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900E F 'L Mo 11.11.2. UTILITY CHLORINATION SYSTEM IMPROVEMENTS - RISK MANAGEMENT PLAN DATE: The Board reviewed a Memorandum of December 14, 1998: December 14, 1998 TO: JAMES E. CHANDLER COUNTY ADI ffMTRATOR FROM: DONALD R. HUBBS, P.. DIRECTOR OF UTILITY $E ;RE PREPARED AND GENE A. RAUTH STAFFED BY: OPERATIONS MANAGER SUBJECT: UTILITY CHLORINATION SYSTEM HViPROVEMENTS BACKGROLTNn As part of Congress's efforts to protect public health and the environment, it enacted legislation in 1990 that would provide significant protection in the event of an accidental release of a hazardous substance. When this legislation was signed into law by President Bush on November 15, 1990, as the Clean Air Act Amendments, it included provisions for regulations to be issued by the Environmental Protection Agency (EPA) to provide this protection. In separate regulations promulgated on January 31, 1994, and on June 20, 1996, EPA created the Accidental Release Prevention (ARP) program. These regulations require that all facilities affected by the ARP program prepare and submit a Risk Management Plan (RMP) no later than June 21, 1999, which documents the hazard assessment, prevention program, and emergency response program necessary to protect public health and the environment in the event of a catastrophic release of some 140 regulated substances including chlorine. Six (6) County facilities (2 water, 4 wastewater) exceed the 2,500 LB threshold set by EPA for chlorine, which is used for disinfection purposes and require submittal of risk management plans for each. To comply with and implement the ARP program the County has assembled a team composed of utility, risk management and emergency management staff which will meet biweekly to prepare and file the necessary information prior to the deadline. While the submittal of the information/plan is required by EPA, the threat of accidental release of chlorine is still present. The Department of Utility Services has established a goal of eliminating the potential threat of accidental chlorine release, beginning with the on-site sodium hypochlorite generation system, being constructed as part of the nearly $12 million Central Region Wastewater Treatment Facility expansion project. Alternative disinfection systems and/or potential safety measures, which are available, include emergency chlorine scrubber systems, on-site sodium hypochlorite generation and bulk commercial grade (10-12%) sodium hypochlorite. Emergency chlorine scrubbers activate when a chlorine leak is detected and absorbs or neutralizes the gas. Sodium hypochlorite, not considered hazardous, is a safer means of disinfection but requires additional electrical power. Many municipalities are now converting their smaller- sized disinfection systems to sodium hypochlorite. DECEMBER 22, 1998 52 0 40