Independence Station - Executive Summary

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           Executive Summary for Independence Station 
 
 
1.   Accidental Release Prevention and Emergency Response Policies: 
Independence Station is strongly committed to employee, public and environmental safety.  This commitment is inherent to a comprehensive accidental release prevention program in place that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility.  It is our policy to implement appropriate controls to prevent possible releases of regulated substances.  Unforeseeably, if such a release does occur, we are completely coordinated with the local Fire Department, and as a result the county hazardous response team, which will provide highly trained emergency response personnel to control and mitigate the effects of the release. 
 
 
2.   The Stationary Source and the Regulated Substances Handled: 
As a Cogeneration Facility, our primary activities encompass those of electric power genera 
tion.  We have one (1) regulated substance present at our facility, 30% Aqueous Ammonia, which is used for gas turbine NOx emissions control.  The maximum inventory of Ammonia at our facility is 448200 lbs. 
 
 
3.   The Worst Case Release and Alternate Case Scenario(s):  
To perform the required offsite consequence analysis for our facility, we have used the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Program, RMP*Comp(tm).  The following paragraphs provide details of the chosen scenarios. 
 
The worst case release scenario submitted for Program 2 toxic substances as a class involves a catastrophic release from the Aqueous Ammonia storage tank via the transfer pipe.  The scenario involves the release of 224100 lb. of Aqueous Ammonia.  Toxic liquid is assumed to be immediately released to form a pool of height 1 cm, from which evaporation takes place.  The entire pool is estimated to have evaporated over a 49.9 minute period.  No Passive mitigatio 
n controls come into play during this scenario.  Under worst case weather conditions, namely Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 3.1 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. 
 
The alternative release scenario submitted for the regulated substance ammonia also involves a catastrophic release from the Aqueous Ammonia System during a transfer from the 6000 gallon delivery truck, to the storage tank.  The scenario involves the release of 44820 lb. of Aqueous Ammonia.  Toxic liquid is assumed to be released from a pressurized truck due to a ruptured hose or separated coupling.  Ammonia is released at the rate of 3080 lb. per minute to form a pool of height 1 cm, from which evaporation takes place.  The entire pool is estimated to have evaporated over a 40.0 minute time period.  No Passive or Active mitigation controls come into play during this scenario.  Under alternate case weather conditions, namely Class D atmospheric stab 
ility and 3 m/s windspeed, the maximum distance of 0.8 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. 
 
 
4.   The Accidental Release Prevention Program: 
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA.  This facility was designed and constructed in accordance with ASTM, ANSI, API and ASME standards. 
 
The following sections briefly describe the elements of the release prevention program that are in place at our stationary source. 
 
       a)  Safety Information 
Independence Station will maintain a detailed record of written safety information that describes the chemical hazards, operating parameters and equipment designs associated with the Aqueous Ammonia System. 
 
       b)  Hazard Review 
Our facility will conduct comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently.  A hazard checklist has been developed 
, and will be used to perform the process hazard review.  The studies will be undertaken by qualified personnel knowledgeable in process operations.  Any findings related to the hazard analysis will be reviewed and addressed in a timely manner. 
 
       c)  Operating Procedures 
For the purposes of safely conducting activities within our covered processes, Independence Station will maintain written operating procedures and checklists.  These procedures address various modes of operation such as startup, normal operations and chemical transfers.  The information will be regularly reviewed and accessible to operators involved with the processes. 
 
       d)  Training 
Independence Station will have a comprehensive training program in place to ensure that employees involved in process operations are qualified in the process systems and operating procedures.  New employees will receive basic training in process operations followed by on-the-job supervision until they are deemed competent to  
work independently.  Refresher training will be a formal part of the training program and will be completed regularly. 
 
       e)  Maintenance 
Independence Station will perform documented maintenance checks on process equipment to ensure it functions properly.  Process equipment examined by these checks includes among others; storage tanks, piping systems, relief and vent systems, controls and pumps.  Maintenance operations will be carried out by qualified personnel trained in maintenance practices.  Furthermore, these personnel will be offered specialized training as needed.  Equipment deficiencies identified by the maintenance checks will be corrected in a safe and timely manner. 
 
       f)  Compliance Audits 
Independence Station will conduct audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented.  These audits will be perfomed at least every 3 years and corrective actions required as a result of the audits will be reviewed an 
d undertaken in a safe and prompt manner. 
 
       g)  Incident Investigation 
Independence Station will investigate incidents which result in, or could reasonably result in a catastrophic release of a regulated substance.  These investigations will be undertaken to identify the situation leading to the incident as well as any corrective actions to prevent it from reoccurring.  Reports will be retained for a minimum of 5 years. 
 
 
5.   Five-year Accident History 
There have been no accidental releases during the past five (5) years. 
 
 
6.   Emergency Response Plan: 
With the exception of defensive action to stop or mitigate a leak (e.g., shutting a valve), or response to incidental releases of hazardous substances that can be easily absorbed, neutralized or otherwise controlled without potential safety or health hazards, employees of Independence Station will not respond to accidental releases of aqueous ammonia.  The facility is included in Oswego County's emergency response plan, and proc 
edures are in place to notify emergency responders in the event of an accidental release. 
 
There are five (5) senior operators at the facility, one for each operating shift.  The requirements for the senior operator position inherently meet the RMP requirements for the facility emergency contact.  The Senior operator on shift at the time of an accidental release is designated as the emergency contact for that release. 
 
 
7.   Current Projects and Planned Changes: 
       a)  New York State regulations which cover storage and handling of hazardous substances (6 NYCRR Parts 595 - 599) require 5 year inspections of the storage tanks.  In April of 1999 the facility began inspecting all hazardous substance storage tanks, including those used for ammonia storage, to comply with these requirements.  We anticipate these inspections will be completed by the fall of 1999. 
 
       b)  The facility is also currently involved in a project to upgrade hazardous substance storage and handling to compl 
y with the new New York State regulations by December 1999.  This project will improve the safety of the Aqueous Ammonia System and may potentially impact the worst and alternate case scenarios by reducing the distance to the toxic endpoint. 
 
       c)  The facility has applied for a CAA Title V permit, and has received notice of satisfactory submission of a complete application, but has still not received a title V permit.  The RMP will be updated with this information upon receiving this permit.
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