San Jacinto River Authority - Water Plant 2 - Executive Summary |
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The San Jacinto River Authority (SJRA) owns and operates three municipal water treatment plants and one municipal wastewater treatment plant in The Woodlands, Montgomery County, Texas. Each of the water treatment plants uses chlorination to treat and disinfect groundwater. The wastewater treatment plant uses both chlorine and sulfur dioxide to disinfect treated effluent wastewater. SJRA has reviewed its obligations under EPA's Risk Management Program Rule (RMP Rule, Section 112(r) of the Clean Air Act). In response to these requirements, SJRA notes that there are two obligations incumbent on the operations at its facility: 1. '112(r)(1) - Purpose and General Duty Clause - The essence of the general duty clause is that an owner/operator that stores and uses hazardous chemicals in any quantity has a fundamental obligation to ensure a safe operation, and to have plans in place in the event of an accident to appropriately manage the situation. SJRA takes this obligation very seriously , and intends to be not only a good neighbor but also a leader in community safety and emergency preparedness. 2. Risk Management Plan - SJRA operates three water treatment facilities that store and use chlorine in excess of thresholds specified in the RMP Rule. Additionally, SJRA operates a wastewater treatment plant that stores and uses both chlorine and sulfur dioxide in excess of the RMP Rule thresholds. Even prior to the promulgation of the RMP Rule, SJRA management has been very aware of the potential hazards posed by storage and use of chlorine and sulfur dioxide, and has established programs to prevent any accidental releases and training for emergency response in the event of a release. These programs are documented and described in this Risk Management Plan. The purpose of the chlorination process at each facility is to disinfect both groundwater and effluent treated wastewater. The purpose of the sulfur dioxide treatment process at the wastewater treatment facility is to remove any chlorine residual prior to discharge into natural waterways. Each process chemical is delivered as a compressed gas in one-ton cylinders, and there are typically three to six cylinders at each plant at any one time. For planning purposes, SJRA has considered the impact of a sudden release of the entire contents of one cylinder within a 10-minute period of time. Very conservative (i.e., "worst case") assumptions about possible weather conditions and a predictive model indicate a potential radius of impact extending to 1.3 miles. A consideration of this radius has been incorporated into our notification and emergency response planning. SJRA also considered the impact of a more likely release, based on operational history and most likely hazard analysis. This analysis suggest that the largest release of chlorine that could realistically be experienced by the facility results in a radius of impact of 0.1 miles (i.e., having potentially few off-site impacts). SJRA has impl emented safety precautions to prevent and mitigate any chlorine release. In addition to maintenance, training, and inspection procedures, SJRA has an active monitoring and alarm system that will detect a release and sound a local alarm and send an alarm notification to the control room and autodialer, which will continue attempting to notify SJRA personnel of the situation until successful. SJRA has extensively coordinated with local emergency responders including The Woodlands Fire Department. SJRA management is committed to: 7 Preventing accidents; 7 Training our employees in correct response procedures in the event of an accident; 7 Providing leadership to the community with respect to emergency preparedness; 7 Addressing any citizen concerns by fully explaining potential hazards associated with facility operations and all steps being taken to prevent and mitigate accidents; and 7 Being a good corporate citizen of Montgomery County. With these objectives in mind, this Risk Manage ment Plan provides information about the management of the risks associated with the chlorination and sulfonation process, but more importantly stresses a commitment to ensuring a safe operation for employees, visitors, and the surrounding community. |