Polk Run - Executive Summary

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Polk Run WWTP 
This facility uses liquid chlorine to disinfect wastewater effluents.  Use of chlorine assures public health and safety when treated wastewater is returned to the receiving stream for downstrean uses such as drinking water supply, recreational, and aquatic life uses.   
The management team of this facility understands the importance of providing a safe work environment for its own employees, and takes precautions to prevent any incidents that could affect its own workers, or the neighboring community.   
This facility has utilized chlorine since 1969, and there have been no instances of a release of chlorine with offsite consequences.  The respondent (or its predecessors) presently operates, or has operated other facilities since 1953, and has a combined record of over two hundred years (200) with no release of chlorine with offsite consequences at any of the sites under its control.  
This facility takes an active role in preventing accidental releases at its facilities 
by ensuring that its employees are properly trained in the safe handling, operation and maintenance of chemicals and chemical processes subject to the Part 68 Risk Management rule. We have established and maintained procedures for emergency notification and response should an incident occur.  These plans are reviewed by management and other employees on a periodic basis to accommodate any changes in chemicals, equipment, processes, and staffing changes. 
Although the covered process for this facility is classified as Program Level 2, the prevention program contains all elements required for Program Level 3.  These elements include process safety information, process hazard analysis, operating procedures, training, mechanical integrity, management of change, planned compliance audits, incident investigations, employee participation, hot work permits, and contractor safety management. 
Prevention program elements most critical in preventing accidental releases from this facility include 
employee training, bot formal and on-the-job, written operating procedures for all to use who operate or maintain the chemicals and processes, and a process equipment preventative maintenance program. 
This facility has established and maintains an emergency response program that is coordinated with the local fire division and other emergency response agencies and LEPC's.  This program, as all, are regularly reviewed.  The local fire department handles HAZMAT response for chlorine emergencies, fire response, and emergency medical response.  The emergency response plan includes procedures for reporting emergencies, notifying the public, evacuation, and process system shutdown.  The plan clearly defines what action employees should take when an emergency occurs.  Lines of internal and external communication are clearly stated. 
Employees are involved in bringing forth ideas to enhance the safety of the chemical system.  Employees are trained and encouraged to recognize hazards and prese 
nt ideas to minimize the potential consequences of those hazards.   
During the development of the RMP document, process hazard analyses were conducted with key experienced employees. To meet the prevention program requirements.  During these sessions recommendations were made for the purpose of improving process safety and preventing accidental releases.  All recommendations are considered for implementation, although not all are usually implemented.  Such activities provide employees with a heightened awareness of safety issues related to the covered processes.  
This facility's Worst-Case Scenario (WCS) [details mandated by the USEPA Part 68 Risk Management Program regulation] involves the catastrophic release of the entire contents of its largest storage vessel, and total vaporization and release in a ten (10) minute period.  This situation, while generally considered unlikely, does result in the release of chlorine beyond the facility property line.   
Chlorine concentrations of t 
hree parts per million (ppm) will cause respiratory effects, and is above the level to which industrial workers may be safely exposed, with likely adverse human health and safety and environmental effects.   
A more plausible release scenario (the Alternate Case Scenario, or  "ACS", involves the failure (shearing off) of connected  regulator from a container during facility operation.  Using USEPA's RMP*COMP estimation software, the effects of chlorine release are limited to a small area, largely contained on or within the facility's property line, but due to the process' location near a fence line will also have off-site consequences.
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