COGEN TECHNOLOGIES NJ VENTURE - Executive Summary |
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Cogen Technologies NJ Venture Program 3 Executive Summary System Description Cogen Technologies NJ Venture (Cogen) owns a 165 megawatt (MW) cogeneration (cogen) plant in Bayonne, Hudson County, New Jersey. GE Contractual Services has been contracted by Cogen to operate the facility. This facility has been in operation since 1988. The facility is located wholly within the boundaries of the IMTT bulk storage terminal. The land use immediately surrounding the facility is industrial. Residential and commercial land use occurs approximately 1,600 feet from the site. Cogen's facility combusts natural gas in three GE Frame 6 combustion turbines to generate electricity. Each combustion turbine is equipped with a heat recovery steam generator (HRSG) that utilizes waste heat from the exhaust to convert water to steam. The steam from each HRSG is combined to drive a steam turbine. Electricity is generated at each gas turbine and the steam turbine. Steam is also piped to offsite indust rial facilities. A State mandated selective catalytic reduction (SCR) system is located within each HRSG to reduce nitrogen oxide (NOx) emissions from the combustion turbine exhaust gas. Each SCR consists of a catalyst and injection grid within the HRSG. Ammonia gas is injected through the grid upstream of the catalyst. The ammonia mixes with the exhaust gas and as the exhaust/ammonia mixture passes through the catalyst, NOx emissions are reduced to nitrogen and water. The ammonia injected into the HRSG is stored in a 30,000 gallon storage tank which is kept pressurized by ambient radiant heat and/or electric vaporizers. No more than 64,000 pounds (lbs) of ammonia is stored on site at any time. The ammonia gas generated in the storage tank flows to an ammonia skid located adjacent to each HRSG. The ammonia gas is mixed with air through a blower system and then the ammonia/air mixture flows to the injection grid. The injection grid is a simple pipe system with outlets provided within the HRSG. Existing Risk Management Activities The ammonia system has been regulated under New Jersey's Toxic Catastrophe Prevention Act (NJAC 7:31), New Jersey's Discharge Prevention regulations (NJAC 7:1E), and OSHA's Process Safety regulation (29 CFR 1910.119). These regulations have required the development of risk management programs and procedures similar to the EPA's risk management requirements. The elements of these programs include safety information, standard operating procedures, training, maintenance, emergency response, incident investigation, hot works, safety reviews, compliance reporting, employee participation, management of change, contractor safety, hazard reviews, and hazard assessments. Cogen has also implemented environmental programs and procedures to ensure compliance with all environmental regulations. These programs and procedures, maintained in manuals at the plant, are kept up to date and available to all plant personnel. The program consists o f the environmental permits and plans required to operate the facility. In addition to these programs, GE also maintains an EHS program. Elements of the GE program include hazard work permits, employee training, and general safety procedures. GE is also ISO 9000 certified. In summary, Cogen and GE have developed, implemented, and maintained environmental programs to ensure that risks associated with all plant operations are minimized and employees, nearby populations, and the environment are protected. Risk Management Program Summary Cogen has maintained a risk management program at the facility. The general manager has overall responsibility for maintaining this program. Responsibilities for specific program elements are shared among Cogen, GE, and East Coast Power LLC (Cogen's parent company). Safety reviews are required for new construction or modifications to the existing ammonia system. These reviews are conducted prior to construction or operation of new or modified s ystems. Safety information is also maintained at the facility. As there have been no changes to the ammonia system, no safety reviews have been required and modifications to the safety information have been minimal. Operating procedures have been implemented at the facility and address the possible operating conditions of the ammonia system. A maintenance program is in place and consists of procedures, testing and inspection schedules as well as a work order system that initiates and tracks work and inspections performed on the ammonia system. Hot works procedures along with other hazard permits (general work permits, lockout/tagout, etc.) exist at the plant and are applicable to all plant work. Contractors working on the ammonia system or any plant equipment/system are required to comply with the facility's contractor safety program. All facility personnel must complete initial and refresher training on procedures applicable to their position. All operators and maintenance pe rsonnel undergo a qualification process which addresses ammonia system operating procedures and/or maintenance procedures along with emergency response training. Administrative personnel must undergo emergency response training. Compliance audits have been conducted on an annual basis. These audits have consisted of a risk management program audit and a safety review of the ammonia system. The program audit consists of reviewing the risk management program and procedures to ensure the program is being implemented. The ammonia system safety review consists of an audit of the ammonia system and operating procedures and interviews with plant personnel to ensure that the ammonia system is designed and operated in accordance with the appropriate safety information. Incident investigation procedures are in place at the facility and not only investigate any events related to the ammonia system, but also any other events that may occur. All matters that are investigated are properly do cumented. Recommendations are promptly addressed. Management of change procedures are maintained at the facility and are implemented when there are any changes to the ammonia system. Change procedures do not apply to replacement in kind. Employee participation has always been implemented at the facility. Employees are included in hazard reviews and incident investigations. In addition, employees conduct self-assessments (plant audits conducted by employees), hold weekly safety meetings, conduct annual drills, and participate in safety committees. Hazard reviews have been conducted at this facility. The last hazard review was conducted in 1998. Hazard reviews identify the hazards associated with the process, opportunities for equipment malfunctions or human errors that could cause an accidental release, safeguards used or needed to control the hazards or prevent equipment malfunctions or human error, and steps used or needed to detect or monitor releases. Once the hazard rev iew is completed, a list of recommendations is developed and reviewed by plant personnel and management. The recommendations are then implemented at the site to further reduce the risk associated with the ammonia system. Hazard Assessment A hazard assessment has been completed to comply with the RMP regulations. The hazard assessment consists of analyzing the effects of a worst case release scenario and an alternate scenario. The worst case release considers the entire contents of the ammonia tank being released within 10 minutes. A dispersion model was utilized to model the offsite impacts of such a release. The model is known as "SLAB." The results of the model estimate that the worst case release scenario may hypothetically have a maximum endpoint distance of 2.13 miles and have a potential impact on residences, hospitals, parks and industrial/commercial facilities. No environmental receptors are believed to be impacted. The only mitigation allowed by the regulation and ap plicable to the site is the secondary containment provided for the storage tank. Cogen submits that this is not a credible scenario as previous hazard assessments have determined that the frequency of a catastrophic vessel failure is 1.5E-05 per year. In addition, the ammonia tank is surrounded by a water curtain that can be utilized to deluge ammonia vapors originating from the tank. Furthermore the ammonia storage tank does not operate under the temperatures or pressures required to facilitate this release scenario. The ammonia storage tank undergoes "in service" and "out of service" inspections in accordance with API standards, monthly safety inspections, and daily inspections. In addition, the ammonia tank is protected by concrete barriers to prevent exposure to traffic in the plant. All truck deliveries are escorted by plant personnel and the plant is enclosed in a security fence with monitored access. The plant also coordinates emergency drills with the local fire departme nt and provides information and equipment to the fire department to support site emergency activities. An alternate release scenario was also analyzed. The alternate release scenario was developed assuming a 1.17 inch diameter hole in an ammonia line releases ammonia for one hour. This scenario may also represent a leak from a delivery hose or a crack in a valve. The EPA RMP*Comp model was used to determine offsite impacts. The results of the modeling estimate that the endpoint distance will be 0.20 miles and have no impact on residences, hospitals, or parks. Only the adjacent industry could be impacted by this release scenario. This scenario takes into account that it will take 60 minutes to respond and stop the release. The mitigation effects of the water curtain were not considered in this analysis. The one hour release duration is a reasonable maximum time period as determined by the fire department's response time confirmed by drills that have been conducted with the Bay onne Fire Department. There have been no accidents or releases from the ammonia system within the last five years. Emergency Response An emergency response program has been implemented at the facility since the plant's construction. The emergency response program includes an emergency response plan and coordination of emergency information and activities with the Bayonne Fire Department. The emergency response plan contains the information and procedures necessary to respond to a release of any hazardous material at the site. Emergency information includes a list of emergency response personnel, notification requirements, evacuation procedures, and health/first aid data. Cogen has confirmed with the Bayonne Fire Department that personnel and equipment necessary to respond to a release of a hazardous substance at the site will be provided. Coordination with the fire department has included providing a copy of the emergency response plan, drawings, and other plant operating dat a. The emergency information has been placed in a computer program that is used as a reference at an emergency site by the department's hazmat unit. The fire department has participated in plant emergency response drills and drill critiques for the last five years. Cogen also contributes emergency equipment to the fire department. In addition to emergency drills, the fire department tours the facility to familiarize their personnel with plant operations and the locations of potential hazards. |