City of Gainesville Linwood WWTP - Executive Summary

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The City of Gainesville Linwood Wastewater Treatment Plant (WWTP) is located at 500 Linwood Drive in Gainesville, Georgia.  The Linwood WWTP utilizes chlorine to treat wastewater for the City of Gainesville area.  The plant is subject to the RMP regulations since it has greater than 2,500 pounds of chlorine on site.  The maximum intended inventory of chlorine will be four 1-ton cylinders. 
The Linwood WWTP provides a vital service to the local community.  The use of chlorine to treat wastewater is a universally accepted process. The City of Gainesville recognizes the hazards associated with utilizing chlorine and has rigorous controls in place to avoid releases.  The Linwood WWTP developed a RMP Program Manual that summarizes their unified approach to RMP compliance.  The RMP Program integrates technology, procedures, and management practices to proactively manage the potential risks associated with chlorine storage and use.  The program seeks to provide for employee safety, public saf 
ety, and response agency interaction. 
The RMP Rule has three different levels of compliance (Programs 1-3).  The required levels depend on a combination of the facility's accident history, the presence of off-site public and environmental receptors within the worst-case release scenario radius, OSHA PSM status, and SIC code.  The Linwood WWTP is subject to RMP Program Level 2 because they have chlorine on-site in excess of the 2,500 pounds threshold quantity and public receptors within the worst-case release scenario circle.  The Program Level 2 Prevention Program in place at the Linwood WWTP is in compliance with the RMP regulations and includes the use of equipment, buildings, and processes designed in accordance with industry codes; formal hazard review procedures; written standard operating procedures; a computerized maintenance system; and, employee training.  Emergency response has been coordinated with the local fire departments and the Hall CountyLEPC.  The site also has forma 
l incident investigation procedures and will be performing RMP Program compliance auditing periodically to ensure the Linwood WWTP remains in compliance with RMP requirements. 
A Worst-Case Release Scenario (WCRS) and Alternate Release Scenario (ARS) was performed for the chlorine stored on-site.  The WCRS is an unrealistic scenario calculated utilizing USEPA-specified parameters.  The purpose of the WCRS is to draw attention to the site.  The WCRS calculated for the Linwood WWTP assumed no administrative controls or passive mitigation.  The WCRS was calculated using RMP Comp and verified against the AWWA guidance for water treatment plants and the USEPA guidance document for wastewater treatment plants.  The ARS was also calculated using RMP Comp.  The scenario specifics were based on information provided by the AWWA guidance document and verified with information from The Chlorine Institute.   The Alternate Release Scenario chosen was Scenario I.D. CLA-3 from the AWWA RMP Guidance Do 
cument (Table 5-5):  Alternative Scenario for 1-ton Chlorine Container with Gas Feed:  Tubing failure, bad connection, or valve failure resulting in the release of gas through the 5/16-inch-diameter valve body opening. 
No chlorine-related accidents have occurred on-site in the past 5 years that resulted in on-site or offsite impacts. 
The City of Gainesville Linwood WWTP will be a defensive responder to accidental releases of chlorine.  A letter was transmitted to the local fire departments and the Hall County LEPC to ask that the facility be included in the community emergency response plan and inviting the fire department to visit the site to prepare for potential emergencies involving chlorine.  Emergency notification and evacuation procedures are posted at facility telephones and outside the facility gate.  Facility personnel will be provided emergency awareness level training at on-site monthly safety meetings. 
Significant upgrades to the Linwood WWTP are planned by the City of  
Gainesville.  The City is contemplating replacing the on-site chlorine treatment system with uV disinfection.  Preliminary planning is underway with potential project completion by the summer of 2004.
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