East Bank Water Treatment 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 Jefferson Parish East Bank Water Treatment Plant (WTP). To meet the regulation requirements, this binder contains useful information on the chlorine system. 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 surrounding 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 the East Bank WTP'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 East Bank WTP falls. Residences lie within the EPA-defined endpoint concentrations of the plant's Worst-Case releases. Therefore, the plant is ineligible for Program I. The East Bank WTP is operated by public pe rsonnel and therefore excluded from Program III. The East Bank WTP is included in Risk Management Program II. The Hazard Assessment is provided in Sections 1 through 3. 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. A mitigation factor of 0.55 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 model. The toxic endpoint for chlorine was determined to be 0.9 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). Alternative Release Scenario The Alternative Release Scenario of chlorine was also modeled using RMP Comp. An estimation of approximately 348 pounds of chlorine gas released was d erived from the scenario of a vacuum regulator check unit failure. The toxic end point for the ARS was determined to be 0.30 miles by RMP Comp. 5 Year Accident History No releases have been documented in the past five (5) years. 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 covered 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 Table ES-1 lists the employees responsible for the Risk Management Program development, implementation, and maintenance. The Plant Superintendent has the ultimate respo nsibility. 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 below. 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 to 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 appraised of the potential health hazards and exposure limits associated with this chemical. 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. 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 f orm 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 itself. Recommendations The result of the Hazard Review is a set of recommendations for the plant to implement. Rule 40 CFR 68.50 requires Jefferson Parish 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. 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: System 1 - Pressure System 2 - Vacuum ~ Examine design of scrubber as possible leak mitigation and/or use of alternative disinfectants. ~ Paint iron pipe in system 1 yellow. Label all piping and contents and flow directions. ~ Implement chlorine vendor audit policy. Examine vendor quality control procedures to ensure structural integrity of ton cylinders. *Because the cylinders are transported from system 2 to system 1 using a forklift. ~ Install cylinder mounted vacuum regulator check units to system 1. ~ Install audible alarms to be heard outside of chlorine rooms. ~ Install redundant chlorine detectors. ~ Vent ton cylinder mounted vacuum regulators outside. ~ Specify in vendor contract that cylinder valves must be aligned properly and the threads in good condition or the cylinder will be returned. ~ Change stainless steel whips as needed, but at least once annually. ~ Examine engineering alter natives to expand chlorine system 1 building to provide additional storage room and storage. Possible options discussed at the review included removing the steps on the west side of the building and replacing the windows on the east side of the building with a garage door. However, the consensus was that a new/larger building for system 1 is necessary. ~ Consider obtaining operating and emergency procedure training from an offsite professional. ~ Consider installing panic hardware on chlorine room doors to ease escape in the event of an emergency. 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 documentation. 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 chlor ine 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 recommendations, 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 in Section 12. As stated previously, this document is public information. Its purpose is submission to the EPA to be uploaded on a public-access database. No other portion of the East Bank WTP Risk Management Program must be made available to the public. Summary of Action Items for the East Bank Water Treatment 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 East Bank WTP. 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 Jefferson Parish may certify in writing that the employee has the required knowledge, skills, a nd 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 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 d ocumentation 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 Jefferson Parish 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 8. 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, 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. Jefferson Parish 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. East Bank Water Treatment Plant: LAN# 19539 |