City of Groves Water Treatment Plant - Executive Summary |
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The City of Groves (herein referred to as the City) owns and operates a municipal water treatment facility in Groves, Jefferson 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 basis of the general duty clause is that an owner/ operator that stores and/or 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. 2. Risk Management Plan - The City operates a water treatment facility that stores and uses chlorine in excess of thresholds specified in the RMP Rule. The purpose of the chlorine water treatment process at the water plant is to treat and disinfect potable water. Chlorine is delivered as compressed gas in one ton cylinders, and there are typically three to four cylinders stored at the water treatment plant at one time. For Risk Management Planning purposes, the City has considered a very conservative (i.e., "worst case") impact of a sudden release of the entire contents of one cylinder within a ten-minute period. Conservative assumptions about possible weather conditions and a predictive model indicate a potential radius of impact of the chemical 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 is going to implement an active monitoring and alarm system that will detect a release and engage a local alarm at the water treatment plant site. The City has coordinated with local emergency personnel, including the Groves Fire Department, and has trained its own staff to respond to emergencies. The City Management is committed to: * Preventing accidents; * Training our employees in correct response procedures in the event of an accident ; * Addressing any citizen concerns by fully explaining potential hazards associated with facility operations; * Taking the necessary steps to prevent and mitigate accidents; and * Being a good corporate citizen of Jefferson County. With these objectives in mind, this Risk Management Plan provides information about the City's management of the risk associated with the chlorine water treatment process, but more importantly s tresses the commitment to ensuring a safe operation for employees, visitors, and community. |