Lee County Solid Waste Resource Recovery Facility - Executive Summary
1.0 EXECUTIVE SUMMARY |
1.1 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICY SUMMARY
The United States Environmental Protection Agency (USEPA) has established a regulatory program to prevent accidental releases of certain regulated substances that may potentially affect public health and the environment. The rule (40 CFR Part 68) requires that some 66,000 facilities across the United States in various industries develop a Risk Management Program (RMP). The RMP incorporates various required elements into a program designed to prevent accidental releases of regulated substances and establish emergency response preparedness in the event of an accidental release of such regulated substances. RMPs must be submitted to the USEPA by the owner or operator of any facility that has a process containing more than a threshold quantity of any of the regulated substances that is covered under the RMP rule. Pursuant to the RMP rule, Ogden Martin Systems of Lee, Inc. (OMSL) has submitted th
is RMP for anhydrous ammonia and propane.
Anhydrous ammonia is a commonly used chemical with various applications in industry and agriculture. By volume, ammonia is the fourth largest industrial chemical produced over 80% of which goes to agricultural fertilizers 1. In addition to ammonia's application as a fertilizer in crop production, some other common uses for ammonia include: air pollution control system reagent, food production and processing, textile and chemical manufacturing, refrigeration (such as refrigerated warehouses) and metal treating.
Anhydrous ammonia is used at the Lee County Solid Waste Resource Recovery Facility (the Facility) exclusively as a reagent in the facility's nitrogen oxide (NOx) control system. The NOx control system is an important part of the Facility's air pollution control equipment that reduces nitrogen oxides to within permitted limits. Nitrogen oxides are pollutants that contribute to acid rain and photochemical smog. Nitrogen oxide (NO) is a
colorless gas produced during high temperature combustion. In ambient air, nitrogen oxide is oxidized to nitrogen dioxide (NO2). The nitrogen dioxide reacts with water in ambient air to form nitric acid, which contributes to the formation of acid rain. Nitrogen oxides also contribute to the formation of photochemical smog by reacting with sunlight to form ozone (O3) in the atmosphere. The Facility's NOx control system reduces nitrogen oxides by the injection of anhydrous ammonia into the furnace section of the boilers. In the boilers, a reaction takes place between the ammonia, nitrogen oxide and oxygen. The resulting products of this reaction are the major components in the air we breathe - nitrogen gas (N2) and oxygen - and water. A significant environmental benefit is achieved through the use of anhydrous ammonia in the operation of the NOx control system.
The propane, similar to that used in backyard barbecue grills, is utilized at the Facility to fire auxiliary burners. The auxi
liary burners increase combustion temperatures during start-up or help to maintain a minimum required temperature until the refuse fire is burnt out during shutdown. These auxiliary burners may also be used during normal operation to ensure proper combustion.
OMSL operates the Lee County Solid Waste Resource Recovery Facility (the Facility) located in Fort Myers, Florida in a manner that is protective of the health and safety of OMSL employees, contractor employees, the public and the environment. In addition, OMSL is committed to operating the Facility in full compliance with applicable Occupational Safety and Health Administration (OSHA) requirements, federal regulatory requirements and applicable state and/or local requirements.
OMSL previously developed an OSHA Process Safety Management (PSM) Program for anhydrous ammonia. The OSHA PSM rule guides employees in the preventive maintenance, safe management and operation of processes that use regulated substances, and aims to protect
employees from accidental releases of these materials onsite. The USEPA's RMP regulation builds and expands upon the OSHA PSM program by requiring facilities to evaluate offsite impacts to public and environmental receptors, in the event of an accidental release. Key elements of the OSHA PSM program have been incorporated into the USEPA RMP regulation.
As part of the USEPA RMP effort, OMSL has updated the OSHA PSM program for anhydrous ammonia and the associated Process Hazard Analysis (PHA). For propane, a Hazard Review, similar to a PHA was conducted. Among the other important components of OMSL's RMP are the policies and procedures for operation and maintenance of the Facility, and the facility-specific Emergency Response Plan (ERP). OMSL has operated the regulated processes for a number of years now without a release due to these solid preventive maintenance programs, safe design and operating practices, and established training programs.
OMSL's Facility Manager has the primar
y responsibility for this RMP and its implementation.
1.2 STATIONARY SOURCE DESCRIPTION
The Lee County Solid Waste Resource Recovery Facility is a waste-to-energy (WTE) facility that burns municipal solid waste and recovers steam to produce electricity. Each day, this WTE facility converts approximately 1,200 tons of Lee and Hendry Counties' municipal solid waste into electricity.
Two processes at the Facility involve the use of a substance regulated under 40 CFR Part 68, thereby requiring the preparation and implementation of an RMP. These covered processes, include the anhydrous ammonia injection system for NOx control and the propane-fired auxiliary fuel system, as previously described in Section 1.1, above. The specific NOX control system utilized at the Facility is a Selective Non-Catalytic Reduction (SNCR) system.
Anhydrous Ammonia System
A maximum quantity of approximately 10,200 gallons of anhydrous ammonia is stored under pressure at the Facility. Administrative controls
(at 85 % of tank capacity) are used to ensure that this maximum is not exceeded.
Both passive and active mitigation systems are used by the Facility to limit the likelihood and/or severity of an accidental release of anhydrous ammonia. Passive mitigation systems do not require human, mechanical or energy input, such as the concrete dike that surrounds the storage tank area. Conversely, active mitigation systems do require human, mechanical or energy input for initiation. Leak detectors and alarms, excess flow valves, pressure relief valves and emergency shut-off devices are examples of the active mitigation systems in place at the Facility.
A maximum quantity of approximately 51,000 gallons of propane is stored under pressure at the Facility. Administrative controls (at 85 % of tank capacity) are used to ensure that this maximum is not exceeded.
To limit the likelihood and/or severity of an accidental release of propane, heat detectors and alarms, excess flow valves,
pressure relief valves, emergency shutoff devices and a heat-activated deluge system have been installed on the propane system as active mitigation safety devices.
1.3 WORST CASE AND ALTERNATIVE CASE ACCIDENTAL RELEASE SCENARIOS
1.3.1 Anhydrous Ammonia
Worst Case Accidental Release Scenario
For each covered process at a facility, 40 CFR 68 requires that a "worst case" accidental release scenario be developed based on several worst case assumptions, as discussed herein. The most unlikely, worst case accidental release scenario for the SNCR system as defined by the regulation could only occur as a result of catastrophic failure of the anhydrous ammonia storage tank. Such an occurrence would only be precipitated by a most unusual event or an unlikely set of conditions.
The regulation specifies that the worst case accidental release quantity must be the maximum amount of anhydrous ammonia held in the largest, single vessel taking into account administrative controls that limit this
maximum storage quantity. A release rate of 10-minutes is specified in the regulation for the worst case analysis of substances that are normally gases at ambient temperature and handled as a gas or as a liquid under pressure, such as anhydrous ammonia. This release rate is based on the USEPA's Technical Guidance for Hazards Analysis, which is consistent with other mechanisms used for community emergency planning activities under the Emergency Planning and Community Right-to-Know Act (EPCRA). Furthermore, the regulation stipulates that active mitigation systems (such as excess flow valves, alarms or emergency shut-off devices) cannot be considered in defining the worst case scenario, and assumes that all released ammonia would behave as a gas in defining the worst case scenario. Based on these parameters set by the regulation, none of the Facility's active or passive mitigation systems were considered in the worst case accidental release scenario.
Additional conservative assumptions
have been specified by the USEPA in the analysis of the worst case accidental release scenario. These assumptions are a low wind speed, a highly stable atmosphere and use of the maximum ambient temperature over a three-year period. These worst case assumptions are used to predict a highly conservative distance to a "toxic" endpoint as defined by the regulations. For anhydrous ammonia, the "toxic" endpoint is specified as an airborne concentration of 0.14 milligrams per liter (mg/L) or 200 parts per million (ppm). This endpoint is based upon the Emergency Response Planning Guideline (ERPG-2) as developed by the American Industrial Hygiene Association (AIHA). This value represents the maximum airborne concentration below which nearly all individuals could be exposed for one-half to one hour without experiencing or developing irreversible or other serious human health effects or symptoms that could impair their ability to take protective action.
For OMSL, the worst case accidental relea
se scenario for anhydrous ammonia, as defined by the USEPA, would involve a release of 10,200 gallons of anhydrous ammonia (as a gas), over a period of ten minutes. The distance to the "toxic" endpoint for anhydrous ammonia was determined using the Areal Locations of Hazardous Atmospheres (ALOHA) air dispersion model. ALOHA was selected because it is the publicly available air dispersion computer model used by over 3,000 Local Emergency Planning Committees (LEPCs) and fire departments for emergency response and planning purposes.
Based on the "worst case" accidental release assumptions discussed above, the worst case accidental release scenario is projected to reach an offsite endpoint. Public and environmental receptors were located within this projected area. Public receptors are defined by the regulation to include off-site residences; institutions; industrial, commercial and office buildings, and parks or recreational areas inhabited or occupied by the public. Environmental rece
ptors as defined by the regulations include National or State parks, forests or monuments, officially designated wildlife sanctuaries, preserves, refuges, or areas and Federal wilderness areas.
The worst case accidental release scenario requires the assumption that an anhydrous ammonia release would disperse in a circle in all directions from the Facility to the endpoint (as defined above). Whereas, a gaseous release of a anhydrous ammonia would most likely take the form of an elongated plume dispersing only in the downwind direction from the Facility and impacting, more realistically, a much smaller area than the area projected to be affected by the worst case release scenario.
Alternative Accidental Release Scenario
A more realistic, alternative accidental release scenario was evaluated for anhydrous ammonia, in accordance with USEPA regulations. The alternative release scenario was chosen based upon the results of a Process Hazard Analysis and is summarized below.
Leak - The analysis considers the failure of a 1/2" pressure gauge tap on the storage tank that could result in a release of gaseous anhydrous ammonia at a rate of approximately 4 gallons per minute for 60 minutes, before the leak can be detected and stopped or repaired.
Assumptions for ambient conditions, including a wind speed, atmospheric stability, and ambient temperature were used for the alternative scenario analysis, based on the USEPA's RMP Offsite Consequence Analysis Guidance (OCAG) and USEPA's Lookup Tables. To be conservative, passive and active mitigation systems were not considered in the alternative accidental release scenario analysis.
Using the assumptions discussed above, the more likely, alternative accidental release scenario is projected to extend offsite. However, no public or environmental receptors were identified within the endpoint radius.
In the event of an actual release, all of the active and passive mitigation systems/features that are available on the
anhydrous ammonia system at the Facility would be used to contain the spread of any accidental release and mitigate potential impacts of the release. The mitigation systems/features include a concrete containment dike around the anhydrous ammonia storage tank and associated equipment, leak detectors and alarms, excess flow valves, pressure relief valves and emergency shutoff devices.
Worst Case Accidental Release Scenario
The worst case accidental release scenario assumes that 51,000 gallons of propane are released over a period of ten minutes, a vapor cloud forms (with the entire mass within the flammable range), and a detonation occurs. This is the quantity in the largest single vessel associated with the process based on the administrative inventory limit, and the time period for release required by the regulatory definition of the worst case scenario. The highly unlikely worst case release scenario described could occur only as a result of catastrophic failure of
Passive mitigation measures, such as a building, likely would not reduce the worst case scenario impacts since the mitigation system must be capable of withstanding the vapor cloud explosion. Although a water deluge system is in place for the propane process, it is an active mitigation system and does not qualify as a passive mitigation system under the worst case regulatory stipulations.
To evaluate the explosion that might result upon release of propane gas, an industry convention has been adopted by the USEPA as a flammable endpoint. It considers an "overpressure" in pounds per square inch (psi). The worst case flammable endpoint is; therefore, specified as an overpressure of 1 psi, which is a pressure that could result in limited property damage, such as shattered windows and window frame damage. Comparatively, overpressures of 5.0 to 7.0 psi can cause nearly complete destruction of a house (per the Handbook of Chemical Analysis Procedures).
Using the methodology pr
escribed in the regulations, the worst case accidental release scenario is projected to reach an offsite endpoint and potentially impact nearby offsite public receptors. No environmental receptors were identified within the endpoint radius.
Alternative Accidental Release Scenario
A more realistic, alternative accidental release scenario was evaluated for propane, based on the Hazard Analysis that was done for the propane system, as summarized below.
Vessel Piping Leak - The analysis considers the failure of a 1/2" pressure gauge tap on the storage tank that could result in a release of propane gas at a rate of approximately 48 gallons per minute for 60 minutes, before the leak can be detected and stopped or repaired, followed by a vapor cloud fire.
The USEPA OCAG methodology was used to evaluate the extent of a fire that might result upon a limited release of propane gas. Such a fire could possibly flash back and represent a heat radiation hazard to anyone in the vicinity of the p
ropane gas release. This methodology estimates the distance to an endpoint where the concentration of propane gas in air will ignite and propagate a flame (known as the lower flammability limit (LFL)). 36 milligrams per liter (mg/L) is the LFL endpoint used for this alternative release analysis.
Although the regulation allows for consideration of both passive and active mitigation systems in the analysis of the alternative release scenario, to be conservative, the result presented does not account for the use of these systems.
Using the USEPA Lookup Tables, the alternative release is projected to extend just a slight distance offsite from the Facility property line. There are no public or environmental receptors identified within the endpoint radius.
In the event of an actual release, all of the active and passive mitigation systems/features that are available on the propane system at the Facility would be used to contain the spread of any accidental release and mitigate potential
impacts of the release. The mitigation systems/features include an earthen berm around the storage tank and associated equipment, heat detectors and alarms, excess flow valves, pressure relief valves, emergency shutoff devices and a heat-activated deluge system.
1.4 ACCIDENTAL RELEASE PREVENTION PROGRAM
The Facility has an accidental release prevention program that is based upon a foundation of employee awareness and proactive system maintenance. This program is documented in the RMP, and meets the requirements of the RMP regulation.
The Facility provides process safety information to employees through written materials, such as Material Safety Data Sheets, various operating and maintenance manuals, system descriptions and safety procedures. Employees attend periodic training and contractors are briefed on process hazards prior to working onsite. Preventive maintenance and regular inspections are conducted to maintain mechanical integrity. Inspections and testing are scheduled thro
ugh the preventive maintenance program. Hazard analysis documents are reviewed periodically and updated as required. Compliance audits are used to evaluate the need for revising or updating the procedures related to the processes.
1.5 FIVE-YEAR ACCIDENT HISTORY
For the five years prior to the submission of this RMP, there have been no accidental releases, as defined in 40 CFR Part 68.42(a) at the Facility, which resulted in injuries or death to onsite (i.e. Facility or contractor employees) or offsite (i.e. the public). Since there has not been an accidental release, there has not been a need for sheltering in place or evacuation; nor has damage to property or environmental receptors ever occurred as a result of an accidental release. In fact, OMSL has operated the Facility in the safest possible manner since it has commenced operations.
1.6 EMERGENCY RESPONSE PROGRAM
The Facility has an Emergency Response Plan (ERP) that defines the sequence of actions to be taken by Facility empl
oyees in the event of an accidental release of anhydrous ammonia or propane. This ERP has been communicated to the local Fire Department and the Local Emergency Planning Committee (LEPC). Individuals who are likely to witness or discover a release have been trained to initiate an emergency response sequence by notifying the proper authorities. It is currently OMSL's policy that individuals that have received the requisite training will attempt to secure a hazardous or flammable substance release if the action can be taken without significant risk of injury or death. The local Fire Department is presently responsible for determining when sheltering-in-place or evacuation of off-site areas is necessary, and for also public notification.
1.7 PLANNED CHANGES TO IMPROVE SAFETY
This RMP incorporates a number of enhancements to the existing Facility procedures, which are designed to improve employee safety awareness and enhance safe operations. These enhancements were developed as a res
ult of the Process Hazard Analysis for anhydrous ammonia and Hazard Review for propane. Also, key items have been added to the preventive maintenance programs for the anhydrous ammonia and propane systems. These enhancements ultimately reduce the likelihood of an accidental release. Further, emergency response procedures have been reviewed and coordinated with local response entities to increase the speed and effectiveness of a response should a release occur.
1 J. Harte, C. Holdren, R. Schneider and C. Shirley. Toxics A to Z - A Guide to Everyday Pollution Hazards, 1991, University of California Press, 479 pps.