If and when the occasion arises, any incident that has resulted in, or could reasonably result in a disastrous release of a regulated substance would promptly be investigated.  These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring.   
Employee Participation 
This facility has incorporated any appropriate employee comments to the Process Safety Management Plan (PSMP).  In addition, all employees have access to all the information developed under this standard.  
If the situation arises that an outside contractor must be hired to perform any maintenance and/or construction work, before choosing a contractor, Lackawanna Sewage Treatment Plant - ECSD #6 will evaluate information regarding th 
e contractors safety performance and programs. The contractors are informed of the known potential hazards related to the work.  In addition, contractors have been explained to any applicable provisions of the Emergency Response Plan (Facility Response Procedure). 
5.  The Five-Year Accident History 
The Lackawanna Sewage Treatment Plant - Erie County Sewer District No. 6, has an outstanding record of preventing accidental releases.  Due to effective release prevention, no accidental releases have occurred over the last five (5) years. 
6.  The Emergency Response Program 
The Lackawanna Sewage Treatment Plant - Erie County Sewer District No. 6 has a written Emergency Response Plan (Facility Response Procedure) that deals with accidental releases.  The procedure includes aspects of emergency response including monitoring and detection, notifications following a release, direction and control, containment, evacuations, mutual aid assistance, emergency equipment inventory, first aid, rev 
iew, updates and training, and other emergencies.  The emergency response equipment is inspected, tested, and maintained in accordance with the DSM Respirator Program.  Each plan is promptly updated to reflect any pertinent changes taking place within this process. 
The Facility Emergency Coordinators (FEC) for this facility are:  
7 Sewer District Manager - Lawrence Krug 
7 Chief WWTP Operator - James Kaszubowski 
7 Senior WWTP Operator - James Balcarczyk 
7 Chief WWTP Supervisor - Glenn Absolom,  
The emergency plan has been coordinated and verified with each FEC.  This procedure is also coordinated with the Erie County Department of Emergency Services and the Lackawanna Fire Department (also refer to the Emergency Response Plan (Facility Response Procedure)). 
7.  Planned Changes to Improve Safety 
The Lackawanna Sewage Treatment Plant - Erie County Sewer District No. 6 has all safety aspects covered, and have no planned changes at this time.
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