BVPISA Waste Water Treatment Facility - Executive Summary

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This document presents the Blacksburg-VPI Sanitation Authority's Stroubles Creek Waste Water Treatment Facility's strategy to comply with the Clean Air Act requirements of Section 112(r)(7), Accidental Release Prevention Requirements: Risk Management Program.  It is the Blacksburg-VPI Sanitation Authority'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 Blacksburg-VPI Sanitation Authority 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 Blacksburg and VPI&SU (SIC Code 4952, NAICS 22131). Chlorine (Chemical Abstracts Services, CAS Number 7782-50-5) is used to disinfect treated wast 
ewater prior to discharging it into the New River. The Blacksburg-VPI Sanitation Authority stores approximately eight (8) 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 New River.  The Blacksburg-VPI Sanitation Authority stores approximately four (4) 1-ton cylinders on site. 
 
3.0  RELEASE SCENARIOS 
 
The worst case release scenario for a release of chlorine involves the failure of a one-ton containers releasing approximately 2,000 lbs of chlorine.  In this scenario, the chlorine 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 travel, before dispersing enough to no longer pose a health hazard, is 0.9 miles.  This distance was limited by considering the enclosed building as a passive mitigation measure. 
 
The worst case release scenario for a release of sulfur dioxide involv 
es the failure of a one-ton container releasing approximately 2,000 lbs of sulfur dioxide.  In this scenario, sulfur dioxide is released over a ten-minute period at a rate of 110 pounds per minute (lbs/min).  The distance to the toxic endpoint the sulfur dioxide would travel, before dispersing enough to no longer pose a health hazard, is 0.9 miles.  This distance was limited by considering the enclosed building as a passive mitigation measure.  
 
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.   This distance was limited by considering the enclosed building as a passive mitigation measure. 
 
 
The alternate release scenario for sulfur dioxide involves the release through a 5/16 inch hole in the storage tank. The release rate is 7 lbs/min. The distance to the toxic endpoint is less than 0.1 miles.  This distance was limited by considering th 
e enclosed building as a passive mitigation measure. 
 
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 Blacksburg-VPI Sanitation Authority 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 Blacksburg-VPI Sanitation Authority Waste Water Treatment Facility has had no accidental releases of chlorine or sulfur dioxide. 
 
6.0  EMERGENCY RESPONSE PROGRAM 
 
The Blacksburg-VPI Sanitation Authority Waste Water Treatment Facility is included in  Montgomery/Blacksburg LEPC's written community emergency response plan.  The facility relies entirely on local community emergency response teams to address releases. 
 
7.0  PLANNED CHANGES TO IMPROVE SAFETY 
 
There are no planned changes to improve safety.
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