Theodore Cogeneration Plant - Executive Summary

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The Theodore Cogeneration Plant is currently under construction.  The Plant will have the capability to generate approximately 210 Megawatts(MW) of electric power for distribution to Alabama Power's customers. 
 
It is the policy of the plant to provide and maintain safe and healthful working conditions and to implement and adhere to operating practices that will safeguard all employees and result in safe working conditions, and an efficient and environmentally safe operation.  The plant has a safety program designed to ensure that the employees' working environment is safe.  This program includes training and instructions. 
 
The process at the natural gas fired electric generating plant subject to the RMP regulations is the ammonia storage and dilution system.  This system is part of the Selective Catalytic Reductions system used to control emissions of nitrogen oxides generated from burning natural gas.   
 
Based on the EPA criteria, the worst-case release scenario at the facility is the 
catastrophic failure of the 18,000 gallon ammonia storage tank.  This would result in the ammonia gas traveling 3.3. miles before it reached the endpoint.  However, this type of failure is extremely unlikely due to the safeguards described in the prevention program. 
 
The worst of the several alternative release scenarios considered for the release of ammonia was due to a liquid leak from a line failure.  A failure of this type would result in ammonia gas traveling 0.2 miles before reaching its endpoint.  There are numerous mechanical and procedural safeguards at the Plant designed to prevent this from occurring.  However, for emergency response planning purposes they were not considered in the alternative release scenario. 
 
The accidental release prevention program at the Theodore Cogeneration Plant is focused on the safe management of ammonia used in the ammonia storage and dilution system.  The first step in the prevention program at the Plant was the establishment of a management s 
ystem to assign overall responsibility and responsibility of the individual program elements.  Additional steps include:  ensuring process safety information on the ammonia storage and dilution system is accurate, complete and up to date; ensuring the system is designed and modified safely by periodically conducting process hazard analyses; ensuring the system is operated and maintained in a safe manner by developing, maintaining and implementing Standard Operating and Preventive Maintenance Procedures; ensuring contractors are qualified, and oriented to the site hazards; and conducting periodic Compliance Audits and Incident Investigations including resolution of recommendations made during these investigations/reviews 
 
No spills have occurred at this facility in the past 5 years. 
 
The Theodore Cogeneration Plant will be included in the Mobile LEPC emergency response plan.  In addition, the Plant has in place an emergency action plan that includes procedures to be followed in the even 
t of an accidental release of ammonia.  The procedures cover the following: evacuation plan; recognizing emergencies; emergency action procedures; coordinating personnel; first aid procedures; notifying the public and local emergency response agencies; emergency response contacts; emergency response equipment; reportable release quantities and documenting releases; emergency alarm system; training; and pre-emergency coordination with the Mobile LEPC.
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