NBU Surface Water Treatment Plant - Executive Summary

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Management of New Braunfels Utilities recognizes a responsibility for the safety of employees and the community.  The aim of management is to provide working conditions and facilities which will help to ensure the health and safety of all employees and the general public.  Management believes that organizational safety is an integral part of an efficient operation.  It is, therefore, a policy of NBU to initiate and apply every practical method of incorporating safety and accident prevention into its processes, equipment and facilities;  to select productive and qualified employees who are willing to preform their jobs with due regard to safety, to train each employee in safe work practices, to provide necessary personal protective equipment to minimize existing job hazards, to consistently enforce established safety rules and safe practices and to actively promote safety and accident prevention. 
NBU is responsible for both potable water and wastewater treatment in a certified service  
area in the general vicinity of the city limits of New Braunfels.  NBU operates one surface water treatment plant and six wells for potable water and three wastewater treatment plants for the processing of sewage.  Currently, chlorine contained in one ton cylinders is used for disinfectant in water treatment.  Chlorine dissolved in water forms hypochlorus acid, which partially dissociates to form hypochlorite ions.  Hypochlorus acid or free chlorine is very effective in destroying bacteria, viruses, and Giardia cysts.   
The worst case release scenario assumes a complete rupture of a one ton cylinder of chlorine.  According to the EPA Guidance manuals, a release of this nature would have offsite impact up to 1.3 miles from the release point.  EPA has stated that the distance to an endpoint estimated under worst case conditions should not be considered a zone in which the public would be in danger;  instead the distance is intended to provide an estimate of the maximum possible area t 
hat might be affected under extreme, unlikely, catastrophic conditions.  In general, the risk of the worst case scenario is very low.  Although catastrophic vessel failures have occurred, they are very rare events.  Combing them with worst case weather conditions makes the overall scenario even less likely.  This does not mean that such events cant or wont happen, but they are very unlikely to happen. 
The alternative release scenario assumes a break in the one inch piping that connects the cylinder to the treatment process.  According to the EPA Guidance manuals, a release of this nature would have offsite impact up to 0.7 miles from the release point for chlorine.  The possibility of harm from this type of release depends on the concentration of the chemical you are exposed to and the length of time you are exposed.  If the wind speed is even moderate, the chemicals will disperse and lower the level of concentration.  If the release is stopped quickly the exposure would be for a ve 
ry short time period.  The released chemicals will move in the direction of the wind.  Only people in a small fraction of the circle around the release site would be exposed. 
NBU complies with the rules and regulations of the Environmental Protection Agency and the Texas Natural Resource Conservation Commission as they apply to the operation of water treatment facilities.  Inspections are performed by these agencies at least annually.  All of our workers are trained on proper operating and maintenance procedures as part of their certification requirements. 
NBU has had no accidental releases of chlorine in the past five years. 
NBU is included in the community emergency response plan developed under the Emergency Planning and Right-To-Know Act (EPCRA).  We have coordinated response action plans with the City of New Braunfels Fire Department and the chemical supplier.  NBU also has appropriate mechanisms in place to notify emergency responders when there is a need for a response.
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