AECI CC Power Plant -- Chouteau Power Plant - Executive Summary

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The Chouteau Power Plant is committed to operating in a manner that is safe for our workers, contractors, the community, and the environment.  To meet this commitment, it has established systems to help ensure safe operation of the processes at this plant.  One component of these systems is a risk management program (RMP) that helps manage the risks involved with using hazardous substances at our plant and that complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule).  One of the requirements of the RMP rule is to submit an executive summary in the risk management plan (RMPlan) describing the RMP at the Chouteau Power Plant.  This document is intended to satisfy the executive summary requirement of the RMP rule and to provide the public with a description of our RMP.  Section 2 of this executi 
ve summary describes the one substance currently used at the Chouteau Power Plant in sufficient quantity to be regulated by the RMP rule. 
The Chouteau Power Plant risk management program consists of three elements: 
1. A hazard assessment designed to inform of (a) the potential offsite consequences of hypothetical accidental releases and (b) accidents that have occurred during the last 5 years associated with the substances regulated by the RMP rule - see Sections 3 and 5 of this executive summary 
2. A prevention program to help maintain and safely operate processes containing significant quantities of substances regulated by the RMP rule - see Section 4 of this executive summary 
3. An emergency response program to help respond to accidental releases of regulated substances from processes covered by the RMP rule - see Section 6 of this executive summary 
Although the RMPlan helps ensure that our plant is maintained and operated in a safe manner, it is only one component of the safet 
y program.  In fact, a comprehensive safety program that establishes many levels of safeguards against accidental releases and against the injuries and damage that could occur from accidental releases. 
Limited use of substances regulated by the RMP rule.  Before using a substance regulated by the RMP rule ("regulated substance"), the plant considered less hazardous alternatives.  Once it was determined that regulated substance must be used, the potential for this substance to adversely affect workers, contractors, the public, and the environment was considered and steps have been taken to minimize or prevent any such effects. 
Preventing releases of the regulated substances used at the plant.  When a regulated substance is used, the equipment used to contain it is carefully designed, built, and operated to reduce the likelihood of an accidental release.   
Limiting damage from a release, if such a release occurs.  We work to prevent accidental releases from occurring.  However, we als 
o train our workforce to recognize accidental releases, quickly assess the severity of a release, and respond to mitigate and stop the release, including contacting the local agency responsible for responding to accidental releases (e.g., the Local Emergency Planning Committee [LEPC]) if emergency response actions are necessary. We work closely with the LEPC to ensure appropriate plans are in place to minimize the impact of the release on our workers and the community. 
Our safety program consists of a number of elements, only some of which are required by the RMP rule.  This RMPlan is primarily intended to describe those parts of the safety program required by the RMP rule. 
We are committed to the safety of workers, contractors, and the public, and the preservation of the environment, through the prevention of accidental releases of regulated substances.  We take appropriate steps to prevent foreseeable releases of re 
gulated substances.  These steps include (1) training programs for personnel, (2) programs to help ensure safety in the design, installation, operation, and maintenance of our process, and (3) programs to evaluate the hazards of our process. 
In the event of an accidental release, we will strive to minimize the release in a manner that will be safe for workers and will help prevent injury to the public or damage to the environment.  We provide response training to our personnel, including working with the LEPC when executing emergency response actions, so that they are well prepared to respond in the event of an emergency situation. 
The Chouteau Power Plant has one substance (anhydrous ammonia) in sufficient quantity to be regulated by the RMP rule.  The anhydrous ammonia used at the plant is covered as a toxic material by the RMP rule.  The ammonia is used to help reduce, nitrous oxide emmisions from the plant that results fro 
m the combustion process. 
The RMP rule requires that we perform an offsite consequence analysis to estimate the potential for accidental releases of the anhydrous ammonia that could affect the public or the environment. In accordance with the regulations, we evaluated one worst-case release scenario and a more realistic (but still highly unlikely) alternative release scenario for the anhydrous ammonia system. 
We do not expect a worst-case release scenario to ever occur.  This scenario is designed to estimate the maximum possible area that could be affected by a release of anhydrous ammonia from our plant, but it is not a realistic scenario.  An alternative release scenario was analyzed to help emergency preparedness and to improve the community emergency response plan.  The alternative release scenario was selected to represent a more realistic release that might occur at a plant like the Chouteau Power Plant. 
The main objective for performing the o 
ffsite consequence analysis is to determine the distance at which certain effects on the public might occur because of an accidental release (called the endpoint distance).  For a release of a toxic material, the toxic endpoint is defined by EPA as the maximum airborne concentration below which it is believed that nearly all individuals can be exposed for up to 1 hour without experiencing or developing irreversible or other serious health effects or symptoms that could impair an individual's ability to take protective action.   
The following information summarizes the offsite consequence analysis.  
3.1  Worst-case Release Scenario  
The worst-case release scenario is a failure of an anhydrous ammonia storage tank that results in the release of the entire contents of the tank.  The maximum inventory of 7,800 gallons (40,200 lb) of ammonia is assumed to be released over a 10-minute time period.  The predicted distance to the toxic endpoint (200 ppm) reaches offsite public receptors. 
2  Alternative Release Scenario 
The alternative release scenario for the anhydrous ammonia process is a rupture of a liquid line from the anhydrous ammonia storage tank.  The predicted distance to the toxic endpoint (200 ppm) for this scenario would reach nearby offsite public receptors.  In evaluating this scenario, credit was taken for the reduction in release rate provided by the excess flow valves that are part of the system design. 
We have developed a comprehensive prevention program that complies with the Occupational Safety and Health Administration's (OSHA's) process safety management (PSM) regulation.  For the Chouteau Power Plant, the prevention program requirements of EPA's RMP rule are also satisfied by this PSM program. The following sections briefly describe the elements of our prevention program that address the RMP rule requirements.  
4.1  Prevention Program 
Our accident prevention progra 
m for anhydrous ammonia consists of the following 12 elements: 
1. Process safety information.  We maintain a variety of technical documents, including an emergency preparedness plan, to help ensure that our employees and local emergency responders know about the hazards associated with our plant.  These documents address (a) physical properties of anhydrous ammonia, (b) operating parameters for our equipment, and (c) design basis and configuration for our equipment.  We ensure that this process safety information is available to our employees. 
2. Process hazard analysis.  We perform and periodically update a process hazard analysis of our anhydrous ammonia process to help identify process hazards and make recommendations that will improve the safe operation of the process.  A multidisciplinary team is assembled to analyze the hazards of the anhydrous ammonia process.  This team includes personnel with engineering and process operating experience and a leader with process hazard analy 
sis experience. The team systematically addresses the hazards associated with operation of the equipment in the anhydrous ammonia system. The team then prepares a written report describing the results of the analysis, including a list of recommendations.  Responsibility for resolving the recommendations is assigned to plant personnel, and, when appropriate, changes to enhance the safety of the system are implemented.  This analysis is revisited at least every 5 years to ensure it is current. 
3. Operating procedures.  Our engineers, operators, and managers work together to develop and maintain operating procedures to define how tasks related to ammonia system operations should be safely performed.  The operating procedures are used to train employees and serve as reference guides for appropriate actions to take during both normal operations and process upsets.  Operating procedures include: 
? Steps for safely conducting activities 
? Applicable safety information, such as safe operatin 
g limits and consequences of deviations 
? Safety and health considerations, such as chemical hazards, personal protective equipment requirements, and actions to take if exposure to a hazardous substance occurs 
4. Training.  We train employees to safely and effectively perform their assigned tasks.  Our training program includes both initial and refresher training that covers (a) a general overview of the system, (b) the properties and hazards of anhydrous ammonia, and (c) a detailed review of the operating procedures and safe work practices.  Classroom training and demonstrations are used to help train employees.  Oral reviews and demonstrations are used to verify that an employee understands the training material before the employee can work on the ammonia system. 
5. Mechanical integrity.  We maintain our ammonia handling equipment to help prevent equipment failures that could endanger workers, the public, or the environment.  Our mechanical integrity (preventive maintenance) progra 
m includes (a) an inspection and testing program to help identify equipment deterioration and damage before the equipment fails and (b) a quality assurance function to help ensure that new and replacement equipment meet the strict design standards required for service in our process. 
6. Management of change.  We have a written procedure to review and approve all proposed changes to the ammonia system, including chemicals, equipment, technology, and procedures to help ensure that the change does not negatively affect safe operations. All changes other than replacement-in-kind (e.g., replacing a valve with an identical valve) must be approved through the full management of change program.  This helps ensure that inadvertent consequences of changes are prevented, safety consequences of changes are addressed, affected process safety information and procedures are updated, and affected employees are notified of the changes. 
7. Pre-startup safety review.  We perform safety reviews of new o 
r modified processes before placing them into service to help ensure their safe operation.  This review confirms that: 
? Construction and equipment are in accordance with design specifications; 
? Adequate safety, operating, maintenance, and emergency procedures are in place; 
? Employee training has been completed; and 
? For a covered process, a process hazard analysis has been performed if the process is new, or management of change requirements have been completed if an existing process has been modified. 
8. Compliance audit.  One of the cornerstones of an effective prevention program is a regular, thorough assessment.  We have a program to perform compliance audits of our ammonia system every 3 years to be certain our prevention program is effectively addressing the safety issues of the process.  This audit is performed by an audit team that includes personnel knowledgeable in the PSM and RMP regulations and in our process designs, and this team evaluates whether the prevention prog 
ram satisfies the requirements of these two regulations and whether it is sufficient to help ensure safe operation of the ammonia system.  The results of the audit are documented, recommendations are resolved, and appropriate enhancements to the prevention program are implemented. 
9. Incident investigation.  We have a program to investigate any incidents or near misses that could reasonably result in serious injury to personnel, the public, or the environment so that similar accidents can be prevented in the future.  We communicate to our employees the requirement to identify and report any incident requiring investigation.  In the event of an incident, an investigation team would be assembled, and the investigation would be initiated as soon as possible, but always within 48 hours of the incident. The results of the investigation are documented, recommendations are resolved, and appropriate process improvements are implemented. 
10. Employee participation.  We have a written employee 
participation program for our covered process to help ensure that the safety concerns of our employees are addressed.  We encourage active participation of personnel in the prevention program activities of all processes at the plant.  Employees are consulted on and informed about all aspects of our accidental release prevention program. 
11. Hot work permits.  We have a hot work permit program to control spark- or flame-producing activities that could result in fires or explosions in our plant.  We reviewed OSHA's fire prevention and protection requirements and created a hot work permit form to comply with these requirements.  Personnel who are to perform hot work are required to fill out the form, and the appropriate supervisor reviews the completed form before work can begin.  Training on hot work activities and on the requirements of the hot work permit program is included in our safe work practices orientation. 
12. Contractors.  We have a program in place to help ensure that cont 
ractor activities related to the ammonia system are performed in a safe manner.  We explain to the contract supervisors the hazards of the processes on which they and their employees will work, our safe work practices, and our emergency response procedures.  Contractors are required to ensure that training has been performed for each of their employees who will work at the plant before that worker begins work at our plant.  We routinely verify that this training has been provided.  
4.2  Chemical-specific Prevention Steps 
In addition to the required prevention program elements, we have implemented safety features specific to anhydrous ammonia.  
The anhydrous ammonia is delivered in tank trucks that must be approved by the Department of Transportation. The anhydrous ammonia storage tanks and equipment are designed and maintained to standards established by the federal government and by industry.  Manual shutoff valves, excess flow devices in the storage tank, and ammonia detectors with 
alarms are provided as process controls that are in place to help prevent or mitigate releases of anhydrous ammonia from the system. 
Because the Chouteau Power Plant is a new facility (commercial operation is scheduled from mid-2000), there is no accident history that would show the continuous safe operation of the ammonia system.  However, the ammonia system has been designed to codes and standards that should minimize the possibility of accidental releases of anhydrous ammonia from the system that could result in exposure to employees, contractors, the public, or the environment. 
Although Chouteau Power Plant personnel will not respond to significant releases of ammonia, we have established a written emergency response program to help facilitate the evacuation of our employees and to ensure the safety of outside emergency responders who could be called on to respond to any accidental releases of hazardous substances. 
 The emergency response plan includes procedures for: 
? Informing local emergency responders about accidental releases that could reasonably result in offsite consequences 
? Providing proper first aid and emergency medical treatment for accidental human exposure to hazardous substances 
? Obtaining outside assistance to control and contain accidental releases of hazardous substances, including the use of emergency response equipment 
? Inspecting and maintaining emergency response equipment 
? Reviewing and updating the emergency response plan 
We have trained our employees to recognize and report emergency situations.  All of our personnel and contractors are trained in evacuation procedures.  The LEPC is responsible for notifying the public of the emergency situation, if necessary. 
The written emergency response plan complies with other federal contingency plan regulations [e.g., the OSHA regulation 29 CFR 1910.38(a)], and a copy of the plan has been provided to the local fire depa 
rtment. Also, a hazardous material inventory has been provided to the LEPC and local fire department, as required by the Emergency Planning and Community Right-To-Know Act. Chouteau Power Plant personnel will maintain a regular dialogue with local emergency planners. 
We are dedicated to continuous improvement of the safety of our processes using recommendations developed through the prevention program and a program soliciting safety suggestions from our employees.  All recommendations received by the plant manager are evaluated and implemented if safety can be improved.  Standard operating and safety procedures for the covered process are reviewed periodically and we provide training to our employees and contractors on a wide variety of safety and operating topics.
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