City of Rosenberg - WWTP 2 - Executive Summary
City of Rosenberg (herein referred to as the City) owns and operates two municipal wastewater treatment plants (WWTPs) in Rosenberg, Fort Bend County, Texas. The City 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, the City 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. The City 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 - The City operates two WWTPs that store and use chlorine in excess of threshol
ds specified in the RMP Rule. Even prior to the promulgation of the RMP Rule, the City 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 municipal wastewater. Chlorine is delivered as a compressed gas in one-ton cylinders, and there are typically two cylinders stored at each WWTP at any one time. For planning purposes, the City has considered the impact of a sudden release of the entire contents of one cylinder 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 3.0 miles. A consideration of this radius has been incorporate
d into our notification and emergency response planning.
The City 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 (i.e. having potentially few off-site impacts).
The City has implemented safety precautions to prevent and mitigate any chlorine release. In addition to maintenance, training, and inspection procedures, the City will be installing an active monitoring and alarm system that will detect a release and sound a local alarm. The City has coordinated with local emergency responders, including The Rosenberg Fire Department.
The City 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;
ressing 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 Fort Bend County.
With these objectives in mind, this Risk Management Plan provides information about the City's management of the risks associated with the chlorine disinfection process, but more importantly stresses the commitment to ensuring a safe operation for employees, visitors, and community.