Capitol Complex - Central Utilities Plant - Executive Summary |
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1.0 Capitol Complex Central Plant Risk Management Plan: Executive Summary ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The Office of State Buildings Capitol Complex Central Plant (Plant) is committed to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of the plant's processes. The Plant's policy is to implement reasonable controls to prevent foreseeable releases of substances. However, if a release does occur, trained personnel will respond to, control, and contain the release. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES The Capitol Complex Central Plant is located in an urban area in Baton Rouge, Louisiana on the east side of the Mississippi River. The Plant consists of five water chilling systems utilizing ammonia in a refrigeration system, which is utilized to cool numerous state buildi ngs. The Plant was evaluated to determine if any regulated flammable or toxic substances exceeded the threshold quantity. There are no listed flammable sources on site. One toxic substance, ammonia (anhydrous), is covered under the Accidental Release Program (ARP). The largest quantity on site and threshold quantity for anhydrous ammonia is 40,000 lbs and 10,000 lbs, respectively. Worst-Case Scenarios The listed substance, which is stored above the threshold quantity at the Plant, is anhydrous ammonia. Based on worst-case analysis using urban conditions, the distance to the endpoint exceeds the distance to public receptors. In addition, the Plant is subject to OSHA PSM. Therefore, the Plant meets the criteria of a Program 3 process under the Accidental Release Prevention (ARP) program. Flammable Substances The Plant does not have any flammable substances above the threshold quantity; therefore, analysis of worst-case release scenarios for flammable substances is not require d. Toxic Substances The endpoint for a worst-case release of a toxic substance is based on the Emergency Response Planning Guideline level 2 (ERPG-2) developed for each substance by the American Industrial Hygiene Association. The toxic endpoint for anhydrous ammonia is 0.14 mg/L. The ARP Program requirement for toxics, in a worst-case scenario, assumes the total quantity is released in ten minutes. The EPA equations were utilized to determine the distance-to-the endpoint for the worst-case release of the above threshold quantity toxic substance. A release of 8,000 lbs of anhydrous ammonia with a 1.05-miles distance-to-endpoint is the worst-case toxic release. Alternative Release Scenarios Alternative release scenarios are those that are more likely to occur than the worst-case release scenario. Alternative release scenarios for toxic substances should be those that lead to concentrations above the endpoints beyond the plant's fenceline. Alternative release scenarios for flammable substances should have the potential to cause substantial damage, including onsite damage. The following conditions may be considered for alternative release scenarios: * Release rate dependent upon the scenario; * Consideration of active and passive mitigation systems. Flammable Substances The Plant does not have any flammable substances above the threshold quantity; therefore, analysis of alternative release scenarios for flammable substances is not required. Toxic Substances One alternative release scenario for each toxic substance was conducted for the Plant under the Accidental Release Prevention program. As with the worst-case release scenario, the alternative release scenario for the toxic substances utilizes the ERPG-2 to determine toxic endpoint. A hypothetical release scenario has been identified for anhydrous ammonia. The Plant will assume a seal leak on one of the compressors utilized in the refrigeration systems. The alternative release scenario of anhydrous ammonia resulted a 150 lb release with a 0.05-mile distance to its endpoint of 0.14 mg/L. GENERAL ACCIDENT RELEASE PROGRAM The following is a summary of the accident prevention program in place at the Plant. The processes at the plant that are regulated by the Environmental Protection Agency's (EPA's) Risk Management Program (RMP) regulation are also subject to the Occupational Safety and Health Administration's (OSHA's) process safety management (PSM) standard. Therefore, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. Employee Participation Active employee participation and involvement in the development and implementation of the Plant's PSM program is an important step toward achieving the objective to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. Employee involvement will help to ensure that all per spectives regarding PSM are considered, and that the best ideas are implemented. Open communications are encouraged between supervisors and employees regarding all safety and health issues. The Plant actively seeks employee involvement in the development and conduct of all accident prevention activities through the appropriate existing safety programs. Accident prevention is discussed at the regularly scheduled safety meetings and/or during special training sessions if necessary. Employees are encouraged to discuss accident prevention with their supervisors if they have questions, comments, or suggestions. Process Safety Information Complete and accurate written process safety information (PSI) concerning process chemicals, process technology, and process equipment is essential to effective PSM and RMP programs and to completing and maintaining a process hazard analysis (PHA). The PSI will be useful to the operators; the team performing the PHA; those in charge of training; contractors; those conducting pre-startup safety reviews; and those in charge of updating the emergency preparedness plans. Process Safety Information is readily available to all employees. The Plant keeps a variety of technical documents that are used to help maintain safe operation of the process. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Chemical-specific information, including exposure hazards and emergency response/ exposure treatment considerations, is provided in material safety data sheets (MSDSs). The Plant also maintains numerous technical documents that provide information about the design and construction of process equipment. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and plant changes to ensure that safety features in the process are not compromised. Process Hazard Analysis (PHA) The Plant has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. The Plant primarily uses the checklist/what if method analysis technique to perform these evaluations. However, as situations warrant, the Plant will use other inductive techniques. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and the team makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team findings are f orwarded to local management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk matrix assigned by the PHA team. The matrix is based on severity (criticality) and probability (frequency). This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options in response to PHA team findings are tracked until they are completed. The final resolution of each finding is documented and retained. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the PHA team periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every five years and will be conducted at this frequency until the process is no longer operating. The recommended order of analysis will be based upon the following criteria: 1. age of proce ss; 2. extent of process hazards; 3. number of affected employees; and, 4. operating history of the process. The results and findings from these updates are documented and retained. The team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained. Operating Procedures The Plant maintains written procedures that address various modes of process operations. These procedures provide guidance for experienced operators and also provide the basis for training new operators. The intent of the operating procedures is to provide workable, useful, and clearly written instructions for conducting operating activities. To have effective operating procedures, the task and procedures directly and indirectly related to the covered process must be appropriate, clear, consistent, and most importantly, communicated to employees. Operating procedures are specific instructions or details on what steps are taken or followed in completing the stated procedures. The specific instructions include the applicable safety precautions and appropriate information on safety implications. Training In addition to training on operating procedures, the Plant has a comprehensive training program for all employees involved in operating the process. New employees receive basic training in process operations and procedures. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every three years. The appropriate frequency of training is based on management in consultation with the employees involved in operating the particular process. All of this training is documented for each operator including the means used to verify that the operator understood the training. Contractors The Plant uses contractors during periods of increased maintenance or constru ction activities. Because some contractors work on or near process equipment, the Plant has procedures in place to ensure that contractors do the following: 1. perform their work in a safe manner; 2. have appropriate knowledge and skills; 3. are aware of the hazards of their workplace; 4. understand what they should do in the event of an emergency; 5. understand and follow site specific safety rules; and 6. inform plant personnel of any hazards that they find during their work. This is accomplished by providing contractors with an orientation session that covers the following: 1. a process overview; 2. information about safety and health hazards including known or potential fire, explosion, or toxic release hazards; 3. emergency response plan requirements; and 4. safe work practices must be developed and implemented regarding control of entrance, presence and exit of contract personnel prior to beginning their work. Pre-startup Safety Review (PSSR) The Plant conducts a P SSR on any new plant modification that requires a change in process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment and highly hazardous chemicals into service. This review provides one additional check to make sure construction is in accordance with design specification and that all-supporting systems are operationally ready. Mechanical Integrity The Plant has established practices and procedures for maintaining process equipment. Another integral part of the mechanical integrity program is quality assurance. The Plant incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. Safe Work Practices The Plant has safe work practices in place to help ensure worker and process safety. Examples of these include the following: 1. control of the entry/presence/exit of support personnel; 2. a lockout/tag out procedure to ensure isolation of energy sources for equipment undergoing maintenance; 3. a procedure for safe removal of hazardous and toxic substances before process piping and equipment is opened; 4. a permit and procedure to control spark-producing activities (i.e., hot work); and, 5. a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change The Plant has written procedures to manage changes to all covered processes. This system requires that changes to items such as process chemicals, process equipment, technology (including process operating conditions), procedures, impact to safety and health and other plant changes be properly reviewed and authorized before being implemented. Incident Investigation The Plant promptly investigates (within 48 hours) all incidents that resulted in or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to gather the facts, determine the root cause, and develop corrective action to prevent the reoccurrence of the incident or a similar incident. The reports are maintained for five years. An investigation team is established to investigate each process incident. The team will consist of members involved in the incident including at least one person knowledgeable in the process involved, a contract employee (if the incident involved the work of a contractor), and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident. The investigation team documents its findings in a report. The report includes dates of the incident and investigation, description of incident, factors contributing to the incident, and develops recommendations to prevent a recurrence, and forwards these results to the business management team for resolution. Compliance Audits To help ensure that the accident prevention program is functioning properly, the Plant periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every three years. Both hourly and staff personnel participate as audit team members with at least one person knowledgeable in the audit techniques. The audit team develops findings in a report that is forwarded to plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked and documented until they are complete. The final resolution of each finding is documented, and the appropriate enhancements to the pre vention program are implemented. The two most recent compliance audit reports are retained. Chemical Specific Prevention Steps The processes at the Plant have hazards that must be managed to ensure continued safe operation. The following sections include descriptions of existing safety features applicable to prevention of accidental releases of regulated substances in the plant. Universal Prevention Activities The accident prevention program summarized previously is applied to the RMP-covered process at the Plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. Specialized Safety Features The Plant has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and, (3) reduce the consequences (mitigate) of a release. The following types of safety features are used in the RMP covered process: Release Detection 1. Sensors with audi ble alarms are located at the plant to detect and warn of leaks. Release Containment/Control 1. Pressure relief valves on applicable tanks. 2. Water deluge systems are utilized at points within the facility to assure the ability to suppress releases. Release Mitigation 1. Standard operating procedures that control, isolate, and terminate leaks. 3. Personnel trained in emergency procedures. 4. Personal protective equipment (e.g., escape respirator, self-contained breathing apparatus, and supplied air breathing apparatus). Five Year Accident History The Plant is reporting a release of 225 lbs of ammonia in March of 1997. It should be noted that this release occurred during construction by a third party prior to completion of the facility. The release; therefore, also occurred prior to the Office of State Buildings initiating operation of the facility in mid-1997. It should also be noted that the leaking equipment has been replaced in order to minimize the potential for additional leaks. Emergency Procedure Information The Plant maintains a written emergency procedure, which is in place to protect worker and public safety as well as the environment. The procedures account for the possibility of a toxic substance being accidentally released, as well as for the possibility of a fire or explosion. The procedures address notification of local emergency response agencies if a release occurs, and post incident cleanup and decontamination requirements. Employees receive training in emergency procedures. The emergency procedure is updated when necessary based on modifications made to the Plant. The emergency procedure changes are administered through the Management of Change (MOC) process, which includes informing and/or training affected personnel in the changes. The overall emergency procedure program for the Facility is coordinated with HAZ MAT. This coordination includes calling 911, which in turn, calls HAZ MAT. |