Victor Valley Wastewater Reclamation Authority - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Victor Valley Wastewater Reclamation Authority (VVWRA) has an emergency response plan in effect. The Emergency Response Plan (Plan) is detailed in the Emergency Planning and Response section of the PSM/RMP document, which is maintained at the facility and updated as necessary. 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 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 reviewed and updated to ensure compliance with the PSM and RMP regulations, as well as to incorporate facility changes. VVWRA has coordinated e mergency response efforts with the local fire department, Victorville Fire Department. In the case of a chlorine-related emergency, it is the policy of VVWRA to evacuate the employees and to allow the fire department to respond to the emergency (potentially with the assistance of trained facility personnel). STATIONARY SOURCE AND REGULATED SUBSTANCE Victor Valley Wastewater Reclamation Authority is located at 20111 Shay Road, Victorville, California 92394. The facility is located approximately 5 miles northwest of Interstate 15, and about 2 miles north of George Air Force Base. The area surrounding the facility is primarily barren desert. The chlorine system was constructed in accordance with all applicable federal, state, and local regulations. The facility is surrounded by chain link fence with access through one gate only. Chlorine at the treatment plant is received and stored in one-ton containers. A maximum of fifteen containers can be stored at any one time. The chlori ne system has a manifold system that allows the system to draw gaseous chlorine from one of six on-line containers (each with a vacuum regulator). Chlorine gas is routed to the chlorinators, where the feed rate is controlled. A vacuum is created when process water is pumped through the injectors, which pull the gaseous chlorine into the water supply, thus treating the wastewater. The chlorine system is operated under vacuum conditions. This implies that a breach in the integrity of the system would result in air being sucked into the system, not a release of chlorine. HAZARD ASSESSMENT SUMMARY * Worst Case Release Result Summary Scenario Description: Release of the maximum quantity of chlorine that can be stored in a vessel (one-ton container) - 2,000 pounds in 10 minutes. The most pessimistic meteorological conditions were used: 1.5 meters per second wind speed, and F stability. The Risk Management Program Guidance for Waste Water Treatment Plants reference tables we re used to determine the maximum distance to the toxic endpoint of 3 ppm in rural conditions. This release reaches off site and may impact population receptors. No environmental receptors were affected by this potential release. * Alternative Release Result Summary Scenario Description: A release of chlorine from resulting from a 1/4 inch diameter hole in a pipe. The release rate of chlorine due to the pressure of the tank is 9.5 pounds per minute (5.2 pounds per minute to the outside atmosphere taking into account the enclosure of the building). The meteorological conditions used were 3 meters per second wind speed, and D stability. The Risk Management Program Guidance for Waste Water Treatment Plants reference tables were used to determine the maximum distance to the toxic endpoint of 3 ppm. This release reaches off site. Due to the remote location of the facility, no population receptors are likely to be affected. No environmental receptors were affected by this pot ential release. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS The VVWRA chlorine system has many safety features. Much of the safety of the system is inherent in the policies and procedures that govern the operation of the system. For example, the VVWRA treatment plant operates in accordance with OSHA's Process Safety Management regulation and the California Accidental Release Prevention (CalARP) Program. Chlorine gas detectors are strategically located in the chlorine building (in the storage room and the chlorinator room). In case of chlorine detection, visible and audible alarms are activated at the site and the on-call operator is paged through the SCADA system. In the event of a power failure, vacuum regulators and check valves prevent chlorine from escaping the system. If vacuum conditions are compromised, the vacuum regulators close stopping chlorine flow from the one-ton containers. Chlorine vent lines are piped to water containers locat ed outside the building. In addition, common industry standards, policies, and procedures are utilized to ensure safe practices are being performed. This includes common practices recommended by the Chlorine Institute. FIVE YEAR ACCIDENT HISTORY There have been no chlorine accidents at the facility since June 1994. EMERGENCY RESPONSE PROGRAM VVWRA has an emergency response plan in effect. The Emergency Response Plan (Plan) is detailed in the Emergency Planning and Response section of the PSM/RMP document, which is maintained at the facility and updated as necessary. 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 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 a rise at the facility. This Plan is reviewed and updated at least once per year. This Plan was reviewed and updated to ensure compliance with the PSM and RMP regulations, as well as to incorporate facility changes due to the renovation of the facility. VVWRA has coordinated emergency response efforts with the local fire department, Victorville Fire Department. In the case of a chlorine-related emergency, it is the policy of VVWRA 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) and the Seismic Assessment provided mitigation measures to improve safety at Victor Valley Wastewater Reclamation Authority located at 20111 Shay Road, Victorville, California 92394. The recommendations are scheduled to be complete by March 1, 2000. * Process Hazard Analysis R01 Coordinate emergency response efforts with the loca l fire department. Consider an annual meeting to clearly define the division of responsibility during an emergency. R02 Establish a procedure to ensure that all employees (including the administrative department) are aware of the presence of and the hazards associated with chlorine at the facility and what actions should be taken in case of an emergency. R03 Determine and follow manufacturer's calibration recommendations for the chlorine detectors. R04 Establish a procedure to document that operators are trained and qualified to change chlorine cylinders. Note: Recommendations 05 and 06 addressed systems that are not subject to the RMP. R07 Establish a procedure to hold annual evacuation drills at the facility. R08 Consider: 1) protecting the piping to the outside eye wash stations from the ambient heat, or 2) establishing a policy to exercise eye wash before working on chlorine system (to fill the system with cool water). R09 Label all chlorine piping and key valves. * Seismic Assessment 1. It is recommended that the attachment for the storage of offline chlorine cylinders be modified. Individual chain attachments similar to those used for the active cylinders should be installed. Spare cylinders should NOT be stored on top of the offline cylinders. 2. It is recommended that if shelving is to remain in the chlorine delivery system room that it be restrained to prevent tipping over in an earthquake. Shelf surfaces should be provided with edging that would prevent contents of shelves from falling off the shelves during violent shaking. |