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Gradney Street Water Treatment Facility

Parent Companies:
City of Sulphur, Louisiana
EPA Facility ID:
100000028409
Other ID:
Facility DUNS:
173712886
Parent Company DUNS:
173712886

Location:

Address:
300 A Gradney Street
Sulphur, LA 70663
County:
CALCASIEU
Lat / Long:
30.238, -93.345 (Get map)
Method:
Interpolation - Photo
Description:
Administrative Building
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
City of Sulphur, Louisiana
Phone:
(337) 527-4500
Address:
500 N Huntington Street
Sulphur, LA 70663
Foreign Address:

Person responsible for RMP implementation:

Name:
Jeremy Lavergne
Title:
Water Plant Assistant Supervisor

Emergency contact:

Name:
City of Sulphur Fire Chief
Title:
Fire Chief
Phone:
(337) 527-4549
24-hour phone:
(337) 527-4545
Ext or PIN:
Email:
N/A

Other contacts:

Facility (or company) email:
Facility phone:
(337) 527-4500
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Calcasieu Parish LEPC
Full-Time Equivalent Employees:
7
Covered by OSHA PSM:
No
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Inspecting Agency:
EPA
Using Predictive Filing:
No

Processes:

5
RMP ID:
1000056487
CBI claimed:
No
Program Level:
2
NAICS:
Water Supply and Irrigation Systems (22131)
Chemical name
CAS#
Quantity (lbs.)
CBI
Chlorine
7782-50-5
4,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Jeremy Lavergne
Address:
101 N. Huntington St.
Sulphur, LA 70663
Foreign Address:

Phone:
(337) 527-4582

Latest RMP Submission:

Date:
July 14, 2014
Type:
Resubmission
Reason:
Voluntary update (not described by any of the above reasons)
Registered:
Yes
RMP ID:
1000045518

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in 5)
CBI claimed:
No
Percent weight:
Physical state:
Gas
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps

3. Toxics: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in 5)
CBI claimed:
No
Percent weight:
Physical state:
Gas
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown

4. Flammables: Worst-case

None

5. Flammables: Alternative release

None

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

No Prevention Program level 3

8. Prevention Program level 2

5, Water Supply and Irrigation Systems (22131)
Prevention Program ID:
1000036170
Safety Review Date
May 1, 2009, since latest RMP submission
PHA Update Date
, since latest RMP submission
Safety Regulations
  • None
Hazards Identified
  • Toxic Release
  • Fire
  • Overpressurization
  • Corrosion
  • Equipment failure
Process Controls
  • Relief Valves
  • Check Valves
  • Alarms
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None Recommended
Training Type
  • Classroom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
May 1, 2009, since latest RMP submission
Training Review Date
June 1, 2009, since latest RMP submission
Maintenance Review Date
June 1, 2009, since latest RMP submission
Maintenance Inspection Date
June 26, 2009, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Management of Change Review Date
Pre-startup Review Date
Compliance Audit Date
Aug. 22, 2008
Compliance Audit Change Completion Date
July 1, 2009
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Hot Work Review Date
Contractor Safety Review Date
, since latest RMP submission
Contractor Safety Eval. Date
, since latest RMP submission

9. Emergency response

Facility In Community Plan:
No
Facility Own Response Plan:
No
Specific Facility Response Plan:
No
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
No
Plan Review Date:
Response Training Date:
None
Local Response Agency:
Local Response Agency Phone:
(337) 437-3512
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
No
Subject To - CWA:
No
Subject To - RCRA:
No
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary


Executive Summary

1. Accidental Release Prevention and Emergency Response Policies

We at the GRADNEY STREET WATER TREATMENT FACILITY are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design installation, operating procedures, maintenance, and employee training associated with the. process at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Unforeseeably, if such a release does occur, we are completely coordinated with the CITY OF SULPHUR FIRE DEPARTMENT which provides highly trained emergency response personnel to control and mitigate the effects of the release.

2. The Stationary Source and the Regulated Substances Handled

Our facilities primary activities encompass TREATMENT OF WELL WATER FOR HUMAN CONSUMPTION. We have I regulated substance present at our facility. This substance is Chlorine. The regulated substance at our facility is used for treatment of well water for human consumption.

The maximum inventory of Chlorine at our facility is 4000.00 lb.

3. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps

Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR Part 68 of the EPA. This facility was designed and constructed in accordance with good engineering practices Our facility is also subject to EPCRA Section 302 notification requirements. Some sections below briefly describe the elements of the release prevention program that is in place at our stationary source.

4. Release Scenarios

Worst-Case Release Scenario Analysis



Having determined that the chlorine is the only regulated substance, a worst-case analysis for the chlorine was conducted. The city of sulfur uses chlorine for a disinfectant in the public water supply. The chlorine
is stored on-site in two 2000 pound chlorine cylinders. Only one cylinder is connected to the process at any given time. When the cylinder being used becomes empty, valves are used to disconnect the empty cylinder and to connect the full cylinder to the process. As required, it was assumed the entire 2000 pounds of chlorine was released into the air at one time. It was assumed that no administrative controls or passive mitigation were used to limit the quantity that could be released. Using EPA?s requirements and RMPComp32, it was determined that the distance to the endpoint is 1.3 miles.



Alternative Release Scenario Analysis



In addition to the worst-case analysis and alternative release analysis were performed using chlorine as the regulated substance. The alternative release scenario assumed that the chlorine cylinder was punctured resulting in a 0.75 square inch hole. The tank pressure was assumed to be 90 psi, the tank temperature was assumed to be 80? F, the topography was chosen to be urban, and the release duration was 10 minutes. It was assumed that no administrative controls or passive mitigation were used. This resulted in a total of 1660 pounds of chlorine being released. Using RMPComp32, the distance to toxic endpoint was calculated to be 0.6 miles.



5. Process Safety Information



The GRADNEY STREET WATER TREATMENT FACILITY maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes.

Process Hazard Analysis

Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is the inspection and testing of all equipment related to chemical injection. The studies are undertaken by qualified personnel. Any findings related to the hazard analysis are addressed in a timely manner.

Operating Procedures

For the purposes of sa
fely conducting activities within our covered processes, the GRADNEY STREET WATER TREATMENT FACILITY maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, and normal shutdown. The information is regularly reviewed and is readily accessible to operators involved in the process.

Training

The GRADNEY STREET WATER TREATMENT FACILITY has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every 3 years and more frequently as needed.

Mechanical Integrity .

The GRADNEY STREET WATER TREATMENT FACILITY carries out documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.

Management of Change

Written procedures are in place at the GRADNEY STREET WATER TREATMENT FACILITY to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification.



Pre-startup Reviews

Pre-start up safety reviews related to new processes and to modifications in established processes are conducted on an as needed basis at the GRADNEY STREET WATER TREATMENT FACILITY. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are su
itable for safe startup prior to placing equipment into operation.

Compliance Audits

The GRADNEY STREET WATER TREATMENT FACILITY conducts audits per RMP regulations to determine whether the provisions set out under the RMP rule are being implemented.

Incident Investigation

The GRADNEY STREET WATER TREATMENT FACILITY will promptly investigate any incident that results in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years.

Employee Participation

The GRADNEY STREET WATER TREATMENT FACILITY operates under the principle that process safety management and accident prevention is a team effort. Employees are encouraged to express their views concerning accident prevention issues and to recommend-improvements. In addition, our employees have access to all information resulting from process hazard analyses in particular.

Contractors

On occasion, our facility hires contractors to conduct specialized maintenance and construction activities. The GRADNEY STREET WATER TREATMENT FACILITY has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes.

6. Five-year Accident History

The GRADNEY STREET WATER TREATMENT FACILITY has had an excellent record of preventing accidental releases over the past 5 years. There has been no accidental release during this period.

7. Emergency Response Plan

The GRADNEY STREET WATER TREATMENT FACILITY has a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations and notification of local emergency response agencies and the public.

To ensure proper functioning, our emergency response equipment is
regularly inspected and serviced as needed. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response.

CALCASIEU PARISH, LA. LEPC is the Local Emergency Planning Committee (LEPC) with which our emergency plan is coordinated.

8. Planned Changes to Improve Changes

No changes are currently planned.