Winchester Wastewater Treatment Plant - Executive Summary

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Winchester Municipal Utilities Wastewater Treatment Plant, located at 2033 Van Meter Road, Winchester, KY, has one independent chlorine and one independent sulfur dioxide injection system.  The chlorine and sulfur dioxide storage is located outdoors.  The chlorination and sulfur dioxide injector processes are located inside a building.  The chlorine system has one (1) one-ton container of chlorine on line and one (1) one-ton container of chlorine on standby at any one time.   The sulfur dioxide system has one (1) one-ton container of sulfur dioxide on line and one (1) one-ton container of sulfur dioxide on standby at any one time.  The systems are operated under vacuum using gas.  There is a Vacuum Regulator-Check Unit (Wallace & Tiernan 500 lb/24 hour capacity) which automatically shuts off the cylinder in the event of a break in the vacuum line.  The supply systems can automatically switch between the on-line and standby chlorine containers when the on-line container is depleted. 
 
Th 
e facility has chlorine and sulfur dioxide detectors to monitor leakage in the chlorinator/sulfurator room. The sensors are located at about twelve inches above floor level.  The detectors will automatically alarm at the Facility and at the main control room panel.  
 
The facility normally stores a maximum of 4 one-ton chlorine cylinders and 3 sulfur dioxide cylinders at the site at any one time. Cylinders not in use are stored outdoors on a loading dock.  During chlorine/sulfur dioxide deliveries, the delivery truck backs up to the unloading area and the cylinders are taken off the truck and placed onto the dock.  
 
Normally, the chlorinator/injector room is secured with doors that remain closed except when the system is being inspected.  Inspection takes place daily. If a chlorine/sulfur dioxide leak is detected, the respective alarm will sound and the Operator will notify the Wastewater Treatment Plant Supervisor.  The Operator and Standby will don the self-contained Breathing Apparat 
us (SCBA) and the operator will then investigate the cause for the alarm.   The exhaust fans will be activated from the exterior of the building.  The air inside the building is evacuated and fresh air is drawn into the building through upper and lower vents respectively.  The Standby will remain outdoors in contact with the Operator ready to call for outside assistance if needed.  The Operator and the Standby are trained in chlorine safety and emergency procedures.  The Operator will shut the chlorine cylinder.  If the leakage is not stopped the Fire Department will be contacted.    
 
The Worst Case release for this facility assumes that a one-ton sulfur dioxide cylinder ruptures during unloading outdoors in a rural area.  The cylinder discharges a dense gas release under worst case meteorological conditions of F Stability and 1.5 meters per second and ambient temperature of 250C.  All two thousand pounds contained in the cylinder are assumed released over ten (10) minutes.  It is only 
presented for comparative purposes and for non-OSHA facilities to determine under which RMP Program Level the facility fits. 
 
The Worst Case Impact Area is three and one-tenth (3.1) miles in radius (EPA CEPP Risk Management Program Guidance For Wastewater Treatment Plants EPA 550-B-98-010 October 1998).  There are about 3,100 people living in the Worst Case release area who could be affected by this type of release.  Located within this area are seven schools (Clark County Board of Education, Clark Middle School, Conkwright Middle School, Central Elementary School, Fannie Bush Elementary School, Hannah McClure Elementary School, and Strode Station Elementary School).  In addition, there are ten child day care facilities (Animal Krackers Discovery Center, Clark Regional Center, D & V Loving Hands Childcare, Golden Rule Christian Day Care, Kid-Doodles Play and Learn Center, Rose Garden Child Care, Thoroughbred Learning Center, Tree Haven Child Care, Wonderland Day Care, and Calvary's Ki 
ds Christian Preschool).  There are also twenty eight churches, one hospital, one nursing home. 
 
The Most Likely case release assumes a release of chlorine occurs due to a pipe leak in the chlorine storage or chlorinator area.  In order to have a leak that emits chlorine outside of the facility, it is necessary to assume the chlorine alarm is activated and the automatic cylinder vacuum loss shut off fails.  The alarm would sound and the facility's emergency response team would be at the location within a few minutes to shut the system down at the cylinder. 
 
Under those assumptions, the most likely release case is assumed to be a steady-state leak of up to 5 pounds per minute of chlorine (either as a gaseous or a two-phase release) for 30 minutes (150 lbs).  It should be noted that a completely filled one-ton cylinder has maximum gaseous discharge rate of about 500 pounds per day (0.35 pounds per minute).  Significant gaseous discharges above this rate will result in the cylinder freezi 
ng up and the discharge stopped.  The Facility has only one (1) one-on cylinder hooked up to the header and a maximum discharge rate from that system could be 0.35 pounds of chlorine per minute.  It is also assumed that the cylinder discharges a dense gas release under meteorological conditions of D Stability and 3.0 meters per second at an ambient temperature of 250 C. 
 
The Most Likely Case Impact Area based upon the above conditions is a tenth (0.1) of a mile in radius (EPA CEPP Risk Management Program Guidance For Wastewater Treatment Plants EPA 550-B-98-010 October 1998).  It is estimated that there are 2 people living in the Most Likely Case release area who could be affected by this release.  There are no schools located within this area.  There are no hospitals or parks located within this area.  In fact most of this release would be contained on the Facility's property.  
 
The Most Likely case release for sulfur dioxide assumes a release  occurs due to a pipe leak in the sulfur  
dioxide storage or injector area.  In order to have a leak that emits sulfur dioxide outside of the facility, it is necessary to assume the sulfur dioxide alarm is activated and the automatic cylinder vacuum loss shut off fails.  The alarm would sound and the facility's emergency response team would be at the location within a few minutes to shut the system down at the cylinder. 
 
Under those assumptions, the most likely release case is assumed to be a steady-state leak of up to 5 pounds per minute of sulfur dioxide (either as a gaseous or a two-phase release) for 30 minutes (150 lbs).  It should be noted that a completely filled one-ton cylinder has maximum gaseous discharge rate of about 500 pounds per day (0.35 pounds per minute).  Significant gaseous discharges above this rate will result in the cylinder freezing up and the discharge stopped.  The Facility has only one (1) one-on cylinder hooked up to the header and a maximum discharge rate from that system could be 0.35 pounds of s 
ulfur dioxide per minute.  It is also assumed that the cylinder discharges a dense gas release under meteorological conditions of D Stability and 3.0 meters per second at an ambient temperature of 250 C. 
 
The Most Likely Case Impact Area based upon the above conditions is a tenth (0.1) of a mile in radius (EPA CEPP Risk Management Program Guidance For Wastewater Treatment Plants EPA 550-B-98-010 October 1998).  It is estimated that there are 2 people living in the Most Likely Case release area who could be affected by this release.  There are no schools located within this area.  There are no hospitals or parks located within this area.  In fact, most of this release would be contained on the Facility's property.                                                                                                                                                                                                                                                                                       
                                             The Facility has not had an accidental release of chlorine from this covered process in the five years prior to the submission of this Risk Management Plan (RMP).
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