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West Bank Water Treatment Plant

Parent Companies:
Jefferson Parish Department of Water
EPA Facility ID:
100000086006
Other ID:
Facility DUNS:
0
Parent Company DUNS:
0

Location:

Address:
4500 Westbank Expressway
Marrero, LA 70072
County:
JEFFERSON
Lat / Long:
29.898, -90.096 (Get map)
Method:
Interpolation - Photo
Description:
Center of Facility
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Jefferson Parish Water Department
Phone:
(504) 736-6050
Address:
1221 Elmwood Park Blvd - Suite 909
Harahan, LA 70123
Foreign Address:

Person responsible for RMP implementation:

Name:
Salvador Maffei, Jr.
Title:
Director, Water Department

Emergency contact:

Name:
David P Mahner Jr.
Title:
Operations Superintendent II
Phone:
(504) 349-5085
24-hour phone:
(504) 415-3936
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(504) 736-6050
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Jefferson Parish Emergency Mgt
Full-Time Equivalent Employees:
52
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:
April 29, 2015
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Disinfection System
RMP ID:
1000062859
CBI claimed:
No
Program Level:
2
NAICS:
Water Supply and Irrigation Systems (22131)
Chemical name
CAS#
Quantity (lbs.)
CBI
Chlorine
7782-50-5
48,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
May 15, 2015
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000050006

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 System)
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:
  • Enclosures
not considered:
  • Dikes
  • 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 System)
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:
  • Enclosures
not considered:
  • Dikes
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Scrubbers
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • 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 System, Water Supply and Irrigation Systems (22131)
Prevention Program ID:
1000039669
Safety Review Date
May 20, 2010, since latest RMP submission
PHA Update Date
, since latest RMP submission
Safety Regulations
  • ASTM Standards
  • ANSI Standards
  • ASME Standards
Hazards Identified
  • Toxic Release
  • Equipment failure
  • Floods
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Alarms
  • Emergency Power
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
Changes since PHA
  • Increased Inventory
  • Process Detection
  • Mitigation Systems
Training Type
  • Classroom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
May 15, 2015, since latest RMP submission
Training Review Date
May 15, 2015, since latest RMP submission
Maintenance Review Date
May 15, 2015, since latest RMP submission
Maintenance Inspection Date
May 15, 2015, 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
May 15, 2015
Compliance Audit Change Completion Date
May 15, 2015
Incident Investigation Date
Nov. 22, 2008
Incident Invest. Change Completion Date
Nov. 22, 2008
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:
May 15, 2015
Local Response Agency:
Local Response Agency Phone:
(504) 349-5360
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

This document was developed to comply with the Environmental Protection Agency's (EPA's)

Risk Management Program II, under Section 112 (r) of the Clean Air Act (CAA) Amendments of

1990, 40 CFR Part 68. The disinfection process is covered under this regulation at the Jefferson

Parish West Bank Water Treatment Plant (WTP).

This document contains information on the chlorine systems at the West Jefferson Water

Treatment Plant that may be used as a training reference in initial and recurring operator and

maintenance training. Training on process fundamentals, operations, and maintenance, coupled

with the current mitigation systems, will reduce the potential hazards to plant personnel and the

surrounding community.

An Emergency Response Program and an Incident Investigation Program are included. These

two programs have been incorporated into both initial and recurring training.

Hazard Assessment

The Hazard Assessment is comprised of a Worst Case and Alternative Release Scenario for the

chlorine system, as well as a 5-Year Accident History for the same. Because the West Bank

WTP is located in a residential neighborhood and is not subject to OSHA programs, the West

Bank WTP is categorized in Risk Management Program Level II.

Worst Case Scenario

The Worst Case Scenario is defined as a ton container (2,000 pounds) of chlorine being

released by a catastrophic event within a 10-minute duration and includes the passive mitigation

related to the chlorine building. The toxic endpoint for chlorine was determined to be 0.9 miles at the 3 ppm toxic

endpoint concentration specified by EPA using the RMP*Comp ver.1.07 software. It should be noted that at this concentration, a person

may be exposed for up to one hour without suffering permanent injuries.



Alternative Release Scenario

The Alternative Release Scenario of chlorine was based on a fusible plug release from an

overfilled 1-ton cylinder containing 2350 lbs with
a release rate of 437 lbs/minute.

A total release of 2350 lbs of chlorine was assumed in this alternative scenario. The

toxic end point for the Alternative Release Scenario was determined to be 0.3 miles using the RMP*Comp Ver.1.07 software;even though we currently we have a scrubber which could contain all of

the chlorine gas. This statement is based on a 2400 SCFM chlorine gas release rate and a 3000 SCFM

scrubber exhaust rate that maintained the chlorine building under negative pressure during the

entire period of the release. It should be noted that this Alternative Release Scenario release

rate of 437 lbs/minute is 2.2 times greater than the Worst Case Scenario required by Risk

Management Program, described above.



Management Program

A Document Management System was established to attribute responsibility for the

development, implementation, and maintenance of the Risk Management Program. The

Program requires that a Compliance Audit to certify compliance with RMP Accident Prevention

provisions at least every three years. In addition, a revised Risk Management Plan (RMP) must

be submitted to EPA every 5 years (within 5 years of the previous submission) or within 6

months of a change that results in a revised process hazard assessment or hazard review, or

that requires a revised offsite consequence analysis. The Document Management System is

largely a function of the Risk Management Program Team, comprised of the Water Purification

Superintendent II, the Water Plant Maintenance Superintendent, Pump Equipment Mechanic,

and Water Quality Scientist IV. The Water Purification Superintendent II has the ultimate

responsibility for this Risk Management Plan.



Prevention Program

The Prevention Program is comprised of Safety Information, Hazard Review, Operating

Procedures, Training, Maintenance, Incident Investigation, and Compliance Audit procedures.

Each has an entire chapter devoted to it in this RMP, and is described
in more detail below.



Chemical Safety Information

Comprehensive chemical data is provided in this section and includes: regulatory reporting

action thresholds, health hazard and chemical exposure limitations, as well as physical

properties of chlorine. It is also imperative that plant operators and managers are appraised of

the potential health hazards and exposure limits associated with this chemical.

Process Safety Information

Process Safety Information includes the basic specifications on each process along with specific

details such as Maximum Intended Inventory, Safe Upper and Lower Temperatures, Safe Upper

and Lower Pressures, and Codes and Standards Used to Design, Build and Operate the

Process.

Hazard Review

A Hazard Review was also conducted for the chlorine systems. The Hazard Review technique

used was a hybrid Hazard and Operability Study (HAZOP), in the form of a "What If" analysis.

The "What If" was developed from HAZOP experience at similar chlorine systems. The Hazard

Review team consisted of plant management, process operating and maintenance personnel,

outside process design engineers, and consultants knowledgeable in the Hazard Review

process itself.

Recommendations

All previous recommendations have been implemented or addressed. There are no

recommendations for improvements at this time.



Operating Procedures



Basic chlorine system operating procedures have been developed and documented for the

facility. They provide system descriptions, specifications, and operating procedures for the

chlorine gas system. Procedures include Start-up, Shutdown, Normal, Abnormal, and

Emergency Operation. Also included are Troubleshooting Procedures.



Training



Training is required by the EPA to be included in the Risk Management 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 do
cumentation. Additionally, a

Training Record has been compiled and included for all affected personnel associated with the

covered processes.





Maintenance



Basic chlorine system maintenance procedures have been developed with associated

documentation forms. 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.



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 chlorine 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.



Compliance Audits



Internal Compliance Audits must be conducted every three years to verify compliance with the

programs and procedures contained in this document. The Plant Manager must certify that the

Risk Management Program team has evaluated 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 audit reports must always be retained in the RMP file.





Emergency Response Program



The Emergency Response Program is included as part of the Risk Management Program, in

case a significant release ever occurs. As in all the above programs, it is important to review this

program regularly. The Rule, 40 CFR 68.95 requires training for all emp
loyees "in relevant

procedures" of the Emergency Response Program.



It is recommended that training on the specific plant safety procedures take place upon initial

employment and every year thereafter, as with most of the other RMP training programs. Other

training recommendations are discussed in the Emergency Response Program as appropriate to

the level of response.







Summary of Action Items for the West Bank Water Treatment

Plant



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. All incident investigations must be conducted

within 24 hours of each incident.



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 West Bank WTP.



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 Jefferson Parish 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. CDM facilitated the development of operating procedures for the facility,

and they 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 Jefferson Parish must train or cause to be

trained 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 manne
r, 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 68.58 requires Jefferson Parish to conduct a Compliance Audit 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 Rule, 40 CFR 68.95 requires training for all employees "in relevant procedures" of the

Emergency Response Program. It is recommended that training on the specific plant

procedures take place upon initial employment and every year thereafter, as with most of the

other RMP training programs. Other training recommendations are discussed in the Emergency

Response Program as appropriate to the level of response. The Emergency Response Program

is discussed in Section 11. Training documentation forms are provided in Section 8.



The Rule, 40 CFR 68.19 requires Jefferson Parish to submit a revised the Risk Management

Plan (RMP) to EPA within 5 years of May 15,2015 or within 6 months of a change

that results in a revised process hazard assessment or hazard review, or that requires a revised

offsite consequence analysis.





Executive Summary