Chapter 9

Emergency Response for the Sanitary, Storm, POTW

9.00PLANNING – WHAT TO EXPECT

Most serious emergencies are usually created by accidents. You could encounter life- threatening situations that would require you to work with other agencies. Environmental Inspectors may be called upon to assist in poisonous gases, large volumes of toxic materials or concentrated acids or bases in the sewer.

Emergencies that one may encounter includes but is not limited to railroad or trucking accidents involving toxic, flammable, explosive or corrosive material. Regardless of the type or cause of an accident, a hazardous liquid could reach the collection system or storm drain and create the potential for an emergency throughout the community, collection system, the plant and the environment.

The most likely source for an emergency situation to occur comes from fixed facilities. Records indicate that 74.8% of chemical releases come from fixed facilities, while 25.2% were in-transit incidents. It is also recorded that 50% of all chemical releases involve ten (10) chemicals. These ten chemicals are: polychlorinated biphenols (PBCs), sulfuric acid, anhydrous ammonia, chlorine, hydrochloric acid, sodium hydroxide, methanol/methyl alcohol, nitric acid, toluene and methyl chloride. The same ten chemicals account for 35.7% of the death and injury events.

9.01SPILL CONTROL PREVENTION PLANS

Each Significant Industrial User (SIU) and certain commercial/industrial users will be required to have aSpillControl Prevention Plan (SCPP). The requirements of the SCPP:

CITY OF BELOIT

SPILL CONTROLPREVENTION/EMERGENCY PLANS
40 CFR 403.12 (f) and 29.40

9.0 BACKGROUND

The City will use three specific tools when protecting the treatment facility, its workers, public health and the environment, these are: 1) the need for a Spill Control Prevention Plan (SCPP), 2) City’s Emergency Spill Response Plan using the NFPA hazard rating system during releases, and 3) chemical affects on the POTW using the Development of Local Limits and identification of Pollutants of Concern (POC) based on Water Quality Standards in NR 140.

The City uses the same checklist for the development of a SCPP and emergency plan (see attachment A). In order to be effective any plan hazardous control procedures are selected based on several factors such as 1) the properties of the material released, 2) characteristics of the release event and subsequent migration of the material and 3) site-specific conditions and considerations. Information gathered during the hazard and risk assessment process is crucial.

If a release is small enough to be handled using personnel and equipment routinely located in the immediate area of the release, the event is treated as an incidental release, rather than an emergency. These incidences are placed on a reporting log sheet in Attachment F.

9.01 DEFINITIONS

SLUG DISCHARGE: 40 CFR 403.8(f)(2)(vi).and 29.40

For purposes of this subsection, a Slug Discharge is any Discharge of a non-routine, episodic nature, including but not limited to an unintentional release or a non-customary batch discharge, which has a reasonable potential to cause Interference, Pass Through, violate the POTW's permit conditions, affect the normal operations/removal efficiencies of the facility or cause health issues/endangerment to workers or public health.

INTERFERENCE

Any discharge which, either alone or together with other discharges from any other source that:

  1. Disrupts or obstructs any process or operation of the POTW; or
  2. Causes the POTW to violate any requirement of its WPDES permit; or
  3. Prevents sewage sludge use or disposal; or
  4. Causes the POTW to lose sewage treatment efficiency.

9.02 SECTION I. SPILL CONTROL PREVENTION PLAN (SCPP):

Synonymous with other titles a Spill Control Prevention Plan (SPCC) is created to protect against release of materials that may pose adverse affect to the treatment facility, worker safety, public health and the environment. The Environmental Coordinator may require any user, that has potential to adversely affect the sewerage system, waters of the state, prevent site run off,appurtenant devices, or POTW resultant sludges and effluents, by accidental or intentional release of any toxic or other dangerous substance on the User’s premises; to develop, submit, and maintain a SpillControl Prevention Plan (SCPP). The elements of such plan shall be as established in regulations by the Environmental Coordinator. The SCPP shall include necessary procedures to:

  1. Prevent accidental spills
  2. Inspect and maintain storage areas
  3. Handle and transfer materials
  4. Control loading and unloading operations
  5. Control facility site run-off and
  6. Train workers

SECTION I, PART A. SCPP MINIMUM REQUIREMENTS

If the POTW decides that a spill control plan is needed, the plan shall contain, at a minimum, the following elements:

(A) Description of discharge practices, including non-routine batch discharges;

(B) Description of stored chemicals;

(C) Procedures for immediately notifying the POTW of slug/spilldischarges, including any discharge that would violate a prohibition under §403.5(b) with procedures for follow-up written notification within five days unless granted a waiver from the city;

(D) If necessary, procedures to prevent adverse impact from accidental spills, including inspection and maintenance of storage areas, handling and transfer of materials, loading and unloading operations, control of plant site run-off, worker training, building of containment structures or equipment, measures for containing toxic organic pollutants (including solvents), and/or measures and equipment for emergency response.

SECTION I, PART B SCPP/ EMERGENCY PLAN CHECKLIST FOR POTW'S

The City uses a SCPP checklist as seen in Attachment Ato ensure all the necessary requirements of a plan are included for each plan submittal. Each area of the plan should be evaluated using the following requirements and checking the appropriate column. A check in the "S" column means the plan is satisfactorily meets the requirements; "U" means that the plan unsatisfactorily meets the requirements; and "A" means that additional information is required to determine if the requirement is met; and "NA" means the requirement is not applicable to the facility. This plan is to be reviewed by the POTW with each permit issuance or re-issuance.

Each SIU’s plan is evaluated annually as part of the annual facility inspection. The Environmental staff uses a form entitled SpillControl/Emergency Response Evaluation Review as seen in Attachment B.

SECTION I, PART C RELEASES THAT MUST BE IMMEDIATELY REPORTED, LOGGED AND WRITTEN NOTICE WITHIN 5 DAYS (ref. 29.40):

LIST OF REPORTABLE MATERIALS THAT MUST BE IMMEDIATELY REPORTED ACCOMPANIED BY A WRITTEN REPORT WITHIN 5 CALENDAR DAYS

  1. Solution of cyanide, arsenic, cadmium, chromium, copper, lead, mercury, nickel, silver or zinc that violates federal, state or local limits
  2. More than 1 gallon of a concentrated toxic organicor any other chemical listed in the EPA’s toxic chemical list.
  3. 20gallons or more of a liquid with a closed cup flash point less than 60o C including flammable petroleum based products.
  4. 55 gallons or more of a solution with a pH below 5.5 OR above an applicable upper pH limit above 11 (spill containment or reporting is NOT required in cases where a release of this material has no reasonable potential to cause a violation of pH permit limits)
  5. Release of 55 gallons or more of hazardous material or a chemical that may or may not enter the sewer must be reported immediatelyto the City’s Environmental staff
  6. Any other liquid/solid material that upon evaluation with respect to point of discharge, volume, and concentration is determined to have potentially adverse effects on the sewerage system, waters of the state,plant operations or public safety. These materials include but are not limited to alkalies or alkaline substances, oils, fuels, foam generating wastes, highly colored wastes, pesticides, high COD/total solids wastes(1), mercury, phosphorus and solvents.
  7. Any potentially hazardous material that runs off site or leaves an impervious surface.

A list of reportable pollutants may be found in Tables A-D in Attachment D.

(1) NOTE: HIGH COD-Products that contain high COD may be found in many materials used throughout the facilities. Loss of a material with high COD values together with sufficient flow may significant increase loading to the POTW. Accidental release of material(s) that would increase facility COD/TSS effluent loadings by 1,000 lbs or more must be logged and reported.

The City requires,by permit, users with high COD potential to collect composite samples and preserve and store them at 40 C for seven days. The City may collect and analyze these stored samples at any time.

Sugars, dairy products and many chemicals are just a few products used in processes that contain high COD values. Below are a few examples:

MaterialCOD mg/L

Dextrose1,050,000

Propylene Glycol1,240,000

Anti foam1,200,000

Acetic acid 60%1,020,000

SECTION I, PART D REQUIREMENTS FOR REPORTING

Emergency Response:

A SCPP must be developed if the user is storing bulk chemicals or uses/uses potentially dangerous materials on the facility site. If an uncontrolled/unintentional release of a REPORTABLE material is released the City Environmental Staff must be notified immediately. During business hours call 608-364-2888; for non-business hours call 608-364-5742. The Environmental Coordinator number is 608-751-4629.Spills of flammable or explosive materials should also be referred to the local Fire Department.

SECTION I, PART E WRITTEN RESPONSE

A written report must be submitted to the Environmental Coordinator within five days unless waived by the City of:

  1. a slug discharge of conventional pollutants that reaches the sewer, or
  2. fire/explosion, or
  3. release of reportable materials

The written report shall be on a form prescribed by the City or similar document must include (see attachment G):

  • Date and time of discharge
  • Discharge location
  • Concentration, volume, waste type, chemical name and harmful characteristics or effects of the material (e.g. explosive, flammable)
  • Response measures being taken
  • Name of agencies or contractors contacted
  • Cause of the incident
  • Specific details of the incident
  • Remedial measures taken
  • Preventive mechanism to avoid reoccurrence of similar incidents

SECTION I, PART FLOG SHEET REQUIREMENTS

Each user required to implement a SCPP or install and maintain a spill containment system and each SIU must keep a log sheet that is available to City’s employees upon request, during inspections or as part of the semi annual report.See log sheet in Attachment F.

What needs to be entered unto the log sheet?

  1. Minor releases of a chemical or potentially hazardous material that do not impose any threat to the environment or public safety that stays on an impervious surface and is properly cleaned up.
  2. 100 gallons of more of impounded materials removed from spill containment areas.
  3. < 20 gallons of flammable material or other petroleum based products that immediately evaporates or is immediately cleaned up by trained facility staff.

The log sheet must contain the following information:

  • Date and time of incident or material is removed from spill containment area
  • Identity of material (an analysis is required if the spill is of unknown origin to determine the type of treatment or remediation required for proper disposal)
  • Quantity (volume)
  • Cause of spill
  • Corrective action implemented to prevent spills from reoccurring
  • Whether or not the SCPP was followed and found to be effective

LOG SHEET SUBMITTALS

Each SIU required to have a SCPP will submit the log sheet as part of its semi annual report for the City’s review.

SECTION II, PART A VIOLATIONS

Failure to submit and maintain plans, install and maintain an adequate spill containment system, submit log sheets, or submit 5 day notification when required is a violation of the City’s WastewaterOrdinance.

SETION III - OTHER PROGRAMS USED BY THE CITY

SECTION III- PART A CITY POTW AND LIFTSTATION ALARMS

The City of Beloit’s POTW and liftstations have an alarm system that notifies an on-call supervisor of problems within the system. A list of these alarms may be found in Attachment C. These alarms include but are not limited to: high/low dissolved oxygen, high/low influent pH, wet well hazardous atmosphere, high/low wet levels, equipment failures, power failures, etc. The alarm system calls the on-call phone and indicates the type and location of the alarm. These alarms are used by City personnel to indicate a potential failure of a critical operation. For example, a low DO alarm can indicate that the plant received a high BOD slug load.

CITY RESPONSE TO ALARMS AND CHANGES TO LAB DATA TRENDS

The City responds to plant/lift station alarms by contacting either the plant Operators or Maintenance staff whoever is appropriate. Collection system problems are given to the Collection Crew. Operational or prohibited discharge issues that may be caused by a user are given to the Environmental staff for investigation.

The lab enters SIU and plant data on a regular basis. Trends are noted for a number of parameters.

SECTION III PART B- EXTRA SAMPLING FOR SIGNIFICANT FOOD INDUSTRIES

In a cooperative effort with the City, to protect the treatment facility against conventional pollutants the significant food industries have agreed to provide daily composite sample collection of their effluent discharge. In addition to monthly self monitoring the City requires that all major food industries collect a daily composite sample and preserve it. The sample is then held at 40 C for seven (7) days. In the event of a plant upset the City collects the preserved samples for analyses.

SECTION III, PART C- EMERGENCY MANUALS

The Water Resources Division Wastewater staff developed an All Emergency Manual for the POTW in 2003 and revised is Hazmat Emergency Manual in 2010. This manual covers emergencies from: power failure, flooding, tornado, ice/snow storm, fire, hazardous materials and terrorism.

The Environmental Staff has a diverse background in environmental, laboratory and plant operation. In 2000 an Industrial Pretreatment Program (IPP) Emergency Response Guide was developed to assist the Environmental Technicians during facility inspections and investigations and/or cleanup of released materials. With laboratory backgrounds the staff is also versed in sample collection and preservation. This manual covers areas of hazmat including identification of material, site control, hazard zone establishment, principles of toxicity, PPE, hazard assessment, risk analysis and cleanup options.

9.03 CITY’S EMERGENCY SPILL RESPONSE PLAN

In 2000, several City departments worked together and developed a Citywide Spill Emergency Response Policy and Procedures Plan 2000. Each department lends its expertise and equipment to minimize and mitigate emergency situations within the scope of their abilities. The purpose of this plan is to efficiently and effectively provide clean up of non-hazardous and certain hazardous materials to protect the public health and environment. The primary goal of this plan is to isolate, contain, confine and stabilize the incident.

Infiltration of groundwater into sewers can contribute explosive or toxic liquids or gases, especially if the water table is above the top of the sewer. Locating the source of the substance and planning and implementing corrective action can sometimes involve long and costly investigations.

Other essential information that should be noted regarding the collection system include:

  1. Can the system either minimize gas accumulation or enhance the opportunities for release of gases?
  1. Is the system free flowing or surcharged?
  1. Are there stagnant or dead spots in the system downstream from the industry discharge point?
  1. Where are the sections of flowing water that are aerobic or anaerobic?

SECTION II , PART A INCIDENT COMMAND AND CONTROL

Activate the notification procedure immediately whenever any hazardous substance has been spilled, released, dumped or abandoned. If you are first on the scene, try to evaluate the situation as quickly as possible without endangering yourself. At this stage of the emergency you must remain a safe distance from the incident. Consider the following:

  1. Use personnel protective equipment:
  1. Clothing, and
  2. Self-contained breathing apparatus (if trained and qualified).
  1. Determine location of the problem and effective area.
  1. Estimate volume and characteristics of the material (liquid, gas, toxic, explosive, asphyxiant, corrosive).
  1. Estimate potential harm to:
  1. People,
  2. Property, and
  3. Environment
  1. Access rescue needs.
  1. Control public access to spill area. Call Fire Department if evacuation is necessary.
  1. Assess immediate remedial action and options (diking, catch basins, drain covers, etc)
  1. Evaluate the situation as it impacts the operations of the pretreatment plant. Are collection systems, lift stations, wet wells and the operations and maintenance people who work on the collection system and the plant at risk as a result of the spill?

SECTION II, PART B -INITIAL STEPS PRIOR TO IDENTIFYING THE MATERIAL

If the spill is from a known industrial facility, then call a representative from the emergency numbers listed in Section 8.01. Survey the actual situation before initiating any containment or sampling procedures.

  1. Call the Fire Department for assistance.
  2. Contact the appropriately trained HazMat personnel for assistance.
  3. Use the proper safety equipment as outlined in the Safety Section 7.
  4. Follow all confined entry protocol, if entry is absolutely necessary.
  5. Use a bottle with rope if possible to collect the necessary samples.
  6. Always monitor the air quality when sampling. If gas or odors are a problem, use the Aims gas detector located in the back office of the Clinton building.
  7. Always use the proper safety equipment.
  8. Always use the buddy system. At least two trained technicians should be on the scene before attempting any response or sampling.

SECTION II, PART C- IDENTIFYING THE MATERIAL

Hazardous substances are substances that fall within the categories as defined under Section 101(14) of CERCLA, any biological agent or other disease causing agent as defined under Section 10(33) pf CERCLA, any hazardous material as listed by the DOT in 49 CFR 172.101, and any hazardous waste as defined by RCRA. The Buddy System is crucial in any Emergency Response scenario. The system basically requires workers or response personnel to be visible and easily accessible to another member of the group, allowing quick response in case of an emergency.