James De Young Generating Station - Executive Summary

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Risk Management Plan Executive Summary for the 
James De Young Generating Station 
The Holland Board of Public Works (HBPW), James De Young Generating Station (JDY Plant) is made up of 3 coal-fired steam generating units capable of producing up to 60 MW of electricity for residential, industrial, and commercial customers in the Holland area.  The plant, located at 64 Pine Avenue, is just within the city limits and is located on Lake Macatawa. 
The use of chemicals is relatively limited at the JDY Plant, however liquefied chlorine gas is utilized to chlorinate water entering the plant so that bacteria and other biological fouling agents do not build up within the plant's critical cooling systems.  The chlorine plays an important role in keeping the plant in an efficient and effective operating condition.   
Chlorine gas is a required submission of 40 CFR Part 68 - Chemical Accident Prevention Provisions (Risk Management Plan) because of its' potential health threat if released into the a 
tmosphere under uncontrolled conditions.  The JDY Plant is a closed system, free from exposure to the atmosphere under normal conditions.  Chlorine gas is handled in 1 ton steel pressurized cylinders, which is fed under a vacuum to a chlorinator that generates a nonhazardous solution with the gas and intake water.  Because the system is closed, under vacuum, and is not open to the atmosphere the release scenarios are minimal.  The release scenarios developed were based on the puncture or intentional release of the steel 1 ton chlorine cylinder (worst case scenario), and a leak around an attached pipe or apparatus (alternate case scenario).    
The worst case scenario of a puncture to the steel cylinder is very unlikely, because the outer walls of the cylinder are approximately 1 inch thick steel, and a release would require that an individual intentionally puncture the cylinder.  An individual could also intentionally remove the plugs on the cylinder, which would create the same worst  
case scenario.  To avoid such a situation the HBPW completes background checks on all prospective employees, requires random drug testing on a continual basis, and has training and supervisory programs and procedures to foresee and prevent problems of this nature. 
The alternate case scenario of a leak around an attached pipe or apparatus is a more conceivable scenario, but training programs and operational procedures have been developed to prevent this type of scenario.   One such procedure requires that two individuals complete the changing of chlorine tanks.  Such a program reduces human errors, because it acts as a check and balance type system.  Operators are also trained in the proper handling techniques and the dangers of chlorine so that they are consciously aware of their responsibilities.  
The threat of a chlorine release is also minimized by the use of chlorine gas monitors that sound immediately if a leak occurs.  Should this occur, operators, trained in proper handling te 
chniques, emergency response measures, and in HAZWOPER response techniques are fully prepared to handle any potential release.  
The JDY Plant has taken significant steps to develop an accidental release prevention and emergency response program, as well as training and procedure guidelines for chlorine storage and use.  The JDY Plant has implemented a Process Safety Management Program for the handling of chlorine.  The Process Safety Management Program was a team effort of plant personnel and included a detailed review of the entire system.  Each piece of equipment and procedure was evaluated for potential failure, the consequences of a failure, and preventative measures taken to reduce the potential.  A preventative maintenance program was put in place to maintain the integrity of the system.  Training on the chlorine system is required for any employee who becomes involved in the operation or maintenance of the system. 
In addition, the JDY Plant has worked and continues to work ver 
y closely with the Local Emergency Planning Committee (LEPC) and other emergency response organizations to develop detailed emergency response plans, should a release occur.  Both the LEPC and the JDY Plant have written two coinciding emergency response manuals to deal with emergency situations.  In addition, on an annual basis the JDY Plant submits the updated amount of chemicals, including chlorine, located at the plant so that the LEPC's records are kept up to date. 
The Holland Board of Public Works and its employees at the James De Young Generating Station are very proud to say that no accidents or releases of chlorine have ever occurred.  However, the HBPW and the JDY Plant are consciously aware of the possibility of a release to the atmosphere.  To mitigate this threat the JDY Plant is currently in the engineering stages of substituting liquid bleach for chlorine gas. The liquid bleach is safer because it remains in liquid state under normal conditions and represents a significa 
ntly less widespread hazard to human health and the environment.  The substitution is expected to be completed by the fall of 1999.  All use of chlorine gas would be eliminated at that time.
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