Lakeway MUD - Wastewater Treatment Plant S-4 - Executive Summary
Lakeway Municipal Utility District (Lakeway MUD) owns and operates municipal water and wastewater treatment facilities in the City of Lakeway, Travis County, Texas. Lakeway MUD 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, Lakeway MUD notes that there are two obligations incumbent on the operations at its facilities: |
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. Lakeway MUD 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 - Lakeway MUD operates a reclaimed water storage pond (Facility
I-4) that stores and uses chlorine in excess of thresholds specified in the RMP Rule. Additionally, Lakeway MUD operates a wastewater treatment plant (Facility S-4) and a water treatment facility (Facility W-3) that stores and uses chlorine in excess of the RMP Rule thresholds. Even prior to the promulgation of the RMP Rule, Lakeway MUD management has been very aware of the potential hazards posed by storage and use of chlorine, 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 chlorine water treatment process is to treat and disinfect water for municipal use. Chlorine is delivered as a compressed gas in 150-pound cylinders or in one-ton cylinders. There are typically two one-ton cylinders at the reclaimed water storage pond (I-4), six one-ton cylinders at the water treatment plant (W-3), and twelve 150-pound cylinde
rs at the wastewater treatment plant (S-4) at any one time. For planning purposes, Lakeway MUD has considered the impact of a sudden release of the entire contents of one cylinder at each facility within a ten-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 for Facilities I-4 and W-3 and extending to 0.4 miles for Facility S-4. A consideration of these radii has been incorporated into our notification and emergency response planning.
We also considered the impact of a more likely release, based on our 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 or less, i.e. having potentially few off-site impacts.
Lakeway MUD has implemented safety precautions to prevent and mitigate any chlo
rine release. In addition to maintenance, training, and inspection procedures, Lakeway MUD 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/or autodialer, which will continue attempting to notify someone of the situation until successful. Lakeway MUD has extensively coordinated with local emergency responders including The Hudson Bend Fire Department.
Lakeway MUD 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 Travis County.
With these objectives in mind, this Risk Management Plan provides information about our
management of the risks associated with the chlorine water treatment process, but more importantly we stress our commitment to ensuring a safe operation for our employees, our visitors, and our community.