Pawnee Station - Executive Summary |
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This executive summary is a brief overview of the Risk Management Program and the associated policies at the Public Service Company of Colorado (PSC) Pawnee Station. Prevention and Response Policies The accidental release prevention and emergency response policies are represented in the Emergency Planning and Response Sections of the Pawnee 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 s urrounding community. This understanding is reflected in procedures described and referenced in the RMP manual. Stationary Source and Regulated Substances Pawnee Station is a coal-burning 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 9 containers (18,000 lbs.) on site. Release Scenarios 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. The RMP*Comp air dispersio n 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 345 pounds of chlorine over a one-hour period due to a severed pigtail on the one-ton container. No active mitigation devices were considered to influence the release scenario. A distance of 0.1 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 Pawnee Station Chlorine System PSM/RMP manual. A new chlorine system (to replace the existing system) was installed in the spring of 1999; system operating procedures, training, mechanical integrity program, pre-startup safety review, and management of change documentation are in the process of being updated to reflect the new system. All components will be completed by June 15, 1999. Th e 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, which has been collected in the Pawnee Station Shift Supervisor's office and summarized in the PSM/RMP manual 7 Process hazard analyses (PHAs) - The initial PHA for the chlorine system was conducted in 1994; the PHA was updated in November 1996. All recommendations from the PHAs have been addressed. A PHA was conducted during the design of a new chlorine system in February 1999; all recommendations from the PHA team were addressed in the revised system design. 7 Operating procedures for the chlorine process, which are included in the Pawnee Station QA Procedures Manual 7 Training for all personnel involved in the operation and maintenance of the chlorine system 7 Contractor management program , which includes provisions for the evaluation and selection of contractors to work on the regulated process, exchange of hazard information, system access control, and oversight during work activities on site. However, it is the facility's policy not to allow contractors to operate or maintain the system after it is operational. 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 equipment is maintained in good and safe working condition. Facility personnel conduct inspections of the chlorine system prior to startup. 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 Pawnee Station Clearance Procedure) 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 Pawnee Station chlorine PSM/RMP program. A PSM audit was conducted on the chlorine process in 1996; a PSM/RMP audit was conducted in February 1999. All findings from the audits have been, or are being, addressed, and recommended actions will be completed by June 15, 1999. 7 Trade secrets provisions allowing contractors and employ ees or their representatives access to system information Accident History 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 detail 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 employees. Employee safety meetings that focus on chemical safety issues are held regularly at this f acility. 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 Pawnee 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 may be implemented, all will be considered. The exercise has provided all affected employees with a heightened awareness of safety issues related to the covered processes. |