Safety and Security: Top Priorities for MPW Facilities

Long before the unbelievable events of September 11, 2001 brought workplace safety and security into the forefront of everyone's mind, these issues were already serious priorities for water and wastewater utilities (as well as many other of our nations ;critical infrastructure systems). Regulatory agencies such as the Occupational Safety and Health Administration (OSHA), Environmental Protection Agency (EPA), South Carolina Department of Health and Environmental Control (SCDHEC), and others have had regulations and guidelines in place for many years to help govern workplace safety and security.

One of the more complex regulations in place for chemical safety, referred to as Process Safety Management, or PSM, was issued by OSHA in May of 1992. Some of the key components and requirements of this regulation include the following:

• Process Hazard Analysis: a formal analysis by a qualified team to identify potential causes of accidental releases, including equipment failure, human error, etc. Recommendations are then implemented to safeguard against all identified potential failures.
• Operating Procedures: written instructions addressing all aspects of the covered process, including normal operations, emergency operations, and emergency shutdown procedures.
• Training: all personnel, including contractors, working with or on any chemical process covered by the regulations must successfully complete detailed training in advance, and must receive routine refresher training on an ongoing basis.
  Mechanical Integrity: procedures must be in place for inspecting and maintaining all equipment in good working order, and for making appropriate repairs as needed.
• Management of Change: procedures must be in place to ensure that ANY changes to a covered process must undergo a detailed review and approval process before being implemented.
• Incident Investigation: any incidents which lead to, or could reasonably have led to a chemical release, must be carefully investigated and documented. Recommendations for future improvements must also be documented and their implementation tracked.
• Emergency Planning and Response: procedures must be in place documenting the plans for responding to an emergency should one occur. (This portion of the regulation commonly overlaps with several other related regulations which deal with emergency planning and emergency response.)
• Compliance Audits: certified compliance audits must be conducted and documented on an ongoing basis.

Risk Management: Protecting Our Community and Environment is Mandatory

Another complex and very similar regulation, commonly referred to as the ;Risk Management Plan, or RMP, was issued by EPA in June of 1996. This regulation mirrors the requirements of OSHA's PSM regulation summarized above with one major exception. OSHA's primary focus is employee safety, so the PSM regulation comes from the perspective of protecting the health and safety of persons working at the facility. EPA's RMP regulation, on the other hand, focuses on the safety of individuals in the community and the environment. To put it in simplest terms, OSHA's regulation addresses what happens inside the fence; EPA's regulation addresses what happens outside the fence.

Due to EPA's different perspective and focus, the RMP regulation includes additional requirements which must consider and address potential offsite impacts. The Emergency Planning and Response section also includes requirements for coordinating with local emergency services (Fire Department, EMS, etc.), as well as public notification procedures in the event of an offsite release.

Fast forward about 9 months past the horrific events of 9-11, and in comes another regulation through EPA entitled the Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (Bioterrorism Act for short). This Act amended the Safe Drinking Water Act of 1974 with specific security-related requirements for all public water systems. Two of the major components and requirements of this Act included the following:

• Security Vulnerability Assessment: formal security evaluations to analyze for potential vulnerabilities at water facilities and within drinking water systems. (MPW voluntarily chose to perform this detailed analysis on all of our facilities, to include wastewater and administrative facilities.
• Emergency Response Plans: plans had to be written or updated to address the findings of the Vulnerability Assessment and to include basic security procedures and precautions.

What does all of this mean for day-to-day operations at MPW facilities? For obvious reasons we cannot divulge the specifics of our security systems and related procedures, but some of our chemical safety procedures and safeguards include the following:

• All chlorine cylinders are stored inside fully enclosed rooms at all times, with entry into these rooms monitored by electronic security systems.
• All chlorine rooms are equipped with chlorine leak detection equipment, which monitors the air 24/7 for the presence of chlorine gas.
• If chlorine gas is detected in the air, an alarm is activated and notifications are sent to Plant Operators and supervisors via pagers and/or cell phones.
• Alarm activations will automatically result in a series of chlorine valves closing and the chlorine feed system will be shut down.
• All Chlorine Leak Alarms automatically activate a scrubber system, which continuously draws air from the chlorine area and passes it through a neutralizing agent before releasing it to the environment.
• Emergency Chlorine Leak Repair Kits are kept at each site, and both MPW personnel and local Fire Department personnel are trained on emergency chlorine leak repair.

While MPW must always be mindful that a chlorine release is possible, and we must remain vigilant and ever-prepared for that possibility, we are proud to report that we have never had an incident involving offsite impacts of any kind.