Illinois Power Company Baldwin Power Station - Executive Summary |
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Illinois Power Company Baldwin Power Station Baldwin, Illinois RISK MANAGEMENT PLAN EXECUTIVE SUMMARY The following executive summary addresses Baldwin Power Station's compliance with Section 112 (r) of the Clean Air Act administered by the U.S Environmental Protection Agency (EPA). This Risk Management Plan (RMP) is submitted in accordance with 40 CFR Part 68, EPA's Chemical Accident Prevention Program. STATIONARY SOURCE AND REGULATED SUBSTANCES Baldwin Power Station, located one mile north of the town of Baldwin, Illinois (approximately 35 miles southeast of the St. Louis Metro area), is the largest provider of electricity in Illinois Power's generating system. Baldwin Station consists of three major fossil fuel-fired units; two Babcock & Wilcox cyclone-fired once-through boilers supplying steam to their respective Westinghouse turbo-generators and one Combustion Engineering forced circulation drum boiler supplying steam to a General Electric turbine-generator. Unit 1 wen t into commercial service on July 12, 1970; Unit 2 on May 21, 1973; and Unit 3 on June 20, 1975. Together these units can produce approximately 1700 net megawatts which represent 38% of Illinois Power's total generating capacity. The electric output of each generator is directed to an associated main transformer which steps up the voltage to 345,000 volts for long range transmission. The electricity flows to the switchyard where it is then routed to one of four 345 kV transmission lines or to a step down transformer that provides 138 kV power for transmission lines to relatively nearby substations. Cooling water for the main and auxiliary condensers of the three units is provided by a 2,000 acre man-made cooling lake constructed by Illinois Power Company. Baldwin Lake is approximately 1.5 miles wide and 2.5 miles long and normally holds about seven billion gallons of water. Three pumps on the Kaskaskia River can pump over 10 million gallons of makeup water into the lake each day. The circulating water system provides over one million gallons of water each minute to the plant's main and auxiliary condensers (all 3 units running at full load). This water system is treated with chlorine to inhibit excessive algae growth within the system. Chlorine is the only chemical listed by the RMP regulation in amounts greater than the threshold quantity at the Baldwin Power Station. By the end of 1999, Koch Nitrogen Company (Koch) will own and operate an ammonia supply terminal on the Baldwin Power Station property with amounts of ammonia greater than the RMP threshold quantity. This Koch terminal will supply the Power Station with ammonia for emission control purposes. Koch will prepare and maintain a separate Risk Management Program for this facility. This RMP addresses the Offsite Consequence Analysis, Prevention Program and Emergency Response Programs for the Illinois Power Company, Baldwin Power Station. Baldwin Power Station employs approximately 250 persons , 142 employees of Illinois Power with the remainder being contractors or vendors. Most of these employees live nearby in Randolph County. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES As an RMP Program Level 3 facility, Baldwin Power Station is in compliance with the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) Program requirements. These requirements include conducting regular Process Hazard Analyses (PHAs) to identify and understand hazards; preparing, following, and auditing Operating Procedures; conducting initial and refresher Training of employees; performing regular Mechanical Integrity reviews of process equipment; developing and implementing written Management of Change procedures; conducting Pre-Startup reviews, Compliance Audits, and Incident Investigations. These requirements form the framework of our accident prevention program and it is the policy of Illinois Power Company to meet or exceed these requirements. The Baldwin Power Station has a written Emergency Response Program which addresses the manpower and equipment necessary to handle onsite emergencies. In complying with this RMP regulation our Emergency Response Plan has been updated to include offsite notification procedures, if necessary. Illinois Power is a participant in the Randolph County LEPC. It is the policy of Illinois Power Company Baldwin Power Station to handle any on site emergencies with our own manpower and equipment. We would rely on outside emergency response assistance for any offsite emergencies. No incident with offsite impacts has occurred since power generation began in 1970. POTENTIAL RELEASE SCENARIOS In accordance with the Offsite Consequence Analysis (OCA) Requirements prepared by the EPA, Baldwin Power Station has evaluated both a worst case scenario and an alternative release scenario for chlorine. The worst case scenario is defined by EPA as the release of the largest quantity of a regulated sub stance from a vessel or process line failure that results in the greatest distance to the applicable toxic endpoint. In our situation this is a release of 6,000 pounds of chlorine in a ten minute period. This scenario would require that three one-ton cylinders interconnected by piping somehow release their entire contents. We consider this scenario to be practically impossible. Based on EPA's OCA model (RMP*Comp Version 1.06) the worst case distance is 5.2 miles. Our Alternative Release Scenario (ARS) is the result of evaluating a variety of failures of the chlorine system that we consider possible, although very unlikely. The scenario resulting in the greatest offsite distance involves complete rupture of a 1" valve or pipe within the chlorine system. The endpoint distance was calculated to be 0.6 miles, again using RMP*Comp, which protectively overestimates the distance. Although unlikely, this distance is considered prudent to use for emergency response planning purposes. A dministrative controls and mitigation measures designed to minimize release distances include 24 hour manning of the facility with regular inspections of the chlorine system, pressure/vacuum alarms for immediate notification to the control room, and HAZWOPR-trained employees prepared to immediately respond. ACCIDENTAL RELEASE PREVENTION AND CHEMICAL-SPECIFIC PREVENTION STEPS Illinois Power has up to 16 one-ton containers of chlorine on site at any one time. We empty approximately three containers per week. These containers must comply with The Chlorine Institute's specifications 106A500, 106A500X, ICC 27 and B.E. 27. They are equipped with safety devices and pressure tested at regular intervals as required by applicable regulations. All containers used in the transportation of chlorine are controlled by federal or other governmental regulations. Chlorine in containers is found in both a liquid and gas state. Neither the gas nor the liquid is explosive or flammable, both reac t chemically with a number of other substances. The gas has a characteristic odor and greenish yellow color and is about two and one-half times as heavy as air. Thus, if it escapes from a container or system, it will seek the lowest level in the building or area in which the leak occurs. Liquid chlorine is clear, amber in color, and is about one and one-half times as heavy as water. Chlorine gas is primarily a respiratory irritant. In sufficient concentration the gas irritates the mucous membranes, the respiratory system and the skin. In extreme cases, the difficulty of breathing may increase to the point where death can occur from suffocation. Liquid chlorine in contact with skin or eyes will cause burns. The characteristic, penetrating odor of chlorine gas gives warning of its presence in the air. Its greenish yellow color make it visible when high concentrations are present. If an alarm sounds indicating a change in pressure within the chlorine system, employees trained an nually in safe techniques for responding to chemical releases will immediately investigate. Self-contained breathing apparatus (SCBA) and valve repair kits are maintained on site for their use. If necessary, the leak is isolated and appropriate repairs performed usually within 30 minutes of detection. In more than 29 years of operation, no leak has occurred which resulted in any offsite impacts. This is a direct result of the accident prevention procedures in place at the facility. FIVE-YEAR ACCIDENT HISTORY There have been no RMP-defined accidents at the Baldwin Power Station in the last five years. Occasionally, there have been OSHA recordable incidents, however, none of these involved the chlorine system. There has never been an offsite impact caused by an accident at the facility. EMERGENCY RESPONSE PROGRAM The Baldwin Power Station has a written Emergency Response Program. This program addresses hazardous waste operations and emergency response procedures at the plant , responsibilities of employees during an emergency, reports required for an emergency, emergency recognition and prevention, safe distance requirements, evacuation plans, security and site control procedures, notification procedures and phone numbers, and personnel protective equipment. In case of an accident or emergency, there is a nearby ambulance service in Red Bud, Illinois. Volunteer Fire Departments are available in the towns of Baldwin, Sparta and Red Bud. The Baldwin Power Station also actively coordinates with the Randolph County LEPC known as the Randolph County Emergency Services and Disaster Agency (ESDA) headed by Nancy J. Schilling. PLANNED CHANGES TO IMPROVE SAFETY As a result of evaluating our alternative release scenario, Baldwin Power Station will implement the following safety measures: 1. Develop a notification system in coordination with the Randolph County Emergency Services and Disaster Agency that is specifically designed to provide warning and precau tionary instructions to potential public receptors. Priority will be given to potential public receptors within the calculated 0.6 mile ARS distance from the chlorine system. 2. Since a portion of Baldwin Lake is within the 0.6 mile ARS distance, warning signs will be posted at each boat launch to the lake to warn boaters to maintain a safe distance from the facility. Due to the small area of the lake within the 0.6 miles, this is not judged to adversely impact use of the lake. 3. Finally, Illinois Power Company plans to redesign the chlorine system from a pressurized system to a vacuum system. This redesign will significantly reduce the potential for releases since a leak will automatically result in system shutdown. This Risk Management Plan is presented as an example and testament of Illinois Power Company's commitment to accident prevention. This commitment is supported by the fact that no accidents with offsite consequences have occurred at this facility. We will continu e to strive for perfection in our accident prevention program and will continue to improve our emergency response program and safety programs. |