Clear Creek Wastewater Treatment Plant - Executive Summary

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The City of Redding has instituted a Risk Management Program for their wastewater treatment facility, Clear Creek Wastewater Treatment Plant, 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 re 
quired 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.   
The City of Redding operates two wastewater treatment plants.  Its Clear Creek Wastewater Treatment Plant is located at 2220 Metz Road, Anderson, CA in Shasta County, and uses chlorine and sulfur dioxide for disinfection and dechlorination in quantities greater than the Federal threshold quantity for these RS's.  The facility is located on the west bank of the Sacramento River in an industrial area just south of Redding.  There are 8 full-time employees at this site.  Chlorine and sulfur dioxide are received in ton containers by truck, handled with an electric hoist, and stored inside a fenced enclosure.  The chlorine is used for odor control of the influent wastewater, to disinfect the wastewater effluent, and for other process uses.  The sulfu 
r dioxide is used to dechlorinate the disinfected effluent for aquatic toxicity control.  Pressurized gas within a ton container is reduced to vacuum at a vacuum regulator valve mounted directly onto the ton container's gas valve.  From there, the gas under vacuum is metered through rate valves and rotameters in chlorinators or sulfonators located in a separate room, and drawn into water solution by the passage of pressurized water through an injector. 
It is the policy of the City of Redding that the receipt, storage and handling of chlorine and sulfur dioxide at its facility 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, the City of Redding has gathered safety information on chlorine and sulfur 
dioxide and on the process, equipment and procedures involving chlorine and sulfur dioxide; performed a structured assessment of hazards of the process and external events which might affect the process; performed an offsite consequences 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. 
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 2,000 lb.  This release scenario is not physically possible, due to the characteristics of chlorine. 
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 cases" considered for this facility are the release of chlorine or sulfur dioxide 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 60 minutes. 
Administrative controls in effect at the City of Redding which 
were considered to mitigate the severity of the Worst Case and Alternative Case release scenarios include the City of Redding's written policies and procedures for training of operators and maintenance personnel, written procedures for control of the inventory of chlorine and sulfur dioxide at the facility, and policies regarding quality level of replacement materials and components for the chlorine and sulfur dioxide systems. 
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 instituted by the City of Redding are categorized as administrativ 
e (management) programs; procedures, training, and engineering controls; and emergency response programs. 
City of Redding has instituted a Process Safety Management (PSM) Program meeting OSHA requirements at 29 CFR 1910.119 covering its disinfection and dechlorination process.  This constitutes the general accidental release prevention program for the City of Redding's operations.  The program and document management procedures included in the PSM Program will be used as the management system for the Risk Management Program. 
Release prevention steps specific to chlorine have been identified and implemented.  These include, among other things, improving the seismic restraint of ton containers and container scales. 
There have been no accidents involving chlorine or sulfur dioxide at this facility within the past five years resulting in injuries or offsite consequences. 
City of Redding's 
Emergency Response Program applicable to chlorine has been coordinated with Redding Fire Department.  The City of Redding maintains HazMat emergency response capability with respect to chlorine and sulfur dioxide releases at its facilities through a joint team of water and wastewater utility staff within the Public Works Department. 
All of the improvements and mitigation measures identified in the process hazard analysis which the City of Redding committed to accomplish have been completed or are in progress.  It is planned to enlarge the chlorine and sulfur dioxide ton container storage area and install additional trunnion sets with straps, to permit all full and empty ton containers of chlorine and sulfur dioxide to be strapped to a trunnion set.   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.
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