Railroad Canyon Wastewater Facility - Executive Summary |
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RISK MANAGEMENT PLAN - Railroad Canyon Wastewater Facility EXECUTIVE SUMMARY Elsinore Valley Municipal Water District (EVMWD) has established a risk management plan according to EPA's regulations (40 CFR Part 68) to enhance already existing safety and emergency response programs. EVMWD is extremely cautious in the handling of all chemicals and is very diligent about safety for its employees and its communities. EVMWD staff is highly trained and utilizes modern equipment to monitor its facilities to provide safeguards, while effectively employing these useful chemicals. These chemicals play an important role in water treatment and water reclamation, enabling everyone to lead healthier lives. Accidental Release Prevention and Emergency Response Policies EVMWD has an emergency response plan in effect to handle potential emergency situations at this facility. This plan was designed to meet the following objectives: 1.) To save lives. 2.) To minimize and avoid injuries. 3.) To prot ect the environment. 4.) To minimize property damage. Key elements of the Emergency Response Plan include specific steps that EVMWD management expects of its employees to take to protect health of the employees and the community. The plan includes key phone numbers and contact points, vicinity and evacuation maps, plans for evacuation, fire, injury, earthquake, chemical spill, and health hazards. Stationary Source and Regulated Substance The chlorination system at Railroad Canyon Wastewater Facility is used for the disinfection of treated wastewater. Chlorine is stored in one-ton containers in the chlorine storage room. These containers are owned, maintained and filled by the chlorine chemical vendor per Department of Transportation regulations and standards. Ton-containers are placed on a scale to allow EVMWD operators to plan ahead for ordering more chlorine and for the change out procedure. Each container is positioned so that the valves are vertically aligned. A vacuum r egulator is connected to the top valve of each one ton container to ensure that chlorine gas is drawn out of the container. A vacuum is created when process water is pumped through an injector. This flow generates a vacuum, which opens the vacuum regulator. Upon loss of vacuum in the line from a ton container, a diaphragm in the vacuum regulator will close, stopping any chlorine from escaping. Any chlorine in the piping upon loss of vacuum will be drawn through the chlorine feeders and into solution. A chlorine scrubber is connected to the room where chlorine containers and other equipment are located. Its sole function is to remove chlorine gas from the room in case of an accidental release from the system. The scrubber is automatically activated by the chlorine detectors that are installed in the room. In the scrubber, the chlorine gas is reacted with sodium hydroxide. The result of which is water and table salt. Hazard Assessment Summary Worst Case Release Result Summ ary Scenario Description: Release of the maximum quantity of chlorine that can be stored in the largest vessel - 2,000 pounds in 10 minutes. The most pessimistic meteorological conditions were used as specified in the regulation. The reference table included in EPA's RMP Guidance for Wastewater Treatment Plants was used to determine the maximum downwind distance to 3 ppm. The result shows that offsite areas may be affected. Alternative Release Result Summary Scenario Description: A release of chlorine gas from 1/4-inch diameter leak until the container is empty (2,000 pounds). The containers are stored inside a building equipped with a scrubber, which will automatically start in the event a chlorine leak is detected by the sensor. However, when these active and passive mitigation measures were incorporated the release is completely mitigated. Consequently, the release rate after these measures were incorporated was too small to lead to a significant offsite concentration. The me teorological conditions specified in the regulation for alternative scenarios were used. Assuming that the scrubber is not functioning, the reference table included in EPA's RMP Guidance for Wastewater Treatment Plants was used to determine the maximum downwind distance to 3 ppm. The downwind distance for this scenario is significantly less than that for the worst case scenario. However, in this case also, assuming that the scrubber is not functioning, offsite areas may be affected. Accidental Release Prevention Program and Chemical-Specific Prevention Steps EVMWD has a Process Safety Management program in place to manage the handling of chlorine. In addition, common industry standards, policies, and procedures are utilized to ensure safe practices are being performed. This includes common practices outlined by the Chlorine Institute. In addition to the Management Programs, there is a chlorine leak detector situated in the chlorination area. In the event of a chlorine gas lea k, the detector relays an alarm to the central control station of EVMWD. The alarm signal actuates the emergency scrubber system for the chlorination building. Five Year Accident History There have been no reportable releases of chlorine at the facility in the past 5 years. Planned Changes to Improve Safety Several process and management system improvements were recommended during the development of the PSM Program for this site. These measures continue to be implemented. For compliance with RMP regulations additional improvements are being considered. Specifically, improvements have been recommended based on the seismic review of the facility. |