COGEN TECHNOLOGIES LINDEN VENTURE, LP - Executive Summary |
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Cogen Technologies Linden Venture Program 2 Executive Summary System Description Cogen Technologies Linden Venture (Cogen) owns a 714 megawatt (MW) cogeneration plant in Linden, Union County, New Jersey. The plant is located wholly within the TOSCO Bayway Refining facility. GE Contractual Services has been contracted by Cogen to operate the facility. This facility has been in operation since 1992. The land use immediately surrounding the facility is industrial. Cogen's facility combusts natural gas in five GE Frame 7 combustion turbines to generate electricity. Each combustion turbine is equipped with a heat recovery steam generator (HRSG) that utilizes waste heat from the exhaust to convert water to steam. The steam from each HRSG is combined to drive three steam turbines. Electricity is generated at the gas turbines and the steam turbines. Steam is also piped to offsite industrial facilities. A State mandated selective catalytic reduction (SCR) system is located within e ach HRSG to reduce nitrogen oxide (NOx) emissions from the combustion turbine exhaust gas. The SCR consists of a catalyst and injection grid within the HRSG. Ammonia gas is injected through the grid upstream of the catalyst. The ammonia mixes with the exhaust gas, and as the exhaust/ammonia mixture passes through the catalyst, NOx emissions are reduced to nitrogen and water. The ammonia injected into the HRSG is stored as 27.5% aqueous ammonia in a 75,000 gallon vertical storage tank. No more than 75,000 gallons of aqueous ammonia is stored on site at any time. The aqueous ammonia is pumped from the storage tank to ammonia skids located adjacent to each HRSG. The aqueous ammonia is vaporized in a steam vaporizer at the skid. Subsequent to vaporization, the ammonia is mixed with air and then blown to the injection grid. The grid is a pipe system with outlets inside the HRSG. Existing Risk Management Activities The ammonia system has been regulated under New Jersey's Discharge Prevention regulations (NJAC 7:1E) since 1992. These regulations have required the development of plans and procedures to reduce the risks of releases of hazardous substances. The elements of these programs include standard operating procedures, training, maintenance, and emergency response. Cogen has also implemented environmental programs and procedures to ensure compliance with all environmental regulations. These programs and procedures, maintained in manuals at the plant, are kept up to date and available to all plant personnel. The programs consist of the environmental permits and plans required to operate the facility. In addition to these programs, GE also maintains an EHS program. Elements of the GE program include hazard work permits, employee training, and general safety procedures. GE is also ISO 9000 certified. In summary, Cogen and GE have developed, implemented, and maintained environmental programs to ensure that risks associated with all plant operations are minimized and employees, nearby populations, and the environment are protected. Risk Management Program Summary The plant manager has overall responsibility for maintaining the risk management program. Responsibilities for specific program elements are shared among Cogen, GE, and East Coast Power LLC (Cogen's parent company). Safety information is maintained at the facility. As there have been no changes to the ammonia system since plant start up, modifications to the safety information have been minimal. Operating procedures have been implemented at the facility and address the possible operating conditions of the ammonia system. A maintenance program is in place and consists of maintenance procedures, testing and inspection schedules, and a work order system that initiates and tracks work and inspections performed on the ammonia system. Hot works procedures along with other hazard permits (general work permit, lockout/tagout, etc.) exist at the plant and are applicable to a ll plant work. Contractors working on the ammonia system or any plant equipment/system are required to comply with the facility's contractor safety program. All facility personnel must complete initial and refresher training on procedures applicable to their position. All operators and maintenance personnel undergo a qualification process which addresses ammonia system operating procedures and/or maintenance procedures along with emergency response training. Administrative personnel must undergo emergency response training. Compliance audits will be conducted on a triennial basis. These audits will consist of a risk management program audit and a safety review of the ammonia system. The program audit will review the risk management program and procedures to ensure the program is being implemented. The ammonia system safety review will consist of an audit of the ammonia system and operating procedures and interviews with plant personnel to ensure that the ammonia system is desi gned and operated in accordance with the appropriate safety information. Employee participation has always been implemented at the facility. Employees are included in hazard reviews and incident investigations even though it is not a requirement of the RMP regulations. In addition, employees conduct self-assessments (plant audits conducted by employees), hold weekly safety meetings, conduct annual drills and participate in safety committees. Incident investigation procedures have been implemented at the facility since start up. A hazard review was conducted in 1998. The hazard review identified the hazards associated with the process, opportunities for equipment malfunctions or human errors that could cause an accidental release, safeguards used or needed to control the hazards or prevent equipment malfunctions or human error, and steps used or needed to detect or monitor releases. Once the hazard review was completed, a list of recommendations was developed and reviewed by plant personnel and management. The recommendations are in the process of being implemented at the site to further reduce the risk associated with the aqueous ammonia system. Hazard Assessment A hazard assessment has been completed to comply with the RMP regulations. The hazard assessment consists of analyzing the effects of a worst case release scenario and an alternate scenario. The worst case release considers the entire contents of the aqueous ammonia tank being released instantaneously and the vaporization rate of ammonia dependant on ambient temperature. A dispersion model was utilized to model the offsite impacts of such a release. The Air Force Toxic Corridor (AFTOX) model was utilized to determine endpoint distances. The results of the model estimates that the worst case release scenario will have an endpoint distance of 1.56 miles and have a potential impact on residences, parks and industrial/commercial facilities. The mitigating effects of the ammonia tank's second ary containment is considered in this scenario. Cogen submits that this is a very unlikely scenario as the ammonia storage tank undergoes in service and out of service inspections in accordance with API standards, monthly safety inspections by plant personnel, and daily inspections by plant personnel. These inspections keep plant personnel aware of any conditions which might initiate a tank failure. In addition, this scenario does not include the impacts of emergency response activities that may be initiated to mitigate the vapor release. The model estimates that the release duration for this scenario is approximately 45 hours. It is estimated that it will actually take emergency teams only one hour to stop ammonia vaporization and reduce endpoint distances. The ammonia tank is protected by a concrete dike that provides secondary containment and protection from exposure to traffic in the plant. The plant also coordinates emergency drills with the local fire department and provid es information and equipment to the fire department to support site emergency activities. TOSCO emergency response personnel are also available to respond to an emergency at the site. An alternate release scenario was also analyzed. The alternate release scenario was developed to consist of a 0.25 inch diameter hole in an ammonia line which lasts for one hour. This scenario may also represent a leak from a delivery hose or a crack in a valve. The same model was used to determine offsite impacts. The results of the modeling estimates that the endpoint distance will be 0.54 miles and only impact the adjacent industrial facility. This scenario takes into account that it will take 60 minutes to respond and stop the release. The one hour release duration is a reasonable maximum time period as determined by the fire department's response time confirmed by drills that have been conducted with the Linden Fire Department. There have been no accidents or releases from the ammonia sys tem within the last five years. Emergency Response An emergency response program has been implemented at the facility since the plant's construction. The emergency response program includes an emergency response plan and coordination of emergency information and activities with the Linden Fire Department. The emergency response plan contains the information and procedures necessary to respond to a release of any hazardous material at the site. Emergency information includes a list of emergency response personnel, notification requirements, evacuation procedures, and health/first aid data. Cogen has confirmed with the Linden Fire Department that personnel and equipment necessary to respond to a release of a hazardous substance at the site will be provided. Coordination with the fire department has included providing a copy of the emergency response plan. The fire department has taken part in plant emergency response drills and drill critiques. Cogen also contributes emergency e quipment to the fire department. In addition to emergency drills, the fire department tours the facility to familiarize its personnel with plant operations and the locations of potential hazards. In addition, plant personnel are trained in the procedures necessary to respond to emergency releases. |