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Algiers Water Purification Plant

Parent Companies:
Sewerage and Water Board of New Orleas
EPA Facility ID:
100000086827
Other ID:
LA0061191
Facility DUNS:
0
Parent Company DUNS:
0

Location:

Address:
900 Lamarque Street
New Orleans, LA 70114
County:
ORLEANS
Lat / Long:
29.944, -90.044 (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) 585-2000
Address:
625 St. Joseph Street
New Orleans, LA 70165 -6500
Foreign Address:

Person responsible for RMP implementation:

Name:
Jack Huerkamp
Title:
Chief of Engineering

Emergency contact:

Name:
Vincent Fouchi
Title:
Water Superintendent
Phone:
(504) 865-0565
24-hour phone:
(504) 329-4776
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(504) 529-2837
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Orleans Parish LEPC
Full-Time Equivalent Employees:
27
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:
1000009705
CBI claimed:
No
Program Level:
2
NAICS:
Water Supply and Irrigation Systems (22131)
Chemical name
CAS#
Quantity (lbs.)
CBI
Chlorine
7782-50-5
12,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Camp, Dresser & McKee
Address:
1515 Poydars St Suite 1350
New Orleans, LA 70112
Foreign Address:

Phone:
(504) 799-1165

Latest RMP Submission:

Date:
June 18, 2009
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
No
RMP ID:
1000008413

Deregistration:

Date:
Effective Date:
Reason:
Other
Other Reason:
Source no longer stores Chlorine at Facility

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:
  • 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)
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, Water Supply and Irrigation Systems (22131)
Prevention Program ID:
1000007456
Safety Review Date
June 24, 2008, since latest RMP submission
PHA Update Date
, since latest RMP submission
Safety Regulations
  • ASTM Standards
  • ANSI Standards
  • ASME Standards
Hazards Identified
  • Toxic Release
  • Floods
  • Hurricanes
Process Controls
  • Vents
  • Scrubbers
  • Interlocks
  • Alarms
  • Emergency Power
Mitigation Systems
  • Enclosure
Monitoring Systems
  • Process Area
Changes since PHA
  • Reduced Inventory
Training Type
  • On the Job
Competency Testing
  • Observation
Procedure Review Date
May 8, 2008, since latest RMP submission
Training Review Date
April 8, 2009, since latest RMP submission
Maintenance Review Date
May 8, 2008, since latest RMP submission
Maintenance Inspection Date
May 30, 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
June 24, 2008
Compliance Audit Change Completion Date
Aug. 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:
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 AgencyA!A|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 chlorine is covered under this regulation at the Sewerage and Water Board of New Orleans (S&WB) Algiers Water Purification Plant (WPP).

To meet the regulation requirements, this report contains useful information on the chlorine 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*Submit 2004, 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 Algiers WPPA!A|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 and Alternative Release Scenario for the chlorine system, as well as
a 5-year Accident History for the same. The Hazard Assessment was conducted as an initial screening procedure as part of determining which Program Level (I, II, or III) the Algiers WPP falls. Residences lie within the EPA-defined endpoint concentrations of AlgiersA!A| Worst-Case releases. Therefore, the plant is ineligible for Program I. The Algiers Water Purification Plant is operated by public personnel and therefore excluded from Program III. Algiers Water Purification Plant is included in RMP II. The Hazard Assessment is provided in Section 1.

ES.1.1 Worst-Case Scenario
The Worst-Case Scenario (WCS) is defined as a 1-ton container (2,000 pounds) of chlorine being released by a catastrophic event within a 10 minute duration. A passive mitigation factor is allowed for this process due to the building which encloses the chlorine system. This scenario was developed and modeled using the EPA approved RMP*Comp software. The toxic endpoint for chlorine was determined to be 0.9 miles for RMP*Comp at the 0.0087 mg/L (3 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 (ARS) of chlorine was also modeled using RMP*Comp. An estimation of approximately 348 pounds of chlorine gas released during 30 minutes was derived from the scenario of a flexible connection failure. This release is contained within the chlorine storage room. The Algiers WPP has a scrubbing system as a means of chlorine release active mitigation, which may be considered when modeling alternative release scenarios. The scrubber is sized to neutralize the 2000 pounds of chlorine (the entire contents of a 1-ton container.) As a result, the release would be entirely neutralized in the chlorine system room and the radius of impact would effectively be zero.

ES.2 Five-year Accident History
No major accident
s 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 2009.

ES.3 Management Program
The Management Program consists of the Document Management System described below:

ES.3.1 Document Management System
A Document Management System was established to attribute responsibility for the development, implementation, and maintenance of the RMP. 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 Team, described below in Table ES-2.

ES.3.2 Risk Management Program Team
Tables ES-1 lists the employees responsible for the RMP development, implementation, and maintenance. The Plant Superintendent has the ultimate responsibility.

Table ES-2
Algiers Water Plant RMP Program
Team Member Position/Expertise
Bob Moeinian Chief of Operations
Vincent Fouchi Water Purification Superintendent
Gary Bergeron Water Purification Operator IV
Keith Pete Safety Engineer

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 chapter devoted to it in this RMP, and is described in more detail below.

ES.4.1 Safety Information
Safety Information is divided between 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 chlorine. This information was compiled from numerous sources, and is intended t
o be a one-stop source for the reader seeking data on this compound. 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 aware of the potential health hazards and exposure limits associated with chlorine.

ES.4.3 Process Safety Information
Process Safety Information was meticulously compiled on each system studied. Basic specifications on each process are included in this document for easy reference. 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 are provided in this section. Used as a training reference, together with the Process Schematics, the reader will readily understand the function and operation of the plant chlorine system.

ES.5 Hazard Review
The Hazard Review conducted for the chlorine system in 2004 has been reviewed and updated. Progress made to date on the 2004 recommendations is also provided.

Recommendations
The result of the Hazard Review is a set of recommendations for the plant to implement. Rule 40 CFR 68.50 requires the S&WB to ensure that problems identified are "resolved in a timely manner." For those items that can not be promptly resolved, it is recommended that a schedule be developed that addresses those issues, with responsibility for each assigned to the appropriate personnel.

Recommendations from 2004 that are still in the process of being completed include the following:
A??? Install gas filters before the chlorinators.
A??? Consider the installation of ceiling mounted room heaters rather than portable space heaters
A??? Evaluate feasibility of hiring an additional Health and Safety Officer to assist with the training, regulatory compliance, and health and safety concerns

ES.6 Operating Procedures
Basic chlorine system operati
ng procedures have been developed and documented for the Algiers WPP. 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.

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.

ES.8 Maintenance
Basic chlorine system maintenance procedures have been developed with associated documentation forms and are available at the facility for operatorsA!A| use. 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.

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 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.

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 Plant Manager must certify that the RMP team has evaluated compliance with the provisions of the Program, and verify that the procedures and practices are adequat
e and are being followed. Audit Report Forms are provided, the two most recent of which must always be maintained. This means that in the year 2011, the Compliance Audit Report for the year 2005 may be discarded. The most recent compliance audit for the Algiers WWP was performed in 2008. A copy of this audit is provided in Appendix D.

ES.11 Emergency Response Program
The Emergency Response Program is included as part of the RMP, 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 employees 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, i.e., OSHA 8, 24, and 40 hour training are discussed in the Emergency Response Program as appropriate to the level of response.

ES.12 Risk Management Plan
A copy of the RMP (EPA Submittal) is provided in Section 12 of this report. As stated previously, this submittal will be made public information. Its purpose is submission to the EPA to be uploaded on a public-access database. No other portion of the Algiers WPP RMP must be made available to the public.

ES.13 Summary of Action Items for the Algiers WPP
The RMP Rule, 40 CFR 68.42 requires that details of all accidental releases be recorded from this date forward. 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 Algiers 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 a
ssigned 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 Algiers 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 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 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. Documentation on incidents investigations between 2004 and 2009 are included in Appendix D.

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 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 o
ther RMP training programs. Other training recommendations, i.e., OSHA 8, 24, and 40 hour training 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 S&WB must submit the RMP to EPA by June 21, 2009. The RMP*eSubmit print outs are located in Section 12.