Spring Creek Facility - Executive Summary

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Executive Summary 
 
    Accidental release prevention and emergency response policies 
 
   A combination of operator training and managements commitment to safety have proven 
effective in preventing accidental releases.  Release prevention has been accomplished by training and step by step instructions contained in the operations manuals.  The Sanitary District has not had a reportable release. 
   Emergency response is handled by the Springfield Fire Department and if needed the associated HAZMAT response teams.  The Springfield Metro Sanitary District has never had an occasion that required emergency response.  The phone number that is used to contact emergency response teams is the standard 9-1-1 emergency access number.  The fire department dispatches trucks to this site from approximately (1) one mile away.  The process site can be easily accessed by emergency vehicles and is well identified by signs.  The chlorine facility has a wind sock that is easily visible and will aide in the approa 
ch of emergency vehicles. 
 
   Facility and the regulated substance 
 
   The process at the Spring Creek plant consists of a chlorine storage facility, chlorine control building and chlorine contact area for disinfecting wastewater treatment plant effluent.  This facility uses chlorine from (3) three ton cylinders hooked up in parallel.  Chlorine is drawn from the cylinder as a liquid and evaporated to the gaseous form.  Chlorine is used for the disinfection of excess flows and plant effluent.  A maximum of (9) nine cylinders are stored on site at any time.    
 
   Worst case and alternative release scenarios 
 
   The worst case scenario was calculated for a catastrophic release of  a (1)one ton cylinder of chlorine in an urban area with an enclosed building, in direct contact with outside air.  We used RMP*Comp to calculate the estimated distance to toxic end point of 0.9 miles. 
   The alternative scenario was calculated using RMP*Comp and involved a catastrophic release of  the (3) Three ton cylin 
ders that are hooked up in series.  The scenario that would cause this release would be a severed manifold line.  Release mitigation includes an enclosed space in direct contact with outside air.  The calculated distance to toxic end point is 0.3 miles. 
   Passive mitigation of a release would include the flood berms that surround the plant and the low area in which the plant was constructed. 
 
   Accidental release prevention 
 
   Training and maintenance procedures have helped us maintain our chemical safety record. 
Training the operators to handle, unload and hook up ton cylinders of  chlorine is overseen by the head operator and the operations supervisor.  Complete instructions for chlorine handling are located in the operations manuals as well as the MSDS for chlorine.  The operators change chlorine cylinders as necessary only during day shift when others are present in the plant.  We require (2) people to change cylinders and that emergency air packs are on hand. 
 
   Maintenance procedures 
require that the system is shut down and purged before any repairs requiring breaking of chlorine liquid or gas line connections are started.  The maintenance department is required to have an operator shut down and start the system per the procedures. 
 
   A process hazard analysis was completed for this process and few items were noted as potential process safety problems.  These safety items are to be corrected before January 2001. 
 
   Refresher training will be completed as required and new operator and maintenance personnel will be trained on the chlorine system.  All training will be recorded. 
 
   Five year accident history 
 
   We have had no reportable accidents in the past five years due to the simplicity of the system, the safe manner in which chlorine is handled and the systems integrity. 
    
   Emergency response program 
   The main scenario that would prevent an operator or maintenance man from isolating the system immediately is a failure with a ton cylinder itself.  In the event that a 
cylinder was to fail, the operator would proceed to the emergency response procedure.  
 
   The emergency response program is administered by the Springfield Fire Department. 
The fire department is responsible for responding to chlorine emergencies at this plant.  In the event of a major release the operator would call the local 9-1-1 emergency number and explain the problem.  The fire department would respond with a HAZMAT team if necessary.  The operators and maintenance department are trained in the use of SCBA units and can use them to shut the system down if necessary. 
 
   Planned changes to improve safety 
 
   The Sanitary District is actively pursuing alternative means of effluent disinfection.  Currently we plan to remove the chlorination system and begin using Sodium Hypochlorite solution. Changing to an alternative disinfectant will bring this plant below the threshold limits for chlorine and  risk management plan requirements.
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