Waukesha Wastewater Treatment Plant - Executive Summary

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The Waukesha Wastewater Treatment Plant is committed to promoting a safe operating environment for the facility, its employees, and the surrounding community. As of June 9, 1999, the facility is completing its compliance program to meet the requirements of Wisconsin ILHR 32.293, "Process Safety Management of Highly Hazardous Chemicals" for the chlorination and dechlorination processes. The remaining training requirements will be completed by mid-July. Compliance with this regulation, and EPA's "Risk Management Program Rule" helps prevent the release of chlorine and sulfur dioxide from these processes. Additionally, these regulations required development of procedures to minimize releases of chlorine and sulfur dioxide in the event that they do occur, and to outline appropriate emergency response steps to take in the event of a release. 
The Waukesha Wastewater Treatment Plant is located at 600 Sentry Drive, Waukesha, Wisconsin, 53186. The facility has fourteen distinct processes that t 
reat wastewater prior to discharge to the Fox River. Two of those processes, the chlorination process and the dechlorination process, utilize chemicals regulated by EPA's Risk Management Program Rule: chlorine and sulfur dioxide. The chlorinination process adds chlorine gas to wastewater to reduce bacteria. The dechlorination process adds sulfur dioxide to remove excess chlorine prior to discharge to the Fox River, protecting aquatic life in the river. Both chlorine and sulfur dioxide are received in ton containers. The chlorination and dechlorination processes each have their own storage and process areas. These processes have been designed in accordance with all local, state, and federal codes. Each process has a gas detection / warning system, providing an alarm should concentration of chlorine or sulfur dioxide exceed 1 part per million. The chlorination and dechlorination processes are maintained and operated by personnel certified by the State of Wisconsin. 
The Waukesha Wastewat 
er Treatment Plant has developed its worst-case release scenario utilizing EPA's "Risk Management Program Guidance for Wastewater facilities." The scenario assumes that a ton container has ruptured, and released its contents within a 10-minute period. The release is assumed to take place outdoors. The release of either 2,000 pounds of chlorine or 2,000 pounds of sulfur dioxide has a toxic endpoint of 1.3 miles. This distance is based on a concentration to which a person could be exposed for up to an hour without suffering irreversible health effects or other symptoms that would make it difficult for that person to escape. It should be noted that such an incident is highly improbable. Ton containers are inspected by the chemical distributor each time they are filled. They are also hydrostatically tested every five years. Loading and unloading activities are attended by trained operators. Ton containers are immediately transferred from the delivery truck into indoor storage areas. All co 
ntainer handling equipment is inspected regularly, and certified for use annually. 
The Waukesha Wastewater Treatment Plant has developed its alternative release scenario also utilizing EPA's guidelines. This scenario presumes that a 1/4-inch liquid leak has developed in either the chlorine system or the sulfur dioxide system. Either release has a toxic endpoint of 0.2 miles. Again, such an incident is highly improbable, as both the chlorination and dechlorination systems have been designed, installed, and maintained to maximize the mechanical integrity of the piping systems. 
The Waukesha Wastewater Treatment Plant's emergency response program is based upon the OSHA requirements for Emergency Action Plans. The plan is coordinated with the City of Waukesha Fire Department.
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