City of Angles Water Treatement Facility - Executive Summary

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FEDERAL MANDATED RMP SUBMISSION             
 
 
EXECUTIVE SUMMARY 
 
1. Accidental Release Prevention and Emergency Response Policies  
 
The Angels Water Treatment Plant, which is located  at 1131 Murphys Grade Rd. Angels Camp , CA. uses chlorine which is considered a hazardous material and is a regulated substance, which is considered in the Risk Management Plan (RMP). The properties of chlorine make it necessary to observe safety precautions in handling chlorine to prevent human exposure, and to reduce the threat to the facility's workers and nearby members of the community. It is the facility's policy to adhere to all applicable Federal and State rules and regulations. Safety depends upon the safe procedures used to handle chlorine; the safety devices and systems designed and constructed into the facility; and the training of the pertinent personnel. 
 
2. Stationary Source and Regulated Substances Handled 
 
The Angles Water Treatment Plant is designed to treat surface water. The treatment plant typ 
e of operation consists of pre-chlorination of raw water, coagulation/flocculation, sedimentation, filtration, and post-chlorination of treated water effluent.  
 
Chlorine is delivered by a commercial supplier in one-ton containers for use at the WTP. Off-loading of the one-ton container from the commercial delivery vehicle is accomplished with a two-ton hoist.  All the one-ton containers are placed in the chlorine storage area on a steel cradle with load-cell type scale device for measurement of daily use. One of the one-ton containers is on -line, the other container is in stand-by. 
 
The Treatment Plant has administrative procedures in place to limit the amount of chlorine at the facility to no more than 2 one-ton containers for a total 4,000 pounds.  Delivery of chlorine one-ton containers is during normal working hours. The driveway provides adequate room for the delivery and parking of the delivery vehicles during the off-loading of the full one-ton containers, and the loading of t 
he empty one-ton containers. The building is not exposed to vehicular traffic.     
 
The chlorine building is locked after normal working hours.  No unauthorized personnel is allowed entry into the chlorine building. The container storage and handling is conducted pursuant to per Sections 2.6, 2.7, and 2.8 of the Chlorine Institute's Chlorine Manual. 
 
This water treatment plant operates twenty four hours per day, seven day a week. This treatment plant is staffed eight hours a day, seven day a week.  The chlorine gas is withdrawn from the one-ton containers by vacuum. This vacuum is created by plant potable service water passing through the throat and tail-way of the injector nozzle. This vacuum opens the vacuum regulator diaphragm, and withdraws the gas from the one-ton container at a controlled feed rate set by the operators at the rotometer. The chlorine gas is injected into the feed water line, where it becomes a chlorine/water solution and is feed where it is needed in the treatment 
process. The container storage room has a inlet and outlet air duct for fresh air entry, chlorine leak detectors, and alarm systems. The V-notch chlorinators are vented to the outside if the diaphragm malfunctions. Treatment Plant personnel are fully trained  to use self-contained breathing apparatus (SCBA). 
 
The receipt, storage, and handling of the subject substances are considered as part of one complete process. 
 
3a. Worst Case Release Scenario 
 
The Worst Case release scenario must consider the largest quantity of a regulated substance handled on site in a single vessel at any time, taking into account administrative controls on the vessel's contents and usage as per 40 CFR Part 68 Section 68.25. 
 
The one-ton (2,000 pounds) chlorine container is the largest vessel size (and only chlorine vessel size) in the chlorine system located at the Wastewater Treatment Facility.   The Worst Case release scenario to be modeled for the one-ton chlorine container assumes that the full 2,000 pou 
nds of chlorine is released over a ten minute period resulting in a release rate of 200 pounds per minute. The distance to the endpoint of  .0087 mg/l for the Worst Case scenario is 1.3 miles.  This chlorine release will extend beyond the boundaries of the stationary source. 
 
3b. Alternative Release Scenario 
 
The Alternative Release scenario for chlorine for the one-ton container located at the Wastewater Treatment Facility assumes a release from a valve packing, resulting in an estimated release of no more than 2 pounds per hour.  The period of release is taken to be one hour in duration, resulting in a total release quantity of 2 pounds for each regulated substance. The distance to the endpoint of  .0087 mg/l for the Alternative Release scenario is 0.1 mile.  This chlorine release will extend beyond the boundaries of the stationary source. 
 
3c. Administrative Controls 
 
Administrative controls to limit the distance for each report scenario exists to restrict to a minimum, the amount o 
f chlorine lost from a one-ton container if accidental release were to occur. This administrative control is inherent in the operational procedures for the chlorine process system and the training provided to the operators of the process system. 
 
3d. Mitigation Measures 
 
Mitigation measures to limit the distances for each reported scenario exists to restrict the amount of chlorine released to a minimum if released were to occur. The mitigation measures are based upon the design, inspection, testing, and maintenance of the chlorine process systems; their related equipment and components; and the treatment system. 
 
4. General Accidental Release Prevention Program and Chemical Specific Prevention Steps 
 
The facility complies with all applicable federal and state codes and regulations. There are safety meetings and safety training. The Process Safety Management (PSM.) program implemented at the facility for the chlorine process system and the related activities and equipment represents the 
facility's main active commitments to an accidental prevention program. 
 
5. Five Year Accident History 
 
There has been no accidental release of chlorine in the last five years. 
 
6. Emergency Response Program 
 
The Emergency Response Program is based upon altering personnel at the facility to evacuate the facility and await the arrival of responders from the Fire Department at the evacuation assembly location if a release occurs that causes the evacuation to be initiated. Calaveras Co. Office of Emergency Services incorporates this response into the Area Plan for the Local Emergency Planning Committee. 
 
7. Planned Changes to Improve Safety 
 
There are commitments made under the Process Hazard Analysis element of the Process Safety Management (PSM) that are planned to be implemented over the next year. Current applicable codes and regulations are reviewed as part of the PSM to determine if the other commitments need to be made to achieve increased operational safety for the regulated chlo 
rine process system. These commitments will be prevention and mitigation measures for the accidental releases of the regulated substance.
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