Air Products, Cambria Cogen Company - Executive Summary |
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Air Products & Chemicals, Inc. Cambria Cogen Company, Ebensburg, PA 1. Accidental release prevention and emergency response policies: At this facility we burn waste bituminous coal to produce steam and electricity. In the burning of coal, nitrous oxides will be formed, which are regulated by the Pennsylvania DEP and the Federal EPA. In order to capture NOx emissions in accordance with environmental permits, aqueous ammonia is injected into the process. Aqueous ammonia is regulated by the EPA as a toxic substance, and falls under the Federal RPM program. It is our policy to adhere to all applicable Federal and state rules and regulations. Air Products manages the safety of the regulated processes by means of following operating procedures, equipment testing and inspections, safety devices (e.g. alarms, shutdowns, instrumentation, relief devices) inherent in the design of this facility and other controls and systems designed to prevent accidental releases of hazardous chemicals. Safe work practices and training of our personnel supplement the inherent safe design of the plant. Our emergency response program is based upon OSHA?s HAZWOPER regulation. The emergency response plan includes procedures for the notification of the local fire authority, as well as an internal response level that relates to confine, contain, and control. This document has been prepared in accordance with the EPA?s Risk Management Program regulation (40 CFR, Part 68). The substances and processes considered during the preparation of this Risk Management Plan (RMP) and the scenarios described were selected based on criteria established in the regulation. 2. The stationary source and regulated substances handled: The primary purpose of this facility is to produce steam and electricity. In the burning of waste coal, nitrous oxides are formed, which are regulated by the Pennsylvania DEP and the Federal EPA. In order to capture NOx emissions in accordance with environmental permits, aqueous ammonia is injected into the process in a selective non-catalytic reduction reaction (SNCR). Once in the combustion gas, the ammonia is broken down into nitrogen and water, and is no longer toxic or regulated. As mentioned, the regulated substance handled at this facility is aqueous ammonia at a concentration of 29% by weight. The maximum amount at this facility is 42,500 pounds of ammonia in an aqueous solution. 3. The worst case release scenario and the alternate release scenario, including administrative controls and mitigation measures to limit the distance for each scenario: The worst case scenario, as defined by the EPA, is associated with a total release of the contents of the ammonia storage tank. This would be a total of 19,000 gallons of solution, or 42,500 pounds of ammonia. A containment dike around the storage tank is designed to contain the entire contents, preventing further release and limiting the evaporative capacity to that from the surface area of t he dike. The maximum distance to the EPA defined endpoint for this worst case scenario is 0.3 miles, or 1584 feet, which reaches two industrial neighbors. No residential, school, or environmental receptors are affected by this worst case. The alternate case scenario for this substance is defined by the most likely scenario with the highest risk and severity. The case chosen was that of a failure of the transfer hose during a transfer of aqueous ammonia from a delivery truck to the tank, emptying at a rate of 250 gpm outside of the containment for two minutes. This results in the release of 3800 pounds of solution to the ground, and the maximum distance to the EPA defined endpoint for this alternate case scenario is 0.2 miles, or 1056 feet, which reaches one industrial neighbor. No residential, school, or environmental receptors are affected by this case. 4. The general accidental release prevention program and specific prevention steps: The facility developed prevention progra m elements based on the Federal EPA?s Accidental Release Prevention Program. The facility was designed and constructed to comply with applicable state and industry codes. 5. Five-year accident history: This facility came on line in 1991. The permanent aqueous ammonia system was installed in 1999 in response to the EPA?s NOx Budget Program. There have been no accidents involving this system, nor have there been any accidental releases of aqueous ammonia. 6. The emergency response program: The facility?s emergency response program is based upon OSHA?s HAZWOPER standard. Employees at this facility will respond to emergencies to contain, control and confine, as well as notify outside emergency response agencies. Employees have been trained to OSHA?s HAZWOPER, First Responder Awareness Level in order to prepare them for this duty. Retraining is conducted annually. The facility maintains an Emergency Procedure Manual that contains specific procedures for employees to take in the ev ent of an emergency or accidental release. This information also contains the names and numbers of responding outside agencies. Emergency actions and response for toxic releases have been coordinated with the local fire department and HAZMAT units. Periodic drills are held in order to review these activities with the responsible units. 7. Planned changes to improve safety: The facility resolves recommendations from PHAs and incident investigations, some of which may result in modifications to the plant design and operating procedures. A Management of Change system, in the form of a Facility Change Notice, is used to ensure that any changes to the system or process first go through an engineering and safety evaluation process to determine the compliance with standards and the effects on other systems. |