El Dorado Hills Water Treatment Plant - Executive Summary
El Dorado Irrigation District has instituted a Risk Management Program for their water treatment facility, El Dorado Hills Water 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 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
El Dorado Irrigation District provides water supply and distribution to portions of El Dorado Hills. Its water treatment facility, El Dorado Hills Water Treatment Plant, is located on Francisco Drive, El Dorado Hills, CA in El Dorado County, and uses chlorine for disinfection in quantities greater than the Federal threshold quantity for this RS. The facility is located east of Folsom Lake in a residential neighborhood. There are three to four full-time employees at this site. Chlorine is received in ton containers by truck, handled with an electric hoist, and stored on ton container scales and storage trunnions inside the building. The chlorine is used to control biological growth on the filters and to disinfect the treated water. Pre
ssurized chlorine gas within a ton container is withdrawn under pressure and piped to a vacuum regulator valve located in the storage room where the gas pressure is reduced to vacuum. From there, the chlorine under vacuum is metered through rate valves and rotameters in chlorinators located in a separate room, 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 El Dorado Irrigation District that the receipt, storage and handling of chlorine 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, El Dorado Irrigation District has gathered safety information on chlorine and on the process, equipment and procedures involving chlorine; p
erformed 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.
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 2,000 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 liquid chlorine from a pinhole in one of the fusible plugs on a received ton container, due to a supplier error or damage in transit, with the release secured by application of a Type "B" Ton Container Repair Kit fixture after 45 minutes.
Administrative controls in effect at El Dorado Irrigation District which were considered to mitigate the severity o
f the Worst Case and Alternative Case release scenarios include El Dorado Irrigation District'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.
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 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 El Dorado Irrigation District are categorized as administrative (management) programs; procedures, training, and engineering con
trols; and emergency response programs.
El Dorado Irrigation District has instituted a Process Safety Management (PSM) Program meeting OSHA requirements at 29 CFR 1910.119 covering its disinfection process. This constitutes the general accidental release prevention program for El Dorado Irrigation District's operations. The program and document mangement 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, among other things, the creation of numerous facility-specific operation procedures with check boxes for completion of critical steps.
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
El Dorado Irrigation District's Emergency Response Pr
ogram applicable to chlorine has been coordinated with El Dorado County Department of Environmental Management, the local agency responsible for hazardous materials inventory reporting and release response coordination. El Dorado Irrigation District maintains First Responder capability with respect to chlorine releases at the EDH Water Treatment Plant.
PLANNED CHANGES TO IMPROVE SAFETY
All of the improvements and mitigation measures identified in the process hazard analysis which El Dorado Irrigation District 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.