G56 Rio Cosumnes Correctional Center WWTP - Executive Summary |
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Sacramento Regional Wastewater Treatment Plant has instituted a Risk Management Program for the Rio Cosumnes Wastewater Treatment Plant (G56), as required by Federal Accidental Release Prevention (ARP) Program regulations at 40 CFR Part 68. The Risk Management Program identifies the equipment, procedures, maintenance, inspection, and training associated with Regulated Substances (RS's) handled at this facility in excess of Federal threshold quantities; describes the structured assessment of hazards which was conducted to assess possible effects on employees and offsite public and environmental receptors; provides the results of an offsite consequences analysis; defines a prevention program, emergency response program, and mitigation measures to reduce the probability and magnitude of accidental releases of RS's; and establishes a schedule and responsibilities for implementation of mitigation measures and auditing of program elements. This Risk Management Plan (RMP) is being filed as required by ARP regulations in order to report the elements of the current Risk Management Program and to describe further measures planned to mitigate or prevent accidental releases of RS's. STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED Sacramento Regional Wastewater Treatment Plant operates and maintains a satellite wastewater treatment plant designated G56, located on the grounds of the Rio Cosumnes Correctional Center between Lambert and Twin Cities Rd. off Bruceville Rd. Elk Grove, CA in Sacramento County, and uses chlorine, an RS, for disinfection in quantities greater than the Federal threshold quantity for this RS. There are no full-time employees at this site. Operators visit the site on a regular basis and also respond to alarm conditions. Chlorine is received in ton containers by truck, handled with an electric hoist, and stored on trunnions inside the building. The chlorine is used for disinfection of wastewater effluent prior to discharge. Pressurized chlori ne gas within a ton container is reduced to vacuum by tank-mounted vacuum regulator valves, metered through manually-adjusted rotameters, and drawn into water solution by the passage of pressurized water through an injector. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES It is the policy of Sacramento Regional Wasewater Treatment Plant that the receipt, storage and handling of chlorine at its facilities be done in a manner which meets regulatory requirements and minimizes the probability and severity of accidental releases of chlorine to the atmosphere, in order to protect the health and safety of its workers, the public, and the environment. In order to accomplish this goal, Sacramento Regional Wasewater Treatment Plant has gathered safety information on chlorine and on the process, equipment and procedures involving chlorine; performed a structured assessment of hazards of the process and external events which might affect the process; performed an offsite conseque nces analysis of defined release scenarios; established a written program for prevention and mitigation of accidental releases; and established a written emergency response program coordinated with emergency response agencies. WORST CASE RELEASE SCENARIO A single "worst case" release scenario is required to be considered for each stationary source, resulting in the maximum distance to an endpoint for all toxic RS's contained on site above the threshold quantity. The worst case release scenario for toxic chemicals is defined in the ARP regulations as the release of the contents of the largest single container of RS (in this case chlorine) over a period of 10 minutes. The scenario considered the release of the contents of the largest container of chlorine on site, in this case 2000 lb. This release scenario is not physically possible, due to the characteristics of chlorine. ALTERNATIVE CASE RELEASE SCENARIO An "alternative case" release scenario is required to be considered for each toxic RS handled in quantities greater than the threshold quantity at the site. The "alternative case" scenario is described in the ARP regulations as a likely release resulting in offsite effects, considering administrative controls and mitigation measures in place, and is to be determined by the facility operators as part of the Process Hazard Analysis required to be performed during RMP development. The "alternative case" considered for this facility is the release of chlorine from the gas valve of a ton container due to an operator error during hookup, with the release secured by emergency responders by closing the gas valve after 30 minutes. ADMINISTRATIVE CONTROLS Administrative controls in effect at Sacramento Regional Wasewater Treatment Plant which were considered to mitigate the severity of the Worst Case and Alternative Case release scenarios include Sacramento Regional Wasewater Treatment Plant's written policies and procedures for training of operators and maintenance personnel, written procedures for control of the inventory of chlorine at the facility, and policies regarding quality level of replacement materials and components for the chlorine system. MITIGATION MEASURES No mitigation measures were considered to limit the severity of the Worst Case scenario. No passive mitigation measures were considered to limit the severity of the Alternative Case scenario. Active mitigation was considered for the Alternative Case, in the form of the timely response of properly trained and equipped personnel following established emergency response procedures. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAMS General accidental release prevention programs instituted by Sacramento Regional Wasewater Treatment Plant are categorized as administrative (management) programs; procedures, training, and engineering controls; and emergency response programs. Sacramento Regional Wasewater Treatment Plant has instituted a Process Safety Management (PSM) Program meeti ng OSHA requirements at 29 CFR 1910.119 covering the disinfection process at the Rio Cosumnes Correctional Center Wastewater Treatment Plant. This constitutes the general accidental release prevention program for Sacramento Regional Wasewater Treatment Plant's operations at this facility. The program and document management procedures included in the PSM Program will be used as the management system for the Risk Management Program. CHEMICAL-SPECIFIC RELEASE PREVENTION STEPS Release prevention steps specific to chlorine have been identified and implemented. These include improvements in operating procedures and training. FIVE YEAR ACCIDENT HISTORY There have been no accidents involving chlorine at this facility within the past five years resulting in injuries or offsite consequences. EMERGENCY RESPONSE PROGRAM Sacramento Regional Wasewater Treatment Plant's Emergency Response Program applicable to chlorine has been coordinated with Sacramento County Environmental Management Depa rtment, Hazardous Materials Division, the agency responsible for hazardous materials inventory reporting and release response coordination, and with the Elk Grove Fire Department, the local agency responsible for Incident Command activities. Sacramento Regional Wasewater Treatment Plant maintains First Responder capability with respect to chlorine releases at sites which it operates and maintains. PLANNED CHANGES TO IMPROVE SAFETY All of the improvements and mitigation measures identified in the process hazard analysis which Sacramento County Water Quality Division committed to accomplish have been completed or are in progress. Any other measures identified by employees during workplace hazard surveys, or as a result of audit activities, will be thoroughly reviewed and considered for implementation. Construction of a wastewater pump station at this site is nearly complete, and when the pump station is operational the Rio Cosumnes Wastewater Treatment Plant, including the chlorine system, will be decommissioned and the chlorine removed. |