Laserfiche WebLink
MWMC FACILITIES PLAN <br /> <br />For the alternative scenario4, the endpoint concentration was reached at a distance of less <br />than 0.1 mile. The radius does cross the fenceline of the facility on the east side, but no <br />dwellings exist in this area. The only offsite consequences under this scenario are a bike <br />path, and a recreational vehicle dump site on the north side. Both chlorine and sulfur <br />dioxide were analyzed under the alternative release scenario and similar endpoints were <br />determined. <br /> <br />Prevention Program <br />The EPA prevention program is a substantial element of the RMP rule. This program <br />focuses on employees at the facility and includes a list of ten components of compliance. <br />These components can be satisfied by complying with similar requirements of the <br />Occupational Safety and Health Association (OSHA) Process Safety Management (PSM) <br />program. The WPCF met the final OSHA PSM compliance deadline of May 1997. <br /> <br />Risk Management Plan <br />The risk management component of the RMP consists of completing general paperwork and <br />submitting it to responsible agencies and to the public. The risk management section <br />completed for the WPCF includes the following sections: <br /> <br />· Description of major hazards, such as equipment failure, human error, and natural <br /> phenomena, that could lead to a significant accidental release <br /> <br />· Description of the consequences of failing to control for major hazards <br /> <br />· Summary of all actions taken or planned to address these hazards, including starting <br /> states <br /> <br />· Methods for prevention or mitigation of significant accidental releases <br /> <br />Public Health Risk from Chlorine and Sulfur Dioxide <br />Chlorine and sulfur dioxide are extremely hazardous substances. Increasing concerns about <br />security and the potential severity of life safety consequences of an uncontrolled major <br />release resulted in a review of alternative disinfection technologies. The MW-MC is <br />interested in replacing gaseous chemical disinfection with a safer alternative disinfection <br />technology such as hypochlorite and bisulfite solutions. Until then, the risks associated with <br />the use of chlorine and sulfur dioxide will continue to be managed through controls such as <br />regular maintenance, engineering features to contain and treat contaminated air, training <br />and work rules at the facility, and operational safety procedures. <br /> <br />Air Toxics and Regulatory Assessment <br />Based on regulatory review, there are no significant, outstanding air quality compliance <br />issues for the WPCF. The facility is in compliance with all federal regulations and with <br /> <br />4 The alternative release scenario allows the use of active mitigation such as the scrubber system. The scrubber system was <br />assumed to be 99 percent efficient and the endpoint concentration was reached at a distance of less than 0.1 miles, he <br />scenario itself was based on a break in a one-inch pipeline used to transport liquid chlorine or sulfur dioxide from the cylinder to <br />the evaporator. A pipeline break was chosen for the analysis not because it represents the most likely scenario, but it does <br />represent a more conservative estimate. The release rate from the broken pipeline in pounds per minute was determined using <br />tables furnished in the guidance documents from EPA for wastewater treatment facilities. <br /> <br />2-14 MWMC_2.0_REV23.DOC <br /> <br /> <br />