Town of South Boston Waste Water Treatment Plant - Executive Summary |
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This document presents the Town of South Boston's Waste Water Treatment Facility strategy to comply with the Clean Air Act requirements of Section 112(r)(7), Accidental Release Prevention Requirements: Risk Management Program. It is the Town of South Boston's intent to enforce the policies and procedures presented in this document to prevent accidental releases of regulated substances or reduce the severity of those releases that do occur. 1.0 POLICIES IN PLACE The Town of South Boston Waste Water Treatment Facility complies with Clean Air Act and Occupation Safety and Health Administration (OSHA) air emissions regulations and has policies in place to ensure continued compliance. 2.0 SOURCE AND SUBSTANCES The facility is responsible for treating waste water for the Town of South Boston (SIC Code 4952, NAICS Code 22132). Chlorine (Chemical Abstracts Services, CAS Number 7782-50-5) is used to disinfect treated wastewater prior to discharging it into the Dan River. The Town of Sout h Boston stores approximately four (4) 1-ton cylinders on site. Sulfur Dioxide (CAS Number 7446-09-5) is used to reduce or eliminate the chlorine residual following the disinfection and prior to discharge into the Dan River. The Town of South Boston stores approximately ten (10) 150-lb cylinders on site. Since this is less than the threshold quantity of 5,000 lbs, Sulfur Dioxide is not considered a regulated substance at the Town of South Boston Waste Water Treatment Facility. In the event that the Facility plans to store 5,000 lbs of Sulfur Dioxide, this RMP must be revised before such quantities are allowed to be stored at the facility. 3.0 RELEASE SCENARIOS The worst case release scenario for a release of chlorine involves the failure of a one-ton cylinder releasing approximately 2,000 lbs of chlorine. In this scenario, the entire amount is released over a ten-minute period at a rate of 110 pounds per minute (lbs/min). The distance to the toxic endpoint the chlorine would t ravel, before dispersing enough to no longer pose a health hazard, is 0.9 miles. The alternate release scenario for the release of chlorine involves release through a 5/16 inch hole in the cylinder. The release rate is 15 lbs/min. The distance to the toxic endpoint is 0.1 miles. In both scenarios, the building enclosure was considered as passive mitigation. 4.0 ACCIDENTAL RELEASE PREVENTION PROGRAM The facility is in compliance with the OSHA Process Safety Management (PSM) rule and, with this document, the Clean Air Act Accidental Release Prevention Program regulations. The Town of South Boston Waste Water Treatment Facility relies on a system of equipment maintenance and periodic testing to prevent accidental releases. 5.0 ACCIDENT HISTORY To date, the Town of South Boston Waste Water Treatment Facility has had no accidental releases of chlorine. 6.0 EMERGENCY RESPONSE PROGRAM The Town of South Boston Treatment Facility does not have an emergency response plan which ha s been coordinated with community emergency responders. The facility relies entirely on local community emergency response teams to address releases. 7.0 PLANNED CHANGES TO IMPROVE SAFETY The Town of South Boston Waste Water Treatment Facility has an ongoing maintenance training and operational training program to continuously update operator knowledge of systems within their facility. |