Orange Cogeneration Facility - Executive Summary |
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RMP Executive Summary for Orange Cogeneration Facility Facility Description and Regulated Substances Handled Orange Cogeneration Facility (Orange Cogen) is an independent cogeneration power plant owned by Orange Cogeneration Limited Partners and operated by CSW Energy, Inc. (CSW). The power and steam generated for sale is produced from two natural gas turbines, each with it's own Heat Recovery Steam Generator and a single steam turbine. Orange Cogen has only one RMP regulated substance at the facility, which is chlorine. It is stored in three one-ton cylinders located near the cooling towers. The chlorine is used for microbiological control in the cooling tower waters. Whereas most of the chlorine is absorbed and consumed by the water, a low (0.3 ppm free Cl2) residual is maintained in the bulk water. Five-Year Accident History Orange Cogen has been in commercial operation since June 16, 1995 and has had no accidental releases of chlorine since that time. General Accidental R elease Prevention Program and Chemical-Specific Prevention Steps Orange Cogen Facility complies with all applicable federal, state, and local statues governing the storage and use of all chemicals. This includes compliance with OSHA's Process Safety Management Program, EPA's Risk Management Program, and Hazardous Chemical reporting under SARA Title III. Since communication and knowledge are important preventative measures in a safety program, a Right-To-Know center in the Control Room provides safety information to all employees, contractors, and visitors to the site. Contained in the center are Material Safety Data Sheets (MSDS), the Emergency Response Guidebook, The Pocket Guide to Chemical Hazards, and Keller's Official OSHA Safety Handbook. The Orange Cogeneration Facility was constructed with many safeguards for chemical handling and usage. The hazardous liquid chemicals on site, sulfuric acid and caustic, are stored in tanks surrounded by secondary containment. The pumps used to deliver the chemicals to the various processes are also inside the containment dike. Chemical piping is double-piped where appropriate. UV resistant tubing has been employed for delivery of chlorine and other chemicals where tubing is exposed to sunlight. Accidental Release Prevention and Emergency Response Policies CSW Energy - Orange Operations is committed to maintaining a safe working environment while using chemicals necessary for power production and its auxiliary processes. CSW Energy maintains a Safety Manual and supplements it with written manuals from equipment vendors and chemical suppliers. Personnel protective equipment is made available to all employees and training is given annually to demonstrate the proper use of the safety equipment provided. In addition specific training is given each year on regulated substances; chlorine, caustic, and sulfuric acid. The MSDS for new chemicals are routed for all personnel to review. An Emergency Action Plan (EAP) was written and implemented beginning with construction of the plant and continuing on through present day plant operations. Features of the EAP include plant communications and alarm systems, evacuation procedures and routes, fire and rescue equipment, general fire protection guidelines, emergency notification procedures and emergency response procedures. The EAP also includes a separate section on chlorine safety and chlorine leak procedures. Employees are trained to be familiar with the contents of the EAP and several copies of the EAP are readily available in the case of an emergency at the facility. Worst-Case Release Scenario and the Alternative Release Scenario CSW Energy - Orange Operations chose to model the worst-case release scenario with the EPA's RMP Comp.(tm) modeling program. The worst-case scenario is the rupture of a one ton cylinder of chlorine. Since the chlorine storage is located in close proximity to a forced draft cooling tower it is assumed that the tower wo uld have some passive mitigating affect on a chlorine release. Chlorine gas could be drawn into the tower and quenched with the falling water in a countercurrent fashion. Although this mitigation may be affective, no credit was taken for the absorption of chlorine in the cooling tower when modeling the toxic endpoint of the release. The alternative release scenario is the release of the entire contents of a one-ton cylinder through a 1" opening, a fault in the fusible plug. Again some passive mitigation could occur due to the proximity of the cooling towers. However no credit was taken for the passive mitigation in the modeling. Active mitigation available in the case of the alternative release scenario includes the use of a water curtain and/or a chlorine cylinder leak repair kit. A water hose with a spray nozzle is readily available for quenching a gas release. A cylinder leak kit is staged in the area of the cylinders. All employees are trained in the use of the repair kit . Again, no credit was taken for any active mitigation in the modeling. Although this summary has outlined two potentially large releases of chlorine gas, the probability of a release of this nature happening is remote. The cylinders are located in an area which is protected from vehicle traffic and industrial activity. The overhead hoist used for loading and unloading cylinders on or off the delivery truck is always stored resting on the ground beside the cylinders. This is to prevent any possible damage due to a falling hoist, while the cylinders are unattended. The lead washer around the service valve is replaced with each new cylinder placed in use. Emergency Response Program CSW Energy - Orange Operations reports for Orange Cogen the hazardous chemicals on site, amount and location, to both the Local Emergency Planning Committee and the local fire department as required by SARA Title III, Section 313. The Tier Two Reports submitted are maintained in an active file syste m in the response vehicle and therefore are readily available to emergency responders to the facility. Facility personnel are trained how to respond to leaks, including notification procedures. When possible, any release is first handled by plant personnel. In the event of a major release, the notification and response plan and procedures in the facility's Emergency Action Plan are implemented. Planned Changes to Improve Safety CSW Energy - Orange Operations is always looking for ways to improve safety for our employees and those who work around us. Trade magazines, conferences with other utility industry personnel and discussions with chemical and equipment vendors are some of the ways facility personnel discover new and improved ways of doing business. We also subscribe to a safety news update publication and attend local OSHA seminars. 06/01/99 |