5.

18 Worker Safety

5.18 Worker Safety

This section describes the systems and procedures that will be implemented to provide occupational safety
and health protection for Project workers. The section includes descriptions of the health and safety
programs that will be used during both Project construction and operation, and provides information on the
Project’s planned fire prevention and protection program system. Descriptions of the Project’s fire
suppression system and fuel gas system are provided in Section 2.0, Project Description.

5.18.1 Summary of Differences between Amended Project and Original SSU6

There are no changes in the affected environment for worker safety from the original SSU6 project. As was
the case with the original project, worker safety programs similar to those at the existing geothermal power
plants operated by the Applicant’s affiliate will be implemented for the Amended Project. There are no
significant changes in the Amended Project’s impacts to worker safety compared to the original SSU6.
There may be minor differences in worker safety programs due to modifications in the plant processes, i.e.
chemical handling systems, but these differences will result in no new or different adverse effects. Indeed,
some of the original project’s effects are lessened or eliminated with the Amended Project (e.g., the
Amended Project will no longer use a carbon absorption abatement system, thereby eliminating possible
benzene exposure during the handling of spent carbon absorption drums).

5.18.2 LORS Compliance

Construction and operations of the Project will be performed in accordance with the applicable LORS in
order to ensure a safe and healthy workplace. The applicable LORS are briefly discussed following the
table and summarized in Table 5.18-1.
Table 5.18-1 Worker Safety LORS Summary

Where Discussed
LORS Applicability
in AP
Federal:
Occupational Safety and Health Act Created Occupational Safety and Health Section 5.18.1
of 1970: 29 U.S. Code (U.S.C.), Administration (OSHA) and provides federal
sections 651 et seq. regulations for worker safety and health in
industrial facilities.
Occupational Safety and Health Contains federal minimum occupational Section 5.18.1
Standards: Title 29, Code of Federal safety and health standards for industrial
Regulations (CFR), Part 1910 et seq. facilities.
Safety and Health Regulations for Contains federal minimum occupational Section 5.18.1
Construction: Title 29, CFR, Part safety and health standards for the
1926 et seq. construction industry.

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5.18 Worker Safety

Table 5.18-1 Worker Safety LORS Summary

Where Discussed
LORS Applicability
in AP
Approved State Plans for These sections provide federal approval of Section 5.18.1
Enforcement of State Standards: 29 California’s plan for enforcement of its own
CFR sections 1952.170 to 1952.175 safety and health requirements, in lieu of
most of the Federal requirements found in 29
CFR §1910.1 to 1910.1500.
State:
Title 8, California Code of Regulations Establishes requirements for a safe and Section 5.18.3.
(CCR) hazard-free work environment. Categories of
requirements include General Industrial
Safety Orders, General Construction Safety
Orders, Electrical Safety Orders, and
Pressure Vessel Safety Orders (see Table
5.18-2 for list of applicable topics covered).
24 CCR Section 3, et seq. Incorporates the current addition of the Section 5.18.3
Uniform Building Code.
California Health and Safety Code, These sections address the requirements for Sections 5.18.3
Sections 25500 through 25541 the preparation of a Hazardous Material and 5.6.2,
Business Plan and an Emergency Response Hazardous
Plan for a hazardous materials emergency at Materials
the facility.
California Health and Safety Code, The California Accidental Release Program Section 5.18.3
Section 25531 to 25543.4 (Cal-ARP) requires the preparation of a Risk
Management Plan (RMP) and Offsite
Consequence Analysis (OCA) and submittal
to the local Certified Unified Program
Authority for approval.
Local:
Imperial County Codified Ordinances, Adoption by the Imperial County of the Section 5.18.3 and
Chapter 8.20 Uniform Fire Code (see below). 5.6.1, Hazardous
Materials
Uniform Fire Code, Article 79, 80 Address prevention, control and mitigation of Section 5.18.3 and
dangerous conditions related to storage, 5.6.1, Hazardous
dispensing, uses, and handling of various Materials
flammable and combustible liquids (Article 79)
and hazardous materials (Article 80). Also
identifies information needed by emergency
response personnel.
Imperial County Codified Ordinances, Adoption by the Imperial County of the Sections 5.18.3
Division 10 Chapter 3 California Building Code (see below). and 5.6.1,
Hazardous
Materials
California Code of Regulations, Title Specifies the relevant building codes Sections 5.18.3
24, Section 501 et seq.; California required. and 5.6.1,
Building Code Hazardous
Materials

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 5.18 Worker Safety

Table 5.18-1 Worker Safety LORS Summary

Where Discussed
LORS Applicability
in AP
Industry Codes and Standards:
National Fire Protection Association Standards needed to establish a reasonable Sections 5.18.3
(NFPA) level of safety and property protection from and 5.6.1,
hazards created by fire and explosion (see Hazardous
Table 5.18-3 for list of standards). Materials
American National Standards Institute Provides specifications and other Appendix C
and American Society of Mechanical requirements for pressure vessels.
Engineers

5.18.2.1 Federal LORS

Federal regulations dealing with worker health and safety are administered by OSHA under the
Occupational Safety and Health Act of 1970. The Occupational Safety and Health Act provide regulations
dealing with equipment and employee safety practices during construction and operation of an industrial
facility. Occupational health and safety standards are provided in 29 CFR §1910 et seq., including §
1910.100 (permissible exposure limits for toxic air contaminants), § 1910.137 (electrical protective
equipment requirements), § 1910.269 (electrical worker safety standards), and § 1910.1200 (requirement
for employers to provide information to employees concerning hazards associated with the use of all
chemicals). Construction health and safety regulations are provided in 29 CFR § 1926. Worker personal
protective equipment (PPE) requirements are addressed in Subpart I of §1910 and Subpart E of §1926.
Federal safety and health regulations for construction are also provided in 40 USC 327 et seq.; these
requirements are addressed in California’s Title 8, CCR, Chapter 4, Subchapter 4, General Construction
Safety Orders.

Per the 1989 Occupational Status Agreement between Federal OSHA and the California Division of
Occupational Safety and Health, housed within the Department of Industrial Relations, the State enforces
California Standards set forth in Title 8 of the California Code of Regulations in lieu of most Federal
regulations and standards, although the Federal OSHA has retained concurrent enforcement jurisdiction for
certain Federal standards (e.g., those related to hazardous waste).

Construction

Construction health and safety regulations are provided in 29 CFR § 1926 and Title 8 CCR. Part 1926
addresses several types of construction activities, such as general safety and health provisions (Subpart C);
occupational health and environmental controls (Subpart D); personal protective and life-saving equipment
(Subpart E); fire protection and prevention (Subpart F); material handling, storage, use, and disposal
(Subpart H); welding and cutting activities (Subpart J); electrical work (Subpart K); scaffolding (Subpart L)
and fall protection (Subpart M); cranes, derricks, hoists, elevators, and conveyors (Subpart N); motor
vehicles and mechanized equipment (Subpart O); excavations (Subpart P); concrete and masonry
construction activities (Subpart Q); steel erection activities (Subpart R); underground construction, caissons,
cofferdams, and compressed air; demolition (Subpart T); power transmission and distribution (Subpart V);
rollover protection structures and overhead protection (Subpart W); stairways and ladders (Subpart X); and
toxic and hazardous substances (Subpart Z). Federal safety and health regulations for construction are also

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5.18 Worker Safety

provided in 40 USC 327 et seq.; these requirements are addressed in Title 8, CCR, Chapter 4, Subchapter
4, General Construction Safety Orders.

Operation

Occupational health and safety standards for industrial facilities are provided in 29 CFR §1910 et seq. and
Title 6 CCR. Part 1910 addresses several types of operational activities, such as walking and working
surfaces (Subpart D); means of egress (Subpart E); powered platforms, man lifts, and vehicle-mounted
work platforms (Subpart F); occupational health and environmental controls (Subpart G); hazardous
materials (Subpart H); personal protective equipment (Subpart I); medical and first aid (Subpart K); fire
protection (Subpart L); compressed gas and compressed air equipment (Subpart M); material handling and
storage (Subpart N); machinery and machine guarding (Subpart O); hand and portable powered tools and
other hand-held equipment (Subpart P); welding, cutting, and brazing (Subpart Q); special industries –
electric power generation, transmission, and distribution (§1910.269); and electrical (Subpart S).

Per the 1989 Occupational Status Agreement between the Federal OSHA and the California Department of
Occupational Safety and Health, the state enforces most Federal regulations and standards, although the
Federal OSHA has retained concurrent enforcement jurisdiction for certain Federal standards (e.g., those
related to hazardous waste). Federal safety and health regulations for construction are also provided in 40
USC 327 et seq.; these requirements are addressed in Title 8, CCR, Chapter 4, Subchapter 4, General
Construction Safety Orders.

5.18.2.2 State LORS

The California Occupational Safety and Health Administration (Cal/OSHA) is responsible for enforcing most
health and safety regulations and standards during industrial facility construction and operation. These
regulations deal with a variety of issues such as equipment design, personnel training, operational
procedures, and safety devices, and are found primarily in CCR, Title 8. Table 5.18-2 identifies specific
topical areas covered in applicable portions of CCR Title 8.

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 5.18 Worker Safety

Table 5.18-2 Potentially Applicable Topics Addressed in Title 8 CCR

Standard Description
Occupational Health and Safety Standards, Definitions
Title 8, §§ 401-428 Administration
Variances
Appeals
Officers
Hearing Board
General Industrial Safety Orders Employee/Employer Communications
Title 8, §§ 3200-6184 Injury and Illness Prevention Program
Emergency Action Plan
Fire Prevention Plan
Hazardous Materials
Control of Hazardous Substances
Hazard Communications
Emergency Medical Procedures
Personal Protective Equipment
Airborne Contaminants
Signs, Tags, and Barriers
Noise Levels
Ventilation
Flammable/Combustible Materials Handling and Storage
Fire Protection Systems
Machine Guarding
Crane and Hoist Operation
Heavy Equipment and Machinery Operation
Rigging
Sanitary Facilities
Traffic Safety
Interface with Other Contractors
Miscellaneous Hazards (including hot pipes, compressed
air systems, relief valves, pipelines, loading docks)
General Construction Safety Orders Construction Accident Prevention Plan
High Voltage Electrical Safety Orders Weekly Toolbox Meeting
Title 8, §§ 1500-1938 Traffic Accidents and Earth Moving
Hoist equipment
Reinforcing Concrete
Fall Protection and Scaffolding
Electrical Installation
Evacuation Plan and Procedures
Fire Safety
Airborne Contaminants
Emergency Medical Procedures
Personal Protective Equipment
Hand and power Tool Use
Crane and Hoist Operations
Illumination
Housekeeping
Excavations
Electrical Safety Orders High Voltage Installation, Operation, and Maintenance
Title 8, §§ 2299-2974 Low and High Voltage Hazards

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Table 5.18-2 Potentially Applicable Topics Addressed in Title 8 CCR

Standard Description
Unfired Pressure Vessel Safety Orders, Design and Construction
Title 8, §§ 450-460 Air Tanks
Pressure Vessels other than Air Tanks
Boiler and Fired Pressure Vessel Safety
LP Gas Systems
Orders, Title 8, §§ 750-797
Aqueous Ammonia
Safe Practices
Design and Construction
Installation, Inspection, Operation, Repairs

Construction

Construction safety orders are published at Title 8 of the CCR, sections 1502, et seq. These requirements
are promulgated by Cal/OSHA and apply to the construction phase of the Project. The construction safety
and health program will include the following:

 Construction Injury and Illness Prevention Plan (8 CCR § 1509);

 Construction Fire Protection and Prevention Plan (8 CCR § 1920);

 Personal Protective Equipment Program (8 CCR §§ 1514-1522); and

 Emergency Action Program and Plan (8 CCR § 3220).

Additional programs under General Industry Safety Orders (8 CCR §§ 3200-6184), Electrical Safety Orders
(8 CCR §§ 2299-2974), and Unfired Pressure Vessel Safety Orders (8 CCR §§ 450-544) will include:
electrical safety program; motor vehicle and heavy equipment safety program; forklift operation program;
excavation/trenching program; fall protection program; scaffolding/ladder safety program; articulating boom
platforms program; crane and material handling program; housekeeping and material handling and storage
program; respiratory protection program; employee exposure monitoring program; hand and portable power
tool safety program; hearing conservation program; back injury prevention program; hazard communication
program; heat and cold stress monitoring and control program; pressure vessel and pipeline safety program;
hazardous waste program; hot work safety program; permit-required confined space entry program; and
demolition procedure (if applicable).

Title 24 CCR, also known as the California Building Standards Code, is a compilation of three types of
building standards from three different origins: building standards that have been adopted by State agencies
without change from building standards contained in national codes; building standards that have been
adopted and adapted from the national model code standards to meet California conditions; and building
standards, authorized by the California legislature, that constitute extensive additions not covered by the
model codes that have been adopted to address particular California concerns. Within 24 CCR there are
several potentially applicable parts, such as Part 3 - California Electrical Code; Part 4 - California
Mechanical Code; Part 5 - California Plumbing Code; Part 6 - California Energy Code; Part 9 - California
Fire Code; and Part 10 - California Code for Building Conservation.

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 5.18 Worker Safety

Operation

Prior to operations, an operations and maintenance safety and health program will be prepared. This
program will include the following programs and plans:

 Injury and Illness prevention Program (8 CCR § 3203);

 Fire Protection and Prevention Program (8 CCR § 3221);

 Personal Protective Equipment Program (8 CCR §§ 3401-3411); and

 Emergency Action Plan (8 CCR § 3220).

In addition, the requirements under General Industry Safety Orders (8 CCR §§ 3200-6184), Electrical Safety
Orders (8 CCR §§ 2299-2974), and Unfired Pressure Vessel Safety Orders (8 CCR §§ 450-560) will apply
to this project. Written (operations) safety programs for the Project will ensure compliance with those
requirements. Table 5.18-2 identifies specific topical areas covered in applicable portions of CCR Title 8.

5.18.2.3 Local LORS

Uniform Fire Code, Articles 80, 79, 4

Article 80 includes provisions for storage and handling of hazardous materials. Other articles that may be
applicable include Article 4, Permits, and Article 79, Flammable and Combustible Liquids. The
administering agency for the above regulations is the Imperial County Fire Department. The Project would
be designed and constructed to comply with all applicable Uniform Fire Code requirements.

California Code of Regulations, Title 24, Section 501 et seq.; California Building Code

This regulation specifies the relevant building codes required by the State of California for the design and
construction of buildings related to fire and life safety, and structural safety. By incorporation, this regulation
references requirements of the 2007 Uniform Building Code (UBC). The Imperial County Planning and
Building Department, which enforces these provisions, uses the 2007 UBC, the 2007 California Building
Codes, and the 1996 National Electric Code as its guidance.

5.18.2.4 Industry Codes and Standards

Several industry codes and trade association standards designed to ensure worker safety and health may
be applicable to the Project. Table 5.18-3 provides a listing of potentially applicable industry codes and
standards. Many of these standards have been incorporated into Federal and State regulations and into
building codes. Of particular relevance to worker safety are the fire and explosion hazards-related
standards of the NFPA, which are identified in Table 5.18-4.

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5.18 Worker Safety

Table 5.18-3 Potentially Applicable Industry Codes and Standards

American Association of State Highway Officials (AASHO)
American National Standards Institute (ANSI)
American Petroleum Institute (API)
American Society for Testing and Materials (ASTM)
American Society of Nondestructive Testing (ASNT)
American Society of Mechanical Engineering (ASME)
American Water Works Association (AWWA)
American Welding Society (AWS)
Underwriters Laboratories (UL)
Uniform Building Code (UBC)
Uniform Fire Code (UFC)
Standards of Tubular Exchanger Manufacturers Association (TEMA)
American Institute of Steel Construction (AISC) Specifications
American Society of Heating, Refrigeration, and Air Conditioning Engineers (ASHRAE)
Asphalt Institute, Pacific Coast Division
California State Fire Marshall (CSFM)
Heat Exchanger Institute
Hydraulic Institute Standards
Institute of Electrical and Electronic Engineers (IEEE)
Instrument Society of America (ISA)
National Association of Corrosion Engineers (NACE)
California Building Code (CBC)
Steel Structures Painting Council Standards (SSPC)
Uniform Plumbing Code (UPC)
Uniform Mechanical Code (UMC)

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 5.18 Worker Safety

Table 5.18-4 Fire Protection Association Fire and Explosion Hazards Standards

Standard Description
NFPA 1 Fire Prevention Code
NFPA 10 Portable Fire Extinguishers
NFPA 12 Carbon Dioxide Fire Extinguishers
NFPA 13 Sprinkler Systems
NFPA 14 Installation of Standpipe and Hose Systems
NFPA 15 Water Spray Fixed Systems
NFPA 17 Dry Chemical Fire Extinguishing Systems
NFPA 20 Centrifugal Fire Pumps
NFPA 22 Water Tanks for Private Fire Protection
NFPA 24 Private Fire Service Mains and Appurtenances
NFPA 26 Valves Controlling Water-Supplied Fire Suppression Systems
NFPA 30 Flammable and Combustible Liquids Code
NFPA 37 Combustion Engines and Gas Turbines
NFPA 50A Gaseous Hydrogen at Consumer Sites
NFPA 68 Explosion Venting
NFPA 69 Explosion Preventing
NFPA 70 National Electric Code
NFPA 71 Installation, Maintenance, and Use of Central Station Signaling Systems
NFPA 72 National Fire Alarm Code
NFPA 78 Lighting Protection Systems
NFPA 80 Fire Doors and Windows
NFPA 90A Air Conditioning and Ventilating Systems
NFPA 101 Design Requirements for Means of Exiting Facilities
NFPA 291 Testing and Marking Hydrants
NFPA 496 Purged and Pressurized Enclosures for Electrical Equipment
NFPA 497 Flammable and Combustible Liquids Classification
NFPA 1961 Fire Hose
NFPA 1962 Care, Use, and Service of Fire Hose including Couplings and Nozzles
NFPA 1963 Screw, Threads, and Gaskets for Fire Hose Connections
NFPA 2001 Clean Agent Fire Extinguishing Systems

5.18.2.5 Involved Agencies and Required Permits

Agency contacts regarding worker health and safety for the Project are shown in Table 5.18-5.

Table 5.18-5 Agencies and Agency Contacts

Agency Contact Phone/E-mail Permit/Issue

Cal/OSHA Duty Officer Consultation Services
Duty Officer (909) 383-4567 See Permits in
464 West 4th Street, Room 339 Compliance Division Table 5.18-6
San Bernardino, CA 92408 (909) 383-4321
Mr. Jurg Heuberger, Director
Imperial County Planning and Building
(760) 482-4236 Building and Safety
Department
jurgheuberger@imperialcounty.net Code adherence
939 W. Main Street, Suite B1
El Centro, CA 92243

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5.18 Worker Safety

Table 5.18-5 Agencies and Agency Contacts

Agency Contact Phone/E-mail Permit/Issue

Tony Rouhotas, Fire Chief Cal-ARP

Imperial County Fire Department (760) 482-2422 Uniform Fire Code
2514 La Brucherie Road jtonyrouhotas@imperialcounty.net and NFPA
Imperial, CA 92251 compliance

Table 5.18-6 provides a listing of applicable health and safety permits, which will be required for the Project.
Additionally, this table provides the activities covered for each permit as well as the application requirements
to obtain the permit. Although the Federal OSHA program does not require permits, instead requiring
compliance with regulations, Cal/OSHA does require some permits for what Cal/OSHA regards as high
hazard work.

All permits given in Table 5.18-6 can be obtained from any district or field office of Cal/OSHA. The permit
notification or application requirement is generally 24 hours prior to commencement of work. A specific
permitting schedule is not provided because the permits may be required at several points in the
construction of the plant or during operation.

Table 5.18-6 Permits and Approvals

Permit/ Issuing Permit

Law/Application Requirements
Approval Agency Schedule
Trenching, Cal/OSHA Permits are required for the following operations: Submit
Excavation, completed permit
Trenches and excavations of more than five feet below
and application within
ground surface where personnel are required to enter.
Erection or 24 hours to any
Demolition Construction of buildings, structures, scaffolding, or false work Cal-OSHA district
Permit that are more than three stories high. or field office
prior to
Demolition of any building, structure, or the dismantling of
commencing
scaffolding or false work that are more than three stories high.
construction.
Erection of a Cal/OSHA Permits are required for the following operations: Submit
Fixed Tower completed permit
Erection, climbing, and dismantling of fixed tower cranes.
Crane application to any
Permit Additionally, notifications to the Cal/OSHA must be made at Cal/OSHA district
least 24 hours prior to the initiation of the following activities: or field office 24
hours prior to
Completion of erection and commencement of operation.
beginning work.
Climbing of the tower crane.
Dismantling of the tower crane.

5.18.3 Affected Environment

Because the Project facilities have not yet been constructed, and because there are no industrial activities
currently on the Project site, there are no relevant baseline conditions to describe.

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 5.18 Worker Safety

5.18.4 Environmental Impacts

Project workers may be exposed to hazardous materials during construction, operation, and maintenance
activities. Potential impacts to worker safety are defined as impacts that could adversely affect Project
personnel, including individuals employed directly by the Project as well as the employees of the contractors,
vendors, or others working on site, during Project construction and/or operation. Impacts to workers can be
minimized through the implementation of appropriate engineering and administrative controls and the use of
personal protective equipment. The Applicant operates several existing geothermal facilities in the Project
vicinity, and there are well established health and safety programs in place at these facilities. These existing
health and safety programs provide a strong foundation for the health and safety programs that will be
implemented for the Amended Project (with, of course, prudent Project-specific adaptations).

Hazards, impacts, and control measures are similar for the construction and operation phases of the
Project. Therefore, many of the health and safety programs and plans that will be developed and
implemented during the construction phase will be revised as the Amended Project transitions to operations.
The health and safety programs and plans for each phase of the Project are discussed in Section 5.18.4.1,
Construction and Section 5.18.4.2, Operations.

5.18.4.1 Construction

Health and safety programs designed to mitigate hazards and comply with applicable LORS will be
developed and implemented to protect worker health and safety during Project construction. Periodic audits
will be performed by qualified individuals to determine whether proper work practices and programs are
being used to mitigate hazardous conditions and to evaluate regulatory compliance.

Construction Safety Program

During construction, the Applicant will hold the general construction contractor (Contractor) responsible for
enforcing contract provisions to assure compliance with the all health and safety requirements to comply
with California Occupational Safety and Health Administration (Cal/OSHA) regulations and to ensure the
safety and health of its employees and its subcontractors. The Contractor will ensure that an appropriate
number of onsite persons are trained in rendering first aid. The closest emergency medical clinic to the site
is the Pioneers Memorial Healthcare at 207 W. Legion Road, Brawley, California, approximately 18 miles
south of the site.

Safety Permits, Certifications and Registrations

Prior to construction, the relevant contractor will possess or obtain a valid construction activity permit and
provide the proper Activity Notification Form for Holders of Annual Permits pursuant to Title 8, CCR, Chapter
4, Subchapter 4, from Cal/OSHA to enable construction of buildings/structures greater than 36 feet or three
stories high. The relevant contractor will also possess or obtain a valid permit if a mobile tower crane is
used. All cranes with a rated capacity exceeding three tons will be certified per 8 CCR § 5021. Applications
for permits and requirements for certifications will be addressed to the San Diego District Office of
Cal/OSHA. An erection plan or notification will be submitted to Cal/OSHA prior to installation of any
elevators pursuant to 8 CCR § 3001(a)(1). The Applicant will follow similar procedures as required for
excavations.

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5.18 Worker Safety

Hazard Analysis

Table 5.18-7 summarizes a hazard analysis of the Project. This table lists work activities and associated
hazards, and also shows programs designed to reduce the occurrence of each exposure, workplace, or
occupational hazard. Because the types of work activities, associated hazards, and hazard control
approaches shown are generic and apply to both construction and operations work activities, Table 5.18-7
applies to both Project construction and Project operations. As Project design, construction, and operation
proceeds, the analyses of hazards and the specifics of control strategies will be updated as needed to
ensure that they are appropriate for Project activities at that time.

Table 5.18-7 Project Hazard Analysis (Construction and Operations Phases)

Activity Hazard Control

Motor Vehicle and Collisions between equipment, Establish a Motor Vehicle and Heavy
Heavy Equipment Use injury to operators and construction Equipment Safety Program.
workers, and damage to
construction and operation
equipment.
Forklift Operation Similar to motor vehicle and heavy Same as above and provide Forklift
equipment use. Operator Training Program.
Working in Elevated Injury to employees from falls from Establish a Fall Protection Program and
Locations elevated locations. Scaffolding Safety Program.
Trenching and Injury to employee and property Establish a Trenching and Excavation
Excavation Operations damage from unsafe trenches and Safety Program, and a confined space
excavations. permits and use of Excavation Permits per
Cal/OSHA.
Use of Cranes or Equipment and property damage Implementation of Crane Permits per
Derricks from falling loads and injuries to Cal/OSHA requirements and establishing a
construction workers. Hoisting and Rigging Safety Program.
Plant Systems, Injury to Employee and property Establish procedures to control energy
Maintenance, and damage from various contacts with sources (e.g., Lockout/Tagout Program,
General Construction hazardous energy sources (e.g., Hot Work Permits, and Cold Work Permits).
Activities heat sources, electrical, tools, and
mechanical equipment).
Working with Flammable Danger of fire or explosions and Establish Flammable and Combustible
and Combustible Liquids damage to property and injury to Liquid Storage and a Chemical Handling
personnel. Program.
Implement Fire Prevention and Protection
Program.
Implement Proper Housekeeping Policy
and Program.

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 5.18 Worker Safety

Table 5.18-7 Project Hazard Analysis (Construction and Operations Phases)

Activity Hazard Control

Working with Toxic Toxic material, maybe fatal if Establish Chemical Handling Program,
Chemicals (e.g., inhaled, ingested, or absorbed including storage.
Aqueous Ammonia) through skin.
Establish a RMP and OCA in the event of a
release.
Establish a Hazard Communication
Program
Cutting and Welding Injury to employee and property Establish a Respiratory Protection
(Hot Work) damage from fire. Program, Hot Work Program, Industrial
Hygiene Monitoring Program, and a
Employee exposure to toxic fumes
Housekeeping Policy.
during cutting and welding
operations.
Eye injury due to exposure to
ultraviolet and infrared radiation
during cutting and welding.
Working on or with Injury to employee and equipment Implement an Electrical Safety Program,
Electrical Equipment and from flashovers and contact with Personal Protective Equipment Program,
Systems electricity. Hazardous Energy Control,
Lockout/Tagout) Program, etc.
Construction Assembly, Injury to employee from hand and Implement Hand and Portable Power Tool
Repair, and/or portable power tools. Safety Program, Personal Protective
Maintenance Activities Equipment Program, and Tool Inspection
Program.
Aggress and Egress Injury to employee and property Establishing a Housekeeping Policy and
Issues damage from inadequate walking Program.
and work surfaces areas.
Hearing Loss Injury to employee from Implement a Hearing Conservation
overexposure or inadequate ear Program and a Personal Protective
protection. Equipment Program.
Lifting Heavy Objects Injury to employee from improper Establish a Safe Lifting Program and
carrying or lifting and of materials Personal Protection Equipment Program for
and equipment. adequate material handling.
Driving Small Vehicle Collisions between equipment, Establish a Safe Driving Program.
injury to operators and construction
workers, and damage to
construction and operation
equipment.
Exposure to Hazardous Injury to employee exposure or Establish a Hazardous Substances
Gases, Vapors, Dust, overexposure to hazardous gases, Program, Respiratory Protection Program,
and Fumes vapors, dusts, and fumes. Personal Protective Equipment Program,
and Industrial Hygiene Exposure Monitoring
Program/Records.

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5.18 Worker Safety

Table 5.18-7 Project Hazard Analysis (Construction and Operations Phases)

Activity Hazard Control

High Pressure Steam/Air Injury to employee and property Install proper relief valves or vents.
Systems Testing, damage from sudden unexpected
Establish Relief Valve Maintenance and
Troubleshooting Repair, release of high pressure steam or
Testing Program.
and Maintenance. air.
Proof testing pressure system components
Hazardous Energy Control, Lockout/Tagout
Program, and Line Breaking Safety
Program.

Construction Injury and Illness Prevention Plan (IIPP)

The written Construction Safety Program will meet the Cal/OSHA IIPP requirements of 8 CCR § 1509 by
inclusion of the following:

 A written Code of Safe Practices that relates to construction operations,

 Posting of the Code of Safe Practices at a conspicuous location at each job site office or providing it to
each supervisor who shall have it readily available,

 Periodic meetings of supervisors and management to discuss past safety incidents and identify and
implement corrective actions, as required,

 A system ensuring employee and subcontractor compliance,

 Procedures for promptly correcting unsafe conditions,

 Identification of the person or persons responsible for implementing the program,

 The system for identifying workplace hazards, including inspections,

 “Tool box” or “tailgate” meetings conducted for employees by supervisors emphasizing safety, and

 Methods of communicating with employees encouraging employees to identify unsafe activities.

When workers are first employed they will be given instructions regarding the hazards and safety
precautions applicable to the type of work in question and directed to read the Code of Safe Practices.
When employees are subject to known job site hazards, they will be instructed to recognize the hazard, to
adopt procedures to protect themselves from injury, and to perform first aid procedures in case of injury.
The Contractor will ensure that all its employees and subcontractor employees are health and safety
qualified (including meeting relevant health and safety training requirements) in their respective work
disciplines and crafts.

Safety Training Program

The Project will develop and implement a Construction Safety Training Program that will be adapted to
serve as an Operations Safety Training Program as the Project transitions from construction into routine
power generation facility operations. As mentioned above for the Project Hazard Analysis and PPE
Program, the elements of the Safety Training Program will be essentially the same for operations as for

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 5.18 Worker Safety

construction, but specifics of the training will be adapted as needed to be suitable for the specific work
activities associated with operations to the extent that the various activities differ between the two phases.
Typical training courses and the employees who are required to receive the training are provided in Table
5.18-8.

Table 5.18-8 Training Programs and Target Employees (Construction and Operation Phases)

Training Course Target Employees

Injury and Illness Prevention Training All employees.
Emergency Action Plan Training All employees.
PPE Training All employees.
Heavy Equipment Safety Training Employees working on, near, or with heavy equipment.
Forklift Operation Training Employees working with forklifts.
Excavation and Trenching Safety Training Employees involved with trenching or excavation
operations.
Fall Protection Training All employees.
Scaffolding and Ladder Safety Training Employees required to erect or use scaffolding and
employees using ladders.
Hoist and Rigging Program Employees and supervisors responsible for conducting
hoists and rigging operations.
Crane Safety Training Employees supervising, crane operators, and employees
involved in crane operations.
Fire Protection and Prevention Training All employees.
Confined Space Entry Program All employees.
Blood Borne Pathogens Training First Responders.
Hazard Communication Training Employees working with or handling hazardous materials.
Electrical Safety Training Employees performing work with electrical systems,
equipment, or electrical extension cords. Additionally,
employees working with lockout/tagout activities.
Hand and Portable Power Tool Safety Training All employees.
Heat Stress and Cold Stress Safety Training All employees.
Hearing Conservation Training All employees.
Back Injury Prevention Training All employees.
Safe Driving Training All employees.
Pressure Vessel and Pipeline Safety Training Employees supervising or working on pressurized vessel,
pipes, or equipment.
Respiratory Protection Training All employees required to wear respiratory protection
equipment.
Hot Work Training All employees working with welding, heating, or other

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5.18 Worker Safety

Table 5.18-8 Training Programs and Target Employees (Construction and Operation Phases)

Training Course Target Employees

equipment that generates ignition sources.

Specific safety program requirements for both construction and operations are identified below.

Develop a Motor Vehicle and Heavy Equipment Safety Program that accomplishes the following:

 Establishes a program for operation and maintenance of Project equipment and vehicles;

 Develops a job site inspection procedure;

 Establishes PPE requirements for job site personnel;

 Determines and establish training and instruction requirements and programs;

 Develops a Forklift Operation Program;

 Defines training and certification requirements for operators based on equipment use;

 Determines fueling and refueling procedures and equipment;

 Establishes safe operating parameters for specific jobs and equipment; and

 Determines and establish training and instruction requirements and programs.

Develop a Forklift Operation Program that accomplishes the following:

 Defines training and certification requirements for operators based on equipment and vehicles;

 Develops a job site inspection procedure;

 Establishes PPE requirements for job site personnel; and

 Determines and establishes training and instruction requirements and programs.

Develop an Excavation and Trenching Program and permit requirements that accomplish the following:

 Establishes shoring, sloping, and benching requirements; and

 Determines job-specific Cal/OSHA permit requirements (e.g., lockout/tagout, confined space, and hot
work).

Develop equipment inspection procedures that accomplish the following:

 Establishes air monitoring requirements and procedures;

 Develops access and egress requirements for job sites;

 Establish calling procedures for the Underground Services Alert program; and

 Determine and establish training and instruction requirements and programs.

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 5.18 Worker Safety

Develop a Fall Protection Program that accomplishes the following:

 Evaluates specific job site of fall hazards;

 Provides requirements for protection device use;

 Determines and establishes training and instruction requirements and programs.

Develop a Scaffolding and Ladder Safety Program that accomplishes the following:

 Establishes construction and inspection requirements for scaffolding erection;

 Determines scaffolding applicability of use and proper use procedures; and

 Determines and establish training and instruction requirements and programs.

Develop an Articulating Boom Platforms Program that accomplishes the following:

 Establishes procedures for inspection of equipment;

 Determines proper load rating of equipment;

 Establishes safe operating parameters of equipment; and

 Determines and establishes training and instruction requirements and programs.

Develop a Crane and Material Handling Program that accomplishes the following:

 Determines certified and licensed requirements for operators;

 Establishes inspection requirements and procedures;

 Determines proper load rates of equipment;

 Establishes safe operating parameters of equipment; and

 Determines and establish training and instruction requirements and programs.

Develop an Employee Exposure Monitoring Program that accomplishes the following:

 Determines and evaluates exposure limitations and requirements for specific job sites (e.g., noise,
chemicals, and dust);

 Establishes monitoring requirements for specific exposures;

 Establishes a medical surveillance program and record keeping requirements;

 Determines and establish training and instruction requirements and programs.

Develop an Electrical Safety Program that accomplishes the following:

 Establishes electrical grounding procedures and requirements;

 Determines lockout/tag-out permitting procedures;

 Determines overhead and underground utilities design and installation requirements;

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5.18 Worker Safety

 Establishes utility clearance requirements;

 Implements electrical equipment inspection procedures; and

 Determines and establishes training and instruction requirements and programs.

Develop a Hand and Portable Power Tool Safety Program that accomplishes the following:

 Evaluates power tools guards and tools proper operation;

 Establishes requirements and procedures for inspecting power tools prior to use; and

 Determines and establish training and instruction requirements and programs.

Develop a Housekeeping and Material Handling and Storage Program that accomplishes the following:

 Determines chemical and other equipment storage requirements;

 Examines walkways and work surfaces for proper clearance and elimination of obstructions;

 Examines equipment handling and storage requirements; and

 Determines and establishes training and instruction requirements and programs.

Develop a Hearing Conservation Program that accomplishes the following:

 Establishes proper hearing protective devices and type to use and

 Determines and establish training and instruction requirements and programs.

Develop a Back Injury Prevention Program that accomplishes the following:

 Determines proper lifting and material handling procedures;

 Provides proper PPE; and

 Determines and establishes training and instruction requirements and programs.

Develop a Hazard Communication Program that accomplishes the following:

 Establishes labeling requirements for chemicals;

 Determines proper storage and handling requirements;

 Makes available Material Safety Data Sheets for chemicals used on site;

 Establishes chemical inventories; and

 Determine and establish training and instruction requirements and programs.

Develop a Respiratory Protection Program that accomplishes the following:

 Determines the appropriate tasks for use of job-specific respiratory equipment;

 Establishes a designated storage area for equipment;

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 5.18 Worker Safety

 Performs a fit test for equipment;

 Establishes medical record keeping requirements;

 Performs proper inspection and repair; and

 Determines and establishes training and instruction requirements and programs.

Develop a Heat and Cold Stress Monitoring and Control Program that accomplishes the following:

 Determines monitoring requirements’

 Develops a process to prevent and control exposures; and

 Determines and establishes training and instruction requirements and programs.

Develop a Pressure Vessel and Pipeline Safety Program that accomplishes the following:

 Implements a pressure line-breaking program;

 Establishes equipment inspection and maintenance procedures;

 Determines blocking, bleeding, and blanking requirements; and

 Determines and establishes training and instruction requirements and programs.

Construction-Personal Protective Devices

Employees will be required to use the required PPE during construction. Required PPE shall be approved
for use and distinctly marked to facilitate identification as required by 8 CCR § 1514. PPE will be used in
accordance with the manufacturer’s instructions. The PPE will be of such design, fit and durability as to
provide adequate protection against the hazards for which they are designed. The type of PPE required for
each job task will be described in the job safety analysis for that task. The use of PPE for site activities
includes, but is not limited to, the items specifically described in Table 5.18-9, and will comply with
Cal/OSHA requirements. When protective insulating equipment is used, it will comply with the Electrical
Safety Codes as required by 8 CCR § 1518. The work atmosphere will be tested per established protocols.
A respiratory protection program complying with 8 CCR § 5144 will be developed that includes respirator
training, fit testing, monitoring, selection, etc., if testing results warrant the need. If monitoring suggests that
the potential exposure to hydrogen sulfide (H2S) exists, an approved supplied-air type respirator may need
to be used during certain activities (e.g., drilling).

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5.18 Worker Safety

Table 5.18-9 Basic Protective Equipment Guide

Body Area Hazards Recommended Action

Eyes/Face Low-velocity flying particles Safety glasses with side shields
High-velocity chips and sparks Impact goggles or safety glasses with full face
shield
Corrosive liquid splash during transfer Splash-proof goggles and face shield
Entering an acid storage system Acid hood
Welding-injurious light rays Welding hood with appropriate eye filter lenses
Head/Ears General wear, overhead rigging, material Hard hat
handling, maintenance, and general
construction operations
Noise exposure Ear plugs or muff
Respiratory Low-hazard inert dusts Dust mask
System Welding fumes Appropriately ventilated area
Low concentration solvent vapors Cartridge-type, positive pressure, full-face
respirator
Acid mists Air line respirator
High-concentration dusts or vapors Self-contained breathing apparatus
Oxygen deficiencies or gases
Hands/ Handling rough or sharp objects Leather gloves
Arms Handling hot objects Insulated gloves
Using solvents Impervious synthetic gloves
Feet/Legs General wear for light handling Safety toe shoes
Handling heavy objects Metatarsal safety shoes
Using brush hooks or scythes Shin guards
Working with corrosive liquids Safety toe boots, full leather, no breather holes
Underground work Safety toe synthetic boots
Work in brush, tall grasses, or other Snake gaiters
vegetation
Trunk/ Hot or corrosive liquids Full body suit made of appropriate materials,
Full Body synthetic apron
Punctures, impact, or cuts Rubber apron for corrosive liquids
Cleanup of broken acid containers. Canvas or leather kickback apron or metal mesh
apron
Full body suit made of appropriate materials
Fall Working from elevated structure of platform Safety harness, arrestor, and lanyard
Protection/ w/o standard railings Harness and lifeline or wristlets and lifeline
Rescue Vessel entry Lifeline, safety harness/lanyard
Suspended scaffolds Boom lift platform with cage

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 5.18 Worker Safety

Construction - Onsite Fire Suppression and Prevention

The Project will rely on both onsite fire protection systems and local fire protection services. The contractor
will develop a Fire Protection and Prevention Plan to be followed throughout all phases of construction and
provide the necessary fire-fighting equipment.

During construction, the permanent facility fire suppression systems will be placed in service as early as
practicable. Construction fire prevention regulations in 8 CCR §§ 1920 et seq. will be followed as necessary
to prevent construction fires. Special attention will be given to operations involving open flames, such as
welding, and the use of flammable materials, and to the hazards created by the potential existence of H2S.
Personnel involved in such operations will have appropriate training by the contractor. A fire watch, using
the appropriate class of extinguishers or other equipment, will be maintained during hazardous or hot work
operations as required. Site personnel will not be expected to fight fires past the incipient stage. As
necessary, the fire protective measures shall be coordinated with the local fire protection services.

Materials brought on site must conform to contract requirements, insofar as flame resistance or fireproof
characteristics are concerned. Specific materials in this category include fuels, paints, solvents, plastic
materials, lumber, paper, boxes, and crating materials. Specific attention will be given to compressed gas,
fuel, solvent, and paint storage. Electrical wiring and equipment located in inside storage rooms used for
Class I liquids will be stored in accordance with Electrical Safety Orders and as prescribed by 8 CCR §
5530. Outside storage areas will be designed to divert possible spills away from buildings and will be kept
clear of vegetation and other combustible materials. Precautions will be taken to protect storage areas
against tampering where necessary.

Elements of the onsite fire suppression system during construction will consist of portable and fixed fire-
fighting equipment. Portable fire fighting equipment will consist of fire extinguishers and small hose lines
that conform to Cal/OSHA and the NFPA. The contractor’s safety representative will conduct periodic fire
prevention inspections.

Fire extinguishers will be inspected routinely and replaced immediately if defective or in need of recharge as
required by 8 CCR § 6151. All fire-fighting equipment will be located to allow for unobstructed access to the
equipment and will be conspicuously marked. A temporary or permanent water supply, of sufficient volume,
duration and pressure to operate the required firefighting equipment, will be provided as combustible
materials accumulate. Designated, approved flammable materials storage areas and flammable materials
storage containers will be provided with adequate fire prevention systems.

Construction - Offsite Fire Suppression Support

Backup support to the onsite fire suppression systems will be provided by the Calipatria City Fire
Department (the Imperial County Fire Department has jurisdiction over the site and vicinity but contracts
with the Calipatria City Fire Department to provide fire response services to the Project area). The local fire
response units will be provided with information regarding the type and location of potential fire hazards.
This information will be included in emergency response planning. Routine fire prevention inspections and
annual Structure Response Drills will be conducted by the Calipatria City Fire Department.

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5.18 Worker Safety

Drilling and Construction of Wells

Because of the potential of H2S and geothermal steam exposure during the drilling and construction of
geothermal wells, the Project will develop and implement a plan to minimize risks from these hazards as
guided by the State of California, Division of Oil, Gas and Geothermal Resources, Publication No. M10
(“Drilling and Operating Oil, Gas, and Geothermal Wells in an H2S Environment”). These plans will be
coordinated with local emergency service providers and may include provisions related to hazard detection
and monitoring, fire prevention, site control, emergency response, and specialized equipment and techniques.

The Project’s non-condensable gas (NCG) stream is expected to contain benzene, which indicates a
possibility that worker exposure to benzene could occur during well installation and development.
Therefore, monitoring will be conducted to determine whether benzene exposure is within the Cal/OSHA
exposure limits. If monitoring results suggest possible exposures higher than the Cal/OSHA limits, a
program to minimize exposures will be implemented in conformance with 8 CCR § 5218.

5.18.4.2 Operation

As noted earlier, the workplace health and safety programs for Project operation will be based on existing
well-established programs at existing geothermal facilities in the Project vicinity operated by the Applicant,
and will also be similar in many ways to those developed for Project construction activities. Many of the
construction programs and plans will be revised so they are appropriate for routine operational activities,
and the Project health and safety programs will transition from the construction phase into the operation
phase as the overall Project makes the transition between phases. The discussions presented earlier for
the Project construction phase concerning the Project’s Hazard Analysis and IIPP apply to Project operation
as well and are not repeated in this subsection.

Plant Operation Safety Programs

Employee safety programs will be implemented for the operational phase of the Project. These programs
will include:

 Regular employee education and training in safe work practices for general and specific task areas;

 Accident and incident evaluations;

 Emergency response;

 Contractor and visitor safety;

 Maintenance of safety performance data;

 Communication of hazards in accordance with Federal and State standards;

 Administrative safety procedures;

 Fire prevention and fire response; and

 Security.

Operations personnel will be provided with written safety guidance. Construction safety programs and
procedures applying to facility operations will be incorporated into the plant operational safety program.

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 5.18 Worker Safety

Fire Protection and Prevention Program

Fire protection will include measures relating to safeguarding human life, preventing personnel injury,
preservation of property, and minimizing downtime because of fire or explosion (National Safety Council,
1992). These measures shall be described in a Fire Prevention Plan as required by 8 CCR § 3221. It will
principally involve physical arrangements, such as sprinkler systems, firewater pump, water supplies, and
fire extinguishers. Fire protection measures will include fire prevention measures to prevent the inception of
fires. Of concern are adequate exits, fire-safe construction, reduction of ignition sources, and control of fuel
sources.

The facility will become the fire protection responsibility of the Imperial County Fire Department (however,
Imperial County contracts fire department response services in the Project area to the Calipatria City Fire
Department). The fire suppression systems will be subject to review and approval by the Imperial County
Fire Department, which will have final approval responsibility. Additionally, facilities will be designed by a
California-registered Fire Protection Engineer and fire protection equipment will be installed and maintained
in accordance with applicable NFPA standards and recommendations (NFPA, 1994).

The Imperial County Fire Department will have the responsibility to perform the final inspection of the facility
when construction is complete and periodic fire and life safety inspections thereafter, including reviewing
and approving programs for regular equipment inspections and servicing and for the training of employees
in fire protection procedures. Additionally, the project’s insurance carrier will provide annual inspections by
a fire protection specialist. A licensed contractor will conduct servicing of the fixed CO2 or dry chemical
systems.

The comprehensive onsite fire protection system and procedures will be designed and implemented to
protect both personnel and property. A Program Fire Protection Station Order will be developed to address:

 Names and/or job titles of those responsible for maintaining equipment and control of accumulation of
flammable or combustible material;

 Fire fighting demonstrations;

 Housekeeping practices;

 Training;

 Procedures in case of fire;

 Fire alarm and protection equipment;

 System and equipment maintenance;

 Monthly inspections; and

 Annual inspections.

Fire Protection System

The following fire suppression systems are proposed:

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5.18 Worker Safety

 Carbon Dioxide Extinguishers. A carbon dioxide extinguisher system will be provided for the turbine
area, as necessary for specific hazards. Fixed carbon dioxide systems will be employed for sealed
engineering spaces and packages. The fixed systems will be augmented by handcart extinguishers.

 Fire Hydrants/Hose Stations. This system will supplement the plant fire protection system. Water will
be supplied from the Imperial Irrigation District (IID) canal water system. These will be located
consistent with fire design code requirements and with 75-foot hoses.

 Sprinkler System. An automatic sprinkler system will provide protection to the turbine generator and
auxiliary equipment areas; an automatic spray system will provide protection for the main step-up
transformer; and automatic sprinklers will protect other administration areas.

 Smoke Detectors, Combustible Gas Detectors, and Fire Extinguishers. These will be provided at all
locations having potential fire hazards because of the presence of combustible liquids, solids, or other
highly flammable materials, and where major property damage could result. Detection system and fire
alarm pull stations will be provided in the Control Room and other appropriate areas in accordance with
NFPA 72. Extinguishers will be located consistent with the CBC at approved intervals throughout the
facility as directed by the local fire inspector and selected for the appropriate class of service.

Water will be used as the primary extinguishing agent. The IID water system will be the primary supply of
water to the fire suppression systems, with a firewater tank reserve capacity of 300,000 gallons. Chemical
and gas extinguishing agents (permanently installed or in portable extinguishers) will be provided in special
hazard areas where water would be ineffective or harmful to the equipment being protected.

Chemical Handling System

As described in Section 5.6 Hazardous Materials, there will be a variety of chemicals stored and used during
construction and operation of the Project. The storage and handling of chemicals will follow applicable
LORS to minimize risk to workers. Chemicals will be identified and stored in appropriate chemical storage
facilities. Bulk chemicals will be stored in aboveground storage tanks; other chemicals will be stored in their
delivery containers. Chemical storage and chemical feed areas will be surrounded by permanent
containment or curbing to contain leaks and spills. The containment areas will be sized to hold an
appropriate volume in consideration of the potential for the local hazard contingencies (e.g., 100 percent of
the largest container plus an allowance for precipitation from a 25-year, 24-hour storm), as designated by a
California-registered Professional Engineer.

Safety showers and eyewash stations will be provided in or adjacent to chemical storage and use areas,
including the hydrochloric acid solution storage area, in accordance with 8 CCR § 5162 requirements.
Typical safety gear for chemical exposure will be provided in a readily available location for use during minor
chemical spill containment and cleanup activities by plant personnel. Adequate supplies of absorbent
material and neutralizing agents will be stored on site for minor spill cleanup. A hazardous material
emergency response team, trained in the containment control and clean-up of accidental chemical releases,
will be available through contract. Emergency contact numbers will be available to summon assistance from
these contractors and for notification of local agencies. These procedures will be detailed in the plant
operations manual prior to commencement of operations.

The primary chemical exposure concerns are anticipated to be H2S that naturally exists in the geothermal
brine, inorganic arsenic that can potentially build up in the scale created from the steam, hydrochloric acid,

February 2009 5.18-24 Amended SSU6 Project

 5.18 Worker Safety

and sodium hydroxide used in the brine handling. Although ammonia is known to be present in the
geothermal brine, the concentration will not be high enough in any process stream (i.e., brine, condensate,
NCG) to expose a worker to airborne concentrations exceeding OSHA or National Institute of Occupational
Safety and Health (NIOSH) exposure thresholds.

The RTO abatement system for treatment of H2S in the NCG and the ChemOx system proposed for H2S
treatment in the condensate will minimize the risk of worker exposure to H2S emissions from routine
operations. During commissioning and startup, and during outages and upset conditions, steam may be
routed through the steam vent tank system. The steam vent tank would release H2S to the atmosphere
without control. Although emissions of H2S are anticipated to be higher when routed through the steam vent
tank (versus through the turbine and control system), the concentrations at the worker level are expected to
be below applicable worker exposure standards including the Immediately Dangerous to Life and Health
limit of 100 parts per million (ppm) and NIOSH Ceiling Limit of 10 ppm. H2S sensors placed in the area of
the steam vent tank will be used to identify any exceedances of these standards. Procedures addressing
employee exposure, response and evacuation will be included in the Emergency Action Plan (see following
subsection).

Potential exposures to trace amounts of toxic metals and other elements will be most likely during outages
and other maintenance and repair activities that require exposing surfaces that have been subjected to
steam; similarly H2S exposure potential also could exist during outages and other maintenance and repair
activities that involve exposing surfaces exposed to steam. PPE will be employed to minimize worker
exposure. In addition, worker monitoring will be used to establish the exposure levels and, if necessary, the
applicant will institute additional mitigation measures to protect the workers pursuant to 8 CCR § 5214.

A chemical spill response team shall be established to handle immediate responses to accidental chemical
releases (e.g., leakage of hydrochloric acid or sodium hydroxide). This team will be qualified and trained in
compliance with 8 CCR 5192, Hazardous Waste Operations and Emergency Response.

Emergency Action Plan

In addition to the incorporation of various safety and environmental features and design measures to
minimize emergencies and their effects on public and worker safety, the Project will have a site specific
Emergency Action Plan. A sample Emergency Action Plan outline is provided in Table 5.18-10. The
Emergency Action Plan addresses potential emergencies, including chemical releases, fires, bomb threats,
pressure vessel ruptures, and other catastrophic events. It describes evacuation routes, alarm systems,
points of contact, assembly areas, responsibilities, and other actions to be taken in case of an emergency.
The plan has a layout map, a fire extinguisher list, and describes arrangements with local emergency
response agencies for responding to emergencies. The Emergency Action Plan will be used in conjunction
with the IIPP.

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 5.18 Worker Safety

Table 5.18-10 Sample Emergency Action Plan Outline

3.0 Response and Notification Plan

1.0 Introduction 2.0 Responsibilities
(Points of Contact)
1.1 Purpose 2.1 Incident Command System 3.1 Supervisor/Emergency Coordinator
1.2 Scope Emergency Response Coordinator 3.2 Health and Safety Manager
Emergency Evacuation Coordinator
Safety Coordinator and Alternates
2.2 Position Description Assignments
Construction/Facility Manager
Construction/Facility Supervisor
Operators
Health and Safety Manager Security
4.0 Response Procedures 5.0 Reference Procedures
4.1 Evacuation Routes and Procedures 5.1 Evacuation Plan
4.2 Accidents Involving Serious Injury and/or Death 5.2 Emergency Equipment Locations
4.3 Fire 5.3 Fire Extinguisher Locations
4.4 Hazardous Waste or Chemical Releases 5.4 Security
4.5 Earthquake 5.5 Accident Reporting and Investigation
4.6 Bomb Threat 5.6 Lockout/Tagout
4.7 Emergency Plant Shutdown 5.7 Hazard Communication
4.8 Site Security 5.8 Spill Containment and Reporting
4.9 Emergency Medical Treatment and First Aid 5.9 First Aid and Medical Response
4.10 Decontamination 5.10 Respiratory Protection
4.11 Documentation and Recordkeeping 5.11 Personal Protective Equipment
4.12 News Media 5.12 Sanitation
4.13 Emergency Notification List 5.13 Work Site Inspections
4.14 Emergency Telephone Numbers List

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 5.18 Worker Safety

5.18.4.3 Cumulative Impacts

Each individual project (the Amended Project as well as other projects in the vicinity), would be separately
responsible for complying with applicable worker safety requirements. Thus, no cumulative impacts on
worker safety are expected as a result of the Amended Project.

5.18.5 Mitigation Measures

Worker safety mitigation measures are embodied in the CEC’s existing Conditions of Certification (COC) for
the original project. The Applicant considers these COCs to be suitable for the Amended Project without
change, as shown in the following section.

5.18.6 Conditions of Certification

Following are the applicable Conditions of Certification (COC) from the Commission Decision on the original
SSU6 project. The Applicant proposes no changes to these COCs.

Worker Safety-1 The project owner shall submit to the CPM a copy of the Project Construction Injury
and Illness Prevention Plan, containing the following:

 A Construction Safety Program;

 A Construction Personal Protective Equipment Program;

 A Construction Exposure Monitoring Plan;

 A Construction Emergency action Plan; and

 A Construction Fire Protection and Prevention Plan.

The Safety Program, the Personal Protective Equipment Program, and the Exposure Monitoring Program
shall be submitted to the CPM for review and comment concerning compliance of the program with all
applicable Safety Orders. The Construction Fire Protection and Prevention Plan and Emergency Action
Plan shall be submitted to the Imperial County Fire Department for review and comment prior to submittal
to the CPM.

Verification: At least 30 days prior to site mobilization, the project owner shall submit to the CPM for
review and approval a copy of the Project Construction Injury and Illness Prevention Program. The project
owner shall provide a letter from the Imperial County Fire department stating that they have reviewed and
commented on the Construction Fire Protection and Prevention Plan Emergency Action Plan.

Worker Safety-2 The project owner shall submit to the CPM a copy of the Project Operations and
Maintenance Safety and Health Program containing the following:

 An Operation Injury and Illness Prevention Plan;

 An Emergency Action Plan;

 Hazardous Materials Management Program;

 Operations and Maintenance Safety Program;

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 5.18 Worker Safety

 Fire Protection and Prevention Program (Cal Code Regs., tit. 8, § 3221); and;

 Personal Protective Equipment Program (Cal Code Regs., tit. 8, § 3401-3411).

The Operation Injury and Illness Prevention Plan, Emergency Action Plan, and Personal Protective
Equipment Program shall be submitted by the project owner to the Cal/OSHA Consultation Service, for
review and commenting concerning compliance of the program with all applicable Safety Orders. The
Operation Fire Protection Plan and the Emergency Action Plan shall also be submitted by the project owner
to the City of Calipatria Fire Department for review and acceptance.

Verification: At least 30 days prior to the start of operation, the project owner shall submit to the CPM a
copy of the final version of the Project Operations and Maintenance Safety & Health Program. It shall
incorporate Cal/OSHA Consultation Service’s comments, stating that they have reviewed and accepted the
specified elements of the proposed Operations and Maintenance Safety and Health Plan.

5.18.7 References

Captain Chris Hall. Calipatria City Fire Department, 175 North Park Avenue, Calipatria, California 92233,
(760)-348-4144. Personal communication with J. Westrum, AECOM, October 7, 2008.

California, State of, Division of Occupational Safety and Health. Requirements for: Permits, Registrations,
Certifications and Notifications. Director of Industrial Relations, December 2001.

Dosch, M.W., and Hodgson, S.F. Drilling and Operating Oil, Gas, and Geothermal Wells in an H2S
Environment. State of California, Division of Oil, Gas, and Geothermal Resources, Publication No. M10,
Sacramento, 1997.

Fire Chief Tony Rouhotas. Imperial County Fire Department, Fire Prevention, 2514 La Brucherie Road,
Imperial, CA 92251 (760-482-2420). Personal communication with S. Hsia, ENSR, October 10, 2008.

National Fire Protection Association (NFPA), 1994. A Compilation of NFPA Codes, Standards,
Recommended Practices and Guides. Quincy, Massachusetts.

National Safety Council. 1992. Accident Prevention Manual. Volume 2, Chapter 6, Fire Protection

Title 8, California Code of Regulations, Division 1, Chapter 4, Subchapter 1 Unfired Pressure Vessel Safety
Orders.

Title 8, California Code of Regulations, Division 1, Chapter 4, Subchapter 4. Construction Safety Orders.

Title 8, California Code of Regulations, Division 1, Chapter 4, Subchapter 5. Electrical Safety Orders.

Title 8, California Code of Regulations, Division 1, Chapter 4, Subchapter 6. Elevator Safety Orders.

Title 8, California Code of Regulations, Division 1, Chapter 4, Subchapter 7. General Industry Safety
Orders.

February 2009 5.18-28 Amended SSU6 Project