Montpelier Water Pollution Control Facility - Executive Summary |
|
EXECUTIVE SUMMARY-MONTPELIER WATER POLLUTION CONTROL FACILITY 1. Accidental release prevention and emergency response policies The WPCF wastewater treatment plant is staffed with five licensed employees with an average on the job experience of 15 years. The Chief of Operations has been at the plant for nearly 20 years. He reports directly to the Director of Public Works. The City of Montpelier is committed to the practice of good safety and to this end has prepared a Safety Manual for Public Works Employees consisting of General Regulations for the Safety and Protection of Employees. An appointed Safety Committee, which consists of the WPCF licensed operators and the Director of Public Works meets quarterly to discuss these regulations and to develop or revise as appropriate. Training is conducted at these quarterly sessions with the use of various training tools such as videos, slides, etc. The Supervisor is the Key to the entire accident prevention program. He is at all tim es responsible for: -The execution in a safe manner of work under his supervision -The safety of all employees under his supervision -The safety of the general public in connection with his work One of the fundamental premises of the employee safety procedure is to operate on the "buddy" system. An employee never enters a confined space or a covered process area (e.g., chlorine storage room) without there being an employee present on the outside to observe. Accident investigations are conducted at the time of an incident. Whenever an injury, fatality, property damage, fire, equipment or vehicle accident occurs, an employee must immediately notify the Supervisor or Chief of Operations. The Supervisor will conduct an investigation of the incident and submit a written report to the Director of Public Works, usually within 24 hours. The plant Safety Officer will conduct or assist in a follow up investigation, if necessary. The Supervisor makes continuous safety inspections of buil dings, machinery, mobile equipment and vehicles, tools and work areas as an integral part of his duties. Defective equipment or unsafe conditions found by these inspections is repaired or remedied as promptly as possible. The Safety Officer performs an entrance and exit interview of employees whenever practicable. Whenever necessary, a written and dated report, signed by the Safety Officer is submitted through proper channels, showing deficiencies observed and a date for compliance. If the date for compliance can not be met by a support staff member, written notification showing why the correction could not or should not be made is made to the Safety Officer. The RMP is the latest step in our continuing efforts to improve the safety of our plant. A result of these improvements will be the prevention of the accidental release of any chemical that could threaten public health or the environment. It also ensures that were an accidental release to occur, real plans are in place to quickly minimize any potential risk to our community. 2. City of Montpelier Wastewater Pollution Control Facility and regulated substances The EPA Risk Management Planning: Accidental Release Prevention Program (RMPProgram) regulations, developed under Section 112 (r) of the amended Clean Air Act (CAA), were signed into law on 15 November 1990. The law mandates a renewed focus upon the prevention of chemical accidents. The objective is to prevent serious chemical accidents that have the potential to affect public health and the environment. The law is intended to prevent and to minimize the impacts upon the employee and the public of accidental releases of extremely hazardous (toxic) substances and flammable substances. The planning requirements of CAA section 112 (r) complement and support the previous laws, including the Emergency Planning and Community Right to Know act of 1986 (EPCRA). EPCRA helps local communities prepare for and respond to chemical accidents. Montpel ier has a local document entitled "Emergency Operations Plan" in place, a copy of which may be reviewed at the Police Department and at various other locations throughout the City. Washington and Orange Counties have been established as the District 5 Local Emergency Planning Committee (LEPC) by the State of Vermont Emergency Management Department. A regionalized emergency response plan is due to be finalized by June 30, 1999. Under the new law, facilities must identify and assess their chemical hazards and carry out prescribed activities which are designed to reduce the likelihood and severity of accidental chemical releases. Information summarizing these activities is available to state and local governments, the public and all other stakeholders. In the broadest sense, Risk Management Planning relates to local emergency preparedness and response to pollution prevention at facilities, and to worker safety. We are proud to say that together with local authorities and other hel pful community representatives, the WPCF has completed and submitted its Risk Management Plan to the EPA. The WPCF utilizes two toxic chemicals at its treatment plant which are subject to the requirements of the Risk Management Program. These chemicals are chlorine, which is a gas liquefied under pressure and which is further stored in industry standard steel containers weighing one ton; and sulfur dioxide, which is also a gas liquified under pressure also in steel containers weighing one ton and is used by the facility to neutralize the effects of the chlorine, following disinfection. (Sulfur dioxide reduces the chlorine concentration to an acceptable level prior to discharging the treated wastewater effluent into the Winooski River. Excess chlorine would in time have a detrimental effect upon the fish and other wildlife inhabiting the waterway). Currently, the facility uses an average of fifty (50) pounds per day of chlorine and fifty (50) pounds per day of sulfur dioxide a s part of the wastewater treatment process that provides this service to the community. We have used chlorine to disinfect our treated wastewater effluent since 1964. Chlorine has historically been the most widely used disinfectant used in drinking water or wastewater for nearly 100 years, reducing or eliminating the risk of waterborne diseases such as cholera, typhoid and dysentery. For this reason, there is abundant information on the safe and proper use, handling and storage of this chemical. The chlorine and sulfur dioxide we use at the plant is stored here at the facility. The room which stores these chemicals has been designed and constructed in accordance with all applicable standards, some of which include Recommended Standards for Wastewater Treatment Works, Chlorine Institute Water and Wastewater Operators Handbook, as well as all applicable state and local building codes. Since we store greater than 2500 pounds of chlorine and 5000 pounds of sulfur dioxide, we are requi red to submit a Risk Management Plan to EPA. 3. Worst Case Release Scenario and alternative release scenario Throughout the various documents related to a Risk Management Program, you will find reference to the terms "Offsite Consequence Analysis", "Worst Case Release" and "Alternative Release Scenario". An Offsite Consequence Analysis (OCA) must be performed to estimate the radius of an area surrounding the facility which could be impacted by a liquid or gaseous release. The area within the circle in theory may contain a concentration of chlorine (or sulfur dioxide) gas which is greater than or equal to the second level of the Emergency Response Planning Guidelines (EPRG-2). The EPRG-2 is the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ability to take protective action. A Worst Case Scenario consists of the sudden and instantaneous liquid release of the total contents of the liquified gas in a one ton (2000 pound) container in 10 minutes. The EPA's developed RMP*Comp computer program was used to determine an EPRG-2 distance of 0.9 miles from the WPCF associated with this type of a release. For the Alternative Scenario, a separate scenario for chlorine and sulfur dioxide each consists of the release of the total contents of a one ton container in 60 minutes. The release scenario assumes that the 5/16 inch gas valve on a ton cylinder remains open. For such a scenario, the operator would have to negligently leave the valve open and the leak detection alarm would need to be ignored for one hour. The downwind distance to the EPRG-2 was thus calculated as 0.2 miles. It should be noted that the ton containers were used in both release scenarios. This is because the WPCF chlorination or sulfonation systems are each designed such that after the liquifie d gas exits the container, it is immediately converted into a gas under a vacuum pressure; this prevents any chlorine liquid or gas from escaping the piping between the cylinder and the point of application. This system is safer than the historically used direct feed, where the chlorine gas is under a positive pressure from the container to the application point. Other mitigative measures or process controls designed to protect employees and the public include the use of leak detectors for both chlorine gas and sulfur dioxide gas. These each trigger alarms which are sent to the Montpelier Police Station. Also, a document titled "Prevention Program", which is designed to fulfill requirements under the OSHA Process Safety management regulation and under the RMP regulation is in place. This document contains about thirteen sections; some of which are process safety, process hazard review procedures, process operations, training and maintenance. For instance, the process hazard revie w must identify the hazards of the substances (chlorine and sulfur dioxide), list potential equipment failures or human errors that could result in an accidental release, (e.g., operator leaves container valve opens and alarms are ignored), present recommended safeguards to prevent failures or errors and implement steps necessary to detect or monitor releases. A system must be developed for addressing the recommendations of a Process hazards team and documenting resolutions and corrective actions taken. 4. General accidental release prevention program and chemical specific prevention steps There are many safety related rules and regulations adhered to by the WPCF in addition to the EPA's Accidental Release Prevention Rule. Some of these include OSHA Hazard Communications, OSHA Hazardous Materials Operations, Emergency Planning and Community Right to Know Act, and the OSHA Process Safety Management regulation. These regulations also contain a general duty clause, which mandates g ood safety practices be maintained at a facility, regardless of whether or not the facility is governed under any legislation. 5. Five year Accident History We have never had an accidental release of chlorine and/or sulfur dioxide at our facility. We had one sulfur dioxide container valve malfunction internally in 1991. This resulted in ice crystallizing on the external piping, but the liquid sulfur dioxide was fully contained within the manifold tubing. The manufacturer was contacted and the bad container was removed. 6. The Emergency Response Program This facility's emergency response program is based upon the Chlorine Institute's Pamphlet 64, Emergency Response Plans for Chlorine Facilities. Representatives of local agencies met on June 14, 1999 to discuss this plan. We have made recent modifications to our plan. A follow up meeting with these agencies is planned for this September to discuss any comments. Plans will be kept on file at the office of the Director of Pu blic Works, the Police Department, the Fire Department, Vermont District 5 Local Emergency Planning Committee and at the Water Pollution Control Facility. Through this RMP, local emergency responders and other community authorities have become an important part of our risk management process. Details of our Risk Management Program are available through our facility to anyone who is interested. If you would like a copy, simply contact us at 802.223.9508 or check the EPA's internet site where the plan will be posted. If you have any suggestions or concerns about the plan, please call the same number. 7. Planned changes to improve safety Our facility was constructed in 1964, was upgraded in 1978, and is currently undergoing capital modifications to improve treatment and to more efficiently process sludge. In 1987 we upgraded the facility again to meet State Regulations to dechlorinate our effluent before discharging into the Winooski River. We are in compliance with general Chlor ine Institute Guidelines and with applicable OSHA guidelines and regulations. We routinely evaluate and update our equipment, training and procedures. We continue to participate in Chlorine Institute programs, our wastewater operators are trained and receive annual refresher training put on by the state in all aspects of operation of this plant. We continue to improve our operations in accordance with the OSHA general duty clause, which pertains to any facility which uses toxic materials. All WPCF employees and on-site contractos will have access to Process Hazard Analyses reports and other RMP Program information required to safely perform their duties. Employees may request access to this information by verbal request through the Director of Public Works, acting as the RMP Program Manager. The RMP Program Manager will provide timely access to approved requests during normal working hours. All current WPCF personnel will receive initial RMP Program orientation concurrent with annual EPCRA right-to-know training. New personnel will receive initial RMP Program orientation concurrent with new operator training prior to commencing working. |