Fort St. Vrain Station - Executive Summary
This executive summary is a brief overview of the Risk Management Program and the associated policies at the Public Service Company of Colorado (PSC) Fort St. Vrain Station. |
Prevention and Response Policies
The accidental release prevention and emergency response policies are represented in the Emergency Planning and Response Sections of the Fort St. Vrain Station PSM/RMP manual for the chlorine system. PSC takes an active role in preventing accidental releases at all of its facilities by ensuring that its employees are properly trained in the safe operation of covered processes and the safe handling of treatment chemicals. As for emergency response, PSC has established and maintained procedures for emergency notification and response. These are reviewed with employees on a periodic basis and revised to accommodate changes in staffing when they occur.
PSC management understands its duty to provide a safe working environment and to take measures to prevent accidents that may have an
effect on the surrounding community. This understanding is reflected in procedures described and referenced in the PSM/RMP manual.
Stationary Source and Regulated Substances
Fort St. Vrain Station is a gas-fired electric generating station. The regulated substance handled at this facility is chlorine. The chlorine is used for cooling and process water biocidal control and is stored in one-ton containers with a maximum intended inventory of 6 containers (12,000 lbs.) on site.
Worst-case and alternative release scenarios have been determined after careful review of the regulation and consideration of the storage vessel configuration at the facility. For worst-case release scenario, the regulation is clear. The assumption is that the single largest container of a regulated substance (one-ton container of chlorine) is released over a ten-minute period. No active mitigation may be considered. Worst-case meteorological conditions are also assumed to be present. T
he RMP*Comp air dispersion model was used to determine distances to the toxic endpoint. A distance of 3.0 miles to the toxic endpoint was calculated for a release of 2000 pounds in ten minutes.
The alternative release scenario for chlorine consists of a release of 960 pounds of chlorine over a one-hour period due to a severed 5/16 inch pigtail on the one-ton container. No active mitigation devices were considered to influence the release scenario. A distance of 0.7 miles to the toxic endpoint was determined.
Prevention Steps for Chlorine
The prevention program and chemical-specific prevention steps are described in detail in the Fort St. Vrain Station Chlorine System PSM/RMP manual. The prevention program includes the following elements:
7 Employee participation, which includes provisions for active participation by plant employees in the development and implementation of the plant PSM/RMP program, as well as ready access to program information
7 Process safety information has be
en collected and summarized in the PSM/RMP manual
7 Process hazard analyses (PHAs) - The initial PHAs for the chlorine system were conducted in 1997 and 1998. All recommendations from the PHAs have been addressed.
7 Operating procedures for the chlorine process, which are included in the Fort St. Vrain Station Chlorine PSM/RMP Manual
7 Training for all personnel involved in the operation and maintenance of the chlorine system
7 Contractor management policy, which is to not allow contractors to operate or maintain the chlorine system
7 Pre-startup safety review procedure for implementation for significant system changes to ensure that the construction and equipment installation is according to design specifications, appropriate procedures are in place and accurate, a PHA has been done and the recommendations resolved, and employees are trained prior to startup of the modified system
7 Mechanical integrity program through the facility SSR system to ensure that the chlorine system equipm
ent is maintained in good and safe working condition. Facility personnel conduct daily visual inspections of the chlorine system. The date and equipment included in 7.7 b and c address the most recent major PM activity.
7 Hot work procedures to require the evacuation of the regulated chemicals from the system equipment (using the Fort St. Vrain Station Maintenance Clearance Procedures) before hot work is performed on the chlorine system
7 Management of change program to ensure that proposed system changes are comprehensively evaluated before implementing the change
7 Incident investigation procedures for the investigation of any catastrophic (or potentially catastrophic) incident associated with the chlorine system, using the PSCo Root Cause Investigation Report form
7 Compliance audits to be conducted at least once every three years to ensure the continued compliance of the Fort St. Vrain Station chlorine PSM/RMP program. Since this facility's chlorine system was installed in 1997,
an audit has not yet been required to be performed.
7 Trade secrets provisions allowing contractors and employees or their representatives access to system information
Within the five-year period prior to the submittal of this RMP, there were no accidental releases of chlorine meeting the requirements of 40 CFR 68.42.
Emergency Response Program
This facility has established and maintains an emergency response program that is coordinated with local response agencies. The program is described in the Emergency Planning and Response section of the PSM/RMP compliance manual and meets the requirement of 40 CFR 68.95. The goals of the program are to protect onsite employees from the hazardous effects of chemical releases and to minimize the effects of releases on the general public. The program is routinely reviewed and updated to reflect personnel and regulatory changes.
Planned Changes for Improved Safety
Ideas for changes to improve safety are actively sought from e
mployees. Employee safety meetings that focus on chemical safety issues are held regularly at this facility. Employees are encouraged and trained to recognize hazards and present ideas to eliminate them or to minimize the potential consequences of those hazards.
During the development of the Fort St. Vrain Station PSM/RMP program, process hazard analyses were conducted with key employees to meet the prevention program requirements. During these sessions, recommendations were made for the purpose of improving safety and preventing accidental chemical releases. Each recommendation has been or will be considered for implementation. Though not all recommendations were implemented, all were considered. The exercise provided all affected employees with a heightened awareness of safety issues related to the covered processes.