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South Wastewater Treatment Plant

Parent Companies:
City of Baton Rouge - East Baton Rouge Parish
EPA Facility ID:
Other ID:
Facility DUNS:
Parent Company DUNS:


2850 Gardere Lane
Baton Rouge, LA 70820
Lat / Long:
30.350, -91.137 (Get map)
Interpolation - Photo
Facility Centroid
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:


City of Baton Rouge - EBR Parish
(225) 389-3240
2443 River Road
Baton Rouge, LA 70802 -8074
Foreign Address:

Person responsible for RMP implementation:

Hugh M. Taylor
SWWTP Superintendent

Emergency contact:

Ms. Cheryl Berry, P. E.
Special Projects Engineer
(225) 389-3240
24-hour phone:
(225) 389-3240
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
Facility (or company) URL:


Local Emergency Planning Committee:
East Baton Rouge LEPC
Full-Time Equivalent Employees:
Covered by OSHA PSM:
EPCRA section 302:
CAA Title Air Operating Permit:
CAA Permit ID#:
OSHA Star/Merit Ranking
Last Safety Inspection Date:
Inspecting Agency:
Fire Department
Using Predictive Filing:


Chlorination System
CBI claimed:
Program Level:
Sewage Treatment Facilities (22132)
Chemical name
Quantity (lbs.)
Public OCA Chemical

RMP Preparer:

Victor J. Sanchez
7389 Florida Blvd.
Suite 300
Baton Rouge, LA 70806
Foreign Address:

(225) 922-5787

Latest RMP Submission:

July 27, 2009
5-year update (40 CFR 68.190(b)(1))


Effective Date:
Source no longer uses any regulated substance
Other Reason:

2. Toxics: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Chlorination System)
CBI claimed:
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
Wind speed (meters per sec):
Stability class:
Passive mitigation
  • Enclosures
not considered:
  • Dikes
  • Berms
  • Drains
  • Sumps

3. Toxics: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Chlorination System)
CBI claimed:
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
Stability class:
Passive mitigation
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown

4. Flammables: Worst-case


5. Flammables: Alternative release


6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

No Prevention Program level 3

8. Prevention Program level 2

Chlorination System, Sewage Treatment Facilities (22132)
Prevention Program ID:
Safety Review Date
June 25, 2008, since latest RMP submission
PHA Update Date
, since latest RMP submission
Safety Regulations
  • None
Hazards Identified
  • Toxic Release
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Floods
  • Hurricanes
Process Controls
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Power
  • Rupture Disks
  • Excess Flow Device
Mitigation Systems
  • Dikes
  • Enclosure
  • Neutralization
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classroom
  • On the Job
Competency Testing
  • Demonstration
  • Observation
Procedure Review Date
Nov. 10, 2008, since latest RMP submission
Training Review Date
May 12, 2008, since latest RMP submission
Maintenance Review Date
Nov. 10, 2008, since latest RMP submission
Maintenance Inspection Date
June 3, 2009, since latest RMP submission
Equipment Tested
Management of Change Most Recent Date
Management of Change Review Date
Pre-startup Review Date
Compliance Audit Date
Sept. 15, 2006
Compliance Audit Change Completion Date
Nov. 15, 2007
Incident Investigation Date
Incident Invest. Change Completion Date
Participation Plan Review Date
Hot Work Review Date
Contractor Safety Review Date
, since latest RMP submission
Contractor Safety Eval. Date
, since latest RMP submission

9. Emergency response

Facility In Community Plan:
Facility Own Response Plan:
Specific Facility Response Plan:
Inform. Procedures in Response Plan:
Emergency Care in Response Plan:
Plan Review Date:
Response Training Date:
June 25, 2008
Local Response Agency:
Local Response Agency Phone:
(225) 389-4617
Subject To - OSHA EAP:
Subject To - CWA:
Subject To - RCRA:
Subject To - OPA:
Subject To - State EPCRA:
Subject To - Other:

Executive Summary

City of Baton Rouge
South Wastewater Treatment Plant

LADEQ Facility Number 7777

USEPA Facility Identifier No. 1000 0004 5471


The City of Baton Rouge continues its commitment to maintain full compliance with all federal, state and local regulations. Pursuant to this commitment, the City makes every effort to operate the wastewater treatment facilities in a safe manner, in accordance with all applicable rules and regulations and according to established good engineering and management principles.

The Baton Rouge South Wastewater Treatment Plant (SWWTP) was designed by qualified and experienced engineers and all operating personnel received the necessary training for the safe operation of the plant.


The SWWTP receives domestic wastewater from the south third of the City's urban perimeter and provides secondary treatment to this wastewater. Before being discharged into the Mississippi River, the treated effluent is disinfected with chlorine. The use of this chemical makes the SWWTP subject to the provisions and requirements of Section 112(r) of the Clean Air Act.

Chlorine. The SWWTP has two 5,000-gallon storage tanks (nominal size) to satisfy the chlorine needs of the wastewater disinfection process. Each tank's working capacity is limited, by means of administrative controls, to a maximum of approximately 4,000 gallons, or no more than 50,000 lb. of liquid chlorine per tank. This chemical is delivered on the plant site by dedicated tanker trucks operated by the chlorine supplier. All of the chlorine storage and handling facilities are enclosed inside a steel-frame and concrete building.

Sulfur Dioxide. The SWWTP no longer uses sulfur dioxide for dechlorination. By tightly controlling the chlorination dosage, it has been possible to maintain the residual chlorine level within required limits, without the need for any s
ulfur dioxide addition.

The SWWTP no longer keeps any sulfur dioxide inventory on site.


The requirements of 40 CFR Part 68 includes, among other items, the development of a Worst-Case Scenario (WCS) and an Alternative Release Scenario (ARS) for the possible release of significant quantities of each regulated toxic substance (chlorine). The Executive Summary (ES) submitted with the original RMP included a discussion of the WSC's and ARS's for both chlorine and sulfur dioxide, in compliance with such requirements.

Considering that the operation of the chlorination system has not undergone any changes that would affect either the WCS or the ARS for chlorine since the original RMP was submitted, the original WCS and ARS for this chemical and their underlying assumptions are still valid. The WCS and ARS for sulfur dioxide are no longer be applicable (this chemical is no longer in use, as mentioned above), therefore they are not included in this RMP update.

The chlorine WCS and ARS will not be discussed further in this Executive Summary (ES). In accordance with the 2004 revisions to 40 CFR Part 68 (69 FR 18819-18837, April 9, 2004), it is no longer required to include a discussion of the WCS's and ARS's in the ES.


1.0 Safety Information

The South Wastewater Treatment plant of the city of Baton Rouge keeps on site the necessary documents related to the operation and maintenance of the plant in a safe manner. Documentation kept on site provides information regarding the chemical properties and chemical hazards associated with the regulated chemicals (not only chlorine but sodium hydroxide solution - caustic - as well); operating limits for all key process parameters; record of the current inventory of these chemicals; and data on equipment design and specifications.

These documents include, but are not limited to the following:

* Copies of current Material Safety Data Sheets (MSDS's) for the chemicals involved
Vendor's Operation and Maintenance (O&M) manuals for each major component of the chlorination and dechlorination systems.
* A complete set of construction drawings and specifications
* A copy of the plant's Emergency Response Plan
* Copies of Shop Drawings and assembly instructions for all major components
* Copies of the Operator's daily log sheets are kept on file. They show material inventories and a record of the shipments of chemicals delivered on site.

The above records are updated as applicable and necessary.

2.0 Process Hazard Analysis (PHA)

A detailed review of the hazards (Process Hazard assessment, or PHA) associated with the operation of the chlorination system at the SWWTP was last performed June of 2004 and a new one has just been performed within the last few days. The Process Hazard and Operability (HAZOP) review technique was used to identify any hazards and to ensure that the necessary controls are in place to manage such hazards.

A team of individuals representing the operations, maintenance, safety, engineering and management departments conducted the HAZOP review and a report that presents and discusses the "Action Items (AI)" is currently being prepared. This report will be submitted to management for resolution. The corrective action(s) identified for each AI, as well as its final resolution, will be documented.

Further, since the sulfur dioxide system at the SWWTP is no longer in operation, a new PHA for this system was not deemed necessary.

3.0 Operating Procedures

The SWWTP keeps on site copies of all operating and maintenance procedures that were prepared and submitted to the city by the plant design firm. These procedures address not only normal plant operations but other operating modes such as start-up, normal shut-down, emergency shut-downs, start-up following emergency shut-downs, etc. These procedures also address the removal of individual components from the process for inspection and/or maintenance and they discuss t
he consequences of deviations from the normal operating conditions and the steps to be followed to correct such deviations.

The plantA?s operating and maintenance procedures are reviewed and updated any time that the process undergoes a significant modification or improvement.

4.0 Training

All of the employees involved in the operation of the chlorination and dechlorination systems at the SWWTP underwent initial class-room and hands-on training provided by the design consulting firm. As a part of this training, the employees were given written tests to verify their understanding of the process, the operating conditions, the hazards inherent in the materials being handled and the appropriate responses to alarm conditions and emergencies.

Any time that the process undergoes modifications, changes or improvements, all operators affected by such changes will be provided with the necessary training. In addition, periodic refresher training sessions are held with the participation of all operating and maintenance personnel.

5.0 Maintenance

The SWWTP has in place procedures for the periodic inspection and maintenance of the major components of the chlorination and dechlorination systems. The operator performs daily rounds, during which he/she visually inspects all process equipment, instruments and piping and also verifies that the system is operating according to design. The operator will enter his/her comments and observations on the daily log, when and as applicable. Any condition that requires the maintenance department's attention will be submitted to the maintenance supervisor, via a work order request.

All members of the maintenance department staff have undergone training and have hands-on experience in the routine repair and maintenance of process equipment. In addition, specialized equipment such as the chlorinators and the control valves are maintained by contract personnel who have experience with this particular type of equipment.

6.0 Complian
ce Audits

The SWWTP has in place compliance safety audit procedures that call for periodic audits to be performed on the plant's Risk Management Program (RMP) at least every three years. These audits will determine how effectively the policies and procedures of the RMP have been implemented. The audit findings are submitted to management for resolution and corrective action as necessary and applicable. Documentation of the audits, findings and resolutions are maintained as part of the prevention program.

The last compliance audit was performed in September of 2006. The audit team included members of the operation, maintenance and management staffs of the wastewater treatment department. A new such audit is due during the current year.

7.0 Incident Investigation

The SWWTP has established procedures to promptly investigate all incidents which result, or could reasonably have resulted, in a significant release of chlorine gas or which could have caused personnel injuries or significant damage to property. The objectives of such investigations are:

* to establish the facts relating to the incident,
* to determine the factors causing or contributing, directly or indirectly, to the incident, and
* to define what corrective actions, if any, are necessary to prevent such incidents from occurring in the future.

The incident investigation team includes members of the staff who are familiar with the process involved in the incident and also includes personnel from the operations, maintenance and management departments.

The investigating team submits its findings and recommendations to plant management for resolution. Corrective actions taken in response to the investigation report are tracked until completed. The final resolution of each finding or recommendation is documented and the investigation results are reviewed with all employees, including contractors, who could be affected by said findings. Incident investigation reports are kept on file for a minimu
m of 5 years.


The SWWTP has not experienced any reportable accidental release of chlorine or sulfur dioxide, as defined at 40 CFR A?68.42(a), in the past five years.


The South WWTP has in place a written Emergency Preparedness and Response Plan for the Chlorine System. Major sections of the Plan are as follows:
* Description of the uses of Chlorine within the plant
* Physical Properties of Chlorine.
* Safety measures that must be taken before working in a Chlorine environment
* Description of monitoring, warning and alarm systems in place at the Chlorine building
* Description of Leak-containing features of the chlorine storage system
* Description of safety features and measures provided at the chlorine facilities.
* Accessibility restrictions in the chlorine area
* Personnel responsibilities during a chlorine emergency, including local and evacuation alarms.
* List of emergency call numbers to be contacted (local agencies and public)
* Communications with the media and with the public
* Emergencies requiring public action
* Emergency medical treatments
* Closure of emergency condition
* Plant evacuation checklist
* Chlorine system design specification summary

The final version of the Emergency Preparedness and Response Plan was issued in 1997, at approximately the time that the chlorine and sulfur dioxide systems were installed. This plan was revised and updated in March, 2,001.
At the State of Louisiana Department of Environmental Quality's (LDEQA?s) request, the full text of the emergency response plan was submitted in 2001 as part of a few minor corrections made to the RMP at that time. There have not been any significant changes made to this plan since. The emergency response plan is periodically reviewed and verified for completeness and correctness.

Emergency preparedness and response drills are held periodically with participation of personnel from all three of Baton Rouge's wastewater treatmen
t plants. These drills also involve the participation of and are executed under the guidance of the Baton Rouge HazMat team and the Baton Rouge Fire Department.


At the present time the SWWTP has not defined any process changes or improvements that may result in improved safety.

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