Friday, November 21, 2008

Another IST Implementation – UV for Chlorine

The Center for American Progress report that I discussed in yesterday’s blog (see: “New IST Report from Center for American Progress”) brought out another story of IST implementation. This time it was the Central Valley Wastewater Treatment Facility in Salt Lake City, UT, one of the facilities that made the 101 Most Dangerous List. The facility made the list because it uses chlorine and anhydrous sulfur dioxide, both PIH chemicals.

Impetus for Change 

According to the Deseret News article, the general manager of the facility has always been aware of the dangers associated with chlorine. After the 2001 terrorist attacks he upped the security at the facility because of concerns about the stored chlorine being used as a weapon.

Cost of a UV Treatment System 

The utility first looked at the substituting a UV treatment system for the chlorine gas treatment in 2003 when the facility made a similar ‘most dangerous list’ put out by “Environmental Defense” (sic). It wasn’t considered practical then because the new system would have cost $19 Million. Since then the cost of the system has come down to $3 Million. Installation and infrastructure is expected to add $5 Million to those costs, but they won’t know for sure until the project is put out for bidding early next year.

Time for Implementation 

The article does not make clear when the design work on the new UV system started, but it was just recently completed. The design has to be approved by the Utah Department of Health and the US EPA. Then, January 2009 or so, it will be placed out for bid. All in all the utility expects to have the new system in operation by early 2010.

Complexities of IST Implementation

This is another example of how complicated it can be to implement a relatively straight forward IST project. I say ‘straight forward’ because the technology is available and most of the problems have been worked out in previous installations. Design and installation problems still have to be overcome, since each treatment facility is slightly different in layout and equipment. The other installation challenge is the fact that water and wastewater treatment plants cannot simply shut down for the installation of new equipment.

The new equipment has to be installed in parallel with the existing equipment. Frequently this is not practical or even possible in some cases due to space limitations at the current facility. In those cases it may require the construction of a completely new installation, adding to the cost. Finally, the old equipment cannot be removed until the installation is complete, running properly and certified.

This all needs to be taken into account when legislation requiring IST implementation is written. To be effective that legislation would have to require that an IST evaluation look into the possibility (not all chemical processes can be changed), practicality (simply moving the hazmat to another location is not necessarily inherently safer) and economic viability of the implementation. It must also provide a time frame for practical implementation. Only once that technical evaluation is made by the facility in question can the political decision be made to order an implementation.

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