National Certification: What Would it Mean for Wastewater Treatment Operators? | TPO – Treatment Plant Operator Magazine

In North America, water, wastewater, and distribution and collections systems do not have a national certification program. In some industries — including teaching, nursing, therapy disciplines and interpreting — a national certification has been the norm for years. 

 

 

National Certification: What Would it Mean for Wastewater Treatment Operators? | TPO – Treatment Plant Operator Magazine.

Let’s Talk About National Certifications

A national certification program for water, wastewater, distribution and collections systems is not currently available in North America. There are some industries where a national certification is the “norm” and has been for years. Industries such as teaching, nursing, therapy disciplines, and interpreting. There should be a way for the liquid utilities to standardize and formalize, under a federal requirement, treatments for drinking water, wastewater, and the related services. This article will explore how it may be possible to have a national certification program and why it may serve the greater good of the field in the future.

Photo Credit: http://www.nomoredebt.co.za/wp-content/uploads/airbrush-tanning-certification.jpg


The Current Certification System


 

In the current system for certification, all states are responsible for creating their own criteria to maintain compliance with FRL-6230-8 found in the Federal Register Volume 64 No. 24 February 5, 1999. The federal register is a publication that give the general public notification of all final rules for the federal government. The ruling is specific to drinking water operator certification, but wastewater certification has been adopted under this ruling. States were given control over items such as:

  • The type of exam that should be given, oral or written
  • The type of operator training
    • EPA is responsible for evaluating the state program on an annual basis
  • They must have a fixed cycle of renewal not to exceed 3 years
  • They must establish training requirements for certification renewal
  • They must follow the operator certification guidelines as outlined by Section II Operator Certification Guideline.

Reciprocation is another issue that goes hand in hand with a national certification program. Reciprocation is where a state will allow an operator that holds a valid license from another state to get credit for that established license. Therefore, the operator will only have to apply for reciprocity with the new state. States like Indiana and Kentucky currently reciprocate with other states. However, some states like Florida do not reciprocate with any other state. An operator that wants to move to Florida and operate a facility must meet all of the state’s requirements as a new operator. Though the experience will still be credited to the operator, he/she must meet the training and testing requirements before they can receive a valid Florida license.

Why Do We Need a National Certification Program?

 

A national certification program would give the liquid utility a much needed image boost and add professional credentialing to a highly technical industry. In an August, 2013 article in the Opflow
magazine, the authors declared “operators also enjoyed comparatively less earning power than other professions, largely due to the fact that the cost of their services are priced much lower then they’re worth”(Copeland, A. & Moore, G., 2013). The article on went on further to introduce a Professional Operator (PO) designation much like an engineer has a Professional Engineering (PE) designation behind their name (Copeland, A. & Moore, G., 2013).

In addition to a PO designation, the liquid utility field can shed the system of reciprocity of one state to the next with a national certification. This certification should not be mandated, but only an option for the operator that may want to keep their options open. In this day and age there are many reasons for a family to have to move states in order to keep two incomes. Operators that must move can have assurance that they will be able to apply for a job in any state without having to take a drastic pay cut while they get a new license.

Lastly, a national certification program will have a uniformed training criteria as developed by the Environmental Protection Agency (EPA), a national operator association, or other entities such as the Association Boards of Certification (ABC). ABC, has an established voluntary, international, operator certification program and has developed a model standards of operator certification that provides a framework and benchmarks for operator evaluation (ABC, 2014). There may be another entity that is developing a national or international certification model, but I’m unaware of any other besides ABC.

How Can We Create a National Certification Program?

 

The creation of a national certification program will have to come from the inside out. Meaning the driver must come from the operators, municipalities that are struggling to hire qualified operators, and the States that are willing to divide the piece of the certification fee, “pie”. The industry has widely established the Sacramento State Course as a standard for drinking water and wastewater certification. Therefore, the course training for the utility sector doesn’t have to change from the established curriculum. However, in addition to these courses, a criteria should be set to determine the perspective operator’s knowledge on specialized systems. Imagine having a national certification with a concentration or endorsement for UV Disinfection, Advance Waste Treatment, or Biological Nutrient Removal. With the endorsement addition to a national certification, then the hiring municipality can be assured that the candidate is qualified to operate “their” system.

States can administer the test or use an online program as most states have currently. CEU requirements will be consistent of the law, not more than 3 years, but that training will be as its current framework within the states. A PO would have to meet the requirements of the ABC program, but each state would have to formally recognize the Professional Operator designation. The future of operations in the States would change forever with a national certification program. Who know, it may lead to an international program where the global Water and Wastewater communities can share talent.

7 Tips For Risk Management Program Compliance

Program Overview

The Risk Management Program (RMP) is an Environmental Protection Agency (EPA) initiative that tracks, audits, and regulates facilities with extremely hazardous substances (EHSs), Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), and toxic chemicals over a certain quantity. Congress enacted the Emergency Planning and Community Right-to-Know Act (EPCRA) in 1986 as a reaction from the 1984 Bhopal, India accident where Union Carbide chemical plant had a release of methyl isocyanate.

This incident cause thousands to die and many injuries in India, but 6 months later a chemical release in West Virginia (EPA, 2012). Therefore, Congress moved under the Code of Federal Regulations (CFR), the protection of environment is Title 40 to create ways of protecting the American public. The RMP can be found 40 CFR Part 68 in the Clean Air Programs section. You can find specific chemicals on “The List of List” for regulated chemicals.

Photo Credit: http://www2.epa.gov/sites/production/files/2013-11/documents/general.pdf

Each owner/operator has a duty to be responsible for the safe handling, storage, and use of regulated hazardous substances under The General Duty Clause (GDC) Section 112 (r)(1). This GDC covers “any stationary source producing, processing, handling, or storing regulated substances or other extremely hazardous substances” (EPA, 2009). The RMP sets a framework for an accident prevention program, reporting system for releases, establishing program levels, and compliance structuring (EPA, 2009).

Having an all-inclusive policy for all facilities is not a practical way of having a RMP on a national level. Therefore, the EPA has divided systems in to programs levels to better “match their size and the risks they pose” (EPA, 2009). The Program Level are as follows:

Program Level 1:

A facility that on its very worst day would not affect the public (as noted in a worst-case scenario modeling) and did not have an accident within the past 5 years

Program Level 2:

A facility not eligible for Program 1 or Program 2 is put into program level 2 status. These facilities have additional hazard assessment, emergency response, and management requirements (EPA, 2009).

Program Level 3:

Program that does not meet level 1 requirements, has to comply with the Occupational Safety and Health Administration (OSHA) Process Safety Management Standard (PSM), or is one of ten specified industry codes from the North American Industrial Classification System (NAICS). Level 3 programs must follow OSHA PSM standards because the RMP incorporates the PSM into its standard.

Photo Credit: http://www2.epa.gov/sites/production/files/2013-10/documents/chap-02-final.pdf

  1. Know Your Deadlines

Drinking Water and Wastewater Facilities have potential to have several substances regulated by the RMP and even OSHA PSM programs. Drinking water facilities (NAICS 22131) have 2,289 total facilities under the RMP, 108 accidents, 90 injuries, and $3,653,153 in property damage in the past 5 years (RTKNET, 2014). Wastewater facilities have 1,514 RMP facilities, 92 accidents, 70 injuries, and $5,179,500 in property damages in the past five years (RTKNET, 2014).

In 2009, the RMP system was updated by EPA in which all current facilities under the program had to resubmit their programs for approval. This program revision and resubmittal must be done every 5 years or if changes in the quantity stored, processes, handling, or any aspect of the program have been made within six (6) months of that change to maintain compliance of 40 CFR 68.36.

Compliance Audits must be conducted and be certified every three (3) years to evaluate the program, procedures, and practices are adequate to comply with the rule. In order for an audit to comply with the 40 CFR 68.58 rule the auditor must be knowledgeable of the process, give a written report of the findings, a compliance schedule for deficiencies must be established, the owner has to retain the two most recent audits.

Here’s a chart to help know your compliance dates:

Year

2009

2010

2011

2012

2013

2014

2015

2016

2017

Revision

x

       

x

     

Audit

     

x

     

x

 

Training

x

   

x

x

x

 

x

x

Note: x=If there is a program change in audit or revision years, then training is required.

Chart Credit: Utility Compliance Inc.

  1. Hazard Reviews

Conducting an accurate Offsite Consequence Analysis (OCA) will product two scenarios, a worst-case and an alternate case scenario. Think of the worst-case scenario as who in the general public will be affected if there is a release of chemicals from the facility. By the quantity of the produce, wind direction, and other variables the scenario should be carried out to its end point. A circle is drawn around the facility to the endpoint distance in all directions to ascertain what public receptors or environmental receptors are in the “circle of death”. Worst-case scenarios are highly unlikely, but must be accounted for in your hazard determination.

Conversely, the alternate scenario is the most likely occurrence with treatment facility. In the case of chlorine gas, when the operators change from an empty bank of cylinders to a full bank some gas may escape the regulator or chlorine distribution system. The gas will be released into the room and in most cases not reach the operations control room before dissipation.

  1. Operating Procedures

There are six phases to the operating procedures that must be effectively addressed. Detail each step and write a narrative as to what is involved in each step of the process. In addition, add the number of personnel needed, Personal Protective Equipment (PPE) that must be worn, and any other considerations for each of the following phases:

  • Normal Start-up
  • Normal Operations
  • Normal Shutdown
  • Emergency Shutdown and Operations
  • Initial Start-up
  • Temporary Operations
  1. Training

Training is an important criteria for this program, because the utility staff are the first line of defense. 40 CFR 68.54, states that the owner or operator “MAY” certify in writing that the employee “has the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as provided in the operating procedures” (EPA, 2014). This is not a requirement, but it’s a good practice to record refresher training, initial training, and annual training events.

With regulators, it didn’t happen unless it is documented in writing (with signatures from attendees). Refresher training SHALL be every three years or if there are changes in the program or process. It’s a good practice to document training with an exam to prove operator mastery of the program and process phases.

  1. Maintenance

Maintaining mechanical integrity of the process systems is a must in 40 CFR 68.56. Training on the safety of working on the maintenance of the components is a requirement for this section. Even the contractor must be trained as to the hazards surrounding the maintenance to the equipment. In addition, the equipment must be tested and inspected to ensure that they are within the recommendation of the manufacturer, industry standards and codes, and good engineering practices.


  1. Compliance Audits


    Abatement

After an internal or external audit is complete, then the process for abatement of deficiencies must be clear and specific. Each action item must be given to an accountable party for correction. It is not enough for the audit review team to tell the operator to fix the problem with no timeline for abatement. Here is a sample form for Action Item assignment with risk assessment and follow-up:

Priority

A-Immediate

B-Within 7 days

C- Within 30 Days

D-Within

60 Days

E-After 60 Days

Action Item

Severity

1-Minor

2-Nominal

3-Serious

4-Severe

5-Catastrophic

Probability

1-Not Likely

2-Possible

3-Probable

4-Very Likely

Risk Total

(Severity x Probability)=

Reference

Code, System, or Regulation

Action to be Completed

Assigned to

Target Date

Completion Date

A

A.I. #1

5

3

15

Chlorine Regulators

Fix slow leak in manifold system

Terri

June 1, 2014

June 1, 2014

Chart Credit: Utility Compliance Inc.

  1. Incident Management

40 CFR 68.60 has a summary of how incident investigations should be conducted and recorded. However, prior to the investigation make sure that in the event stage that all notifications are made to the National Response Center (NRC) and/or State Emergency Response Commissions (SERCs). When making the initial notification have these items ready for the incident notification center:

  • The chemical name
  • An indication of whether the substance is extremely hazardous
  • An estimate of the quantity released into the environment
  • The time and duration of the release
  • Whether the release occurred into air, water, and/or land
  • Any known or anticipated acute or chronic health risks associated with the emergency, and where necessary, advice regarding medical attention for exposed individuals
  • Proper precautions, such as evacuation or sheltering in place
  • Name and telephone number of contact person (As quoted from EPA, 2014).

Written notification is required to local emergency response and the state emergency response entities as soon as practicable after the event. Other notification rules can be found in 40 CFR 355.40 to avoid penalties (40 CFR 355.50) that can be up to $25,000 for each violation, civil penalties up to $25,000 per day, and criminal penalties for up to two years imprisonment.

The RMP system is necessary to protect the surrounding community from extremely hazardous chemical, but the regulations are very strict and daunting. There has been a movement for utilities to replace the use of these chemicals where practical and appropriate. If you have an active RMP, then these 7 tips will help you meet or to stay in compliance.

 

5 Steps to Peak Plant Performance | TPO – Treatment Plant Operator Magazine

 

Wastewater treatment plants should aim to produce quality effluent without using a treatment aid for process control, and the best way to do that is by being proactive. By using these five steps, a plant will operate efficiently and will produce quality effluent well within the National Pollution Discharge Elimination System permit limits.

 

Read more:

5 Steps to Peak Plant Performance | TPO – Treatment Plant Operator Magazine.