Water Reclamation Facility - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES City of San Clemente Utilities Division has an emergency response plan in effect. The Emergency Action Plan (Plan) is detailed in the Emergency Planning and Response section of this PSM/RMP document. This Plan was designed to meet the following objectives: 1.) To save lives. 2.) To minimize and avoid injuries. 3.) To protect the environment. 4.) To minimize property damage. City of San Clemente Utilities Division maintains a safety committee whose members are the designated emergency coordinators for the facility. The Plan provides the response organization and notification procedures, evacuation routes, chlorine health hazards, and mitigation procedures which will be implemented to respond effectively to emergency situations that may arise at the facility. This Plan is reviewed and updated at least once per year. This Plan was be reviewed and updated to ensure compliance with the PSM, RMP, and CalARP regulations, an d to ensure that the plan is kept current. STATIONARY SOURCE AND REGULATED SUBSTANCE Startup of the chlorine system occurred in 1988. The process is located at 380 Avenida Pico, San Clemente, California 92672. The chlorine system for the Water Reclamation Facility of City of San Clemente Utilities Division consists of chlorine one-ton containers which are the storage vessels. Chlorine gas is drawn from a maximum of four tanks on line through a vacuum regulator to the chlorinators. Still under vacuum from the chlorinators, it is drawn to injectors and mixed with water from the treatment processes. The maximum quantity of chlorine that can be stored on site is 16,000 pounds. HAZARD ASSESSMENT SUMMARY Worst Case Release Result Summary Scenario Description: Release of the maximum quantity of chlorine that can be stored in a vessel - 2,000 pounds in 10 minutes. Although, the one-ton containers are stored enclosed in a building at the Water Reclamation Facility, the containers ar e unloaded from the delivery truck outside before being storing inside the building. This creates the potential for operator error or equipment failure that would result in an unmitigated release, therefore, passive mitigation measures were not used. The most pessimistic meteorological conditions were used: 1.5 meters/second wind speed, and F stability. Reference table from the EPA's RMP Guidance for Wastewater Treatment Plants was used to determine the distance for the toxic point of 3 ppm. This release reaches off-site and may affect population receptors. No Environmental receptors were affected by the potential release scenario. Alternative Release Result Summary Scenario Description: A release of chlorine gas from 5/16 inch diameter leak. The release rate of chlorine due to the pressure of the tank is 14.6 pounds per minute. However, passive mitigation measures were incorporated since the chlorine system is located inside an enclosed building at the Water Reclamation Facil ity. Consequently, the release rate to the outside atmosphere was calculated to be 8.0 pounds per minute. The meteorological conditions used were 3 meters per second wind speed, and D stability. Reference table from the EPA's RMP Guidance for Wastewater Treatment Plants was used to determine the distance for the toxic point of 3 ppm. This release reaches off-site and may affect population receptors. No Environmental receptors were affected by the potential release scenario. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS City of San Clemente Utilities Division 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 gas detector in the storage room that is set at 1 ppm and will activate the visual/audible alarm, the scrubber system, shut off the ventilation system, and page the operator on duty. FIVE YEAR ACCIDENT HISTORY The accident history researched back five years to June 1994 shows that the City of San Clemente Utilities Division's facility has not had an accidental release or "near miss" of chlorine. EMERGENCY RESPONSE PROGRAM The City of San Clemente Utilities Division has an emergency response plan in effect at the facility. The Emergency Response Plan (Plan) is detailed in the Emergency Planning and Response section of the PSM/RMP document. This Plan was designed to meet the following objectives: 1.) To save lives. 2.) To minimize and avoid injuries. 3.) To protect the environment. 4.) To minimize property damage. The City of San Clemente Utilities Division maintains a safety committee whose members include the emergency coordinators for the facility. The Plan provides the response organization and notification procedures, evacuation routes, and mitigation procedures which will be implemented to respond effectively to emergency situations that may arise at the facility. The Plan also includes the Emergency training for all City of San Clemente Utilities Division employees. The City of San Clemente Utilities Division performs periodic emergency evacuation drills to enhance the emergency response skills of its personnel. The Emergency Response Plan is reviewed and updated by the City of San Clemente Utilities Division Water Reclamation Plant responsible person, Mr. A. J. Howard at least once a year. This Plan will be review and updated to ensure compliance with the PSM, RMP, and CalARP regulations, and to ensure that the plan is kept current. The City of San Clemente Utilities Division has coordinated emergency response efforts withe the local fire department, Orange County Fire Department. In the case of a chlorine-related emergency, its is the policy of City of San Clemente Utilities Division to evacuate the employees and to allow the fire department to respond to the emergency (potentially with the assistance of trained facility personnel). PLANNED CHANGES TO IMPROVE SAFETY The Process Hazard Analysis (PHA) provided the mitigation measures outlined below to improve safety at the City of San Clemente Utilities Division Water Reclamation Plant. The PHA was comprised of one session that included a HAZOP study, a Plant Walkthrough, a "What-if" analysis, and a series of checklists. The changes will be completed by December 1, 1999. R01 Provide new chemical suits in the electrical room at the Water Reclamation Facility. R02 Contact the vacuum regulator manufacturer to determine if the ventilation line can be routed to the sensor inside the chlorine storage building. Also determine whether this will cause the scrubber to turn on during every tank change. R03 Verify the maintenance and performance of the chlorine sensor with the scrubber system. Include manufacturer's maintenance recom mendation in the Mechanical Integrity program. R04 Conduct an emergency evacuation drill at the Water Reclamation Facility at least once a year and document the results. (Note: The Water Treatment Facility is an unmanned facility.) R05 Assign responsibility for roll call during evacuation at the Water Reclamation Facility. Ensure that the supervisors understand that they will be required to account for the whereabouts of operators on site during an evacuation. (Note: The Water Treatment Facility is an unmanned facility.) R06 Install windsocks at both facilities to determine the wind direction. R08 Ensure both chlorine and sulfur dioxide sensors are connected to the scrubber system. R09 Include in the Mechanical Integrity procedures that a tag showing the replacement date for the flexible tubing be attached to the system tubing. R12 Confirm the removal of the manifold bracing during the system modification (Water Reclamation Facility). R13 Complete the Human Factor Engineering checklist (Tables 5-2 and 5-3) at such time when the modification of both facilities is finished and the chlorine/sulfur dioxide systems are operational. R14 Review Emergency Response checklist (contained in Appendix C) after the completion of the facility's emergency response plan. Seismic Assessment 1. Each container should be secured using two nylon "Kevlok" straps which use a "come-along" buckle to ensure that the strap is tight (520-881-2130). Typically, these straps are rated at 5000 pounds. Two chains can be used to secure each container, but they must be kept tight around the container. 2. The gap between the door opening for the crane rail should be eliminated. 3. The point of discharge for the floor drain should be verified. |