Double "C" Limited - Executive Summary
1.0 Introduction |
A Risk Management Program (RMP) has been implemented at Double "C" Limited to reduce accidental releases of hazardous materials. The Risk Management Plan summarizes the management, administrative, procedural, and technological controls that work together to minimize the risk to the community of hazardous chemical releases. The Risk Management Plan is organized to correspond with specific U.S. Environmental Protection Agency (U.S. EPA) RMP definitions and requirements, including:
-Policies to protect health, environment, and safety;
-Facility identification and regulated substances covered processes;
-Five-year accident history;
-Emergency response plan; and
-Planned changes to improve safety.
2.0 Double "C" Limited Policies to Protect Health, Environment, and Safety
Risk management and safety are important concerns at Double "C" Limited; this Risk Management Plan formalizes and documents activities to address
these concerns. Double "C" Limited is committed to conducting its operations in a safe and responsible manner and to reducing risks to human health and to the environment.
This commitment to health, the environment, and safety starts with upper management. Upper management demonstrates this commitment by investing resources in accident prevention efforts, such as ensuring that safety systems are incorporated into the design, installation, operation, and maintenance of the facility. Upper management implements both administrative and engineering controls to reasonably minimize the risk of an uncontrolled release of a hazardous substance. Double "C"'s commitment to safety is demonstrated in the training programs for all employees. The training programs provide information on preventing accidents through knowledge of hazards and safe work practices.
3.0 Facility Identification
Double "C" Limited is located at 10245 Oilfield Road, Bakersfield, California. Double "C" is a limited partne
rship of separate private investors but is operated by Dynegy Operating Company. The facility produces electricity and steam utilizing two natural gas burning turbines. The facility uses anhydrous ammonia to minimize air pollution of nitrogen oxides. The anhydrous ammonia reacts with the nitrogen oxides in the exhaust gas stream to form nitrogen and water, which are then released to the atmosphere. Use of anhydrous ammonia results in greater than 90% reduction of nitrogen oxide emissions. Anhydrous ammonia is regulated under 40 Code of Federal Regulations (CFR) Part 68, the U.S. EPA RMP rule. The maximum amount of ammonia present at the facility is approximately 2,500 gallons, or 14,225 pounds, which is above the RMP threshold quantity of 10,000 pounds.
4.0 Hazard Assessment - Worst Case Scenario
The worst-case accidental release scenario is a catastrophic failure of the anhydrous ammonia tank. The ammonia is maintained as a liquid via pressurization, and the quantity is limited by
an administrative control, resulting in a maximum of 14,225 pounds of ammonia.
Hazard assessment modeling shows that, under the worst-case weather conditions and a 10-minute release period, the worst-case release could travel downwind until the toxic endpoint of 200 parts per million (ppm) is reached; this would affect public receptors. It should be noted that the worst-case scenario is an extremely unlikely event. Also, qualified individuals operate the process and the ammonia equipment is inspected and maintained according to established preventive maintenance schedules, which further reduce the likelihood of this occurrence.
The LandView III program was used to estimate off-site impacts to the population using the uniform population density (proration method) over an entire census tract. In some rural areas, where there is a small high-density population group within a census tract (such as a small rural town), the program will overestimate the population in those rural areas. Fur
ther, based upon knowledge of the surrounding community by facility personnel, it is known that this population estimate as provided by the LandView III program, and reported in this RMP, is significantly overestimated. The Landview III program was used to estimate off-site impacts for both the worst-case release scenario and the alternative release scenario.
5.0 Hazard Assessment - Alternative Release Scenario
An alternative release scenario, which is more credible than the worst-case scenario, was also modeled for ammonia in the hazard assessment. In the alternative release scenario, a break in the ammonia piping is assumed to occur. The pipe break would normally create a high flow of ammonia out of the tank, which would cause the excess flow valve, set at 45 gallons per minute (gpm), to close. In this case, the amount of ammonia released would be minimal. However, the alternative release scenario selected assumes that the pipe break would be small enough to maintain the flow rate
less than 45 gpm and the excess flow valve would not close. The release is assumed to last for 40 minutes before emergency responders can close the valve to shut off the ammonia supply. The dispersion modeling shows that the release would travel off site before the toxic endpoint of 200 ppm is reached. The release may impact public receptors in this scenario.
6.0 General Accidental Release Prevention Program
A prevention program is in place to minimize the risk of hazardous chemical releases in accordance with the California Occupational Safety and Health Administration (CalOSHA) Process Safety Management (PSM) standard (Section 5189 of Title 8, CCR) and the U.S. EPA RMP. This prevention program covers the process that handles anhydrous ammonia above the threshold quantity of either PSM or RMP rules.
The prevention program provides a structured approach to preventing accidents. Specific activities in the prevention program include the following:
- Process safety information is prov
ided to all employees upon hire and is accessible at all times.
- In-depth process hazard analyses are completed by qualified personnel using techniques approved
under the PSM standard.
- Written operating procedures (kept up to date) are used for training and guiding the work of operators.
- Training is provided to all employees upon hire, and refresher training is given annually or upon request.
- Operators, mechanics, and contractor personnel are qualified, trained in the general hazards in the
facility, and informed of any temporary situations affecting safety.
- Pre-startup safety reviews are conducted to insure that conditions for safe operation have been
satisfied prior to starting new or modified equipment.
- A program is in place to maintain the mechanical integrity of the process, which includes written
procedures, training requirements, equipment deficiency requests for employees, work orders,
scheduled maintenance, and computerized documentation.
hot work permit system assures that welding, grinding, or other spark-generating work is done safely
- A management of change system is in place to ensure that changes are managed safely.
- Incidents are investigated and actions are taken as part of a continuous improvement effort.
- Routine audits are conducted to assure that safe practices are being followed.
- Although no changes were recommended as a result of the last process hazard analysis; the chemical
inventory of anhydrous ammonia was reduced from 10,200 gallons to 2,500 gallons.
This systematic approach to process safety involves employees and strives for continuing improvements in overall safety. The training, qualifications, and safety awareness of our operations, maintenance, and management personnel are a key element in reducing and mitigating accidents.
7.0 Five-Year Accident History
From January 1994 to the present, no accidents or releases of regulated substances from the covered process h
ave occurred that meet U.S. EPA criteria for the five-year accident history. Such "RMP accidents" would involve serious accidents with either on-site deaths, injuries, or significant damage or known, off-site deaths, injuries, property damage, or environmental damage. Double "C" Limited realizes that the community may also be interested in smaller releases of regulated chemicals that do not meet such criteria. Double "C" Limited has been diligent in reporting releases of hazardous materials and in investigating and correcting the causes of such releases.
8.0 Emergency Response Plan
An emergency response plan has been implemented at Double "C" Limited. Plant personnel are trained to the First Responder Awareness and First Responder Operational levels; therefore, Double "C" Limited personnel are considered defensive emergency responders. The Federal RMP and CalARP regulations grant exemptions for the emergency response plan to facilities that only conduct defensive emergency response.
The exemption is valid provided that the facility is included in the community emergency response plan and that there is an appropriate mechanism in place to notify emergency responders when there is a need for a response.
The emergency response plan provides procedures for responding to an emergency, including the potential release of anhydrous ammonia. The procedures include instruction for response, communication, first aid, evacuation, accounting for personnel, company and agency notification procedures, and post incident cleanup and decontamination. This emergency response plan has been submitted to Kern County Haz Mat Station 66. Double "C" Limited's emergency response plan protects employees, ensures public safety, and protects the environment.
9.0 Planned Changes to Improve Safety
Chemical safety is an important part of Double "C" Limited operations. Appropriate training as well as implementing regulatory requirements have minimized chemical exposure risks to employees and
the public through ongoing internal risk reduction efforts. For example, emergency shutoff valves were installed on the ammonia transfer lines to quickly shutdown the system in the event of an emergency during loading, and isolation valves were installed on the vaporizer skid.
Other improvements will be made when identified and approved by management.