City of Franklin Wastewater Treatment Plant - Executive Summary

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The City of Franklin owns and operates a wastewater treatment plant in Franklin, Tennessee.  The plant uses chlorine for disinfection and sulfur dioxide for dechlorination.  Both of these chemicals are classified as extremely hazardous substances. 
 
Since the plant uses and stores chlorine in excess of 2,500 pounds, it is subject to federal requirements including the preparation of PSM and RMP programs.  (Sulfur dioxide usage and storage is below the threshold quantity for PSM and RMP.)   Stringent RMP requirements (known as "Program 3 Level") apply to the City of Franklin because of Tennessee's OSHA jurisdiction.  The City of Franklin has developed an emergency plan to provide employees with specific details for emergency operations.  Additionally, in-house procedures are in place for training personnel on the chlorine system, mechanical inspection of equipment, incident investigation,compliance audits, and emergency response and action plan. 
 
Two release scenarios (worst-case and alte 
rnate-case) were modeled using the Areal Location of Hazardous Atmospheres, ALOHA(R), computer program.  The worst-case for chlorine (i.e., catastropic failure due to corrosion, impact, or construction defects causing a direct release of 2,000 pounds of chlorine over a 10-minute period, resulted in an endpoint of 2.6 miles.  The estimated number of persons residing in the 2.6-mile radius is 21,200.  The alternate-case scenario (i.e., gaseous release through a short pipe or valve) resulted in an endpoint of 0.4 mile.  The estimated number of persons residing in the 0.4-mile radius is 110. 
 
There has not been an accident involving chlorine that caused deaths, injuries, property or environmental damage, or sheltering in place at this facility in the past 5 years.
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