Saginaw Charter Township WWTP - Executive Summary |
Executive Summary Saginaw Charter Township WWTP Saginaw Michigan A. A Process Safety Management Plan was developed in 1994 and is still current. The plan was prepared in accordance with 29CFR 1910.119 and summarizes the steps involved to comply with the regulation. This plan included a time schedule for implementing the Process Hazard Analysis. A Pollution Incident Prevention Plan (PIPP) was also developed in 1994 and is still current. This plan repeats much of the information included in the RMP registration information. The PIPP discusses spills of chemicals on site, how they are contained, who to call for clean up, proximity to a sewer, and pertinent regulatory agencies and downstream contacts. In progress the Township is updating operating procedures and providing additional training as new equipment and different operating procedures warrant it. B. At the WWTP, ton cylinders of chlorine gas are located in the chlorine building in the chlorine room while being used. For the purpose of the Risk Management Program no other regulated chemicals on used or stored on site. C. Both the worse case and alternate case scenarios were based on the American Water Works Association (AWWA) guidelines per the Emergency Response Planning Guide 2. The worse case scenario is: A catostrophic failure due to corrosion, impact, or construction defects resulting in a 2,000 pound release of 200 pounds per minute over 10 minutes. The distance to endpoint per ERPG-2:3ppmv is 2.631 miles. The alternate case scenario is: A tubing failure, bad connection, or valve failure resulting in the release of gas through the 5/16" diameter valve body opening. This would result in a 317 pound release at a maximum average sustained relesae rate of 10.5 pounds per minute over a 60 minute duration. The distance to endpoint per ERPG-2:3 ppmv is 0.48 miles. The controls in place to minimize the distances for each scenario, although not totally credited in the AWWA model are the facts that the site is surrounded by a dike that not only keeps flood waters out but will keep the chlorine on site. The chlorine, while in use is stored indoors in a separate room that is monitoried by leak detection equipment. The controls are considered fail safe in that should there be a loss of power or loss of vacuum in this case, the equipment will shut done and stop allowing chlorine out of the vessel. The controls in place have been updated with in the last six months and were originally designed around the Great Lakes Upper Missippi River Board Ten States Standards for chlorine safety. Administratively, all personnel share in the daily tasks due to the small staff on site and are all trained in operating and addressing releases. D. For the plan itself please refer to the comments made in item A above. Many chemical specific prevention steps have been taken into mind when designing and operating the system, whether it be through the use of newly installed direct mounted valves and regulators or the simple use of a window, light interlocked to a fan or regularly maintained detection equipment. The intent of all of these features is safety. E. There have been no reportable accidents from this facility in the past five years. F. The emergency repsonse plan has been carefully coordinated with the Township fire department. It is the fire department who will be called through the use of calling 911 to respond to a reportable release. It is the fire department that has the training on notifying surrounding residents and performing the actual response activities and or seeking assistance as appropriate. The WWTP personnel have been trained to contact the fire department and to provide assistance with this agency to respond to a release. The main reason for this is due to the fact that at time thw WWTP is unmanned and mitigating a release is not a one person job. G. Recent changes that have been made and that will continue to be made include the reduction of inventory. The Township is very cognizant of its surroundings and is genuinely concerned. The Township realizes through evaluating the use of alternative disinfection chemicals, reducing inventory, replacing outdated equipment, providing personnel training and performing daily and routine inspections by plant staff as well as by manufacturers representatives the risks will be reduced and safety improved. R:\DATA\ENVIR\JMI\WP61\EXESUM.WPD |