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Carrollton Water Purification Plant

Parent Companies:
Sewerage and Water Board of New Orleans
EPA Facility ID:
100000085686
Other ID:
LA0000086
Facility DUNS:
75047787
Parent Company DUNS:
0

Location:

Address:
8800 S. Claiborne Avenue
New Orleans, LA 70118
County:
ORLEANS
Lat / Long:
29.960, -90.130 (Get map)
Method:
Interpolation - Photo
Description:
Center of Facility
Horizonal accuracy:
10 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
12000

Owner/Operator:

Name:
Sewerage and Water Board of N.O.
Phone:
(504) 865-2000
Address:
625 St. Joseph Street
New Orleans, LA 70165
Foreign Address:

Person responsible for RMP implementation:

Name:
Chad Lavoie
Title:
Water Purification Superintendent

Emergency contact:

Name:
Chad Lavoie
Title:
Water Purification Superintendent
Phone:
(504) 865-0406
24-hour phone:
(504) 865-0643
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(504) 865-0400
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Orleans Parish LEPC
Full-Time Equivalent Employees:
93
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:
State environmental agency
Using Predictive Filing:
No

Processes:

Disinfection
RMP ID:
1000047750
CBI claimed:
No
Program Level:
2
NAICS:
Water Supply and Irrigation Systems (22131)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
48,435
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
Feb. 7, 2014
Type:
Resubmission
Reason:
Process no longer covered (source has other processes that remain covered) (40 CFR 68.190(b)(7))
Registered:
Yes
RMP ID:
1000038881

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 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:
  • Excess flow valve
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • 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

Disinfection, Water Supply and Irrigation Systems (22131)
Prevention Program ID:
1000031652
Safety Review Date
June 16, 2009, since latest RMP submission
PHA Update Date
, since latest RMP submission
Safety Regulations
  • ASTM Standards
  • ANSI Standards
  • ASME Standards
Hazards Identified
  • Toxic Release
  • Overpressurization
  • Floods
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Automatic Shutoffs
  • Alarms
  • Emergency Power
  • Rupture Disks
  • Excess Flow Device
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • Classroom
  • On the Job
Competency Testing
  • Observation
Procedure Review Date
Oct. 17, 2013, since latest RMP submission
Training Review Date
Oct. 23, 2013, since latest RMP submission
Maintenance Review Date
Oct. 7, 2013, since latest RMP submission
Maintenance Inspection Date
Oct. 7, 2013, 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
March 30, 2016
Compliance Audit Change Completion Date
Sept. 2, 2016
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:
June 17, 2009
Local Response Agency:
Local Response Agency Phone:
(504) 565-7200
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:
No
Subject To - Other:

Executive Summary

Executive Summary



This document was developed to comply with the Environmental Protection Agency's (EPA's) Risk Management Plan (RMP) Program II, under Section 112 (r) of the Clean Air Act (CAA) Amendments of 1990, 40 CFR Part 68. An outline of the RMP Program is provided in Table ES-1. The disinfection process using ammonia is covered under this regulation at the Sewerage and Water Board of New Orleans (S&WB) Carrollton Water Purification Plant (WPP).

To meet the regulation requirements, this report contains useful information on the ammonia system. The technical information contained in this report may be used as a reference in initial and recurring operator training. Training on process fundamentals, operations, and maintenance, coupled with the recommended process modifications discussed below, will reduce the potential hazards to plant personnel and the surrounding community.

Table ES-1



Outline of RMP Program

HAZARD ASSESSMENT

Worst-Case Scenarios

Alternative Release Scenarios

5-year Accident History

MANAGEMENT PROGRAM

Document Management System

PREVENTION PROGRAM

Safety Information

Hazard Review

Operating Procedures

Training

Maintenance

Incident Investigation

Compliance Audit



EMERGENCY RESPONSE PROGRAM

RISK MANAGEMENT PLAN



An overview of the Emergency Response Program and an Incident Investigation Program are also included in the report. These two programs should be an integral part of both initial and recurring training.

Print outs from the RMP*eSubmit, which summarizes the RMP in the format required by the EPA, are included in Section 12 of this document. It consists of a summary of data elements as required by EPA for inclusion in a public access database. The RMP is intended to inform the public of Carrollton WPP's proactive stance toward protection of the environment and the surrounding community.



ES.1 Hazard Assessment

The Hazard Assessment is comprised of a Worst-Case Scenario (WCS) and Alternative Release Scena
rio (ARS) for the ammonia system, as well as a 5-Year Accident History. The Hazard Assessment was conducted as an initial screening procedure as part of determining which Program Level (I, II, or III) the Carrollton WPP falls. Residences lie within the EPA-defined endpoint concentrations of Carrollton's Worst-Case releases. Therefore, the plant is ineligible for Program I. The Carrollton WPP is operated by public personnel and therefore excluded from Program III. Carrollton WPP is included in RMP Program II. The Hazard Assessment is provided in Section 1 and Attachment No. 5.



ES.1.1 Worst-Case Scenario

The WCS for the ammonia system (10,000 gallon tank) is defined as 10,000 gallons (51,500 lbs) of ammonia being released by a catastrophic event within a 10-minute duration. This scenario was developed and modeled using the EPA approved RMP*Comp model. The toxic endpoint for ammonia was determined to be 2.6-miles by the RMP*Comp model at the 0.14 mg/l (200 ppm) concentration specified by the EPA. It should be noted that at this concentration, a person may be exposed for up to one hour without suffering permanent injuries (ERPG-2).



ES.1.2 Alternative Release Scenario

The alternative release scenario of ammonia was also modeled using RMP*Comp. An estimation of approximately 820 pounds of ammonia released was derived from the scenario of an outdoors piping failure. The toxic endpoint for the ammonia system ARS was determined to be 0.1 miles.



ES.2 Five Year Accident History

No major accidents resulting in deaths, injuries, or significant property damage on-site, or known off-site deaths, injuries, evacuations, sheltering in-place, property damage or environmental damage have occurred between 2004 and July 2013. Documentation for minor release incidents/leaks for the ammonia systems is included in Appendix D.



ES.3 Management Program

The Management Program consists of the Document Management System described below:



ES.3.1 Document Management Syst
em

A Document Management System was established to attribute responsibility for the development, implementation, and maintenance of the RMP Program. The Program must be updated every three years, or any time a covered process undergoes a physical or administrative modification. The Document Management System is largely a function of the RMP Program Team, summarized in Table ES-2.



ES.3.2 Risk Management Program Team

Table ES-2 lists the employees responsible for the RMP Program development, implementation, and maintenance. The Chief of Operations is responsible for RMP implementation and has the ultimate responsibility.



Table ES-2

Carrollton Water Plant RMP Program Team

Team Member Position/Expertise RMP Program Element

Chad Lavoie Water Purification Supt. Overall RMP Manager

Jason Higginbotham Emergency Manager RMP Oversight

Ann Wilson Chief, Environmental Affairs Preparer and Certifying Official RMP, Alternate RMP Manager

Thomas Lobell Water Purification Operator IV Member, RMP Team

Felicia Bergeron Mechanical Engineering Member, RMP Team

Scott Finney Utility Services Manager Member, RMP Team

Melvin Reis Water Purification Operator III Member, RMP Team

Alton DeLarge Water Purification, Utilities Member, RMP Team

Service Manager

Ulysess Honore Water Purification Operator III Member, RMP Team



ES.4 Prevention Program

The Prevention Program is more appropriately entitled the Accidental Release Prevention Program. It is comprised of Safety Information, Hazard Review, Operating Procedures, Training, Maintenance, Incident Investigation, and Compliance Audit procedures. Each has an entire section devoted to it in this report, and is summarized below.



ES.4.1 Safety Information

Safety Information is comprised of Chemical Safety Information and Process Safety Information. Each is briefly described below.



ES
.4.2 Chemical Safety Information

Comprehensive chemical data is provided in this section to include: regulatory reporting action thresholds, health hazard and chemical exposure limitations, as well as physical properties of ammonia. This information was compiled from numerous sources, and is intended to be a one-stop source for the reader seeking data on these compounds. The physical data will provide useful information in the inevitable event the plant process is modified, thereby requiring revisited dense gas dispersion modeling. It is also imperative that plant operators and managers are apprised of the potential health hazards and exposure limits associated with these chemicals.



ES.4.3 Process Safety Information

Process Safety Information was compiled on each system studied. Basic specifications on each process are included in this document for easy reference. Details such as maximum inventory, safe upper and lower temperatures, safe upper and lower pressures, and codes and standards used to design, build, and operate the process are provided in this section. Used as a training reference, together with the process schematics, the reader will be able to understand the function and operation of the plant ammonia system.



ES.5 Hazard Review

The Hazard Review was conducted for the ammonia system in 2004, 2009 and 2013. Each Hazard Review has been reviewed and updated. Progress made to date on the 2013 recommendations is provided.



ES.5.1 Ammonia System Hazard Review

The hazard review for the ammonia system was conducted as an EPA approved Facility Audit. Recommendations were noted on the Hazard Review found in Sections 1 and 5.



ES.6 Prevention Program

Basic ammonia system operating procedures have been developed and documented by the Carrollton WPP and are provided in Section 6 and Appendix H. They provide system descriptions, specifications, and operating procedures for the ammonia system. Procedures include Start-up, Shutdown, Normal, an
d Temporary Operation. Also included are Troubleshooting Procedures.



ES.7 Training

Training is required by the EPA to be included in the RMP Program. A program has been developed with guidelines on how to conduct regular and structured plant training. Training Record Forms are included with the Program for the required documentation. The Training Policy is found in Section 8. Training records are found in separate files from the RMP Manual.



ES.8 Maintenance

Basic maintenance procedures have been developed by the Carrollton WPP and are included in Section 7. Sound preventive maintenance will reduce potential hazards to personnel onsite, as well as to the off-site public. In the event of an inspection or compliance review, state and federal regulators will request to see documentation and record keeping associated with the Maintenance Program. These records are found in separate files from the RMP Manual.



ES.9 Incident Investigation

An Incident Investigation Program has also been developed. The EPA has established strict guidelines to follow in the aftermath of any release involving the ammonia system. The Incident Investigation Program outlines key milestones that must be accomplished within 24-hours of any covered incident, and the actions that must occur subsequently. Ultimately, it is desired that the plant learns from the incident and takes action to prevent similar incidents in the future. Incident Investigation Report Forms are included, and must be maintained for a minimum of five years after each incident. No reportable incidents occurred at the Carrollton WPP during the 5-year reporting period (between 2004 and 2009) and at the present time for the current reporting period (between 2009 and 2014).



ES.10 Compliance Audits

Internal Compliance Audits must be conducted every three years to verify compliance with the programs and procedures contained in this document. The Chief of Operations must certify that the RMP Program team has ev
aluated compliance with the provisions of the Program, and verify that the procedures and practices are adequate and are being followed. Audit Report Forms are provided, the two most recent of which must always be maintained. The most recent compliance audit was performed in 2013 and is found in Appendix F.



ES.11 Emergency Response Program

The Emergency Response Program is included as part of the RMP Program, in case a significant release ever occurs. As with all the above programs, it is important to review this program regularly. The Emergency Response Plan is found in Section 11.



ES.12 Risk Management Plan

A copy of the RMP*Submit submittal is found in Section 12. As stated previously, this information will be made public information. Following submission to the EPA, the information will be uploaded on a public-access database. No other portion of the Carrollton WPP RMP Program will be made available to the public.



ES.13 Summary of Action Items for the Carrollton WPP

The RMP Rule, 40 CFR 68.42 requires that details of all accidental releases be recorded. The format details are provided in Sections 2 and 9.

The RMP Rule, 40 CFR 68.15 requires that the Document Management System (e.g., the RMP Team) be updated anytime personnel changes or administrative changes are made that would affect the lines of authority or responsibility for maintaining the RMP at the Carrollton WPP. The format details are provided in Section 3.

The RMP Rule, 40 CFR 68.54 requires that each employee presently operating a process, and each employee newly assigned to a covered process be trained or tested competent in the operating procedures. As an alternative, the S&WB may certify in writing that the employee has the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as provided in the operating procedures. Training documentation forms are provided in Section 8. Operating procedures for the Carrollton WPP are provided in
Section 6. These operating procedures may be used as training guides as well.

The RMP Rule, 40 CFR 68.56 also requires training on the plant maintenance procedures. Maintenance guidance is provided in Section 7. The S&WB must train or ensure the training of each employee involved in maintaining the on-going mechanical integrity of the process. To ensure that the employee can perform the job tasks in a safe manner, each such employee must be trained in the hazards of the process, in how to avoid or correct unsafe conditions, and in the procedures applicable to the employee's job tasks. Refresher training on operating and maintenance procedures must be provided every three years. Training documentation forms are provided in Section 8.

The RMP Rule, 40 CFR 68.60 requires incident investigations not later than 24 hours following each incident. That guidance is provided in Section 9.



The RMP Rule, 40 CFR 68.58 requires the S&WB to certify compliance with RMP Accident Prevention Program provisions at least every three years to verify that the procedures and practices developed under the rule are adequate and are being followed. That guidance, along with Compliance Audit forms, is provided in Section 10.

The Emergency Response Program is discussed in Section 11. Training documentation forms are provided in Section 8.

The S&WB must submit the RMP to EPA by June 21, 2014. The RMP*eSubmit print outs are located in Section 12.