Saginaw Township Center Road Retention Basin - Executive Summary
Executive Summary |
Saginaw Charter Township CSO Retention Basin
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
In progress the Township is updating operating procedures and providing additional
training as new equipment and different operating procedures warrant it.
B. At the Combined Sewer Overflow Retention Treatment Basin ton cylinders of chlorine
gas located in the chlorine room of the equipment building.
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
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
ease 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.