Onondaga County Resource Recovery Facility - Executive Summary |
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1.0 EXECUTIVE SUMMARY 1.1 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICY SUMMARY The United States Environmental Protection Agency (USEPA) has established a regulatory program to prevent accidental releases of certain regulated substances that may potentially affect public health and the environment. The rule (40 CFR Part 68) requires that some 66,000 facilities across the United States in various industries develop a Risk Management Program (RMP). The RMP incorporates various required elements into a program designed to prevent accidental releases of regulated substances and establish emergency response preparedness in the event of an accidental release of such regulated substances. RMPs must be submitted to the USEPA by the owner or operator of any facility that has a process containing more than a threshold quantity of any of the regulated substances that is covered under the RMP rule. Pursuant to the RMP rule, Ogden Martin Systems of Onondaga, LP (OMSO) has submit ted this RMP for anhydrous ammonia. Anhydrous ammonia is a commonly used chemical with various applications in industry and agriculture. By volume, ammonia is the fourth largest industrial chemical produced over 80% of which goes to agricultural fertilizers (1). In addition to ammonia's application as a fertilizer in crop production, some other common uses for ammonia include: food production and processing, textile and chemical manufacturing, refrigeration (such as refrigerated warehouses), metal treating and as an air pollution control reagent. Anhydrous ammonia is used at the Onondaga County Resource Recovery Facility (OCRRF) exclusively as a reagent in the facility's nitrogen oxide (NOx) control system. The NOx control system is an important part of the OCRRF's sophisticated air pollution control equipment that reduces nitrogen oxides to a level below the limits contained in the OCRRF's air pollution control permit(s). Nitrogen oxides are pollutants that contribute to acid rain and photochemical smog. Nitrogen oxide (NO) is a colorless gas produced during high temperature combustion. In ambient air, nitrogen oxide is oxidized to nitrogen dioxide (NO2). Nitrogen dioxide reacts with water in ambient air to form nitric acid, which contributes to the formation of acid rain; and, nitrogen oxides also contribute to the formation of photochemical smog by reacting with sunlight to form ozone (O3) in the atmosphere. The OCRRF's NOx control system reduces nitrogen oxides by the injection of anhydrous ammonia into the furnace section of the boilers. In the boilers, a reaction takes place between the ammonia, nitrogen oxide and oxygen. The resulting products of this reaction are the major components in the air we breathe - nitrogen gas (N2) and oxygen - and water. A significant environmental benefit is achieved through the use of anhydrous ammonia in the operation of the NOx control system. OMSO operates the OCRRF located in Jamesville, New York in a manner that is protective of the health and safety of OMSO employees, contractor employees, the public and the environment. In addition, OMSO is committed to operating the OCRRF in full compliance with applicable Occupational Safety and Health Administration (OSHA) requirements, federal regulatory requirements and applicable state and/or local requirements. OMSO previously developed an OSHA Process Safety Management (PSM) Program for anhydrous ammonia. The OSHA PSM rule guides employees in the preventative maintenance, safe management and operation of processes that use regulated substances, and aims to protect employees from accidental releases of these materials on-site. The USEPA's RMP regulation builds and expands upon the OSHA PSM program by requiring facilities to evaluate off-site impacts to public and environmental receptors, in the event of an accidental release. Key elements of the OSHA PSM program have been incorporated into the USEPA RMP regulation. As part of the USEPA RMP effo rt, OMSO has updated the OSHA PSM program for anhydrous ammonia and the associated Process Hazard Analysis (PHA). Among the other important components of OMSO's RMP are the policies and procedures for operation and maintenance of the facility, and facility-specific Emergency Response Plan (ERP). OMSO has operated the regulated processes for a number of years without a significant release due to these solid preventative maintenance programs, safe design and operating practices, and established training programs. OMSO's Facility Manager has the primary responsibility for this RMP and its implementation. 1.2 STATIONARY SOURCE DESCRIPTION The OCRRF is a waste-to-energy (WTE) facility that burns solid waste and recovers steam to produce electricity. Each day, this WTE facility reduces the volume of approximately 990 tons of solid waste more than 90% while converting the otherwise wasted energy into electricity. One process at the OCRRF involves the use of a substance regulated under 4 0 CFR Part 68, thereby requiring the preparation and implementation of an RMP. This covered process is the NOx control system (discussed in Section 1.1 above) which utilizes ammonia injection for NOx control. The specific NOx control system utilized at the OCRRF is a Selective Non-Catalytic Reduction (SNCR) system. Anhydrous ammonia is the reagent utilized in the OCRRF's NOx control system in order to significantly reduce nitrogen oxide emissions, as discussed above. Anhydrous Ammonia System A maximum quantity of approximately 10,750 gallons of anhydrous ammonia is stored at the OCRRF. Administrative controls (at 85 % of tank capacity) are used to ensure that this maximum quantity is not exceeded. Both passive and active mitigation measures are used by the OCRRF to limit the likelihood and/or severity of an accidental release of anhydrous ammonia. Passive mitigation systems do not require human, mechanical or energy input, such as the concrete dike that surrounds the ammonia stor age tank area. Conversely, active mitigation systems do require human, mechanical or energy input for initiation. Leak detectors and alarms, excess flow valves, pressure relief valves, emergency shut-off devices and a water sprinkler system are examples of the active mitigation systems in place at the OCRRF. 1.3 WORST CASE AND ALTERNATIVE CASE ACCIDENTAL RELEASE SCENARIOS Anhydrous Ammonia Worst Case Accidental Release Scenario For each covered process at a facility, 40 CFR 68 requires that a "worst case" accidental release scenario be developed based on several worst case assumptions, as discussed herein. The most unlikely, worst case accidental release scenario for the OCRRF SNCR system as defined by the regulation could only occur as a result of catastrophic failure of the anhydrous ammonia storage tank. Such an occurrence would only be precipitated by a most unusual event or an unlikely set of conditions. The regulation specifies that the worst case, accidental release quan tity for the OCRRF must be the maximum amount of anhydrous ammonia held in the largest, single vessel taking into account administrative controls that limit this maximum storage quantity. A release rate of 10-minutes is specified in the regulation for the worst case analysis of substances that are normally gases at ambient temperature and handled as a gas or as a liquid under pressure, such as anhydrous ammonia. This release rate is based on the USEPA's Technical Guidance for Hazards Analysis, which is consistent with other mechanisms used for community emergency planning activities under the Emergency Planning and Community Right-to-Know Act (EPCRA). Furthermore, the regulation stipulates that active mitigation systems (such as excess flow valves, and the OCRRF's deluge system) cannot be considered in defining the worst case scenario, and assumes that all released ammonia would behave as a gas in defining the worst case scenario. Based on these parameters set by the regulation, none o f the OCRRF's active or passive mitigation systems were considered in the worst case accidental release scenario. Additional conservative assumptions have been specified by the USEPA in the analysis of the worst case accidental release scenario. These assumptions are a low wind speed, a highly stable atmosphere and use of the maximum ambient temperature over a three-year period. These worst case assumptions are used to predict a highly conservative distance to a "toxic" endpoint as defined by the regulations. For anhydrous ammonia, the "toxic" endpoint is specified as an airborne concentration of 0.14 milligrams per liter (mg/L) or 200 parts per million (ppm). This endpoint is based upon the Emergency Response Planning Guideline (ERPG-2) as developed by the American Industrial Hygiene Association (AIHA). This value represents the maximum airborne concentration below which nearly all individuals could be exposed for one-half to one hour without experiencing or developing irreversible o r other serious human health effects or symptoms that could impair their ability to take protective action. For the OCRRF, the worst case accidental release scenario for anhydrous ammonia, as defined by the USEPA, would involve a release of 10,750 gallons of anhydrous ammonia (as a gas), over a period of ten minutes. The distance to the "toxic" endpoint for anhydrous ammonia was determined using the Areal Locations of Hazardous Atmospheres (ALOHA) air dispersion model. ALOHA was selected because it is the publicly available air dispersion computer model used by over 3,000 Local Emergency Planning Committees (LEPCs) and fire departments for emergency response and planning purposes. Based upon the "worst case" assumptions discussed above , the worst case accidental release scenario is projected to reach an off-site endpoint. Public receptors and one environmental receptor are located within this projected area. Public receptors are defined by the regulation to include off-site resid ences; institutions; industrial, commercial and office buildings, and parks or recreational areas inhabited or occupied by the public. Environmental receptors as defined by the regulations include National or State parks, forests or monuments, officially designated wildlife sanctuaries, preserves, refuges, or areas and Federal wilderness areas. The worst case accidental release scenario requires that the assumption be made that an ammonia release would disperse in a circle in all directions from the OCRRF to the endpoint (as defined above). Whereas, a gaseous release of ammonia would most likely take the form of an elongated plume dispersing only in the downwind direction from OCRRF and impacting, more realistically, a much smaller area. Alternative Accidental Release Scenario A more realistic, alternative accidental release scenario was evaluated for anhydrous ammonia, in accordance with USEPA regulations. The alternative release scenario was chosen based upon the results of a Proc ess Hazard Analysis and is summarized below. Vaporizer Piping Leak - The analysis considers a leak in a >-inch diameter welded pipe that connects the vaporizer vent line to the vaporizer relief valve, that could result in a release of gaseous anhydrous ammonia at a rate of less than one gallon per minute for 11 minutes, before the leak can be detected and stopped or repaired. Assumptions for ambient conditions, including a wind speed, atmospheric stability, and ambient temperature were used for the alternative scenario analysis, based on the USEPA's RMP Offsite Consequence Analysis Guidance (OCAG) and USEPA Lookup Tables. To be conservative, passive and active mitigation systems were not considered in the alternative accidental release scenario analysis. The alternative accidental release scenario, using the assumptions discussed above, is projected to reach an offsite endpoint and a minimum number of public receptors. No environmental receptors were identified within the endpoint radius. In the event of an actual release, all of the active and passive mitigation systems/features that are available on the anhydrous ammonia system at the OCRRF would be used to contain the spread of any accidental release and mitigate potential impacts of the release. The mitigation systems/features include a concrete containment dike around the anhydrous ammonia storage tank and associated equipment, leak detectors and alarms, excess flow valves, pressure relief valves, emergency shutoff devices and a sprinkler system. 1.4 ACCIDENTAL RELEASE PREVENTION PROGRAM The OCRRF has an accidental release prevention program that is based upon a foundation of employee awareness and proactive system maintenance. This program is documented in the RMP, and meets the requirements of the RMP regulation. The OCRRF provides process safety information to employees through written materials, such as Material Safety Data Sheets, various operating and maintenance manuals, system descriptions and safety procedures. Employees attend periodic training and contractors are briefed on process hazards prior to working on-site. Preventive maintenance and regular inspections are conducted for maintaining mechanical integrity. Inspections and testing are scheduled through the preventative maintenance program and/or as required by the NYSDEC Bulk Chemical Storage Regulations. Hazard analysis documents are reviewed periodically and updated as required. Compliance audits are used to evaluate the need for revising or updating the procedures related to the processes. 1.5 FIVE-YEAR ACCIDENT HISTORY For the five years prior to the submission of this RMP, there have been no accidental releases, as defined in 40 CFR Part 68.42(a) at OCRRF, which resulted in injuries or death to on-site (i.e. Facility or contractor employees) or off-site (i.e. the public). Since there has not been an accidental release, there has not been a need for sheltering in place or evacuation; nor has damage to propert y or environmental receptors ever occurred as a result of an accidental release. In fact, OMSO has operated OCRRF in the safest possible manner since it has commenced operations. 1.6 EMERGENCY RESPONSE PROGRAM The OCRRF has an Emergency Response Plan (ERP) that defines the sequence of actions to be taken by OMSO employees in the event of an accidental release of anhydrous ammonia. This ERP has been communicated to the local Fire Department and the Local Emergency Planning Committee (LEPC). Individuals who are likely to witness or discover a release have been trained to initiate an emergency response sequence by notifying the proper authorities. It is currently OMSO's policy that individuals that have received the requisite training will attempt to secure a release of anhydrous ammonia if the action can be taken without significant risk of injury or death. The Incident Commander from the local emergency response agency is presently responsible for determining when sheltering-in-place or evacuation of off-site areas is necessary, and also for public notification. 1.7 PLANNED CHANGES TO IMPROVE SAFETY This RMP incorporates a number of enhancements to the existing Facility procedures, which are designed to improve employee safety awareness and enhance safe operations. These enhancements were developed as a result of the Process Hazard Analysis for anhydrous ammonia. Also, key items have been added to the preventive maintenance program for the anhydrous ammonia. These enhancements ultimately reduce the likelihood of an accidental release. Further, emergency response procedures have been reviewed and coordinated with local response entities to increase the speed and effectiveness of a response should a release occur. FOOTNOTE 1 J. Harte, C. Holdren, R. Schneider and C. Shirley. Toxics A to Z - A Guide to Everyday Pollution Hazards, 1991, University of California Press, 479 pps. |