Ingrams Mill Treatment Plant - Executive Summary
Philadelphia Suburban Water Company owns and operates the Ingrams Mill Water Treatment Plant on North Creek Road in West Chester, PA. Philadelphia Suburban Water Company is dedicated to providing a safe and healthy work environment for all its employees. The Corporate Mission is to continue in a leadership role as a good corporate citizen and encourage employees' active participation in the communities served. The Ingrams Mill Water Treatment Plant conducts a safe, productive business, contributing to the community while minimizing risk to employees and neighbors. |
The plant uses chlorine to disinfect water for public consumption. These chemicals are stored in standard 1-ton containers, outside within a fenced area. The following process is covered by the Risk Management Program regulations (40 CFR 68):
Chlorine - 24,000 pounds inventory
The plant has developed and implemented an effective release prevention program that consists of the following elements:
Process Hazard Analysis
Management of Change
Pre-Startup Safety Review
A Management Team, consisting of qualified management personnel located onsite and at Corporate Headquarters, is accountable for enforcement and oversight of the above elements of the release prevention program.
Emergency Response to any potential incident at the plant is accomplished in accordance with the site's Integrated Contingency Plan. The Integrated Contingency Plan identifies response capabilities and qualification requirements of the onsite Emergency Response Team. The Plan complies with the emergency response requirements of OSHA, EPA and PADEP. The Plan is tested annually for effectiveness.
In addition to the onsite Emergency Response Team, the plant maintains liaison with the following response agencies:
West Bradford Fire Company
West Chester Boro Poli
Chloramone Hazardous Response Team
Philadelphia Suburban Water Company has performed hazard assessments to define the worst case release scenario and alternative release scenarios for the Ingrams Mill facility. The worst case scenario is defined as the release of the largest quantity of a substance from a process under defined atmospheric conditions. Catastrophic releases such as these are rare. The alternative release scenarios are defined as "more likely" events that are modeled under site-specific conditions with consideration of existing active safeguards.
The worst case release scenarios have been modeled for the unmitigated release of one container of chlorine. The distance to the toxic endpoint of 3 PPM has been reported to USEPA as 1.30 miles. An alternative, more practical, release scenario for chlorine is the gaseous release from a leaking chlorine pipe or fitting from the process within the building. The distance to endpoint for thi
s scenario has been reported as 0.10 miles.
To prevent the occurrence of chlorine releases, the Ingrams Mill Water Treatment Plant uses the following state-of-the-art process controls:
As an indication of the effectiveness of the above-mentioned programs, the site has experienced no accidental releases within the past five years. An accidental release is defined as any release that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage.
Prevention Program improvements planned for the site in the near future will include increased training and equipment for emergency responders, improved operating and emergency procedures, installation of a new indoor chlorine storage facility and upgraded chlorine equipment.