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TPCG Pollution Control - North Treatment Plant

Parent Companies:
Terrebonne Parish Consolidated Government
EPA Facility ID:
100000136952
Other ID:
Facility DUNS:
0
Parent Company DUNS:
0

Location:

Address:
2000 St. Louis Canal Road
Houma, LA 70364
County:
TERREBONNE
Lat / Long:
29.629, -90.732 (Get map)
Method:
Interpolation - Digital map source (TIGER)
Description:
Other
Horizonal accuracy:
1 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
Terrebonne Parish Consolidated Govt
Phone:
(985) 873-6731
Address:
P. O. Box 2768
Houma, LA 70361
Foreign Address:

Person responsible for RMP implementation:

Name:
Dwayne Deroche
Title:
WWTP Superintendent

Emergency contact:

Name:
Dwayne Deroche
Title:
WWTP Superintendent
Phone:
(985) 673-6727
24-hour phone:
(985) 873-9313
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Terrebonne Parish LEPC
Full-Time Equivalent Employees:
16
Covered by OSHA PSM:
No
EPCRA section 302:
No
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
June 23, 2004
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Unspecified process
RMP ID:
1000056489
CBI claimed:
No
Program Level:
2
NAICS:
Waste Treatment and Disposal (56221)
Chemical name
CAS#
Quantity (lbs.)
CBI
Sulfur dioxide (anhydrous)
7446-09-5
14,000
No
Chlorine
7782-50-5
14,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Richard Martin
Address:
P. O. Box 3106
Houma, LA 70361
Foreign Address:

Phone:
(985) 856-0424

Latest RMP Submission:

Date:
July 14, 2014
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000045520

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 Unspecified process)
CBI claimed:
No
Percent weight:
Physical state:
Gas
Model used:
EPA's RMP*Comp Ver. 1.07
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
Public OCA Chemical (in Unspecified process)
CBI claimed:
No
Percent weight:
Physical state:
Gas
Model used:
EPA's RMP*Comp Ver. 1.07
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 Unspecified process)
CBI claimed:
No
Percent weight:
Physical state:
Gas
Model used:
EPA's RMP*Comp Ver. 1.07
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
Public OCA Chemical (in Unspecified process)
CBI claimed:
No
Percent weight:
Physical state:
Gas
Model used:
EPA's RMP*Comp Ver. 1.07
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

No Prevention Program level 3

8. Prevention Program level 2

, Waste Treatment and Disposal (56221)
Prevention Program ID:
1000036171
Safety Review Date
May 14, 2009, since latest RMP submission
PHA Update Date
, since latest RMP submission
Safety Regulations
  • None
Hazards Identified
  • Toxic Release
  • Corrosion
  • Equipment failure
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Manual Shutoffs
  • Alarms
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
Training Type
  • None
Competency Testing
  • Demonstration
  • Observation
Procedure Review Date
May 15, 2014, since latest RMP submission
Training Review Date
May 15, 2014, since latest RMP submission
Maintenance Review Date
Nov. 9, 2009, since latest RMP submission
Maintenance Inspection Date
Jan. 13, 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
April 13, 2012
Compliance Audit Change Completion Date
April 13, 2012
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:
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:
(985) 873-6357
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

Facility LDEQ Agency Interest (AI) Number: 19176





United States Environmental Protection Agency (U.S. EPA) rule "Chemical Accident Prevention Provisions," 40 CFR Part 68, states that "the goal of the rule is to prevent accidental releases of toxic and flammable substances that can cause serious harm to the public and the environment and to mitigate the effects of releases that do occur".



The process that is covered under the Risk Management Program for the Terrebonne Parish Consolidated Government North Treatment Plant (TPCG-NTP) includes the use and storage of seven (7) 2,000-pound chlorine tanks and seven (7) 2,000-pound sulfur dioxide tanks. The substances are used in the treatment of wastewater at the Terrebonne Parish Consolidated Government facility located at 2000 Saint Louis Canal Road near Houma, Louisiana. The individual storage containers of the covered process do not exceed the threshold quantities outlined in 40 CFR Part 68; however, the containers for each substance are maintained in close enough proximity as to be considered one process for chlorine and sulfur dioxide. The facility process met the Program 2 criteria, because it did not qualify for consideration under Program 1 due to the distance of the nearest receptor within the impact areas identified during the evaluation of the worst-case scenarios, and did not qualify for Program 3, because the facility is not subject to the OSHA Process Safety Management requirement.



Program 2 requirements include: 1) the development of a management program which identifies the responsibilities of management personnel relative to the Risk Management Program, 2) a Prevention Program to establish procedures and document information that will help to prevent an accidental release, 3) an Emergency Response Program that outlines the necessary procedures and contacts in the event of an accidental release, 4) and the evaluation of a worst case and alternative scenario of a potential release from the
covered process.



The TPCG has prepared specific accidental release prevention and emergency response policies to ensure the safety of employees and receptors, which fall within the distance of the worst-case scenario endpoint. These policies include monthly maintenance and inspection procedures to ensure proper operation of the equipment and integrity of the storage vessels; biannual safety training by certified instructors regarding equipment and regulated substance use. These policies are documented in written operating and maintenance procedures.





1.0 PROGRAM IDENTIFICATION



1.1 APPLICABILITY OF 40 CFR SECTION 68



1.1.1 Stationary Source Identification



Clean Air Act (CAA) Section 112(r)(2)(c) defines stationary sources as "any buidlings, structures, equipment, installations, or substances emitting stationary activities which belong to the same industrial group, which are located on one or more contiguous properties, which are under the control of the same person, and from which an accidental release may occur."



The Terrebonne Parish Consolidated Government-North Treatment Plant (TPCG-NTP) meets the definition of stationary source.



1.1.2 Regulated Substance Identification



A facility is subject to the Chemical Accident Prevention Provisions (40 Code of Federal Regulations (CFR) Part 68) if they handle, manufacture, use or store any of the toxic and/or flammable substances listed in 40 CFR 168.130 above the specified threshold quantities in a process. A review of site operations revealed that two substances stored on site were regulated under Section 68.130, which include chlorine and sulfur dioxide. Seven 2,000-pound chlorine tanks and seven 2,000-pound sulfur dioxide tanks are stored at the northeast corner of the plant site, next to the sludge press building. The total maximum on-site storage of chlorine is 14,000 pounds, and the total maximum on-site storage of sulfur dioxide is 14,000 pounds. The threshold limits for these
substances are 2,000 pounds and 5,000 pounds, respectively.



1.1.3 Process Identification



A process is defined in 40 CFR 68.3 as "any activity involving a regulated substances, including any use, storage, manufacturing, handling, or on-site movement of such substances, or combination of these activities. For the purposes of this definition, any group of vessels that are interconnected, or separate vessels that are located such that a regulated substance could be involved in a potential release, shall be considered a single process."



One process was identified at the TPCG-NTP. As stated above, seven 2,000-pound chlorine tanks and seven 2,000-pound sulfur dioxide tanks are located at the plant site. Both substances are considered one process due to the close proximity of the chlorine and sulfur dioxide tanks to each other.



1.2 PROGRAM IDENTIFICATION



The process identified at the TPCG North Treatment Plant was determined to meet the criteria for Program 2 status. The facility has had no accidents within the past five years, and the facility is not subject to Occupational Safety and Health Administration, Process Safety Management (OSHA, PSM) requirements, because it is a local governmental facility. However, the endpoint for the worst case scenario falls beyond the boundaries of the facility and reaches public receptors including residences and schools. Because the process does not meet Program 1 or Program 3 status, it must fall within the requirements of Program 2. The program criteria are described in the following sections.



1.2.3 Management Program



Regulations require that a management system be developed to oversee the implementation of the risk management program (RMP). Terrebonne Parish Consolidated Government has assigned responsibility for development, implementation and integration of the RMP persons familiar with the process. Responsibility is documented at the facility.





2.0 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRA
M



Program 2 requires the compilation of up-to-date safety information related to the regulated substances, process, and equipment. The seven elements listed below are part of a general accidental release prevention program, which are detailed in subsequent sections:



A? Safety Information

A? Hazard Review

A? Operating Procedures

A? Training

A? Maintenance

A? Compliance Audits

A? Incident Investigation



2.1 SAFETY INFORMATION



Written safety information pertaining to the hazards of the regulated substances used or produced by the process and information pertaining to the technology and equipment of its process at the North Treatment Plant have been compiled prior to conducting the hazard analysis required by this rule. Safety information required for the RMP include the following:



A? Material Safety Data Sheets (MSDS)

A? Maximum Intended Inventory

A? Safe Upper and Lower Parameters

A? Equipment Specifications

A? Codes and Standards



2.1.1 Material Safety Data Sheets



Material Safety Data Sheets (MSDS) are maintained to identify and understand the hazards posed in the process involving regulated substances. MSDS's for chlorine and sulfur dioxide are maintained at the facility.



2.1.2 Maximum Intended Inventory



2.1.2.1 Chlorine



The maximum number of tanks currently stored at the North Treatment Plant is seven 2,000-pound chlorine tanks. The Chlorine Institute recommends that chlorine tanks not be filled beyond 95% capacity at a maximum temperature of 122A?F. The maximum filling density is 125%.



2.1.2.2 Sulfur Dioxide



The maximum number of tanks currently stored at the North Treatment Plant is seven 2,000-pound sulfur dioxide tanks. Information related to the safe temperature and filling capacity of tanks is provided by the Compressed Gas Association and is provided in the Risk Management document maintained at the facility.



2.1.3 Storage and Process Limits



Storage and process limit
s provide safety information relative to the recommended storage parameters for the specific equipment used on site including tanks and lines. Equipment manuals are maintained at the facility.



2.1.4 Equipment Specifications



Information pertaining to process equipment is used to identify and understand hazards involving the operation of the equipment. Equipment specifications were provided by the manufacturer/supplier and are maintained at the facility.



2.1.5 Codes and Standards



Subpart C, Section 68.48 of the rule states that the owner must ensure that the process is designed according to good engineering practices. Compliance with state and federal codes and industry specific standards meets this requirement. The equipment specification manuals list the codes and standards used for the design and installation of the process equipment.



2.2 HAZARD REVIEW



The hazard review includes the identification and documentation of hazards associated with the handling and use of chlorine and sulfur dioxide, opportunities for malfunctions and errors that could lead to releases, safeguards used or needed to prevent causes of releases, and steps used or needed to detect, or monitor releases. The following two specific hazards are identified by the Chlorine Institute as main causes for chlorine releases.



Reuse of gaskets - according to the Chlorine Manual, prepared by the Chlorine Institute, a release of chlorine is most often a result of reusing gaskets. The operating procedures specify the use of new gaskets during change out of tanks at the NTP.



Improperly made up pipe joints - Specifications for pipe joints are outlined in the equipment manuals for making up pipe joints and are incorporated into the operation procedures for the NTP.



The hazard review provides a means for determining if the process is designed and operated in accordance with standard industry codes and federal and/or local regulations. The review requires a documented insp
ection of the process and operating procedures to ensure compliance. The hazard review must be updated, at a minimum, every five years or after major process changes. A copy of a hazard review checklist provided in the Risk Management Program Guidance for Wastewater Treatment Plants is included in the Risk Management Plan document maintained at the facility. This checklist is used to perform Hazard Reviews at the NTP.



2.3 OPERATING PROCEDURES



Written step-by-step operating procedures that describe activities associated with the covered process are maintained at the facility. Operating procedures were developed based upon manufacturer's/supplier's written specifications as documented in the equipment manuals.



2.4 TRAINING



Safety related training is conducted biannually by certified instructors although it is only required every three years. Training includes classroom instruction and on the job training. Testing is conducted by observing the trainee while he/she performs the operations. Safety information is obtained from the equipment manuals, the MSDS's, and the training courses conducted by certified instructors.



2.5 MAINTENANCE



Equipment is inspected monthly and maintained in accordance with manufacturers or suppliers specifications. Specific maintenance instructions are maintained at the facility. A maintenance action form is used to schedule maintenance activities outside of the regularly scheduled events. A log is kept on file to document the dates and actions completed during maintenance events as well as management oversight of maintenance activities.



2.6 COMPLIANCE AUDITS



Compliance audits are conducted every three years to certify that the process is in compliance with EPA's requirements for the Program 2 Prevention Program. The audit serves as a means for identifying potential deficences related to the procedures and practices developed under the rule. The Compliance Audit Checklist contains the checklist t
hat was provided in the RMP Guidance Document that is used to complete the compliance audit at the NTP. Compliance audits are maintained on file for a minimum of five years.



2.7 INCIDENT INVESTIGATION



Incidents that result in, or reasonably could result in a catastrophic release, are investigated as quickly as possible, but no later than 48 hours following the incident. Investigation results are documented and maintained on file for use in training employees about incident prevention and determining the potential need to re-evaluate operating or safety procedures, or update equipment. The following information is provided during the course of the incident investigation



A? Date of incident

A? Date investigation began

A? Description of incident

A? Factors contributing to incident

A? Recommendations resulting from incident

A? Recommendations, resolutions, and corrective actions shall be documented

A? Findings will be reviewed with affected employees

A? Investigation summaries will be retained for five years



2.8 FIVE YEAR ACCIDENT HISTORY



A review of accidental releases at the NTP which resulted in deaths, injuries, or significant property damage on site or known off-site deaths, injuries, evacuations, sheltering in place, property or environmental damage are documented in the five year accident history. Terrebonne Parish Consolidated Government North Treatment Plant has had no accidental releases under the definition established by this rule.



2.9 CHEMICAL SPECIFIC PREVENTION



The North Treatment Plant & South Treatment Plant Risk Management, Chemical Accidental Release Prevention Program outlines step by step procedures for cylinder receipt, physical leak check, stowage procedures, connection and disconnection and start up. The chlorine and sulfur dioxide containers are stored in a covered area to prevent direct exposure to sunlight and elevated temperatures within the tanks that could result in a rupture. As discussed previously
, the use of new gaskets and the proper make up of pipe joints are used to prevent the release of chlorine or sulfur dioxide. Manufacturer's specifications are followed to ensure safe use of these substances.





3.0 EMERGENCY RESPONSE



Emergency response actions relative to a release at the Terrebonne Parish Consolidated Government North Wastewater Treatment Plant are outlined in the North Treatment Plant & South Treatment Plant Risk Management, Chemical Accidental Release Prevention Program. Response actions have been coordinated with the Terrebonne Parish, Office of Emergency Preparedness (OEP). The telephone numbers for the OEP, the state and local law enforcement agencies, as well as other reporting agencies are included in the above referenced document. Step by step procedures for on site personnel are outlined in the event that a leak is detected including identifying the severity of the release, use of prepackaged repair kits, reporting and follow-up procedures, as well as severe weather procedures. Detailed procedures for use of the repair kits are provided in the equipment specific manuals.