Panther Creek Energy Facility - Executive Summary |
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The Panther Creek Energy Facility, located in Nesquehoning, Pennsylvania, is committed to ensuring a safe work environment for the employees and the community. To this end, the management strongly supports the implementation of safe procedures for all aspects of operation, including the one regulated process: anhydrous ammonia. The facility fully complies with the regulation and intent of both the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) rule and the Environmental Protection Agency's (EPA) Risk Management Program (RMP). The success of the facility's commitment is verified by the fact that there have been NO accidents which involve the anhydrous ammonia system at any time since the system was installed. The Panther Creek Energy Facility is a small electric generation facility. Power at the facility is generated through the burning of culm, which is a waste product generated from the production of purified coal. A byproduct from any coa l/culm burning process is the generation of gaseous nitrous oxides (NOx). Panther Creek Energy Facility is committed to a clean environment, and as required by the Pennsylvania Department of Environmental Protection (PADEP), desires to minimize the release of NOx from the facility. Injecting ammonia into the boiler cyclone is one way of converting NOx to natural byproducts of nitrogen and water. Panther Creek Energy Facility therefore purchases, stores, and utilizes anhydrous ammonia in order to prevent the release of NOx to the atmosphere. Anhydrous ammonia is delivered to the facility in tank trucks and stored in a 25,000-gallon storage tank before being vaporized and injected into the boiler stacks. As part of the RMP requirements, facilities which contain a regulated substance (such as anhydrous ammonia) at quantities exceeding 10,000-pounds must consider the impact of a worst-case and an alternate-case release of the substance. In order to determine the impact a release wo uld have, Panther Creek Energy Facility utilized the Dense Gas Dispersion (DEGADIS) Model developed by the University of Arkansas for the U.S. Coast Guard. DEGADIS can handle ground-level passive releases and is available on the EPA's web site. By definition, a worst-case release involves a catastrophic failure under the worst possible atmospheric conditions, and is therefore extremely unlikely. For this facility, the worst-case scenario is the failure of the 25,000-gallon storage tank when filled to the greatest amount allowed (85% of capacity). The evaporating ammonia released in this situation would reach offsite endpoints and nearby public receptors. The ammonia tank is on a regular maintenance and inspection schedule and is in a protected and fairly isolated location, making a catastrophic failure all the more unlikely. The alternate-case release which was evaluated involved a small hole in a liquid ammonia line releasing ammonia for a period of 60 minutes. In this situat ion, evaporating ammonia would leave the property boundaries and would reach a minimal number of offsite endpoints; no sensitive public or environmental receptors would be impacted. Again, a regular maintenance and inspection schedule and an isolated pipeline location reduces the potential for release. As part of this facility's commitment to provide a safe work environment, the Panther Creek Energy Facility complies with OSHA's PSM rule. Monthly safety training is conducted for all employees, and specific training is given to operators of the ammonia system. All components of the ammonia system are covered under a Mechanical Integrity program to assure that they operate safely are and are physically sound. Appropriate standard operating procedures (SOPs) are in place for start-up and shutdown of the ammonia process, in both normal and emergency situations. All other components of the PSM program are in place, and are outlined and discussed in a PSM/RMP manual in use at the facil ity. As mentioned previously, this facility has had no accidents involving anhydrous ammonia within the five-year accident history period. In fact, there has never been an ammonia accident during the history of the facility. In the event of an ammonia release, the Panther Creek Energy Facility has in place an Emergency Response (ER) Plan which is reviewed and updated whenever a significant change to the ammonia system occurs. All employees have been trained on this procedure. An On-Duty Shift Supervisor is available in the Control Room 24 hours per day, and is the designated 24-hour emergency contact. The facility ER plan defines "Controllable" and "Uncontrollable" ammonia releases. A controllable release is defined as a situation where the ammonia flow can be shut-off or contained without the employee being exposed to any health or safety risks, or where the rate of release does not pose any immediate danger. An uncontrollable release is defined as a significant release of ammonia where shut-off or control would place an employee at a health or injury risk. In this situation, the employee will not attempt to contain the release; the area will be evacuated and the local fire department will be immediately notified. The facility has coordinated with the local fire department, and the fire department is aware of the presence of anhydrous ammonia at the facility and is prepared to respond in the event of an emergency. In addition to defining the severity of the ammonia release, the facility's emergency response plan establishes a written procedure to follow in the event of a release. The procedure contains specific actions required to control an ammonia release from equipment or piping damage, a leaking valve, or the activation of a pressure relief device. In addition, the plan discusses the procedures to be implemented in the event of a fire adjacent to the ammonia system. The emergency response plan also contains procedures to alert facility personnel of the danger potential; a list of emergency contacts; evacuation procedures and primary/secondary locations; and the establishment and use of an Emergency Rescue Crew. If required, the emergency rescue crew will locate and evacuate any missing persons. The crew will be comprised of two people per shift who have training in CPR, First Aid, Ammonia Safety, Fire Escort Training, Atmospheric Monitors and SCBA use. The Panther Creek Energy Facility is committed to continuously improving the overall safety and environmental performance record at the facility. Although no specific changes are currently planned, specific policies aimed at improving safety will be continually improved. These policies include: continuing development of best management practices; conducting site- and job-specific training; continuing coordination with the Local Emergency Planning Committee; and upholding the facility's goal for a safe workplace. In summary, the Panther Creek Energy Facility is fully commi tted to the safe storage, use, and operation of the anhydrous ammonia system utilized at the facility. The facility fully complies with the regulation and intent of both the PSM rule and RMP. As a result of effective facility planning, well-trained and capable employees, and implemented safety procedures, the facility has never had an accident involving the anhydrous ammonia system. |