Burlington Generating Station - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES |
The PSEG Fossil, LLC - Burlington Generating Station has a long-standing 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 our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, generating station trained personnel will respond to control and contain the release and/or contact outside response personnel as appropriate.
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES
The Burlington Generating Station, located in Burlington, New Jersey, operates an electrical generating facility to supply electricity to New Jersey and Pennsylvania. The Burlington Generating Station has only one regulated toxic substance, aqueous ammonia. The maximum ammonia
concentration within the solution is 27.5% by weight.
OFFSITE CONSEQUENCE ANALYSIS RESULTS
The worst-case scenario (WCS) associated with toxic substances in Program Level 2 processes at the facility is a catastrophic pipe failure in the storage tank, resulting in a release of 208,620 lb of aqueous ammonia over a 60-minute period. Although we have numerous controls to prevent such releases and to manage their consequences, credit for only passive mitigation measures, the diked area around tank and administrative controls which limit tank volume, were taken into account in evaluating this scenario. The maximum distance to the toxic endpoint of 0.14 milligrams per liter for this WCS is 0.4 miles.
The alternative release scenario (ARS) for ammonia storage process is a pipe leak in the storage tank, resulting in a release of 208,620 lb of ammonia over a 60-minute period. The 60-minute release duration is the approximate time necessary for the entire volume of ammonia solution to lea
k out of the tank. No other mitigation measures were taken into account in evaluating this scenario. The maximum distance to the toxic endpoint of 0.14 milligrams per liter for this ARS is 0.2 miles.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM
The following is a summary of the accident prevention program in place at the facility.
Process Safety Information
The Burlington Generating Station keeps a variety of technical documents that are used to help maintain safe operation of processes. These documents address chemical properties and associated hazards, limits for key process parameters, specific chemical inventories, and equipment design basis/configuration information. Specific departments at the facility are assigned responsibility for maintaining up-to-date process safety information. A table summarizing the reference documents and their location is readily available as part of the written risk management program to help employees locate any necessary process safety in
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 any known hazards associated with the inadvertent mixing of chemicals. The facility ensures that the process is maintained within these limits using process controls and monitoring, highly trained personnel and protective instrument systems (e.g., automated shutdown systems).
The Burlington Generating Station 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.
The Burlington Generating Station 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.
The Facility primarily uses the What If?/Checklist analysis technique to perform these evaluations on the ammonia storage and injection process. The analysis was 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. The Hazard Review team findings are f
orwarded to local and corporate management for resolution.
The Burlington Generating Station 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, and (6) initial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. These procedures are periodically reviewed and annually certified as current and accurate. The procedures are kept current and accurate by revising them as necessary to reflect changes made.
To complement the written procedures for process operations, the Burlington Generating Station has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in facility operations if they are not already familiar with such operatio
ns. 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 periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every 3 years. All of this training is documented for each operator, including the means used to verify that the operator understood the training.
The Burlington Generating Station 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 condition. The basic aspects of this program
include: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (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 performance 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 (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into servi
ce (if possible), or a management of change team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment.
FIVE-YEAR ACCIDENT HISTORY
The Burlington Generating Station has an excellent record of accident prevention over the past 5 years. There have been no reportable accidents over the last five years. Should an accident occur, PSE&G would investigate every incident very carefully to determine ways to prevent similar incidents from recurring.
EMERGENCY RESPONSE PROGRAM INFORMATION
The Burlington Generating Station maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance. 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 evacuat
ion, notification of local emergency response agencies and the public if a release occurs, and post-incident cleanup and decontamination requirements. In addition, the plant has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is updated when necessary based on modifications made to gas plant processes or other facilities.
The overall emergency response program for the Generating Station is coordinated with the Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The facility 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. In addition to periodic LEPC meetings, the facility conducts periodic emergency drills that involve the LEPC and emergency response organizations, and the facility provides annual refresher, training to local emergency responders regarding the hazards of regulated substances in the facility.