Pedricktown Cogeneration Plant - Executive Summary
A. Description of Stationary Source and Regulated Substances Handled |
The Pedricktown Cogeneration Plant is owned by Pedricktown Cogeneration Limited Partnership (PCLP) and operated under contract by Conectiv Operating Services Company (COSC). The facility utilizes anhydrous ammonia in its Selective Catalytic Reduction (SCR) air pollution control system. The ammonia vapors reduce the nitrogen oxide (NOx) content in the gas turbine exhaust. Generally, the process involves receipt of anhydrous ammonia by way of tanker trucks and storage in a 12,000 gallon storage tank. The ammonia vapor is mixed with air and then injected into the exhaust stream. The ammonia is drawn into the injection system from the storage tank through a supply line.
As a result of this process, anhydrous ammonia is stored at the facility in quantities that exceed the 10,000 pound threshold quantity (TQ) specified by EPA regulations and the 5,200 pound TQ specified by the New Jersey Department of Environmental P
rotection's Toxic Catastrophe Prevention Act (TCPA). PCLP has one covered process that requires compliance with Program 3 of both the EPA Risk Management Program (RMP) regulation and the New Jersey TCPA regulation.
B. Accidental Release Prevention & Emergency Response Policies of PCLP
Pedricktown Cogeneration Limited Partnership is committed to protecting facility personnel, the public and the environment from workplace and accidental release hazards. Appropriate responses to releases of regulated chemicals are documented in the Emergency Response Program/Plan.
Safety, environmental protection and risk management programs are fully implemented and coordinated with community emergency responders for emergency planning and response efforts.
C. Release Scenario Discussion
The following offsite consequence analyses were performed in accordance with the requirements of the RMP and TCPA regulations.
' One worst-case release scenario for anhydrous ammonia; and
' One alternate release
scenario for anhydrous ammonia.
The following are brief descriptions of the release scenarios that are being submitted by PCLP in the Risk Management Plan (RMPlan). PCLP elected to use EPA's RMP Guidance for Ammonia Refrigeration Reference Tables to determine the distance to the toxic endpoint.
Worst-Case Release Scenario
For the purposes of the RMP and TCPA rule, the worst case release scenario, as defined by the USEPA, for the Pedricktown facility assumes the loss of the contents of the ammonia storage tank (53,000 pounds) within 10 minutes. This quantity takes into account written procedures that prevent more than 1,800 gallons from being present in the 12,000 gal tank. Using EPA's RMP Guidance for Ammonia Refrigeration Reference Tables, the release was estimated to reach the toxic endpoint for anhydrous ammonia at approximately 4.0 miles from the release location. Sections 2.12, 2.13 and 2.14 of the RMPlan provide information regarding the residential population, public and e
nvironmental receptors located within the distance to the endpoint for this scenario.
Alternative Release Scenario
The alternative release scenario for anhydrous ammonia was determined to be an outdoor release through a leak/hole in a pipe containing ammonia liquified under pressure. It is estimated that the leak would result in a release rate of less than 10 pounds per minute of anhydrous ammonia. Using EPA's RMP Guidance for Ammonia Refrigeration Reference Tables, the release was estimated to reach the toxic endpoint for anhydrous ammonia at approximately 0.1 miles from the release location. Sections 3.12, 3.13 and 3.14 of the RMPlan provide information regarding the residential population, public and environmental receptors located within the distance to the endpoint for this scenario.
D. Five-year Accident History
Under the EPA RMP regulations, an accidental release is defined as a release of a regulated substance that "resulted in deaths, injuries or significant property dama
ge on-site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage." The Pedricktown facility has had no such accidental releases.
E. Prevention Program Elements
Management System - A management system has been developed that assigns overall responsibility for the development and implementation of the Risk Management Program (RMProgram) to a qualified individual or position of responsibility. It clearly delineates accountability and responsibilities for any elements where responsibilities are delegated.
Process Safety Information - Up-to-date process safety information will be maintained for use by employees operating the covered process in accordance with 40 CFR Part 68.65.
Process Hazard Analysis (PHA) with Risk Assessment- A PHA with risk assessment has been performed for the Program 3 covered process at the Pedricktown plant in accordance with 40 CFR Part 68.67 and N.J.A.C. 7:31-4.2. The PHA was performed using the What
-If/Checklist method. The PHA identified the hazards associated with the ammonia process; causes of potential accidental release scenarios; safeguards used to prevent accidental releases; and methods used to detect, monitor or control accidental releases. Issues identified during the PHA were documented and addressed in a timely manner. The PHA with risk assessment will continue to be revalidated and updated once every five years.
Operating Procedures - Operating procedures have been developed and will be maintained for the covered process in accordance with 40 CFR Part 68.69 and N.J.A.C. 7:31-4.3. Operating procedures provide clear instructions for safely conducting activities involving a covered process in a manner consistent with process safety information and are readily accessible to employees involved in a covered process. Operating procedures are reviewed to ensure that they remain current and accurate.
Operating procedures cover each operating phase of the covered process
including initial system startup, normal operation, temporary operations, emergency shutdown and conditions when required, emergency operations, normal shutdown and startup following a turnaround or emergency shutdown. Operating procedures also incorporate or reference relevant process safety information.
Training - A training program has been developed for employees working with the covered process in accordance with 40 Part CFR 68.71 and N.J.A.C. 7:31-4.4. The training includes an overview of the process and emphasizes process operating procedures, safe work practices, health and safety hazards, and emergency operations including shutdown. Those employees already involved in operating or maintaining a covered process prior to June 21, 1999 have been trained (via annual refresher training) to have "the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as specified in the operating procedures.
Refresher training will be provided at a mi
nimum of once every three years to all employees involved in working with the covered process. Documentation will be maintained for each employee to ensure that he or she received and understood the required training.
The training program includes written job descriptions, which include the duties and responsibilities for each EHS operator position. The qualifications required for the personnel responsible for training the EHS operators is also included in the training program.
Mechanical Integrity - A mechanical integrity program has been developed in accordance with 40 CFR Part 68.73 and N.J.A.C. 7:31-4.5 for covered process equipment. Employees involved in the maintenance of the covered process equipment receive additional training, which includes an overview of the process, its hazards, and applicable procedures to ensure that the employee can perform the job in a safe manner.
Written procedures have been developed to ensure that covered process equipment is properly maintain
ed, tested, and inspected at regular, scheduled intervals and that such activities are thoroughly documented. Maintenance, inspection and testing procedures and frequencies are consistent with applicable manufacturer's recommendations. Any equipment deficiencies identified during maintenance, inspection or testing are corrected in a safe and timely manner. The mechanical integrity program also includes a quality assurance program.
A system has been implemented for maintaining records of inspections, breakdowns, repairs and replacements of EHS equipment.
Management of Change (MOC) - A written MOC procedure has been implemented to manage changes in process chemicals, technology, equipment and operating procedures for the covered process in accordance with 40 CFR Part 68.75 and N.J.A.C. 7:31-4.6. The MOC procedure does not apply to "replacements in kind" which are defined as replacements that satisfy the original design specifications (e.g., replace a pressure reducing valve with a
new identical valve supplied by the original equipment manufacturer).
All employees involved in operating or maintaining the modified process are informed of the change and trained accordingly prior to startup of the modified process.
Pre-Startup Safety Review (PSSR) - PSSRs are performed in accordance with 40 CFR Part 68.77 and N.J.A.C. 7:31-4.7 for new covered processes and for modified covered processes when the modification is significant enough to require a change in the process safety information. The PSSR confirms the following:
' Equipment and construction satisfy design specifications;
' Safety, operation, maintenance, and emergency procedures have been developed and are adequate;
' A PHA has been performed for new covered processes, and all recommendations have been resolved or implemented prior to startup;
' The MOC procedure has been completed for the process modifications; and
' Training of all employees involved in operating or maintaining the new or modified process
has been performed.
Compliance Safety Audits - RMProgram compliance will be confirmed through safety audits that are performed at least once every year in accordance with 40 CFR Part 68.79. The audits will be completed by at least one person knowledgeable in the process. A report of the findings will be generated following the audit, and all deficiencies and/or recommendations will be promptly addressed and the resolution will be documented. Safety audit reports will be maintained at the facility.
Incident Investigation - Specific incident investigation, reporting, and documentation procedures have been implemented and are followed in accordance with 40 CFR Part 68.81 in response to any EHS accident/incident involving a covered process that did or could have reasonably resulted in a catastrophic release of a regulated substance.
Employee Participation - A written employee participation plan has been implemented that provides employees with access to PHA and all other information
developed under the RMP regulation in accordance with 40 CFR Part 68.83. The employee participation plan describes employee participation in conducting PHA and in implementing all other RMP elements.
Hot Work Permit - An authorization and permit program for hot-work operations has been prepared and implemented for hot-work conducted on or near a covered process in accordance with 40 CFR Part 68.85. The permit is used to document that fire prevention and protection standards in 29 CFR Part 1910.252(a) have been implemented prior to beginning the hot-work operations. Also, the permit lists the date(s) authorized for the hot-work and identifies the equipment to be worked on or near.
Contractors - A contractor safety program in accordance with 40 CFR Part 68.87 covers all contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process. Each contractor employee is informed of the known potential fire, explosion hazards
related to work on a covered process as well as the relevant provisions of the emergency response program. Procedures are in place to control the entrance, presence, and exit of contract employees in covered process areas. Periodically, the performance of the contract owner or operator is evaluated while working in or adjacent to a covered process.
F. Emergency Response Program
PCLP has an emergency response program that includes an emergency response plan addressing the regulated substance present at the facility.
The emergency response plan is reviewed to reflect changes at the facility and ensure that employees are informed of the changes. The emergency response program includes procedures for the use of on-site emergency response equipment and for its inspection, testing and maintenance. Employees are trained periodically on emergency response procedures.
The emergency response program also includes:
7 A schedule for initial and annual refresher emergency response trainin
g for employees in relevant procedures to implement the emergency response plan;
7 A schedule to perform at least one emergency response exercise per calendar year;
7 a written assessment of the emergency response plan and of the adequacy or need for emergency response equipment after each plan implementation or exercise;
7 A description of the emergency notification system at the stationary source.
G. Planned Changes to Improve Safety
PCLP is committed to continuous improvement efforts in the safety and risk management areaa. At the time of this submittal, there are no specific plans for process safety program enhancements related to the regulated substance; however, as opportunities/recommendations for enhancements are identified, they will be considered as appropriate