Hamakua Energy Partners - Executive Summary |
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I. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY POLICIES Hamakua Energy Partners recognizes management's responsibility in protecting it's employees, equipment, property, and the environment against the hazards of an unintentional ammonia release. The safety and health of all employees and the public is very important. The control of accidents has been and will continue to be a basic responsibility of all personnel in the facility. The Hamakua PSM/RMP program assigns and documents the specific responsibilities for developing, implementing and integrating the OSHA PSM and the EPA RMP standards into its safety program. The Hamakua PSM/RMP program focuses attention on "Making PSM/RMP the way we manage our ammonia storage and use system" rather than a project we expect to complete and put on the shelf when the filing date has passed. Hamakua Energy Partners believes that Employee participation is the key to a successful program. Operating level employees, particularly the Facility Manager and the Ammonia Storage and Use System Operators, have been deeply involved in the PSM/RMP program development, implementation and integration and they assume the major responsibility for operating the Honokaa, Hawaii facility safely. The Hamakua Emergency Response Program has been developed with the cooperation and support of the Hilo Fire Department. All Hamakua employees have received documented ammonia awareness training. II. STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED Hamakua Energy Partners Manages an SCR Process for NOx Removal. The ammonia storage and use system is a necessity for the processing, storage and distribution of electric energy. The ammonia storage and use system contains no more than 45,000 pounds of Anhydrous Ammonia. Anhydrous Ammonia is the only Hazardous Material on site in quantities above the threshold quantity. III. SUMMARY OF WORST CASE AND ALTERNATIVE RELEASE SCENARIOS The WORST CASE release scenar io involves the complete rupture of the High Pressure Receiver. A maximum release of 45,000 pounds of ammonia over a 10-minute period was considered. Under worst case weather conditions ammonia could travel up to 2.3 miles before dispersing. A WORST CASE release is very, very, very, unlikely to occur during the life of the facility, this is because of administrative controls, equipment safeguards, operator training, and release prevention and mitigation features incorporated in the Hamakua Energy Partners PSM/RMP program. An alternative case release scenario that we call WORST CASE CREDIBLE was slightly more likely. A 3000-pound ammonia vapor loss from failure of a safety relief valve to reseat or from ruptured vapor piping. Under worst case weather conditions ammonia could travel up to 0.1 mile before dispersing. This release is very, very unlikely to occur during the life of the Hamakua Energy Partners facility. An alternative case release tha t we call MOST LIKELY, MOST SEVERE was slightly more likely still. A 100 pound ammonia loss from a failing ammonia transfer hose during the unloading operation. Under worst case weather conditions ammonia could travel up to .1 mile before dispersing This release is very unlikely to occur during the life of the Hamakua Energy Partners facility. IV. DESCRIPTION OF THE HAMAKUA ENERGY PARTNERS ACCIDENTAL RELEASE PREVENTION PROGRAM Hamakua Energy Partners will conduct an annual training and response exercise with the Hilo Fire Department to practice, train and update the Hamakua Emergency Response Program. Hamakua Energy Partners will conduct an annual PSM/RMP implementation progress audit of the entire PSM/RMP program to identify strengths and weaknesses and make improvements. Hamakua Energy Partners considers the PSM/RMP manuals to be "living" documents that must be updated and revised regularly to maintain their viability. Hamakua Energy Partners empha sizes and insists on "employee participation" from the ammonia storage and use system operators in all aspects of the development, implementation, and integration of their PSM/RMP program. Hamakua Energy Partners provides a comprehensive, computer based, user-friendly training program with "one-on-one" teacher involvement in specific training modules for each ammonia storage and use system employee. Hamakua Energy Partners maintains a pro-active "open-door" policy toward neighbors and concerned community citizens. Facility tours and risk management discussions are scheduled and conducted upon written request. V. FIVE YEAR ACCIDENTAL RELEASE HISTORY There have been no releases of ammonia that resulted in an injury, or that had an off-site impact, or that resulted in significant property damage either on-site or off-site. VI. Emergency Response Program Hamakua Ammonia System Operators have been trained to respond defensively to an accidental ammonia relea se. The site emergency plan has been coordinated with the community emergency plan under the jurisdiction of the Local Emergency Planning Commission (LEPC) and the Hilo Fire Department. VII. PLANNED CHANGES TO IMPROVE SAFETY Hamakua Energy Partners recognizes that their PSM/RMP program will provide much needed improvement to their safety effort. The PSM/RMP program is considered to be a set of "living" documents and procedures that will require constant attention, development, and revision before "Safety" becomes second nature. Hamakua Energy Partners expects to improve safety performance by emphasizing the following elements of their PSM/RMP Program (1) Employee Participation is the "Key" to a successful program. Both Management and the Ammonia Storage and Use System Operators will be deeply involved in Verifying the P&ID's, Developing and updating the Standard Operating Procedures, and performing the documented Preventive Maintenance Inspections. (2) The Hamakua Energy Partners PSM/RMP Program will increasingly become: (a) computer based, (b) user friendly, (c) based on "one-on-one" involvement with specified and qualified trainers, (d) revised and re-written to minimize paperwork and maximize documentation, and (e) revised and re-written to be understood and used by the operating level employees. (3) All recommendations developed during the HAZOP were designed to improve the safety performance of the Hamakua Ammonia Storage and Use system. Hamakua Energy Partners expects to evaluate each recommendation in a timely manner and implement, as soon as possible, those recommendations that will reduce the possibility of a release and/or mitigate the consequences of an unintentional release. |