Treatment Plant Safety
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Chemical Handling and Safety

Chemical Handling and Safety

When you work at a water or sewer treatment plant, you almost certainly work with hazardous chemicals.

Some of the most common include:

·         Chlorine (in one or more of its forms)

·         Sulfur dioxide

·         Lime

·         Polymer

·         Methane

·         Methanol

·         Ferric chloride

·         Alum

·         Ammonia

·         Acids (sulfuric, hydrochloric, nitric)

·         Bases (ammonium hydroxide, sodium hydroxide)

You may have an on-site laboratory, with numerous chemicals used for process or compliance testing. Laboratory safety and chemical hygiene plans will be covered in a different section.

 

Rules for Chemical Handling and Safety

Depending on which chemicals you have at your plant, and the amount you store, the following rules may apply. The Occupational Safety and Health Administration (OSHA) regulates safety for privately owned companies. OSHA might not have legal authority over publicly owned treatment works, but it’s a good idea to follow the OSHA rules and keep everyone safe.

Check with your state and local governments as well, as there may be other safety regulations for those jurisdictions.

 

Hazard Communication, OSHA 29 CFR 1910.1200. Also called the “Right to Know” law, this rule applies if you have any chemicals onsite. All employees must be informed of the chemicals they’re exposed to. The rule requires keeping Material Safety Data Sheets for every chemical, and providing employee training on how to safely handle the chemicals and take protective measures.

 

Process Safety Management of Highly Hazardous Chemicals, OSHA 29 CFR 1910.119. This rule targets highly hazardous chemicals that could cause catastrophic events resulting in employee deaths. The rule encompasses every aspect of chemical use—system design, written information available (including process flow diagrams and piping and instrument diagrams), operation, employee training, contractors, pre-startup safety, mechanical integrity, non-routine work, and managing change. Employees must be involved in the Process Safety Management development and implementation.

One of the most important elements of the Process Safety Management Program is the Process Hazards Analysis (PHA). A PHA is a complete evaluation of the chemical process to determine potential hazards associated with handling these materials. During a PHA, employees analyze equipment, instrumentation, utilities, people and their actions, and external factors to find ways to improve safety. The ultimate goal is to reduce the risk of fires, explosions, toxic releases or chemical spills.

The need for Process Safety Management is based on the amount of certain highly hazardous chemicals stored and/or used on site. For instance, the threshold level for chlorine is 1,500 pounds. Any treatment plants that keep more than 1,500 pounds of chlorine on-site must implement Process Safety Management.

OSHA has an easy-to-understand Process Safety Management guidebook available.

 

Risk Management Plan, 40 CFR 68.130. The purpose of the Risk Management Plan Rule is to protect the public and the environment from the release of highly hazardous chemicals.

The Risk Management Plan Rule (RMP) is a U.S. Environmental Protection Agency (EPA) regulation, under the Clean Air Act, requiring facilities that produce, use or store highly hazardous chemicals to develop a Risk Management Plan which documents the treatment plant’s risk management program and submit it to the EPA.

Elements of the Risk Management Plan can closely track those of OSHA’s Process Safety Management (PSM). In fact, many utilities write their plan to meet both PSM and RMP requirements. However, be aware that EPA’s thresholds requiring RMP compliance are different from those for PSM.

Important items for Risk Management Plans include:

·         the analysis of potential offsite consequences for a worst-case accidental release

·         a five-year accident history

·         a release prevention program

·         emergency planning

Appendix F: Supplemental Risk Management Program Guidance for Wastewater Treatment Plants is available on EPA’s website.

 

Emergency Planning and Community Right to Know Act (EPCRA) is another rule under EPA, and requires planning and reporting on hazardous and toxic chemicals. The “community right to know” provisions give the public access to information on chemicals at various facilities, their uses, and releases.

If hazardous chemicals are present in amounts over the threshold quantities, the facility must cooperate with the state and local government in emergency plan preparation. Treatment plants must submit Material Safety Data Sheets and a chemical inventory to state and local emergency planning officials and the local fire department.

Any spills or releases in amounts over the “reportable quantity” must be reported to state and local officials immediately. A Toxic Release Inventory form must be completed and submitted each year.

An example of the different threshold quantities for the various rules is shown below for chlorine and sulfur dioxide. Be sure to check your quantities to see which regulations apply to your plant:

 

Chemical

PSM

Threshold Qty., Pounds

RMP

Threshold Qty., Pounds

EPCRA – Threshold Planning Qty. Pounds

EPCRA – Reportable Qty. Pounds

Chlorine

1,500

2,500

100

10

Sulfur Dioxide

1,000

5,000

500

500

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