St. Johns River Power Park - Executive Summary |
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ST. JOHNS RIVER POWER PARK RISK MANAGEMENT PLAN DRAFT SUBMITTED: AUGUST 1998 EXECUTIVE SUMMARY 1. Corporate Prevention and Emergency Response Approach The St. Johns River Power Park (SJRPP) is co-owned by Florida Power and Light Company and the Jacksonville Electric Authority. As the only facility developed and operated by this partnership, the SJRPP operates as an independent entity. The facility has developed and maintains accident prevention programs and an emergency response plan to prevent and mitigate the effects of hazardous chemical releases. The Plant Manager retains ultimate responsibility for these procedures, while specific duties are delegated to the Section Environmental Leader, the Chemical Process Supervisors, the Operations Superintendent, Department Directors and Managers, and the Safety/Security Supervisor. 2. Description of Stationary Source The SJRPP is a two-unit power generation plant located at 11201 New Berlin Road, northeast of downtown Jacksonvi lle, Florida, 2 miles north of the I-295 and Hecksher Drive intersection. SJRPP adds chlorine as a biocide to the cooling tower recirculating water. SJRPP stores liquefied chlorine in up to four one-ton containers at the Cooling Tower Recirculating Water process. Two containers are always connected to the process, while up to two additional containers are stored adjacent to the connected containers. The total chlorine inventory in the process at any one time ranges from 4,000 to 8,000 lbs. This is greater than the 2,500 lb. RMP threshold quantity for chlorine. This process has no passive mitigation. 3. Description of the Worst Case and Alternative Release Scenarios The Worst Case release scenario is the rupture of a ton container from the Cooling Tower Recirculating Water process, releasing 2,000 lbs. of chlorine gas over a ten minute period. Under worst case weather conditions, the chlorine gas could travel 3.0 miles before dispersing enough to no longer pose a hazard to th e public or environment (reaching a concentration less than .0087 mg/L) using WWTP Guidance Method. The alternative release scenarios characterized by a break from the gas supply valve due to the valve connection failure from worker/human error, external impact, or corrosion. For the Cooling Tower Recirculating Water Process, the release rate was determined to be 83.1 lbs/min. Under normally expected weather conditions, the chlorine gas could travel 0.4 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .0087mg/L) using WWTP Guidance. 4. Prevention Program For the chlorination process, this facility exceeds the chlorine threshold quantity for the OSHA Process Safety Management (PSM) Standard, 1910.119, and is therefore subject to the PSM requirements. For RMP compliance purposes, this places the SJRPP chlorination process in the Program 3 level. The SJRPP facility will use its PSM program as the required Program 3 Prevention Program. The SJRPP has a program in place to comply with the OSHA Process Safety Management Standard, 29 CFR 1910.119. To ensure that all requirements of the RMP regulation were met, the PSM Program was reviewed and updated in 1998. The PSM Program includes written operating procedures for the chlorination process. These procedures cover all phases of operation and include information on worker protection. These procedures will be used to train all operators and mechanics who work on the chlorination process to ensure consistency of operation and minimize human error. The PSM Program also includes a preventative maintenance plan which requires all chlorination equipment to be periodically inspected and serviced. This will ensure that the equipment remains in good operating condition and will minimize the probability of accidents due to faulty equipment. Safe work practices, such as Lockout/Tagout and Hot Work Permit, have long been required by the SJRPP S afety/Security Department. These were reviewed and updated to ensure that all non-routine work can be performed safely. Other components of the Prevention Program include the collection and review of all equipment information and the development of updated Piping & Instrumentation Diagrams (P&IDs). These actions will ensure that the equipment meets all chlorination industry standards and that accurate equipment information will be available when needed. The staff also performed a Process Hazard Analysis of the process. Other PSM procedures, including Management of Change, Pre-Startup Safety Review, Compliance Audits, and Incident Investigation have also been incorporated into this program to ensure continued safe operation and prompt correction of deficiencies. The PSM Program receives full support of plant management and involvement of employees at all levels. 5. Accident History The SJRPP facility has had no accidental releases of chlorine in the past five years. 6. Emergenc y Response Program The SJRPP has an Emergency Response Plan in place. The program complies with 29 CFR 1910.38. The site also has some internal emergency response capability and has a procedure for addressing small releases of chlorine, entitled "SJRPP Procedure for Chlorine Emergency Response" (SJRPP Procedure SF-039). The current plan has been coordinated with the Environmental Recovery Group, a private company whose service is the repair and clean-up of chemical spills. If needed, additional assistance can be obtained from the Jacksonville Fire Department and Hazardous Materials Response Team, and the Regional Local Emergency Planning Committee. Notification is made locally by dialing 911, and by notifying Florida State Warning Point at (800) 320-0519 or (904) 413-9911. |