Northside Generating Station - Executive Summary |
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1.1 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICY SUMMARY The JEA Northside Generating Station (NGS) is a critical part of the JEA electrical power generating system. JEA is committed to operating this and other JEA facilities in a manner that is protective of the health and safety of JEA and Contractor employees, the public, and the environment. JEA is committed to operating this and other JEA facilities in full compliance with all applicable Occupational Safety and Health Administration (OSHA) and Environmental Protection Agency (EPA) regulatory requirements. To ensure that the Facility is operated in a safe manner and in compliance with applicable OSHA and EPA regulations relevant to accidental release prevention, JEA has developed an integrated Process Safety Management/Risk Management Plan (the Plan). Among the important components of the Plan are JEA's system of policies and procedures for operation and maintenance of the Facility, and JEA's Emergency Response Plan (ERP) for the Facility. 1.2 STATIONARY SOURCE DESCRIPTION The facility generates electrical power for the City of Jacksonville. JEA operates a potable water chlorination system at the Facility that treats water used in the boilers and for other uses at the Facility. Chlorine is delivered to the Facility via truck in ton (2,000 pounds) containers, which are used onsite as storage vessels. These containers are stored and used in a building as one process near the center of the Facility property. The maximum intended inventory of chlorine at this location is 8,000 pounds, in one-ton containers (4 containers). This quantity is greater than the threshold quantity for PSM and RMP applicability of 1,500 pounds and 2,500 pounds, respectively. To facilitate the chlorination process, two (2) one-ton containers (4,000 pounds) are simultaneously connected to a vacuum demand, split manifold. However, only one container is active and in use at any given time. JEA also operates a boi ler condensate chemical injection system that uses aqueous ammonia (concentration greater than 20%) for control of pH in the boiler condensate water. The System uses aqueous ammonia for this purpose. Aqueous ammonia is delivered to the Facility via tanker truck and stored in a 6,000 gallon vertical steel tank near the center of the Facility property. The maximum intended inventory of aqueous ammonia at this location is 35,200 pounds based on an administrative maximum fill volume of 88% of the tank capacity. 1.3 WORST CASE AND ALTERNATIVE CASE RELEASE SCENARIOS The worst case release scenario is the 10 minute release of the contents of one (1) full one-ton container of chlorine, or 2,000 pounds, as required by applicable Risk Management Plan (RMP) regulations. Consideration was given to a release of the full 35,200 pounds of aqueous ammonia over a ten minute period, however, the endpoint for that scenario was found to be a shorter distance from the Facility than that for the chlor ine release. Because the chlorine containers are stored and used within a building, the Facility qualifies for a passive mitigation credit of 45 percent that is applied against the release rate. Using the methodology prescribed in the regulations, this results in potential impacts to public and environmental receptors. A more realistic, alternative release scenario also was examined for chlorine. For this scenario, it was assumed that the gas flow regulator mounted on the active ton container is damaged, resulting in a release of 1,000 pounds of chlorine over a period of 30 minutes. A credit of 45 percent was applied to the release rate to account for the passive mitigation provided by the building. This scenario results in potential impacts to public receptors, but there were no identified environmental receptors. A more realistic, alternative release scenario also was examined for aqueous ammonia. For this scenario, it was assumed that a line leak resulted in a release of 855 pounds of aqueous ammonia over a period of 30 minutes. This scenario does not result in potential impacts to public or environmental receptors. 1.4 ACCIDENTAL RELEASE PREVENTION PROGRAM The Facility has an aggressive accidental release prevention program that is based upon a foundation of employee awareness and proactive system maintenance. This program is documented in the integrated Plan and is based on the requirements of applicable PSM/RMP regulations. The effectiveness of this program is evident by the fact that the Facility has had no significant releases of chlorine in the five years prior to the date of this Plan. 1.5 FIVE-YEAR ACCIDENT HISTORY There have been no accidental releases at the Facility in the five years prior to the date of the Plan that resulted in injuries or death to Facility or Contractor employees on site or the off-site public, or damage to potential environmental receptors. 1.6 EMERGENCY RESPONSE PROGRAM The Facility has an Emergency Response Plan (ERP) that defines the sequence of actions to be taken by Facility employees in the event of an accidental release of hazardous materials. This ERP has been communicated to the City of Jacksonville Fire and Rescue Department (JFRD) and the Local Emergency Planning Committee (LEPC). The JEA is currently in the process of revising the Facility ERP to include the use of Facility personnel as part of an Emergency Response Team (ERT). The ERT approach will enable JEA to effectively address on-site emergency situations in a more timely fashion. With regard to public notification of a chemical release that has the potential to go off site, the JFRD is presently responsible for determining when evacuation of off-site areas is necessary and for public notification. 1.7 PLANNED CHANGES TO IMPROVE SAFETY The Plan incorporates a number of modifications to Facility procedures designed to improve employee safety awareness, enhance safe operations and maintenance of the chlorine system, reduce the potential for accidental releases to occur, and increase the speed and effectiveness of the Facility's response should a release occur. |