City of Marshall Wastewater Treatment Plant - Executive Summary |
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The facility covered in the Risk Management Program (RMP) includes the City of Marshall Wastewater Treatment Plant. The process included in the RMP is the chlorine disinfection process. Currently the plant uses one ton chlorine cylinders (2000 lbs). The chlorine system includes four cylinders mounted for use, with two cylinders on-line (4,000 lbs) and two cylinders ready for service on stand-by (4,000 lbs). Since the threshold quantity for chlorine is 2,500 lbs, the process is regulated by the current RMP rules. The facility utilizes several other chemicals and processes. These chemicals are either not on the list of regulated toxic substances or do not exceed the current threshold limits. A worst-case release scenario and an alternative release scenario were developed for chlorine at the plant. The OCA Guidance Tables from the EPA Guidance Manual were used for the worst-case and alternative release scenarios for chlorine. Mitigation measures were not considered in the analys is. The worst-case release scenario for the process consists of the release of the greatest amount held in a single vessel over a ten minute period of time. The chlorine scenario produced a distance to end-point of release of 4.3 miles. The alternative release scenario chosen for the chlorine cylinders consists of failure of a 1-inch schedule 80 pipe connected to two 1-ton containers. The result is a distance to end-point of release of 0.24 miles. The alternative release scenario was chosen to better represent a possible release event in accordance with any previous accidental releases that occurred or potential problems experienced at the plant. The prevention program developed for the plant consists of several sections, including safety information, hazard review, operating procedures, training, maintenance, compliance audits, and incident investigations. The safety information includes material safety data sheets for each chemical, maximum inventories, safe operating limits, equipment specifications, and codes and stardards for design. The plant will maintain a form specifying the current safety information used and document any changes as they occur. The hazard review information includes the forms necessary for the reviews that will be performed at least every five years for the different processes. The operating procedures information includes standard operating procedures for initial startup, normal operations, temporary operations, emergency and normal shutdown, and startup following an emergency or normal shutdown. A form is provided to document procedures and any problems when changing chlorine cylinders. A copy of the chlorine manual is included for basic chlorine system operating information. The training information includes job descriptions and certification that all employees have been trained for the processes and equipment that they operate. Copies of all training certificates documenting intial training and refresher training are als o maintained. Maintenance information includes a copy of the operations and maintenance manual for the chlorinators. Forms are provided to document testing and inspections, including a Daily Work Log, Maintenance Inspection Report, Equipment Data Sheet, Preventative Maintenance Record, Equipment Lubrication Schedule, and Spare Parts Inventory. The compliance audit information includes the forms necessary for the audit and the certification to be completed at least every three years. Incident investigation information includes the Accident Investigation Report to be completed upon occurrence of an accident involving the chemical processes. The Accident Investigation Summaries are maintained for at least five years. There have not been any recorded accidents over the past five years. In the emergency response program, only incidental releases will be handled by plant employees. These releases include leaks encountered when installing the cylinders for use, dismantling the chlor ine cylinders, and any minor release found upon inspection or testing of the equipment. Proper equipment is maintained at the plant for use in the incidental release situations. Major releases will be handled by outside assistance. The plant is currently set-up to contact the City of Marshall Fire Department for assistance with chemical releases. The local Hazmat team will then be contacted by the fire department if needed. The First Call emergency contact system is also available for facilities in Harrison County. The fire department will iniate contact with the First Call program for assistance. Formulation of the RMP material is the only new information anticipated to affect safety at the facility in the immediate future. Safety procedures and training will be maintained in regard to the chemical process listed and all others at the plant. All of the the information discussed above will be maintained and documented for the chlorine process and stored at the plant. |