AES Cayuga LLC - Executive Summary |
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AES Cayuga LLC PSM/RMP ROGRAM I. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY POLICIES AES Cayuga LLC recognizes management's responsibility in protecting it's employees, equipment, property, and the environment against the hazards of an unintentional ammonia release. The safety and health of all employees and the public is very important. The control of accidents has been and will continue to be a basic responsibility of all personnel in the facility. The AES Cayuga LLC PSM/RMP program assigns and documents the specific responsibilities for developing, implementing and integrating the OSHA PSM and the EPA RMP standards into its safety program. The AES Cayuga LLC PSM/RMP program focuses attention on "Making PSM/RMP the way we manage" our ammonia based process rather than a project we expect to complete and put on the shelf when the filing date has passe d. AES Cayuga LLC believes that Employee Participation is the key to a successful program. Operating level employees, particularly the Operators and Maintenance personnel, will be deeply involved in the PSM/RMP program development, implementation and integration and they will assume a major responsibility for operating the ammonia process safely. The AES Cayuga LLC Emergency Response Program has been developed with the complete cooperation and support of the Lansing Volunteer Fire Department. All AES Cayuga LLC employees have received documented emergency response training. II. STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED AES Cayuga LLC operates a Fossil Fuel Power Generating Station. Ammonia is used to control NOx emissions in their stack gas. Anhydrous Ammonia is the only Hazardous Material on site in amounts above the threshold quantity. III. SUMMARY OF WORST CASE AND ALTERNATIVE RELEASE SCENARIOS The WORST CASE release scenario involves the complete rupture of the Ammonia Storage Tank. This maximum ammonia release from a ruptured storage tank was assumed to occur over a 10 minute period. The distance of travel for the generated ammonia vapor cloud has been calculated and the information is available from Plant Management. A WORST CASE release is very, very, very, unlikely to occur during the life of the facility, this is because of the release prevention and mitigation features incorporated in the AES Cayuga LLC PSM/RMP program. An alternative case release scenario that we call WORST CASE CREDIBLE was slightly more likely. An ammonia vapor release from a failed pressure relief valve or from ammonia vapor piping was considered. The distance to the Toxic Endpoint under worst case weather conditions has been calculated. The information is available from AES Management on a need to know basis. This release scenario is also very, very unlikely to occur during the life of the facility. A second alternative scenario was also considered which we call MOST LiIKELY, MOST SEVER. This scenario considered the release of ammonia from a ruptured ammonia loading hose during the tank fill operation. The distance to the Toxic Endpoint under worst case weather conditions has been calculated. The information is available from AES Management on a need to know basis. Even this release scenarionis very unlikely to occur during the life of the facility. IV. DESCRIPTION OF THE AES Cayuga LLC ACCIDENTAL RELEASE PREVENTION PROGRAM AES Cayuga LLC plans an annual training and response exercise with the Lansing Volunteer Fire Department to practice, train and update the AES Cayuga LLC Emergency Response Program. AES Cayuga LLC conducts an annual PSM/RMP implementation progress audit of the entire PSM/RMP program to identify strengths and weaknesses and make improvements. AES Cayuga LLC considers t he PSM/RMP manuals to be a collection of "living" documents that must be updated and revised regularly to maintain their viability. AES Cayuga LLC emphasizes and insists on "employee participation" from the ammonia system operators in all aspects of the developent, implementation, and integration of their PSM/RMP program. AES Cayuga LLC provides a comprehensive, training program with full documentation of specific training modules for each ammonia system employee. AES Cayuga LLC maintains a pro-active "open-door" policy toward neighbors and concerned community citizens. Facility tours and risk management discussions are scheduled and conducted upon written request. V. FIVE YEAR ACCIDENTAL RELEASE HISTORY There have been no releases of ammonia that resulted in an injury, or that had an off-site impact, or that resulted in significant property damage either on-site or off-site. VI. Emergency Response Program AES Cayuga employees have been trained to respond to an accidental ammonia release. The site emergency plan has been coordinated with the community emergency plan under the jurisdiction of the Local Emergency Planning Committee (LEPC) and the Lansing Volunteer Fire Department. VII. PLANNED CHANGES TO IMPROVE SAFETY AES Cayuga LLC recognizes that (even though their Ammonia release and injury experience has been excellent) their PSM/RMP program will provide much needed improvement to their safety effort. The PSM/RMP program is considered to be a set of "living" documents and procedures that will require constant attention, development, and revision before "Safety" becomes second nature. AES Cayuga LLC expects to improve safety performance by emphasizing the following elements of their PSM/RMP Program. (1) Employee Participation is the "Key" to a successful program. Both the Maintenance and Ammonia System Operator s will be deeply involved in Verifying the P&ID's, Developing and updating the Standard Operating Procedures, and performing the documented Preventive Maintenance Inspections. (2) The AES Cayuga LLC PSM/RMP Program will increasingly become: (a) computer based, (b) user friendly, (c) based on specific training by qualified trainers, (d) revised and re-written to minimize paperwork and maximize documentation, and (e) revised and re-written to be understood and used by the operating level employees. (3) All recommendations developed during the HAZOP were designed to improve the safety of the AES Cayuga LLC facility. AES Cayuga LLC has evaluated each recommendation and has implemented those recommendations that will reduce the possibility of a release and/or mitigate the consequences of an unintentional release. |