Carrollton Water Purification Plant - Executive Summary

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 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. An outline of the Risk Management Program is provided in Figure ES-1.  
 The disinfection process (i.e., chlorine system) 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 binder contains useful information on the chlorine and 
 ammonia systems.  The technical information herein 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 recommended process modifications discussed below, will reduce the potential 
 hazards to plant personnel and the surrou 
nding community. 
 An Emergency Response Program and an Incident Investigation Program are included.  These two programs should be 
 an integral part of both initial and recurring training. 
 A Risk Management Plan (RMP), in the format required by the EPA, is included at the end of the main body 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. 
 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 Carrollton WPP falls.  Residences lie within the EPA-defined endpoint concentrations of 
Worst-Case releases. Therefore, the plant is ineligible for Program I.  The Carrollton 
 Water Purification Plant is operated by public personnel and therefore excluded from Program 
 III.  Carrollton Water Purification Plant is included in Risk Management Program II.  The 
 Hazard Assessment is provided in Chapters 1 through 3. 
 Worst Case Scenario 
 The Worst Case Scenario (WCS) for the chlorine system is defined as a 55-ton railcar (110,000 
 pounds) of chlorine 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 chlorine was determined to be 9.9 miles by RMP Comp at the 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). 
 The WCS for the ammonia system (10,000 gallon tank - 80% full) is defined as 8,000 gallons 
 (45,520 lbs 
) of ammonia being released by a catastrophic event within a 10 minute duration.  This 
 scenario was developed and modeled using the EPA approved dense gas dispersion model 
 SLAB.  The toxic endpoint for ammonia was determined to be 0.83 miles by the SLAB model at 
 the 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). 
 Alternative Release Scenario 
 The Alternative Release Scenario (ARS) of chlorine was modeled using RMP Comp. An 
 estimation of approximately 3983 pounds of chlorine gas released was derived from the scenario 
 of a flexible connection failure.  The toxic endpoint for the chlorine system ARS was determined 
 to be 0.8 miles. 
 The alternative release scenario of ammonia was also modeled using SLAB.  An estimation of 
 approximately 2700 pounds of ammonia released was derived from the scenario of an outdoors 
 piping failure.  The to 
xic endpoint for the ammonia system ARS was determined to be 0.17 
 5 Year Accident History 
 One (1) qualifying chlorine accident has been documented within the past 5 years.  In 1998 a 
 minor release of chlorine occurred due to a check valve that cracked during rail car 
 disconnection.  The crack separated the valve from the rest of the piping and allowed chlorine to 
 escape into the atmosphere.  Four employees were exposed to chlorine gas during the release, 
 however, all four were wearing protective equipment and escaped serious injury.  There were 
 no off-site consequences or impacts caused by this incident. 
 Management Program 
 The Management Program consists of the Document Management System described below: 
 Document Management System 
 A Document Management System was established to attribute responsibility for the 
 development, implementation, and maintenance of the Risk Management Program. The 
 Program must be updated every three years, or any time a co 
vered process undergoes a physical 
 or administrative modification.  The Document Management System is largely a function of the 
 Risk Management Program Team, described below in Table ES-1. 
 Risk Management Program Team 
 Tables ES-1 lists the employees responsible for the Risk Management Program development, 
 implementation, and maintenance. The Plant Superintendent has the ultimate responsibility. 
 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. 
 Safety Information 
 Safety Information is divided between Chemical Safety Information and Process Safety Information.  Each is briefly described 
 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 and 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 appraised of the potential health hazards and exposure limits associated with 
 these chemicals. 
 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 Sta 
ndards 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 and ammonia 
 Chlorine System Hazard Review 
 A Hazard Review was also conducted for the chlorine system.  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 experts, 
 outside process design engineers, and consultants knowledgeable in the Hazard Review process 
 The result of the Hazard Review is a set of recommendations for the plant to implement.  Rule 
 40 CFR 68.50 requires the Sewerage & Water Board to ensure that problems identified are 
 "resolved in a timely man 
ner."  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.   
 Please note that these are not the recommendations of Camp Dresser & McKee, Inc.  Rather, 
 they are recommendations developed by the Hazard Review Team with a consensus from all 
 team members.  CDM's role was to facilitate the Hazard Review process.  
 Recommendations are summarized below: 
 ~    Conduct feasibility study of alternative disinfectants and/or installation of chlorine 
        scrubbing/enclosure alternatives for both the rail car and 1-ton cylinder systems 
 ~    Install additional chlorine detector north of evaporators 
 ~    Move vacuum regulator (upstream) closer to evaporators 
 ~    Install temperature switch interlock on evaporator bath to automatic supply shut-off 
 ~    Install leak detector interlock to supply shut-off 
 ~    Re-evaluate piping/valving a 
nd consider additional expansion tanks 
 ~    Install chlorine gas/liquid filters 
 ~    Construct sheltered area with monorail for one-ton container storage 
 ~    Mount vacuum regulator check units directly on the ton containers 
 ~    Install panel hardware on evaporator room doors 
 ~    Install speaker system so that all employees may hear warning/emergency 
 ~    Coordinate Emergency Response Procedures with New Orleans HAZMAT. 
 Ammonia System Hazard Review 
 The hazard review for the ammonia system was conducted as an EPA approved Facility Audit.  
 The recommendations resulting from the audit include the following: 
 ~     Properly label all liquid/vapor lines, 
 ~    Conduct a feasibility study of enclosing/scrubbing the ammonia storage tank. 
 Operating Procedures 
 Basic chlorine and ammonia system operating procedures have been developed and 
 documented for the Carrollton WPP.  They provide system descriptions, specifications, and 
 operating p 
rocedures for the chlorine gas system.  Procedures include Start-up, Shutdown, 
 Normal, Abnormal, and Emergency Operation.  Also included are Troubleshooting Procedures. 
 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 documentation. 
 Additionally, a Training Record has been compiled and included for all affected personnel 
 associated with the covered processes. 
 ~    Install warning system for offices adjacent to ammonia tank. 
 ~    Implement special emergency procedures for adjacent office area. 
 ~    Coordinate Emergency Response Plan with New Orleans HAZMAT. 
 Basic maintenance procedures have been developed with associated documentation forms. 
 Sound preventive maintenance will reduce potential hazards to personnel onsite, as well as to 
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 or 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. 
 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 of which must always be maintained.  This means that 
 in the year 2006, the Compliance Audit Report for the year 2000 may be discarded. 
 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 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 re 
commendations, i.e., OSHA 8, 24, and 40 hour training are discussed in the 
 Emergency Response Program as appropriate to the level of response. 
 Risk Management Plan 
 A copy of the Risk Management Plan (EPA Submittal) is provided. As stated previously, this 
 document is public information.  Following submission to the EPA, the information will be 
 uploaded on a public-access database.  No other portion of the Carrollton WPP Risk 
 Management Program must be made available to the public.  
 Summary of Action Items for the Carrollton Water Plant 
 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 10. 
 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  
 Purification Plant. 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 7.  
 CDM facilitated the development of operating procedures for the Carrollton WPP, 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 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. 
 The RMP Rule, 40 CFR 68.58 requires the New Orleans 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 p 
rocedures" 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, 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 10. 
 The S&WB must submit the Risk Management Plan (RMP) to the appropriate agency by June 21, 
 1999.  The RMP is a summary of the Program, and is located in Section 12. The RMP will be 
 submitted electronically using EPA's RMP Submit software.
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