Ripon Cogeneration, Inc. - Executive Summary |
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1.1 Executive Summary This document represents the updated and revised Risk Management Plan (RMP) 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 RMP 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 RMP requirements. 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 M w (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 4500 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 28900 lbs. of ammonia. The distance to the toxic endpoint is 3.4 miles and affects approximately 10800 individuals. 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 0.4 mile and affects approximately <=1000 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 elements: - 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 RMP. - 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 ma nagement staff for appropriateness and implementation. |