Chevron USA Production Kern River Eastridge cogen - Executive Summary |
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DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES The Chevron USA Production Kern River Cogeneration Facility is located in Bakersfield, California and produces steam and electricity from natural gas. The steam is used for enhanced oil recoveryand a portion of the electrical power is consumed by Chevron, while all surplus power is sold to the local utility. A new aqueous ammonia process unit is being added to the existing Cogeneration Plant and is scheduled to start up in 2nd quarter 2000. The ammonia will reduce the amount of nitrogen oxides (NOx) in the flue gas, which is accomplished by injecting ammonia vapor in the flue gas just prior to exposure to a catalyst. The resultant chemical reaction reduces the NOx to harmless nitrogen and water. The aqueous ammonia that is used is a <30% concentration. The maximum quantity of aqueous ammonia at the facility is above EPA's Risk Management Program (RMP) threshold quantities,and above the California Accidental Release Prevention Program (CalARP) threshold quantity. There are no other process units or substances at the Kern River Cogeneration Facility that are regulated under RMP or CalARP. ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The Eastridge Cogeneration Facility has a long-standing commitment to workers and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, trained plant personnel will respond to control and contain the release. OFFSITE CONSEQUENCE ANALYSIS RESULT The Worst Case Scenario (WCS) at the Eastridge Cogeneration Plant is a release of the maximum quantity of 72,000 lbs of aqueous ammonia from the storage tank. A written procedure is in place to limit the storage inventory to this quantity. There is a dike area around the tank and is large enough to fully contain the content of the entire tank. The resulting distance to the endpoint concentration of 200 ppm has off-site impacts. The only impacted public receptors are adjacent unmanned well sites. No other public receptors or manned facilities are within the endpoint. The OCA (offsite consequence analysis) is based on EPA's RMP*Comp program, version 1.06. The Alternative Release Scenario (ARS) for aqueous ammonia is a leak from a ?" hole in the piping system. It is assumed that the leak continues for 20 minutes until the leak can be stopped. The contents from this release would be fully contained in the diked area. The resulting distance to the endpoint concentration of 200 ppm has off-site impacts. The only impacted public receptors are adjacent unmanned well sites. No other public receptors or manned facilities are within the endpoint. The OCA analysis is based on EPA's RMP*Co mp program, version 1.06. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM The following is a summary of the accident prevention program in place at the plant. It is our policy at the Eastridge Cogeneration Plant to adhere to all Federal, State and Local laws. Our management demonstrates its commitment to safety and the environment by enforcing Chevron's Corporate Policy 530. Policy 530 states that the Company will conduct scientific hazards assessments, as needed, to identify, characterize, and safely manage any potential hazards of company operations. In addition policy 530 outlines a number of management practices covering all facets of company operations and attainment defenitions describing compliance. Employee Participation: The Eastridge Cogeneration Plant encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team. Employees have access to all information created as part of the plant accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that is maintained at the plant and addresses each accident prevention program element. Process Safety Information: The Eastridge Cogeneration Plant keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific individuals within the plant are assigned responsibility for maintaining up-to-date process safety information. A table summarizing the reference documents and their location is readily available as part of the written employee participat ion plan to help employees locate any necessary process safety information. Chemical specific information, including exposure hazards and emergency response/ exposure treatment considerations, is provided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For specific process areas, the plant has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in a Key Process Parameter Document. The plant ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems). The plant also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of con struction, design pressure and temperature ratings, and electrical rating of equipment. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. Amanagement of change process is in place and is used to document changes within the plant that will effectsafety and environment, as well as changes which modify the facility or changes, which modify the facility or change operating conditions. Process Hazard Analysis (PHA): The Eastridge Cogeneration Plant has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. The Eastridge Cogeneration Plant p rimarily uses the Process Hazard analysis technique. The PHA methodology is recognized to be a systematic and thorough hazard evaluation technique. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and the team makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team findings are forwarded to local and corporate management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options in response to PHA team findings are tracked until they are completed. The final resolution of each fin ding is documented and retained. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the plant periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained. Operating Procedures: The Eastridge Cogeneration Plant maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) emergency shutdown(4)normal shutdown, (5)innitial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent trainin g of new operators. These procedures are periodically reviewed and annually certified as current and accurate. The procedures are kept current and accurate by revising them as necessary to reflect changes made through the management of change process. Upper and lower operating limits and consequence of deviation and how to correct deviation on most of the critical equipment most particularly the fractionation section are incorporated in the written standard operating procedures. This information is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their tasks. Training To complement the written procedures for process operations, the Eastridge Cogeneration Plant has implemented a refresher training program for all employees involved in operating a process. New employees receive basic training in plant operations if they are not already familiar with such operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate (e.g., through tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted every year. All of these training is documented for each operator, including the means used to verify that the operator understood the training. Maintenance: The Eastridge Cogeneration Plant has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedur es, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process. Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their jobs in a safe manner. Written procedures help ensure that work is performed in a consistent manner and provide a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or a management of change team will review t he use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. Another integral part of the mechanical integrity program is quality assurance. The Eastridge Cogeneration Plant incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. Safe Work Practices: The Eastridge Cogeneration Plant has a long-standing safe work practices in place to help ensure worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous substances before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit an d procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Incident Investigation: The Eastridge Cogeneration Plant promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to plant management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. The final resolution of each fin ding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations. Compliance Audits: To help ensure that the accident prevention program is functioning properly, the Eastridge Cogeneration Plant periodically conducts a number of audits to determine whether the procedures and practices required by the accident prevention program are being implemented. Audits include our level 3 SERT inspections, level II compliance audits and level 1 corporate audits. Audits are conducted at least every year. Both hourly and staff personnel participate as audit team members. The audit team develops findings that are forwarded to plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are compl ete. The final resolution of each finding is documented, and the two most recent audit reports are retained. CHEMICAL-SPECIFIC PREVENTION STEPS The processes at the Eastridge Cogeneration Plant have hazards that must be managed to ensure continued safe operation. The following is a description of existing safety features applicable to prevention of accidental releases of regulated substances in the facility. All Chemicals newly introduced to theEastridge Cogeneration Plant has to have MOC document, Product Acceptance certification approved by the Facilities Engineer, Environmental Safety Specialist, Chevron Chemical Group and the Operations Supervisor. All Chemicals delivered to the facility must have a Material Safety Data Sheet. Chemical truck drivers are required to follow Plant Entry Procedures which involve signing of the Sign In/Sign Out log and safety orientation overview training. Operator has to supervise the driver during the unloading process to ensure that chemical wil l go to the right storage or container. Specialized Safety Features: The Eastridge Cogeneration Plant has safety features to help contain/control a release, and reduce the consequences of (mitigate) a release. The following types of safety features are used in the aqueous ammonia system: Release Containment/Control: 1. Tank relief valves discharge away from personnel and equipment in the event of over-pressurizing of the storage tank. 2. Valves permit isolation of the process. 3. High pressure alarm in the storage vessel. 4. Containment wall sorrounds the storage tank and equipment to fully contain any potential spill or release. Any collected material can be routed for decontamination and disposal. 5. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump) Release Mitigation: 1. Fire extinguishing system 2. Trained emergency response personnel 3. Personal protective equipment (e.g ., chemical protective clothing, self-contained breathing apparatus, fire fighting turnouts) FIVE-YEAR ACCIDENT HISTORY The Eastridge Cogeneration Plant has an excellent record of accident prevention over the past 5 years. We investigate every incident very carefully to determine ways to prevent similar incidents from recurring. Since the ammonia system is a new addition to the existing Cogeneration Plant, there are no accidents to report for the five-year accident history. EMERGENCY RESPONSE PROGRAM INFORMATION The Eastridge Cogeneration Plant maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance. The procedures address all aspects of emergency response, including proper first aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local eme rgency response agencies and the public if a release occurs, and post incident cleanup and decontamination requirements. In addition, the plant has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is updated when necessary based on modifications made to the Chevron USA Production Kern River Cogeneration Plant processes or other third party facilities that may affect the operations at the plant. The overall emergency response program for the Eastridge Cogeneration Plant is coordinated with the Bakersfield Fire Department. This coordination includes periodic meetings, which includes local emergency response officials and industry representatives. The Chevron USA Production Kern River Cogeneration Plant has around-the-cl ock communications capability with appropriate Public Safety officials and/or emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to monthly safety meetings, the Chevron Kern River Cogeneration Plant conducts periodic emergency drills that involve the plant operators. In addition, the plant operators are given annual refresher training for emergency response regarding the hazards of regulated substances in the plant. All plant personnel have undergone hazardous material training and are classified under LEVEL 5 of the Hazwopper designation which covers the First Responder,and First Responder Operational.The supervisor of the facility has also been trained to a level 5 Response level, incident commander training. PLANNED CHANGES TO IMPROVE SAFETY Planned changes to improve safety include but are not limited to the following. Prior to system star-up;a hazardous communications training event will be offered to all those plant personnel involved with plant operations,including the operation of the aqueous ammonia system. this training event will cover hazards and precautions to be taken when working with ammonia. A procedure has been implemented for the loading and unloading of ammonia into storage which includes the use of a standby observer, safety watch, and the wearing of the proper PPE(personal Protective equipment) as well as the monitoring of the area for hazards and releases;and isloation of the area to non-essential personnelwhile aqueous ammonia is being off-loaded. A number of detectors have been installed in the storage and process area that will give early warning in case of an accidental release of ammonia vapors. All plant presonnel have been trained in emergency response and hazard assesment and wil l respond accordingly. Additional procedures are being implemented to secure the plant and insure that no unathorized entry is allowed without first reporting to the control room, and receiving a briefing on the proper response procedures while on plant premises. Where necessary plant procedures will be modified accordingly to insure compliance with Chemical accident prevention procedures. |