Las Vegas Street Wastewater Treatment Plant - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

This executive summary provides a brief overview of the Risk Management Program (RMP) and the associated policies at the Las Vegas Street Wastewater Treatment Plant (Las Vegas Street WWTP), one of several facilities owned and operated by the Colorado Springs Utilities (CSU). 
 
Prevention and Response Policies 
CSU believes that it is important to provide a safe workplace to its employees and minimize the impact of its operations on the surrounding community and the environment.  Accordingly, CSU has developed proactive safety and environmental programs, which are reliant upon active employee participation and management leadership and support.  This same proactive philosophy was employed in the development and implementation of the Las Vegas Street WWTP RMP for the chlorine and sulfur dioxide systems.  Correspondingly, CSU has determined to comply with the RMP Program 3 requirements although it is eligible for the less comprehensive requirements of Program 2.  By doing so, CSU affirms it 
s proactive safety and environmental philosophy and acknowledges the inherent value of full RMP compliance. 
 
The RMP prevention program is arguably the most important element of the rule.  Its program elements require the active participation of facility employees and management in conducting activities aimed at preventing accidental releases of regulated chemicals.  If prevention activities could be completely successful, there would be no need for emergency response activities, since no releases would occur.  Accordingly, a well-developed and properly-implemented prevention program will lower the possibility of an accidental release and minimize the consequences of a release should one occur. 
 
CSU takes an active role in preventing accidental releases at all of its facilities by ensuring that its employees are well-informed regarding the hazards associated with the regulated processes (e.g., chlorine and sulfur dioxide at the Las Vegas Street WWTP) and actively participated in compre 
hensive process hazard analyses.  The system employees are properly trained in the safe operation of the covered processes and the safe handling of treatment chemicals.  They are aided in this work by complete, understandable system operating procedures. 
 
CSU management understands its duty to provide a safe working environment and to take measures to prevent accidents that may have an effect on the surrounding community.  This understanding is reflected in procedures described and referenced in the Las Vegas Street WWTP RMP procedures and policies. 
 
As for emergency response, CSU has established and maintained procedures for emergency notification and response.  These are reviewed with employees on a periodic basis and revised to accommodate changes in staffing when they occur. 
 
Stationary Source and Regulated Substances 
The Las Vegas Street WWTP is located at 825 Las Vegas Street in Colorado Springs, El Paso County, Colorado.  The Las Vegas Street WWTP treats wastewater through a ser 
ies of physical, biological, and chemical treatment operations.  The facility provides service to over 300,000 people residing within a 150 square-mile area.  An average of 45 million gallons per day (MGD) of wastewater is treated daily;  the maximum treatment rate of the facility is 75 MGD (wet) or 65 MGD (dry). 
 
The Las Vegas Street WWTP utilizes chlorine as a biocide in the treatment of wastewater.  The chlorine is stored in one-ton containers with a maximum intended inventory of sixteen containers (32,000 pounds) on site.  In addition, the Las Vegas Street WWTP utilizes sulfur dioxide for the dechlorination of treated effluent.  The sulfur dioxide is stored in one-ton containers with a maximum intended inventory of ten containers (20,000 pounds) on site.  Therefore, the Las Vegas Street WWTP is regulated under the RMP rule due to the volume of chlorine and sulfur dioxide stored and used at the facility. 
 
Release Scenarios 
Worst-case and alternative release scenarios have been deter 
mined after careful review of the regulation and consideration of the storage vessel configuration at the facility.  For worst-case release scenario, the regulation is clear.  The assumption is that a full one-ton container of chemical is released over a ten-minute period.  No active mitigation may be considered.  Worst-case meteorological conditions as specified in the RMP regulation are also assumed to be present.  The release is also assumed to occur outdoors. 
 
For the alternative release scenario, the facility reviewed the consequences of a valve breaking off at the container connector during hookups inside the storage room.  No active mitigation was considered. The same scenario was assumed for both chlorine and sulfur dioxide. 
 
Results of the off-site consequence analyses are described in Sections 2 and 3 of the RMP*Submit plan for the Las Vegas Street WWTP. 
 
Prevention Steps for Chlorine 
The prevention program and chemical-specific prevention steps are described in detail in the 
Las Vegas Street WWTP RMP manual.  The prevention program includes the following elements: 
7 Process safety information, which includes information pertaining to the hazards of chlorine in the process, process technology, and process equipment 
7 Process hazard analysis (PHA), which includes a systematic evaluation (by an employee team) of:  the hazards of the chlorine process, identification of previous process incidents, engineering and administrative controls, consequences of failure of the engineering and administrative controls, facility siting, human factors, and possible safety and health effects of failure of controls 
7 Operating procedures, which include steps for each operating phase, operating limits, safety and health considerations, and safety systems and their functions 
7 Training for each Las Vegas Street WWTP employee involved in operating the chlorine system 
7 Mechanical integrity procedures to maintain the on-going integrity of the chlorine process equipment 
7 Managem 
ent of change procedures to manage changes (other than "replacements in kind") to the chlorine system 
7 Pre-startup safety review for additions or significant modifications to the chlorine process, or any new regulated chemical process 
7 Compliance audits at least every three years from 1999 to evaluate Las Vegas Street WWTP RMP compliance 
7 Incident investigation, to be conducted and documented for each incident that resulted in, or could have reasonably resulted in, a catastrophic release of chlorine from the Las Vegas Street WWTP 
7 Employee participation in the development and implementation of the Las Vegas Street WWTP RMP, and employee access to RMP information 
7 Hot work prohibition policy on or near the chlorine system when chlorine is present in the affected section of the process 
7 Contractor management program, to ensure appropriate evaluation and selection of qualified contractors for work on or near the chlorine system, proper notification of contractors regarding known chl 
orine system hazards and the Las Vegas Street WWTP emergency evacuation plan, limited access to the chlorine process, and evaluation of contractor performance 
 
In addition to these elements, the chlorine storage facility at the Las Vegas Street WWTP is equipped with a chlorine detection device that continuously monitors the air for chlorine gas.  If the chlorine sensor detects a specified level, a high rate ventilation system is automatically activated, which can also be activated manually.  The ventilation system withdraws chlorine and air from a low elevation in the chlorine storage room into a trench and dumps it into #3 reservoir.  The facility is also planning to install a chlorine chemical scrubber during the fall of 1999.  In the event of a release of chlorine in the storage room, the normal ventilation system will shut down and the chlorine-contaminated air will be sent to the scrubber for neutralization.  The scrubber will be maintained and tested on a regular basis to ensure  
proper operation during a chlorine release event.  Management of Change procedures will be used for the upgrades to the chlorine system. 
 
Prevention Steps for Sulfur Dioxide 
The prevention program and chemical-specific prevention steps are described in detail in the Las Vegas Street WWTP RMP manual.  The prevention program includes the following elements: 
7 Process safety information, which includes information pertaining to the hazards of sulfur dioxide in the process, process technology, and process equipment 
7 Process hazard analysis (PHA), which includes a systematic evaluation (by an employee team) of:  the hazards of the sulfur dioxide process, identification of previous process incidents, engineering and administrative controls, consequences of failure of the engineering and administrative controls, facility siting, human factors, and possible safety and health effects of failure of controls 
7 Operating procedures, which include steps for each operating phase, operating limits,  
safety and health considerations, and safety systems and their functions 
7 Training for each Las Vegas Street WWTP employee involved in operating the sulfur dioxide system 
7 Mechanical integrity procedures to maintain the on-going integrity of the sulfur dioxide process equipment 
7 Management of change procedures to manage changes (other than "replacements in kind") to the sulfur dioxide system 
7 Pre-startup safety review for additions or significant modifications to the sulfur dioxide process, or any new regulated chemical process 
7 Compliance audits at least every three years from 1999 to evaluate Las Vegas Street WWTP RMP compliance 
7 Incident investigation, to be conducted and documented for each incident that resulted in, or could have reasonably resulted in, a catastrophic release of sulfur dioside from the Las Vegas Street WWTP 
7 Employee participation in the development and implementation of the Las Vegas Street WWTP RMP, and employee access to RMP information 
7 Hot work prohib 
ition policy on or near the sulfur dioxide system when sulfur dioxide is present in the affected section of the process 
7 Contractor management program, to ensure appropriate evaluation and selection of qualified contractors for work on or near the sulfur dioxide system, proper notification of contractors regarding known sulfur dioxide system hazards and the Las Vegas Street WWTP emergency evacuation plan, limited access to the sulfur dioxide process, and evaluation of contractor performance 
 
In addition to these elements, the sulfur dioxide storage facility at the Las Vegas Street WWTP is equipped with a sulfur dioxide detection device that continuously monitors the air for sulfur dioxide gas.  If the sulfur dioxide sensor detects a specified level, a high rate ventilation system is automatically activated, which can also be activated manually.  The ventilation system withdraws sulfur dioxide and air from a low elevation in the sulfur dioxide storage room into a trench and dumps it in 
to #3 reservoir.  The facility is also planning to install a sulfur dioxide chemical scrubber during the fall of 1999.  In the event of a release of sulfur dioxide in the storage room, the normal ventilation system will shut down and the sulfur dioxide-contaminated air will be sent to the scrubber for neutralization.  The scrubber will be maintained and tested on a regular basis to ensure proper operation during a sulfur dioxide release event. Management of Change procedures will be used for the upgrades to the sulfur dioxide system. 
 
Accident History 
Within the five-year period prior to the submittal of this RMP, there were no accidental releases of chlorine or sulfur dioxide meeting the requirements of 40 CFR 68.42. 
 
Emergency Response Program 
This facility has established and maintains an emergency response program that is coordinated with local response agencies, including the City of Colorado Springs Fire Department and Hazardous Materials Response Team.  The program is described  
in detail in the Las Vegas Street WWTP RMP manual and meets the requirements of 40 CFR 68.95, which include facility notification of emergency responders and evacuation.  The goals of the program are to protect onsite employees from the hazardous effects of chemical releases and to minimize the effects of releases on the general public.  The program is routinely reviewed and updated to reflect personnel and regulatory changes. 
 
Planned Changes for Improved Safety 
Ideas for changes to improve safety are actively sought from employees.  Employee meetings that focus on safety issues are held regularly at the Las Vegas Street WWTP.  Employees are encouraged and trained to recognize hazards and to present ideas to eliminate them or to minimize the potential consequences of those hazards. 
 
As part of the development of the Las Vegas Street WWTP program, process hazard analyses were conducted with key employees to meet the prevention program requirements.  During these sessions, recommendatio 
ns were made for the purpose of improving safety and preventing accidental chemical releases.  Each recommendation has been or will be considered for implementation.  Though not all recommendations may be implemented, all will be considered.  The exercise has provided all affected employees with a heightened awareness of safety issues.
Click to return to beginning