TRACY BIOMASS PLANT - Executive Summary

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Tracy Operators, through an O&M agreement with the plant's owners, Thermal Energy Development Partnership, L.P., operates the Tracy Biomass Plant.  The Tracy Biomass Plant burns agricultural, industrial, and urban wood wastes to produce 21 MW of electricity.  Tracy Operators has in place process safety management procedures and emergency response procedures that will minimize the impact that an accidental hazmat release would have on plant personnel, plant property, our neighbors, and the environment. 
 
Source Description and Regulated Substances: 
 
The Tracy Biomass Plant burns agricultural, industrial, and urban wood wastes in a steam boiler.  The steam drives a turbine-generator to produce electricity.  A non-selective catalytic reduction (NSCR) of the oxides of nitrogen (NOx) generated during the combustion of the wood waste fuel is required to keep NOx emissions below the permitted limit specified in the Permit to Operate issued by the San Joaquin Valley Unified Air Pollution Contro 
l District. 
 
The NSCR process used at the Tracy Biomass Plant is called the Thermal DeNOx system.  The Thermal DeNOx system mixes anhydrous ammonia and steam, which is injected into the steam boiler through nozzles.  The anhydrous ammonia chemically reacts with the NOx to reduce NOx emissions.  The Thermal DeNOx system consists of a 12,000-gallon ammonia storage tank, ammonia piping, steam piping, pressure/flow control station, and injection headers.  Tracy Operators is required to submit a Risk Management Plan to EPA because the Thermal DeNOx system has a regulated substance (anhydrous ammonia) present in an amount that exceeds both the State and Federal threshold quantities.   
 
Hazardous Material Release Scenarios: 
 
The worst-case release scenario is failure of the storage tank containing 60,000 lbs. of anhydrous ammonia released over a period of 10 minutes.  The toxic endpoint for ammonia is 200 ppm (0.14 mg/L).  This airborne concentration has been published by the American Industr 
ial Hygiene Association (AIHA) and is the maximum airborne concentration below which it is believed that nearly all individuals can be exposed for up to one hour without experiencing or developing irreversible or other serious effects or symptoms which could impair an individual's ability to take protective action. 
 
Because more than 50% of the land mass in a 1-mile radius is rural, the plant site is considered rural.  The distance to the toxic endpoint (rural) for this worst-case release scenario is approximately 3.7 miles. 
 
The alternative release scenario considered for the RMP was the failure of the transfer line during tank filling, resulting in a 1,600 lb/min release of 60,000 lbs.  The distance to the toxic endpoint (rural) for this alternative release scenario is approximately 1.0 miles. 
 
Accidental Release Prevention Program: 
 
Tracy Operaters has in place an OSHA Process Safety Management Program for anhydrous ammonia.  In addition, the plant has a Hazardous Materials Manageme 
nt Plan that addresses all hazardous materials stored at the plant, including anhydrous ammonia.  The PSM Program addresses most of the items listed in Section 7 of this RMP, including the review of operating and maintenenance procedures, annual employee training, equipment inspections, and the review of contractor safety procedures. 
 
Five-Year Accident History:  
 
Tracy Operators has never experienced an accidental release of anhydrous ammonia that resulted in personal injury, property damage, or environmental damage.  Tracy Operators began operation of the Tracy Biomass Plant following construction completion in 1989. 
 
Emergency Response Program: 
 
In addition to the Process Safety Management System and Hazardous Materials Management Plan, Tracy Operators has in place an Emergency/Disaster Action Plan.  All employees receive annual Emergency/Disaster Action Plan training.  All of the Lead Operators are certified First Responders (awareness level) and the Plant Operations Superintendent 
is a certified First Responder (operational level).  The local fire department, Tracy Fire District, is the emergency response agency for the plant.
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