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Lafourche Parish Water District No. 1- South Plant

Parent Companies:
EPA Facility ID:
100000029523
Other ID:
Facility DUNS:
62641212

Location:

Address:
5753 Highway 308
Lockport, LA 70374
County:
LAFOURCHE
Lat / Long:
29.665, -90.537 (Get map)
Method:
GPS Code Measurements (Psuedo Range) Precise Positioning Service
Description:
Storage Tank
Horizonal accuracy:
3.0 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
Lafourche Parish Water Dist. No. 1
Phone:
(985) 532-6924
Address:
P.O. Box 399
Lockport, LA 70374
Foreign Address:

Person responsible for RMP implementation:

Name:
Jared Allemand
Title:
Chemist

Emergency contact:

Name:
Scott Thibodeaux
Title:
Purification Dept. Superintendent
Phone:
(985) 532-6924
24-hour phone:
(985) 637-9939
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(985) 532-6924
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Lafourche Parish LEPC
Full-Time Equivalent Employees:
62
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:
Dec. 6, 2011
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Water Treatment Plant
RMP ID:
1000051204
CBI claimed:
No
Program Level:
2
NAICS:
Water Supply and Irrigation Systems (22131)
Chemical name
CAS#
Quantity (lbs.)
CBI
Chlorine
7782-50-5
18,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
May 14, 2014
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000041566

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 Water Treatment Plant)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
Areal Locations of Hazardous Atmospheres [ALOHA(R)]
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Rural
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 Water Treatment Plant)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
Areal Locations of Hazardous Atmospheres [ALOHA(R)]
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Rural
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
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

Water Treatment Plant, Water Supply and Irrigation Systems (22131)
Prevention Program ID:
1000033701
Safety Review Date
April 21, 2014, since latest RMP submission
PHA Update Date
, since latest RMP submission
Safety Regulations
  • None
Hazards Identified
  • Toxic Release
  • Corrosion
  • Equipment failure
  • Hurricanes
Process Controls
  • Relief Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
  • Emergency Power
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
March 27, 2014, since latest RMP submission
Training Review Date
April 21, 2014, since latest RMP submission
Maintenance Review Date
April 21, 2014, since latest RMP submission
Maintenance Inspection Date
March 20, 2014, 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
April 16, 2014
Compliance Audit Change Completion Date
April 21, 2014
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:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
Feb. 17, 2014
Local Response Agency:
Local Response Agency Phone:
(985) 446-8427
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

Lafourche Parish Water District No. 1

P.O. Box 399

Lockport, LA 70374





Risk Management Plan

2014 Update





Executive Summary: South Treatment Plant



The accidental release prevention and emergency response policies at your site



Due to regulations under the Chemical Accident Prevention Program, the District has developed a Risk Management Plan for Chlorine gas. The requirements involve instituting a prevention plan to avoid unnecessary Chlorine leaks in addition to developing, revising, and updating its existing emergency response procedures. The expectations of the above mentioned requirements are to allow minimal injury and damage to occur, as well as to provide aid and guidance for other responders in the event of an accident.



The prevention plan, developed by the District, has been designed to ensure that all precautions are taken so as to prevent and mitigate any possible Chlorine release. One element of this plan is to assess the Chlorine process for potential hazards that could contribute to a leak then correct the problems immediately. Another essential component is written operating procedures for all duties associated with Chlorine, while another is to provide proper training to employees involved in those duties. All training and inspection information will be documented for future reference.



The emergency response plan was implemented with the intention that plant personnel will respond, contain and repair all Chlorine leaks. One reason for this is because we feel our employees are properly trained and experienced enough to resolve the problem in a timely manner. Another reason is because plant policy only allows Chlorine cylinders to be handled only during normal working hours so an adequate amount of qualified responders are present to initiate a response if necessary. Nonetheless, it is possible to have a release after hours, even though, because two people are on site at all times they will be able mitigate to the situatio
n.







Your Facility and the Regulated substance handled



Location of Facility (South)



The Lafourche Parish Water District No. 1, South Treatment Plant, is located on LA Highway 308 just north of Lockport. The physical address is 5753 Highway 308, Lockport.

Background Information (South)

The Lafourche Parish Water District No. 1 - South Plant is a potable drinking water production facility. The District purifies water taken from Bayou Lafourche and distributes the water to customers throughout Lafourche Parish.

Chlorine gas is used as a disinfectant in the treatment process and is stored, handled, moved, and fed continuously. The District has one (1) ton cylinders on site. Plant personnel remove one (1) ton cylinders when empty and replace them with full cylinders. This involves transporting cylinders with a forklift, lifting the cylinders with a hoist, and mounting a regulator onto the cylinder valve. All of which is done during normal working hours in order to reduce potential leaks from occurring after hours.

District personnel can deal with most emergency response and repair situations; however, outside assistance may be necessary depending on the severity of the Chlorine leak. PPE and repair equipment used to respond to Chlorine releases are provided and stored in a dedicated Emergency Response area. "B" repair kits, portable SCBAs, Level B containment suits, gloves, and extra air bottles can be found in an Emergency Response Cart in this Emergency Response area. The Level A containment suits are located in a cabinet in the Emergency Response area as well. There are four (4) Self Contained Breathing Apparatus located at the South Plant. Two are located on the first floor in the plant foyer, and the other two are portable units located in the emergency response cart.

Sugarcane and pastureland surround the plant on three sides with LA Highway 308 on the other. The closest residence is located across Bayou Lafourche approxi
mately 900 feet west of the plant.







The Worst Case scenario and the Alternative Case scenario



Worst Case Scenario (WCS)



The worst case scenario for a Chlorine gas release is when the total content of a one ton cylinder is expelled within ten minutes. In this event, the total quantity released is 2000 pounds with the release rate being 200 pounds per minute. The variables used in determining the distance that the gas travels is a rural topography, an F-stability class (atmosphere conditions), and a wind speed of 1.5 m/s. When these conditions exist, the toxic endpoint is 3.04 miles according to the ALOHA model, CLW-2, in "Compliance Guidance and Model Risk Management Program for Water Treatment Plants". The population affected by this scenario is approximately 8,900 people. No environmental receptors would be affected in such a case; however, schools, recreational areas, businesses, residences, and a hospital are within the 3.04 mile endpoint. For this reason, it is crucial that extreme precautions be taken to prevent this from ever occurring.



Alternative Case Scenario (ACS)



The most likely case scenario of a Chlorine gas release for Lafourche Parish Water District #1 is a malfunctioning valve on the cylinder itself. Using the ALOHA model, CLA-3, in "Compliance Guidance and Model Risk Management Program for Water Treatment Plants", the release rate for a malfunctioning valve is 10.5 pounds per minute. Because this scenario will tend to occur during normal working hours, as explained above, the time taken to repair the leak will be minimal. It is estimated that it takes approximately sixty (60) minutes to repair a leak such as this. Accordingly, this would allow 317 pounds of chlorine to be expelled. The variables used in determining the distance that the gas travels is a rural topography, an F-stability class (atmospheric conditions), and a wind speed of 1.5 m/s. When these conditions exist, the toxic endpoint is 0.57 miles according to
the ALOHA model. The population affected by this scenario is approximately 150 people. No environmental receptors would be affected in such a case; however, residences are within the 0.57 mile endpoint. For this reason, it is crucial that extreme precautions be taken to prevent this from ever occurring.





The general accidental release prevention program and chemical-specific prevention steps



General:

The following information represents general prevention program policies to prohibit unnecessary Chlorine leaks.

1) Safety information documented and distributed to employees

2) Properly designed chlorination equipment

3) Hazard review conducted

4) Written operating procedures

5) Periodic training (equipment, safety, leak repair)

6) Regularly scheduled maintenance

7) Emergency Chlorine scrubber



Specific:

The following information represents specific prevention program policies to prohibit unnecessary Chlorine leaks.

1) Area Chlorine leak detectors with alarm.

2) Personnel make general observations of the Chlorine process every half-hour to ensure normal conditions.

3) All Chlorine cylinders are inspected upon delivery.

4) The following written operational procedures:

Chlorine - Normal Operations

Chlorine Delivery - Transporting and Storing Chlorine Cylinders

Connecting and Disconnecting Chlorine Cylinders

Chlorine Leak (Discovery)

Chlorine - Emergency Response

Personal Protective Equipment

Chlorine Inventory Control

Temperature Recordation

Plant Shut Down - Emergency

Plant Shut Down - Controlled

Plant Start Up

Lockout/Tagout

Hot Work

Scrubber Operations

Scrubber - Temporary Operations



5) Hands on training for mounting chlorination equipment given by supervisors.

6) Three plant employees always on site while Chlorine cylinders are changed.

7) The Chlorine room is kept clean and free of excess traffic with all tubing neatly positioned out of the way.

8) Emergency Chlorine scrubber





5 -Year Accident History



The Lafour
che Parish Water District No. 1 has not had an accidental release of Chlorine over the last five years that resulted in death, injury, property damage (on or off site), evacuation, shelter-in-place, or environmental damage.



The Emergency Response Program



As mentioned, the goal of our emergency response program is to effectively respond to Chlorine leaks allowing minimal injury or damage to occur. It will also aid other emergency response personnel by providing guidance in the event of an accident. Some of the elements of this plan are referenced below.



Alarm



A Chlorine leak detector sounds an alarm when elevated Chlorine concentrations are found. The Chlorine alarm will sound continuously for the duration of the abnormal concentrations. It will not silence until the Chlorine leak is repaired and/or the concentrations have fallen. All employees, contractors, visitors, etc. should exit the leak area while observing the wind direction and immediately report to their designated primary assembly area as noted in the next section. The Ranking Supervisor for the Purification Department shall proceed with the Emergency Response Coordination.





Assembly Area



Upon hearing the Chlorine alarm, all purification personnel should immediately report to the Lab/Control Room. If it is inaccessible, they should then report to an area in the yard that is upwind of the leak. A windsock is located on the plant roof and on top of the lime silo for determining wind direction.

Purification Department:

Primary Lab/Control Room

Secondary Designated by wind direction



Administration personnel, distribution personnel, contractors, visitors, etc. should immediately report to their primary assembly area as long as it appears safe. Otherwise, they should report to their secondary assembly area as described below.

Others:

Primary Exit Gate (upwind of leak)

Secondary Area designated by wind direction





Overall Emergency Response Coordination

After gath
ering as much information as possible from the staff, the Ranking Supervisor (on site) will be responsible for coordinating the following during an emergency response:

1) Notify all employees, contractors, visitors, and front office staff of leak via intercom and telephone.

2) Ensure that all personnel, visitors, contractors, etc. are accounted for.

3) Determine the severity of the leak by gathering as much information as possible from available personnel.

4) Establish a safe zone according to the wind direction.

5) Contact the standby supervisor as well as the plant superintendent, the assistant superintendent, head operators, and maintenance men and have them report immediately to the plant in question.

6) While waiting on additional responders to arrive, someone should hang the "Danger" sign on the entrance gates, leaving one gate halfway open for additional responders to enter.

7) Using the information gathered, decide if a plant shut down is warranted. If so, shut the plant down using "Plant Shut Down - Emergency" SOP. (Caution: PPE may be required for plant shut down.)

8) At any time the leak threatens to have an offsite impact, or, if the leak is known to be greater than 10 pounds, the ranking supervisor (on site) shall immediately begin notifying the following agencies: (Note: A release of 10 pounds or more must be reported to these agencies within 1 hour of the release. However, keep in mind that the emergency Chlorine scrubber is designed to neutralize the entire content of a one (1) ton chlorine cylinder.)

9) Once 3 responders are on site, the ranking supervisor will appoint duties to responding personnel and initiate the Leak Assessment as outlined in the "Chlorine - Emergency Response" SOP.

10) Conduct an incident investigation.



Emergency Response



The details of our Emergency Response for Chlorine are provided in the "Chlorine - Emergency Response" SOP. Generally, this response is divided into 3 phases: the Coordination phase as
explained in the section above, the Leak Assessment phase, and the Leak Repair phase. Even though the Coordination phase can begin immediately, the other phases cannot begin until a minimum number of responders are present. The Leak Assessment requires there to be at least three (3) responders on site and the Leak Repair requires at least four (4) responders.

A personal protective equipment SOP is available. Also, an explanation and supporting documentation regarding recommended chemical suits are provided.





After Hours



Purification Department day workers normal working hours are 7:00 a.m. to 4:00 p.m., Monday through Friday; otherwise, there are two people operating the plant at all times. Plant policy allows handling of Chlorine cylinders only during normal working hours in order that sufficient workers are present in case an emergency response is initiated. If an emergency situation arises after hours, the man on standby and any other supervisor available shall be contacted and notified of the situation. These supervisors shall report to the plant immediately to assist in the Emergency Response. The Ranking Supervisor will use discretion when calling on outside assistance, although he is required to notify specific agencies if a Chlorine leak threatens to have offsite impact or exceeds a ten (10) pound release.



Outside Assistance (Offsite Impact or 10 pound Chlorine leak)



When a Chlorine leak threatens to have an offsite impact or is known to be greater than 10 pounds, the Ranking Supervisor is required to contact the following agencies:

Laf. Sheriff's Office, Fire Dept. 911

State Police (225) 925-6595

Laf. Parish Emerg. Planning Comm. (985) 446-8427, (537-7603)

Chem Trec (800) 424-9300

National Response Center (800) 424-8802

Dept. of Environmental Quality (985) 532-6206

Detailed information of the situation will be given, including wind direction and the designated assembly area. Depending on available personn
el, someone will meet the responders at the front gate to update them on the situation and direct them to the response.



Shelter / Evacuation (Employee)



A decision as to evacuate or to shelter-in-place will be made by the Ranking Supervisor at the time of the incident. Generally, a major Chlorine release will last at most 30-40 minutes; therefore, shelter-in-place will more than likely be used in an emergency situation. If shelter-in-place is initiated, all air conditioning must be shut off and all vents, windows, and doors closed. In addition, office personnel shall keep customers from leaving during this time. Office personnel should listen for further advisories.

Office personnel will be prepared to evacuate the premises on short notice. Evacuation will be utilized if there is a massive quantity of Chlorine released or if the wind direction threatens the assembly area.





Public Notification



If outside assistance is required, the Sheriff's Office, State Police, and the Fire Department will be notified. Evacuation or shelter-in-place of residences will be at the discretion of the Law Enforcement Agencies. These agencies may choose to shelter residences within ? mile of the plant. If so, residences should be instructed to shut windows, close any ventilation system, and listen for further advisories.





Phone Answering



During normal working hours, the front office will answer telephone calls, whereas after hours, any available personnel will do so.



Media Inquiry



The media will be updated by one person who is authorized to do so at the appropriate time. When time permits, the media will be given background information on Chlorine. When facts are known of the situation, these will be given to the media. Any person discussing the incident should not speculate as to the cause, but should advise the media that the situation is under investigation. If the cause is known, so advise.



Emergency Treatment



Any injured employee or re
sponder suffering from Chlorine inhalation should be sent to the hospital immediately. First aid can be administered if applicable. Medical management information is available in the RMP.



All Clear



The Ranking Supervisor will determine when the situation is no longer threatening. He will then notify all parties involved as soon as possible.



Response and Repair Training



The Lafourche Parish Water District No. 1 will ensure that each employee, involved in the Chlorine process, is trained to safely carry out the duties and responsibilities of the position.

No employee will be allowed to take part in any task, which he is not properly trained or believed competent. All new purification employees will be provided orientation material.

Trainers will consist of senior staff, suppliers, vendors, manufacturer's representatives, etc. Chlorine suppliers will provide training for District personnel concerning Chlorine safety, repair kits, etc. no less than once per two-year period. Municipal & Industrial Chlorination will provide training and updates to day shift staff on how to properly change, remove, and install chlorination equipment. They, in turn, will train others involved in this process.

Training and qualification documentation for maintenance contractors, suppliers, etc. are provided in the RMP.



Planned Changes to Improve Safety



Although the WCS and the ACS do not use this mitigation in its modeling assumptions, all Chlorine cylinders are housed indoors for additional protection and containment. We have begun a more aggressive training, maintenance, and inspection program as per an audit conducted on March 17, 2002. We have posted more warning signs and labels throughout the facility, and installed an additional windsock as per a hazard review conducted on February 6, 2004. On September 17, 2007, a Chlorine scrubber was placed in service as an additional safety precaution. We also improved the posting of warning signs, labeled Ch
lorine solution lines, developed new lockout/tagout SOP, and posted refresher memos concerning several items involving the Chlorine process as a result of a hazard review and RMP update in March of 2009. A "Scrubber-Temporary Operations" SOP was also implemented as a result of an April 16, 2014 audit.