Pasadena Cogeneration, L.P. - Executive Summary |
|
A. Describe the Accident Release Prevention and Emergency Policies Farmland Dairies is committed to safety. We believe all injuries can be prevented and expect all employees to assume the responsibility for working safely. Ammonia safety is a key item in our safety program. We take many precautions to prevent or minimize accidental releases of ammonia. These precautions include safety controls (alarms and automatic shutdown devices) which are designed to identify and prevent potentially unsafe conditions like pressure increases that could cause a system failure, a preventive maintenance program designed to maintain the on-going integrity of the system, a training program designed to ensure that the system is operated by qualified personnel, and emergency response procedures which enable trained personnel to respond quickly to system upsets. The Regulatory Compliance Manager is responsible for the management of the ammonia safety program. B. Stationary Source and Regulated Sub stances Handled The Farmland Dairies facility in Wallington, NJ processes milk and other dairy products. The plant uses an ammonia refrigeration system to provide cooling for the dairy products and the production area. The maximum ammonia inventory at the plant is approximately 17,000 pounds. Ammonia is the only regulated substance handled at the plant. C. Summary of Worst-Case and Alternative Release Scenarios The worst-case toxic release scenario at the Farmland Dairies Plant involves the release of 9,700 pounds of ammonia due to the failure of the main receiver. This maximum inventory reflects the written administrative procedures in place at the plant to limit the amount of ammonia stored in the main receiver to 80% of its capacity. Under worst-case conditions, the resulting vapor cloud could have off-site impacts. The alternative toxic release scenario at the plant involves the release of 775 pounds of ammonia over a 2 minute period due to the rupture of a ?" liquid lin e because of a vehicular accident. Under alternative release conditions, the resulting vapor cloud could have off-site impacts. The worst-case and alternative toxic release scenarios are unlikely for the following reasons: o The weather conditions that were used for the worst-case release scenario do not occur, while those used for the alternative case are uncommon; o Industry standards are followed for the design and manufacture of the equipment in the ammonia refrigeration system; o The ammonia receivers are protected from vehicular traffic; o Pressure safety valves on the main receiver should limit any pressure increases inside the receiver; o Ammonia is not corrosive in this service; o The facility has a preventive maintenance program in place to maintain the on-going integrity of the ammonia refrigeration equipment; and, o The facility has a training program designed to ensure that the systems are operated by qualified personnel. D. Description of the Accidental Release P revention Program The facility has a program level 3 accident release prevention program for the ammonia system that complies with OSHA's Process Safety Management Standard, EPA's Risk Management Program Regulation, and New Jersey's Toxic Catastrophe Prevention Act (TCPA). The ammonia prevention program consists of the following elements: o Employee Participation Program o Process Safety Information o Process Hazard Analysis o Operating Procedures o Training Program o Contractor Safety Program o Pre-Startup Safety Review Procedures o Mechanical Integrity Program o Hot Work Permit Procedures o Management of Change Procedures o Incident Investigation Procedures o Compliance Audit Procedures E. Five-Year Accident History One ammonia-related incident was identified for the plant during the previous five years that resulted in significant on-site or offsite consequences. This incident resulted in one on-site injury. Additional training has been provided to prevent a reoccurrence o f this incident. F. Description of the Emergency Response Program An emergency response program has been implemented at the plant. This program contains procedures describing how the facility will respond to ammonia leaks and other emergencies, including evacuation procedures. The emergency response program includes the following elements: o Pre-Emergency Planning and Coordination o Personnel Roles and Duties o Emergency Response Procedures o Evacuation Routes and Procedures o First Aid Procedures The program has been coordinated with the Wallington Fire Department. G. Planned Changes to Improve Safety ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES Pasadena Cogeneration, L.P. has a strong commitment to worker 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 processes. It is the policy of Pasadena Cogener ation to implement reasonable controls to prevent foreseeable releases of regulated substances. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES Pasadena Cogeneration, located in Harris County, Texas, is a gas-fired combustion turbine cogeneration plant that produces stream and electricity. The steam is consumed by local and industrial users. Electricity is also sold to local industry with the remaining output being placed on the grid for general consumption. As a means of reducing nitrogen oxide emissions from the three gas-fired combustion turbines, anhydrous ammonia is injected into the turbine exhaust streams. The anhydrous ammonia is stored on-site in three, individual storage tanks. The total storage capacity of this toxic material exceeds the threshold level for RMP applicability. There are no other toxic or flammable materials on-site which exceed RMP levels. OFFSITE CONSEQUENCE ANALYSIS RESULTS The worst case scenario (WCS) associated with a release of a toxic substance at Pasadena Cogeneration is a release involving one of the anhydrous ammonia storage tanks. Based on guidance from the EPA, the WCS involves the complete inventory in the storage tank released over a 10-minute period. The 14,200-gallon anhydrous ammonia tank is limited to 85% storage capacity by administrative controls. Assuming a specific gravity of 0.6386 for liquid anhydrous ammonia, the maximum storage tank capacity is 64,284 lbs. The WCS is modeled based on a release rate of 6,428 lbs/min. The EPA's RMP*Comp model indicates that the endpoint for this type of release is 2.8 miles. There are public receptors within this distance. Therefore, a Program 3 RMP is required for the anhydrous ammonia process. Alternative scenarios were addressed as required by rule. Based on EPA guidance, alternative release scenarios of anhydrous ammonia most likely involve flashing liquid releases. The anhydrous ammonia systems are designed such that all piping downstream of the storage tank is laid beneath concrete. Each storage tank is set in a reinforced concrete containment area which would contain any spills and also provides protection from any blast effects. The truck loading point is surrounded by traffic posts and is equipped with pull-away valves and a breakaway hose. There is a water deluge system over the storage tank which is triggered by an atmospheric concentration of 200 ppmv. Anhydrous ammonia is water soluble. If the deluge system is activated, the released anhydrous ammonia is flushed from the atmopshere. The water/ammonia mixture enters the plant drainage system. All piping and vessels have a pressure rating that is greater than normal operating pressures. The system is equipped with redundant control systems including shutoff valves, pressure relief valves, pressure indicators, etc. Alternative release scenarios were identified as: (1) tank leak due to external impact and, (2) tank truck pull-away. The alternative scenarios invo lving a tank leak impacts public receptors. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM The following is a summary of the accident prevention program in place at the plant. Because processes at the plant that are regulated by the Environmental Protection Agency's (EPA's) risk management program (RMP) regulation are also subject to the Occupational Safety and Health Administration's (OSHA's) process safety management (PSM) standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. Employee Participation Pasadena Cogeneration actively encourages employees to participate in all facets of process safety management and accident prevention. Each employee is urged to participate in the continual upgrading and maintaining of all health and safety programs. Employee involvement is achieved through direct participation on a voluntary basis, active consultation with affected employees, and parti cipation in the process hazard analysis (PHA) team. Employees have access to the PHA and all other information required to be developed under the process safety management standard. Process Safety Information Pasadena Cogeneration maintains a variety of technical documents that are used to help maintain safe operations of the plant with regards to the anhydrous ammonia systems. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific personnel within Pasadena Cogeneration are assigned responsibility for maintaining up-to-date 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 as sociated 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). 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 construction, 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. Process Hazard Analysis (PHA) Pasadena Cogeneration 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. Pasadena Cogeneration primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. 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. To help ensure that the process controls and/or process hazards do not eventually deviate s ignificantly 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. Operating Procedures Pasadena Cogeneration maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, (6) startup after an emergency shutdown, (7) operating limits, and (8) safety and health considerations. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. The procedures are kept current and accurate by revising them as necessary. Training To complement the written procedures for process operations, Pasadena Cogeneration has a comprehensive training program for all employees involved in operating the anhydrous ammonia 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 receive refresher training at least once every three years on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. All training is documented for each operator, including the means used to verify that the operator understood the training. Contractors Pasadena Cogeneration uses contractors to supplement its workforce during periods of increased maintenance or const ruction activities. Because some contractors work on or near process equipment, the plant has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform plant personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to their beginning work. In addition, Pasadena Cogeneration evaluates contractor safety programs and performance during the selection of a contractor. Plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-startup Safety Reviews (PSSRs) Pasadena Cog eneration conducts a PSSR for any new facility or facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. Mechanical Integrity Pasadena Cogeneration 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 c ondition. The basic aspects of this program include: (1) performing and documenting inspections and results, (2) conducting maintenance training, (3) developing written procedures, (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. If a deficiency is identified, employees will correct the deficiency before placing the e quipment back into service (if possible), or management will review the 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. Pasadena Cogeneration 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. Hot Work Permit Pasadena Cogeneration has a hot work program in place to help ensure worker and process safety. The hot work permit and procedures are designed to control spark-producing activities and to ensure that adequate precautions are in place before work begins in the hazardous area. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change Pasa dena Cogeneration has a comprehensive system to manage changes to the anhydrous ammonia system. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change. Incident Investigation Pasadena Cogeneration promptly investigates all incidents that results in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injur y. 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 finding 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 a minimum of 5-years so that the reports can be reviewed during future PHAs and PHA re-validations. Emergency Planning and Response Pasadena Cogeneration has a written emergency action plan that describes the safety and emergency procedures and tools recommended to be used to handle and control accidenta l spills and/or fires in the anhydrous ammonia storage and processing area. All personnel are trained in standard first aid and CPR training. In the event of an emergency, plant personnel can contact the Pasadena Fire Department. Pasadena Cogeneration personnel can also contact the Houston Chemical Complex (HCC) via two-way emergency radio. The anhydrous ammonia storage tanks are equipped with a detector alarm that triggers at an atmospheric concentration of 200 ppmv. In the event of an alarm, plant personnel assess the situation. If it is determined that a major ammonia spill has occurred, plant personnel will contact the local fire department, the LEPC, the Pasadena police and county sheriff, and HCC. Personnel will evacuate the plant and meet emergency response teams at the designated meeting point and accompany them to the proximity of the emergency. Plant personnel are not trained nor equipped to respond to a worst-case release event in the anhydrous ammonia system. Compl iance Audits To help ensure that the accident prevention program is functioning properly, Pasadena Cogeneration periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Pasadena Cogeneration management will certify that the PSM has been evaluated at least every three years. The audit team develops findings that are forwarded to plant personnel for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained. CHEMICAL-SPECIFIC PREVENTION STEPS The anhydrous ammonia process at Pasadena Cogeneration has 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. Universal Prevention Acti vities The accident prevention program summarized previously is applied to the RMP covered process at the power plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. Specialized Safety Features Pasadena Cogeneration has safety features on many units to help (1) contain/-control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in the covered processes: Release Detection * Ammonia detectors (200 ppmv trigger) with audible alarms Release Containment/Control * Valves to permit isolation of the process (manual or automated) * Automated shutdown systems for specific process parameters (e.g., temperature/pressure/flow rates) * Redundant equipment and instrumentation * Atmospheric relief devices * Anhydrous ammonia storage tank water deluge system * Reinforced concrete containment basi n FIVE-YEAR ACCIDENT HISTORY Pasadena Cogeneration has been operating since 1998. The facility has an excellent record of accident prevention. To date there have been no accidents that have occurred which resulted in offsite effects as defined in 40 CFR 68. The following table is a summary of the number of accidents that have occurred during the past 5 years which resulted in: * on-site deaths, injuries, or significant property damage * offsite deaths, injuries, property damage, evacuations, sheltering in place, or environmental damage 1995 1996 1997 1998 1999 Number of RMP Events with Onsite Effects N/A N/A N/A 0 0 Number of RMP Events with Offsite Efffects N/A N/A N/A 0 0 EMERGENCY RESPONSE PROGRAM INFORMATION Pasadena Cogeneration maintains a written emergency response program, which is in place to protect worker and public safety. The program consists of procedures for responding to a release of a regulated substance, including the possibility for a release of anhydrous ammonia. 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 emergency response agencies and the public if a release occurs. Plant employees are trained to handle small emergencies only. Employees are not trained to respond to RMP releases. In the event of an RMP release, employees will activate shutdown procedures, evacuate the plant, and notify local emergency response teams. The emergency response program is updated when necessary based on modifications made to the plant processes. The overall emergency response program for Pasadena Cogeneration is coordinated with the Pasadena Local Emergency Planning Committee (LEPC). This coordination includes attendance at periodic LEPC meetings. Pasadena Cogeneration has around-the-clock communications capability with appropriate LEPC officials and 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. EXECUTIVE SUMMARY Pasadena Cogeneration, L.P. Argent Consulting Services, Inc. |