HRSD Chesapeake-Elizabeth WWTP - Executive Summary

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Executive Summary 
Hampton Roads Sanitation District (HRSD), a political subdivision of the Commonwealth of Virginia, serves a population of 1.5 million in 16 cities and counties in southeast Virginia.  Our mission is to prevent pollution, protect public health, and support community development by providing wastewater collection, treatment, and related services.  For more information about HRSD, please visit our Web site at 
HRSD is dedicated to protecting the public and its employees and to preserving the quality of the waters of the Chesapeake Bay, by operating its facilities safely, efficiently, and in compliance with all regulatory requirements.  Among HRSD's nine publicly owned treatment works is the Chesapeake-Elizabeth wastewater treatment plant (WWTP) in Virginia Beach, Virginia, a 24-million-gallon-per-day (mgd)  secondary treatment facility that operates in compliance with all of the U.S. Environmental Protection Agency's (EPA) National Pollutant Discha 
rge Elimination System (NPDES) requirements.   
In the process of disinfecting and dechlorinating the plant's final effluent, the Chesapeake-Elizabeth WWTP currently uses gaseous chlorine and sulfur dioxide (anhydrous), which are classified by the EPA as regulated substances under its Risk Management Plan (RMP).  RMPs are due to EPA on June 21, 1999.  Prior to regulations that focus on these types of compounds including RMP, HRSD constructed special containment systems (buildings with chemical sensor alarms, special ventilation systems, and locked doors) and has installed emergency scrubbing systems.  HRSD has implemented the Occupational Safety and Health Association's (OSHA) required Process Safety Management (PSM) program at the Chesapeake-Elizabeth WWTP, which promotes the safe operation of the plant and facilitates compliance with the EPA's RMP rule.  
In accordance with Section 68.155 of the EPA's RMP rule, the following is submitted on behalf of HRSD.  For further information re 
garding HRSD's PSM or RMP programs, please contact Mr. Mark Feltner, Environmental Scientist, at (757)460-4254.  
Accidental Release Prevention and Emergency Response Policies (68.155(a)) 
HRSD's accidental release prevention policy involves a unified approach that integrates proven technology, staff fully trained in safe operation and maintenance practices, and tested management system practices.  All applicable procedures of the OSHA's PSM and EPA's RMP Prevention Program are adhered to, including key elements such as comprehensive training, detailed systems management, and practiced emergency response procedures. 
This document complies with the EPA's RMP, under Section 112 (r) of the Clean Air Act (CAA) Amendments of 1990, 40 Code of Federal Regulations (CFR) Part 68.   HRSD Chesapeake-Elizabeth WWTP has a chlorination system that uses chlorine gas fed from liquid chlorine containers and a dechlorination system that uses sulfur dioxide gas fed from liquid sulfur dioxide container 
s.  This document summarizes HRSD's existing health and safety programs, our internal management response team, policies, procedures, and on-going actions that are designed to prevent or minimize impacts of any accidental releases of chlorine or sulfur dioxide to the environment.  HRSD has prepared a detailed and comprehensive emergency response plan to handle any potential accidental releases that is designed to safeguard people both on- and off-site.  To date, we have had an excellent record in preventing accidents from occurring. 
Stationary Source and Regulated Substances Handled (68.155(b)) 
HRSD's Chesapeake-Elizabeth WWTP treats the wastewater from the residences, businesses, and industries in HRSD's service area.  The plant currently utilizes gaseous chlorine and sulfur dioxide (anhydrous) in pressurized one-ton containers for the disinfection and dechlorination of the plant's final effluent.  
Worst-Case and Alternate Release Scenarios (68.155(c)) 
The RMP off-site consequence 
analysis requires consideration of two release scenarios, identified as "worst-case" and "alternate" release scenarios. The worst-case scenario requires that the single largest vessel or pipe be evaluated for off-site impacts from either chlorine or sulfur dioxide.  An alternate release scenario is required for both substances.  Per EPA, the absolute worst-case scenario for the Chesapeake-Elizabeth facility is the complete loss of a single 2,000-pound container of chlorine or sulfur dioxide over a 10-minute period, under the worst possible atmospheric conditions, and shows an off-site impact.   An example of such an accident is a container rupture. The chlorine and sulfur dioxide containers are stored in an enclosed building, which provides containment of any potential release.  Therefore, in accordance with EPA guidance, the passive mitigation of the building was considered.  Active controls, such as the existing scrubbing system, are not allowed to be used under the worst-case relea 
se scenario; thus, this scenario represents the worst-case release potential for this facility. 
EPA's alternate release scenarios are represented by a transfer hose or vessel leak that also would occur inside the building where the containers are located and operated.  However, unlike the worst-case release scenario, this scenario is mitigated by the emergency scrubbers. 
Accidental Release Prevention Program and Chemical-Specific Steps (68.155(d)) 
HRSD is in full compliance with Federal RMP and State OSHA's PSM requirements.  Chemical-specific prevention steps include availability of self-contained escape breathing apparatus (worn by the operators during connection and disconnection of the chlorine and sulfur dioxide supplies), awareness of the hazardous and toxic properties of chlorine and sulfur dioxide, and the presence of chlorine and sulfur dioxide detectors and alarms. 
HRSD's  accidental release prevention program is based on the following key elements: 
7 Detailed management  
system and clear levels of responsibility and roles; 
7 Comprehensive safety process information that is readily available to staff, emergency responders, and contractors; 
7 Comprehensive preventive maintenance program; 
7 Completed process-hazard analysis of equipment and procedures, with operation and maintenance staff participation and review; 
7 Use of state-of-the-art process and safety equipment; 
7 Use of accurate and effective operating procedures, written with operations and maintenance staff participation; 
7 High level of training of operators and maintenance staff; 
7 Implementation of an incident investigation, inspection, and auditing program using qualified staff. 
Comprehensive chemical data have been assembled to include regulatory reporting and action thresholds, health hazards, and chemical exposure limitations, as well as detailed physical properties of each regulated substance.  This information was compiled from numerous sources and is intended to be a single source for 
the reader and the plant operator seeking data about these substances.  This information includes chlorine and sulfur dioxide background information, Material Safety Data Sheets (MSDS), and chlorine and sulfur dioxide reaction chemistry. 
Equipment safety information has been meticulously compiled on the chlorine and sulfur dioxide processes.  Specifications for each process have been collected in one place for easy reference for operators and maintenance staff.  On file at this facility are details such as maximum intended inventory; safe upper and lower temperatures; safe upper and lower pressures; and codes and standards used to design, build, and operate the processes.  Procedures are in place to trigger update of safety information if there is a major change that makes existing information inaccurate. 
Five-Year Accident History (68.155(e)) 
The RMP regulations require that facilities compile a history of accidents involving a release of chlorine or sulfur dioxide the could have  
caused safety or health hazards (deaths, injuries, property or environmental damage, evacuations, or sheltering in place).  The facility must report any accident within the last five years.   No accidents have occurred at HRSD's Chesapeake-Elizabeth facility in the last five years nor have there been any accidents in the entire thirty plus year history of this plant. 
Emergency Response Program (68.155(f)) 
HRSD has established a written emergency response program to be followed by employees, to help them safely respond to any accidental release of hazardous substances.  This program has been coordinated by HRSD's Safety Division and with the Virginia Beach Fire Department, which is a member of the Local Emergency Planning Committee (LEPC).  This program includes an emergency response notification plan.  Emergency response drills and drill evaluations are conducted every 12 months; emergency operation and response procedures are also reviewed at that time.  In the event of an emergency 
, community-wide notification systems are in place, and the Virginia Beach Fire Department coordinates the response actions. 
Planned Changes to Improve Safety (68.155(g)) 
HRSD has implemented all the necessary safety precautions, including the emergency scrubbing systems, and has had no accidents.  However, HRSD has made the commitment to convert all of its disinfection and dechlorination facilities to nonhazardous alternatives.  HRSD is evaluating the alternatives for the Chesapeake-Elizabeth WWTP.  Until the optimum disinfection and dechlorination alternative is determined and implemented in the future, HRSD will continue to operate the facility in the safest possible manner and in compliance with OSHA's PSM and EPA's RMP programs.
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