City of Norfolk WPC - Executive Summary

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EXECUTIVE SUMMARY 
The City of Norfolk (WPC), Water Pollution Control is comprised of the wastewater treatment plant and a staff of 13 employees.  It provides activities necessary to clean wastewater to the State of Nebraska standards prior to discharge into the Elkhorn River and activities necessary to treat the resulting residual solids to Enviromental Protection Agency standards prior to being returned to farmland as a product for benificial use. 
 
1.  Accidental release prevention and emergency response policy: 
WPC staff is trained on safe chlorine operating and handling procedures.  Staff also performs preventive maintenance and yearly checks on the chlorination, scrubber, and leak detection systems.  The emergency response plan includes procedures for notification of the Norfolk Fire Division, which activates the Local Emergency Operations Plan (LEOP) and notifies any potentially affected neighbors.  Norfolk Fire Division is a member of the Elkhorn Valley LEPC. 
 
2.  Regulated Subst 
ance: 
As a part of the State of Nebraska standards, we are required to have a minimum fecal coliform count in the wastewater prior to discharge from May 1 through September 30, which is accomplished by using chlorine gas.  We utilize one ton, (2,000 lbs.) containers and may have up to 4 containers onsite. 
 
3.  The worse-case scenario and alternative release scenario: 
 
Worse-Case Scenario - A possible broken container valve on a one tone container will release chlorine gas, and could travel a distance of 1.3 miles.  If this type of leakage would occur, we would activate the emergency response program to protect our residential neighbors.  With staff training, we expect the probability of this scenario unlikely. 
 
Alternative Scenario - A leaking lead gasket that seals the container valve and vacuum regulator can possibly release a chlorine vapor cloud 15 lbs./min. and could travel a distance of 0.10 miles.  The containers are housed inside a concrete building and are monitored with chlor 
ine gas detectors, which activate a chlorine scrubber.  If this type of scenario did occur, we feel that trained staff and the associated scrubber can mitigate the offsite consequences. 
 
4.  Five-year accident history: 
We have not had any accidental releases since we started using chlorine in 1995. 
 
5.  Emergency response program: 
Our emergency response is to utilize an onsite chlorine scrubber, which is activated when a chlorine leak is detected and is able to consume a one ton container within 5 minutes.  WPC staff is also trained to respond to chlorine leaks by activation of the emergency respnse plan, which includes procedures for notification of the Norfolk Fire Division, which activates the Local Emergency Operations Plan (LEOP) and  notifies any potenially affected neighbors.  Norfolk Fire Division is a member of the Elkhorn Valley LEPC, which assists with contacting CHEMTREC and other agencies that initiates response from a HAZMAT team. 
 
6.  Planned changes to improve safety: 

e will keep up with the latest technology for safe chlorine use.
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