City of Victoria Water Plant 4 - Executive Summary

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Executive Summary 
It is the policy of the City of Victoria, Texas, to operate safe water and wastewater treatment facilities, reducing to the greatest extent possible any hazards associated with our processes, and reducing any subsequent risk to the surrounding community, our employees, and the environment. It is also our policy to work with the surrounding community and local emergency response agencies, and promote a spirit of cooperation and teamwork, to orchestrate an effective contingency plan in the unlikely event that a process incident occurs at one of our plants. 
Primary Activity 
The primary activity at the Victoria Water Plant 4 is municipal drinking water treatment. 
Use of Regulated Substances 
Chlorine is used primarily as a disinfectant and protectant for water introduced into the drinking water supply. 
Quantities Handled or Stored 
Chlorine: 8,000 pounds 
Worst-Case Release Scenario 
The EPA-defined worst case scenario is a failure of a 2,000-pound container full of chlorine. 
The 10-minute release is mitigated by a factor of 0.55 because a building encloses the process.  This is the equivalent of 1,100 pounds of chlorine being released. Under worst case weather, chlorine could travel 1.55 miles before dispersing enough to no longer pose a hazard to the public. 
Alternative Release Scenarios (ARS) 
A more conceivable release, although still remote, is a failure of a flexible connection at the ton container. The release would be mitigated by an enclosure, resulting in a release rate of 5.8 pounds per minute and a distance from the Plant of 0.26 miles.  This is about the most realistic release that would ever be expected to occur.  However, the plant policy is to replace the flexible connections at prescribed intervals. 
Accidental Release Prevention Program and Chemical-Specific Prevention Steps 
The Victoria Water Plant 4 is in compliance with the RMP Rule, 40 CFR 68. Plant and City personnel have conducted a comprehensive review of all systems, as well as admi 
nistrative, technical, operating and maintenance procedures, in addition to the other required program elements of the Rule. As a result of a Hazard Review at this plant, recommendations were developed to install or upgrade some safety items.  
Five Year Accident History 
The Water Plant 4 has never had a significant release of a hazardous substance as defined by this Rule. 
Emergency Response Program 
This Plant has an Emergency Response Program that is coordinated with the community plan. 
Planned Changes to Improve Safety 
The following recommendations, among others, were made as a result of the Water Plant 4 RMP. Some of the recommendations are currently being implemented. Others are being prioritized and budgeted accordingly. 
' We are upgrading Plant 4 to include leak detection and alarms  
' We have updated our operating and maintenance (O&M) procedures, and have elaborated on procedures more prone to human error. 
' We will require each operator to be trained on the plant's  O&M. 
' We w 
ill endeavor to develop and implement a chlorine supplier audit program.  For example, do they have emergency container repair kits? Do they maintain their equipment?  What is their pre-shipment inspection procedure? 
' We have developed an Emergency Response Program in coordination with the City of Victoria Fire Department
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