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Westbank Sewage Treatment Plant

Parent Companies:
Sewerage & Water Board of New Orleans
EPA Facility ID:
100000031734
Other ID:
Facility DUNS:
0
Parent Company DUNS:
0

Location:

Address:
3501 East Canal Street
New Orleans, LA 70131
County:
ORLEANS
Lat / Long:
29.908, -89.967 (Get map)
Method:
Interpolation - Photo
Description:
Plant Entrance (General)
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Sewerage & Water Board of NO
Phone:
(504) 585-2212
Address:
625 Joseph Street
New Orleans, LA 70165
Foreign Address:

Person responsible for RMP implementation:

Name:
Ann Wilson
Title:
Chief of Environmental Affairs

Emergency contact:

Name:
Donald Patterson
Title:
Project Manager
Phone:
(504) 277-5400
24-hour phone:
(941) 447-2316
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(504) 942-3855
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
New Orleans Emergency Response
Full-Time Equivalent Employees:
12
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
March 27, 2014
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Disinfection
RMP ID:
1000054599
CBI claimed:
No
Program Level:
3
NAICS:
Sewage Treatment Facilities (22132)
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:
June 10, 2014
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
No
RMP ID:
1000044206

Deregistration:

Date:
Effective Date:
Reason:
Source reduced inventory of all regulated substances below TQs
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 Disinfection)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
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 Disinfection)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
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

Disinfection, Sewage Treatment Facilities (22132)
Prevention Program ID:
1000045704
Safety Review Date
March 31, 2014, since latest RMP submission
PHA Update Date
March 31, 2014, since latest RMP submission
PHA Techniques
  • What if
Hazards Identified
  • Toxic release
  • Equipment failure
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Demonstration
  • Observation
Procedure Review Date
May 21, 2014, since latest RMP submission
Training Review Date
March 27, 2014, since latest RMP submission
Maintenance Review Date
May 16, 2014, since latest RMP submission
Maintenance Inspection Date
June 8, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
March 16, 2007
Management of Change Review Date
May 21, 2014
Pre-startup Review Date
None
Compliance Audit Date
May 21, 2014
Compliance Audit Change Completion Date
July 22, 2014
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
May 21, 2014
Hot Work Review Date
May 21, 2014
Contractor Safety Review Date
May 21, 2014, since latest RMP submission
Contractor Safety Eval. Date
March 31, 2014, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
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:
(504) 297-3439
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

SEWERAGE AND WATER BOARD OF NEW ORLEANS



Westbank Sewage Treatment Plant

New Orleans, Louisiana

(EPA ID: 1000 0003 1734)

(LDEQ Facility ID: 4688)





EXECUTIVE SUMMARY

FOR

THE RISK MANAGEMENT PLAN



Accidental Release Prevention and Emergency Response Policies



Accidental Release Prevention: Both the Sewerage & Water Board (S&WB) and its Contractor, Veolia Water North America Operating Services (VWNAOS) are committed to the safe operation of the Westbank Sewage Treatment Plant (WBSTP). Continuous review of standard operating procedures (SOPs) and mechanical integrity programs help to ensure that the chlorine system is operated and maintained in a safe manner. VWNAOS provides formal training for all operators and maintenance personnel focusing on chlorine safety. The Hazardous Material (HAZMAT) Team of the New Orleans Fire Department (NOFD) conducts annual site visits to the plant review and familiarize themselves with the Chlorine system.



Emergency Response Policies: Operators at the WBSTP will not respond to leaks beyond their ability to control the use of valves. In the event of such release, plant personnel will evacuate with the exception of the plant supervisor or chief operator who will remain on the site to activate the New Orleans City's emergency system. The NOFD will be the first responders for any emergency response. They will establish a safe perimeter and begin public notification until the HAZMAT team of the NOFD arrives to contain the release. This facility is included in the Local Emergency Planning Committee's community emergency response plan.



Westbank Sewage Treatment Plant



The WBSTP is a 20-million gallons per day trickling filter plant and services the entire West Bank of Orleans Parish. Treated effluent from the plant is discharged to the Mississippi River. Disinfection of the effluent is accomplished by injecting chlorine in to the effluent box directly behind split box #1. Chlorine is stored in a maximum of
nine one-ton cylinders. The plant is owned by the S&WB but is operated and maintained by a private contractor, VWNAOS. Located on the West Bank of the Mississippi River in Orleans Parish, the facility is close to the Plaquemines Parish to the South and near the English Turn community to the East.



General Accidental Release Prevention Program and Chlorine Release Prevention



The WBSTP is subject to the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) rule. The PSM incorporates several elements that aid in operating a safe plant and in reducing the possibility for off-site releases. Among the critical elements that have been reviewed and updated are the SOPs, Mechanical Integrity Program, and Training Program. These three programs have a significant impact on the continued safe operation of the chlorine system.



Five-Year Accident History



There have been no accidents, as defined in 40 CFR 68.42, at the WBSTP in the last five years.



Emergency Response Program



As described above, personnel at the WBSTP will not act as responders to uncontrollable release of Chlorine. Rather, the Emergency Action Plan will be implemented which notifies the City's HAZMAT Team who will contain chlorine releases beyond the ability of plant personnel. The WBSTP is included in the community emergency response plan for the City of New Orleans.



Planned Changes to Improve Safety



The S&WB and VWNAOS took the following actions at the WBSTP to mitigate the consequences of an uncontrolled release of chlorine:



1. Installed additional process alarms;

2. Installed indicators of chlorine release in the operator control room; and

3. Installed cameras in the chlorine storage area



The WBSTP currently utilizes gaseous chlorine as a disinfectant. Recognizing the obvious safety hazard and accidental release consequences based on our long years of experience in working with gaseous chlorine and as identified by the RMP, the S&WB has inve
stigated a number of possible solutions to these problems.



At the time the original RMP was developed, the S&WB did not have specific first-hand knowledge of, or experience with alternative disinfection processes, their operation or use histories. In fact, many processes now becoming more commonplace were refined and made more practical as a result of RMP requirements. Since the initial RMP was developed the S&WB has investigated a number of commercially available on-site gaseous chlorine and sodium hypochlorite generation processes, from large to small volume generation. These were compared to the cost and practicability of providing enclosures and vapor scrubbers for on-site gaseous chlorine storage and use. The relative costs and safety considerations led the S&WB to select sodium hypochlorite as the chemical of choice of disinfection at the WBSTP. This decision was based on evaluation studies conducted at the WBSTP by Tulane University, on-site demonstration projects conducted by equipment manufacturers at the S&WB's Algiers Water Purification Plant, and plant visits by S&WB staff to similar municipal facilities. The developing knowledge within the water and wastewater industry since the RMP process was initiated has also yielded valuable knowledge relative to alternative disinfectant use. Due to the cost of using sodium hypochlorite as an alternative disinfectant, the Board does not have available funds to do this project at the present time. The SWBNO and its contractor, Veolia, will continue to use chlorine at the West Bank Sewer Treatment Plant.