Saginaw Township Center Road Retention Basin - Executive Summary

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                      Executive Summary 
         Saginaw Charter Township CSO Retention Basin 
                       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 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.  
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