Stanton Energy Center - Executive Summary
STANTON ENERGY CENTER |
RISK MANAGEMENT PLAN
1. Corporate Prevention and Emergency Response Approach
The Stanton Energy Center is a division of Orlando Utilities Commission, headquartered in Orlando, Florida. Corporate policy requires each site to develop and maintain accident prevention programs and an emergency response plan appropriate to the site. The Corporate environmental organization provides support to the sites in the form of advise and direction on regulatory compliance issues, training for site employees, budgeting and procurement of environmental services, and assistance in the development of new programs.
2. Description of Stationary Source
The Stanton Energy Center is a two unit coal- fired power generating facility that supplies 420 MW electric power from each unit to the greater Orlando metropolitan area and distributes excess capacity.
The Stanton Energy Center adds chlorine to the water in the cooling tower basins as a biocide. Liquefied
chlorine gas is stored in up to 10 one ton containers at the Circulating Water Chemical Feed facility. Five containers are always connected to the system, and up to five are stored nearby. The total chlorine inventory in the process at any one time ranges from 10,000 to 20,000 lbs. This is greater than the 2,500 lb. threshold quantity.
The Stanton Energy Center also stores liquefied anhydrous ammonia in two 30,000 gallon tanks for addition to the Selective Catalytic Reduction System. Although the tanks have a total capacity of 60,000 gallons, the Ammonia Unloading, Storage and Supply procedure limits the tank levels to 85% of capacity, or a maximum total inventory of 51,000 gallons. This is equivalent to approximately 259,000 lbs. of ammonia, which exceeds the 10,000 lb. threshold quantity.
3. Description of the Worst Case and Alternative Release Scenarios
The Worst Case release scenario is rupture of a 2,000 lb. container, releasing 2,000 lbs. of chlorine ga
s 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 the public or environment (reaching a concentration less than .0087 mg/L), using the WWTP Guidance Method.
The alternative release scenario is a leak at a rate of 78 lb/min. from the container gas supply valve due to failure of the fitting. Under normally expected weather conditions, taking into consideration the alarm system at the Circulating Water Chemical Feed facility, the chlorine gas could travel 0.4 miles before it dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .0087 mg/L), using the WWTP Guidance Tables.
The worst case release scenario is rupture of one storage tank, releasing 129,500 lbs. of ammonia over a ten minute period. Under worst case weather conditions, the ammonia gas could travel 6.9 miles before dispersing enough to no longe
r pose a hazard to the public or environment (reaching a concentration less than .14 mg/L), using the WWTP Guidance Table.
The alternative release scenario is a leak of ammonia gas from a hole created by the failure of a 2" relief valve connection to the tank. Under normally expected weather conditions, the ammonia gas could travel 0.3 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .14 mg/L), using the WWTP method.
4. Prevention Program
The RMP regulation requires classification of each process into a Program Level 1, 2, or 3 in order to determine the prevention program requirements. Since the worst case release from both processes would impact a public receptor, the processes cannot be classified as Program 1. Program 3 processes include those that are not Program 1, but are subject to OSHA's Process Safety Management Standard, 1910.119, or are part of an industry in one of 10 NAICS codes listed in the R
MP regulation. Stanton Energy Center, as a power plant, has an NAIC code of 22111, which is not one of the ten listed codes. This means that the Stanton Energy Center processes would be classified as Program 3 only if they are subject to the PSM Standard.
The OSHA Act states that states or political subdivisions of states are not employers and are therefore not subject of OSHA regulation. Stanton Energy Center, as part of a city-owned power commission, may be considered a political subdivision of a state and therefore not technically subject to Process Safety Management; however, OSHA Standard 1975.5, States and Political Subdivisions Thereof, lists public utilities as an example of the type of entity which "would normally not be considered a 'political subdivision of a state'." This would indicate that utilities, and therefore, Stanton Energy Center, are subject to the PSM Standard. Additionally, the Florida Department of Labor, Division of Safety, which governs state entities a
dopts all OSHA Standards, including PSM, and enforces compliance with them. This reasoning has lead Stanton Energy Center to consider its processes as subject to PSM and to implement a PSM program. For RMP compliance purposes, this places the Stanton Energy Center processes in the Program 3 level. The chlorine and ammonia processes will use the PSM program which was already under development at the time of the RMP promulgation as the required Program 3 Prevention Program.
The Stanton Energy Center has a program in place to comply with the OSHA Process Safety Management Standard, 29 CFR 1910.119. The PSM Program was established in 1994 for the chlorine process and was extended to cover the ammonia process when the SCR system was constructed in 1996. Improvements have been made to the program as a result of two audits performed in July of 1997and May of 1999. The Stanton Energy Center PSM Program receives full support of plant management and involvement of employees at all levels.
5. Accident History
The Stanton Energy Center has had no accidental releases of chlorine or ammonia in the past five years.
6. Emergency Response Program
The Stanton Energy Center has an emergency response plan in place that complies with 29 CFR 1910.38. The plan has been coordinated with the Orange County Fire Department, and the District 6 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.