Seguin Water Plant - Executive Summary

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The City of Seguin owns and operates a surface water treatment plant in Guadalupe County, Texas.  The City of Seguin is aware of its obligations under section 112(r) of the Clean Air Act.  The City of Seguin notes that there are two obligations that are required of the Seguin Water Treatment Plant. 
 
112(r)(1)- Purpose and General Duty Clause: 
The substance of the general duty clause is that the owner/operator that stores and uses hazardous chemicals in any quantity has an obligation to ensure safe operatioon and to have a plan in the event of an accident.  The City of Seguin Water Treatment Plant has developed plans to prevent and implement steps to respond to an emergency situation. 
 
Risk Management Plan: 
The Seguin Water Treatment Plant has one process that involves a chemical stored in excess of thresholds specified in 112(r), the chlorine in the water treatment process.  The Seguin Water Treatment Plant has been aware of the potential hazards posed by storage and use of chlorine an 
d has established programs to prevent any acccidental releases and training for emergency response in the event of a release. 
 
The purpose of the chlorine in the water treatment process is to treat and disinfect the water in the treatment process.  Chlorine is delivered as a compressed gas and liquified gas in one ton cylinders and there are usually four(4) one ton drums at the plant at one time.  For planning purposes the Seguin Water Treatment Plant has considered the impact of a sudden release of 1500 pounds of chlorine gas within a ten minute period of time. This worst case assumption has a potential  radius of impact of 0.8 miles. 
 
The City of Seguin Water Treatment Plant has implemented safety procedures to prevent and manage any chlorine releases.  Plant personel are trained regularly on proper techniques in handling chlorine, use of safety equipment and safety procedures.  The City of Seguin Water Treatment Plant has coordinated plans with the Seguin Fire Department and the Seg 
uin Police Department.
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