Ripon Cogeneration, Inc. - Executive Summary

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1.1  Executive Summary 
    This document represents the updated and revised Risk Management and Prevention Plan 
(RMPP) for the cogeneration facility owned by CRSS Inc., operated under the name of Ripon 
Cogeneration, Inc., located in Ripon, CA. This document has been prepared in order to address 
the following issues: 
    - Repeal of the State RMPP Program as delineated in HSC 25531-25543.3. 
    - Promulgation of the Federal RMP program per 40 CFR 68. 
    - Adoption of the Federal program requirements by the State of California. 
    - Acknowledge the facility change of ownership. 
    - Acknowledge the addition of processes at the facility which are subject to RMPP 
    The RMP represents a revision of the previously required state document to incorporate 
the federal requirements as outlined in 40 CFR 68. Federal RMP requirements give facilities until 
June 21, 1999 to file the RMP, but the General Duty clause of the 40 CFR 68 regulations requires 
all faciliti 
es to properly: 
    - identify hazards 
    - design and maintain a safe facility 
    - prevent releases 
    - minimize consequences of releases. 
    The accepted approach to accomplishing the above is to have a documented risk 
management and prevention program which outlines all the steps and procedures a facility will 
take to prevent and mitigate accidental releases. Ripon Cogeneration, Inc. (RCI) has chosen to 
prepare and implement its RMP in advance of the federal program due date in order to fulfill its 
obligations with respect to the General Duty clause and to protect its employees and the 
surrounding community from the effects of accidental releases. 
    Pursuant to 40 CFR 68.155 the following summary is given: 
        The RMP applies to the Ripon Cogeneration, Inc. facility located at 
         944 South Stockton St., Ripon, CA. 95366. 
        The Ripon Cogeneration Facility is a gas turbine based cogeneration facility rated 
         at 49.9 Mw (nominal rating).  
The facility consists of a LM5000 gas turbine, heat 
         recovery steam generator, and auxiliary boiler. The gas turbine is equipped with 
         a Selective Catalytic Reduction system for the control of Oxides of Nitrogen. The 
         SCR system utilizes anhydrous ammonia as the reactant in the catalyst. Ammonia 
         is stored in a stationary storage tank rated at 18000 gals., but state law and site 
         operating procedures limit the tank capacity to no more than 9000 gals. 
        The facility utilizes five (5) ambient ammonia sensors and alarms in the tank area 
         as well as a single sensor for ammonia in the machinery room. 
         Leak detection is confirmed by the cogen operator console and the water 
suppression system is automatically initiated. The water suppression system is designed to mitigate 
a major portion of any tank related release. 
        The accidental release prevention and emergency response policies at the stationary 
   source are delineated in Sections 1.9, 1.10, 1.11, 2.1, 2.2, 2.3, and 3.1. 
        Worst Case release scenario is the failure or the anhydrous ammonia storage tank. 
         This scenario results in the release of approximately 55500 lbs. of ammonia. The 
         distance to the toxic endpoint is 5.0 miles and affects approximately 16000 
        Alternative release scenario is the rupture of the main section of ammonia 
         distribution piping. This scenario results in the release of approximately 9257 lbs. 
         of ammonia. The distance to the toxic endpoint is approximately 1.0 mile and 
         affects approximately 9300 individuals. 
    Piping and distribution network is equipped with a number of manual and automatic  
    valves which effectively limit the amount of any accidental release. System pressures are  
    monitored at the cogen console. The inlet air cooling portion of the ammonia system has  
    two monitors as well  
as an emergency diffusion tank to mitigate any potential releases  
    from this system. 
        The general accidental release prevention program is comprised of the following 
         - Proper maintenance of all system equipment. 
         - Proper operation of all system equipment. 
         - Internal operating policies with respect to ammonia tank capacity. 
         - Comprehensive personnel training. 
         - A written emergency response plan. 
         - A written hazardous materials management plan. 
         - Documented safety procedures for employees and contractors. 
         - Inclusion of ammonia specific health, safety, and response data in the RMPP. 
         - Use of site-ambient monitors and chemical specific mitigation systems to detect  
            and mitigate potential releases. 
        The site has never experienced an accidental release of ammonia or any other    hazardous 
substance in the last 5 years, or since the system was  
originally installed. 
        The site has a written emergency response plan and procedures. See section 2.3. 
         The Ripon Fire Department (RFD) will be the first responder in an ammonia 
         emergency. RCI personnel will perform "awareness" duties only, which simply 
         means that once the ammonia spill or release is discovered, RCI personnel will 
         make the proper notifications and set the emergency procedures in motion. RFD 
         will handle leak containment. In the event of a major release, RCI will join forces 
         with RFD and State/County OES personnel in a "unified command effort" until the 
         emergency has been contained. 
        The facility is constantly striving for improved performance and reliability from 
         all its   processes. As specific process and safety improvements are identified, they 
         will be evaluated by site and management staff for appropriateness and 
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