Rensselaer Cogen - Executive Summary |
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Coastal Technology Inc., Rensselaer Cogeneration (Rensselaer Cogen), located in Rensselaer, New York, Rensselaer County, is a combined cycle, natural gas fired, cogeneration power facility which supplies electric power to the Niagara Mohawk Power Company and can supply process steam to BASF Chemical Corporation. The facility, or stationary source, is located on 39 Riverside Avenue, just ouside Albany, New York. Rensselaer Cogen employs approximately 15 full time individuals. Accident Release Prevention Program and Emergency Response Policy (? 68.155a) It is the policy of management at Rensselaer Cogen to implement the requirements of this Risk Management Program in accordance with the USEPA regulations under 40 CFR Part 68. The objective is to minimize the risk of a release of aqueous ammonia and, if a release occurs, to minimize the potential impact to Rensselaer Cogen's employees, the public, and the environment. This objective will be accomplished by utilizing good operating proc edures, by providing appropriate training to all employees, and by coordinating response activities, as necessary with the local emergency response providers. Rensselaer Cogen's management is committed to providing the resources necessary to implement this policy. The Stationary Source and the Regulated Substances Handled (? 68.155b) Rensselaer Cogen is comprised of a combustion turbine/generator, a Heat Recovery Steam Generator (HRSG), a steam turbine/generator, a steam surface condense, a cooling tower, steam, water and wastewater systems, and fuel handling and storage systems. The plant operates two shifts, seven days per week. The facility uses aqueous ammonia in the selective catalytic reduction (SCR) system. The aqueous ammonia system consists of one (1) 10,000-gallon aboveground storage tank and associated piping, valves, and other miscellaneous equipment. Local and remote level gauges are used to monitor tank level during filling and to prevent overfill. The remote indica tion is located in the facility's control room, which is continuously manned during tank filling, and is equipped with a high level alarm. An ambient atmosphere ammonia gas monitor located near the tank also provides an alarm in the control room in the event of a leak. The fill connection is located adjacent to the west side of the tank. The tank, supported by a cradle, is located in a concrete secondary containment area, which has a containment capacity of 110% of the tank volume. A portion of the aboveground ammonia steel piping is also located within the containment area. Catch basins, incorporated in the containment design, prevent spills and allow drainage of accumulated rainwater to the site's storm drain system. The tank and secondary containment are visually inspected several times daily for leakage. Rensselaer Cogen handles aqueous ammonia in quantities over the regulatory threshold of 20,000 pounds and falls under the Level 2 Program. Aqueous ammonia is classified as a toxic chemical under the Risk Management Program. Aqueous ammonia enters Rensselaer Cogen by tanker truck. A maximum of 73,790 pounds of 29.4 percent aqueous ammonia (which is equivalent to 21,400 pounds of 100 percent ammonia gas) is stored onsite at any given time. Worst-Case and Alternative Release Scenarios (? 68.155c) An off-site consequence analysis was performed to estimate the potential for an accidental release that would cause an off-site impact. The RMP rule requires an off-site consequence analysis to evaluate a: ? "worst-case release scenario" for one toxic substance and one flammable substance over the regulatory thresholds which represents all regulated toxic substances and all regulated flammable substances. Each toxic and flammable substance analyzed must cause the greatest impact for the regulated substances. ? "alternative release scenario" for each toxic substance and one flammable substance over the regulatory threshold. In reality, however, Rensselaer Cogen does not expect a worst-case release scenario to ever occur. The alternative release scenarios are developed to help the Local Emergency Planning Committee (LEPC) improve the community emergency response plan. The USEPA recommended LandView? III program was utilized to estimate the number of people living within this distance from the location of the storage tank. United States Geological Survey (USGS) maps and LandView (including MARPLOT? Mapping System) were utilized to identify the public, industrial, and environmental receptors located within this distance. Worst-Case Scenario Rensselaer Cogen's worst-case release scenario for aqueous ammonia is defined as an instantaneous release of all the contents of the aqueous ammonia storage tank (73,790 pounds) and its subsequent vaporization (it would take approximately 3,236 minutes for the ammonia solution to completely volatilze if no cleanup measures were taken) as manda ted by USEPA. Under the USEPA default worst weather conditions, this worst case toxic release impacts a distance of 0.1 miles before the concentration of ammonia was reduced to below 0.14 mg/L (which is the "endpoint" Emergency Response Planning Guideline value established in the RMP rule). USGS maps indicate that one industrial building is located within the impact area. No additional public receptors or environmental receptors are located within this distance. Alternative Scenario The "alternative case release scenario" involves the release from a flexible 2- inch diameter transfer hose connection. The release duration was chosen to be 1 minute based on a reasonable response time to shut-off the tank outlet nozzle. The amount of aqueous ammonia that would be released is 36 pounds of which 1.24 lb/min would volatize over a 29.1 minute period. The ammonia cloud would travel less than 0.06 miles before reaching a concentration of 0.14 mg/L (based on a wind speed of 6.7 mph (3 meters/ sec), a D stability class, and urban topography). USGS maps and LandView indicate that no public or environmental receptors are located within this distance. General Accidental Release Prevention Program and Chemical Specific Prevention Steps (?68.155d) The key concepts in Rensselaer Cogen's release prevention program are employee participation, appropriate design and maintenance of equipment, and appropriate training of all employees. Employee participation in the release prevention program is encouraged and supported by Rensselaer Cogen management. Key personnel are responsible for conducting and implementing the findings from the Process Safety Review for the aqueous ammonia system. Rensselaer Cogen's policy is to construct all new equipment, systems, and facilities in accordance with the most current building and safety codes. This ensures the appropriate safety and release prevention systems are included from the beginning of each project. Rensselaer Cogen maintains a log of maintenance activities to ensure that key systems are maintained appropriately to minimize the risk of a release. Rensselaer Cogen is committed to providing appropriate training to all employees regarding safety procedures. New employees are provided comprehensive safety training during their initial orientation of the facility. In addition, each year Rensselaer Cogen conducts regularly scheduled safety training for all employees. Additional training is provided to maintenance personnel for the systems they are responsible for. Five Year Accident History (?68.155e) Rensselaer Cogen has never had a release of aqueous ammonia from the Rensselaer facility that has affected the public, employees, or the environment. Emergency Response Program (?68.155f) The Rensselaer Cogen emergency response plan has been developed to meet the emergency planning, response and notification requirements of the following regulations: ? OSHA 29 CFR 1910.120 (p) and (q) - Hazardous Waste Operat ions and Emergency Response (HAZWOPER) ? OSHA 29 CFR 1910, Subpart L - Fire Protection ? Title 6 NYCRR Part 595.3, 596.6, and 598 - Incident Report and Emergency Response Plan ? EPA 40 CFR Part 302.6 - Notification Requirements ? EPA 40 CFR Part 355.30 - Facility Coordinator and Emergency Response Plan ? EPA 40 CFR Part 355.40 - Emergency Planning and Release Notifications ? EPA 40 CFR Part 112 - Spill Prevention, Control and Countermeasures Plan ? EPA 40 CFR Part 68 - Risk Management Programs for Chemical Accidental Release Prevention ? EPCRA section 302 - List of Extremely Hazardous Substances The emergency response strategy for the facility is to prevent and/or control emergency situations via the use of engineering, design, and fixed fire protection systems. Fixed fire protection systems are designed to National Fire Protection Association (NFPA) guidelines. The plant has an Emergency Response Team to respon d and initiate response actions to contain, control and if possible mitigate the release. It is Rensselaer Cogen's policy to contact off-site emergency responders for assistance in the event of a major accidental release of aqueous ammonia. A major leak is one that cannot be readily and safely isolated or that poses a hazard to personnel outside the site. Rensselaer Cogen's employees will contain and cleanup small spills and leaks. Rensselaer Cogen's employees, trained in the safe operation of the aqueous ammonia system, will close automatic and/or manual shutoff valves and securing pumps to terminate the flow of aqueous ammonia if the valves can be accessed safely. For all other scenarios, Rensselaer Cogen will evacuate the area and notify off-site responders so they may respond to the aqueous ammonia emergency. Rensselaer Cogen is an active participant in Rensselaer County Local Emergency Planning Committee. A copy of the plant's Emergency Response Plan has been forwarded to th e Office of Emergency Preparedness as per the requirements of 40 CFR 355 and New York State regulations (6NYCRR Part 596.6 and 598.1(k)(x). Planned Changes to Improve Safety (?68.155g) Rensselaer Cogen has completed a safety review of the aqueous ammonia system. Based on the review and New York regulations, the facility is required to install containment around the ammonia unloading area to contain leaks. The containment area was completed in 1999. Certification (? 68.185): To the best of the undersigned's knowledge, information, and belief formed after reasonable inquiry, the information submitted is true, accurate, and complete. _**___________________________ _Harry Brand____________ Signature Print Name _Plant Manager_________________ _August 14, 2000_________ Title Date **The original signature is included in the attached cover lett er. |