City of Kerrville WWTP - Executive Summary |
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The City of Kerrville (herein referred to as the City) owns and operates a municipal wastewater treatment facility in Kerrville, Kerr 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 facility: 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 a wastewater treatment facility that stores and uses chlorine in exces s of thresholds specified in the RMP Rule. Additionally, the City operates a water treatment plant that stores and uses chlorine in excess of the RMP Rule thresholds. The purpose of the chlorine water treatment process at the wastewater treatment plant is to treat and disinfect municipal wastewater. Chlorine delivered as a compressed gas in one-ton cylinders, and there are typically two to three cylinders stored at the wastewater treatment plant at any one time. For planning purposes, the City has considered the impact of a sudden release of the entire contents of one cylinder of chlorine 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 for a chlorine release extending to 1.3 miles. A consideration of this radius has been incorporated 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 has an active monitoring and alarm system that will detect a release and engage a local alarm at each site. The City has coordinated with local emergency personnel, including The Kerrville Fire Department, and has trained its own staff to respond to emergencies. 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; 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 Kerr County. With these objectives in mind, this Risk Management Plan provides information about the City's management of the risks associated with the chlorine water treatment process, but more importantly stresses the commitment to ensuring a safe operation for employees, visitors, and community. |