Gulf Power Co. Lansing Smith Elec Generating Plant - Executive Summary |
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Gulf Power Company - Lansing Smith Electric Generating Plant Accidental Release Prevention and Emergency Response Policies The Gulf Power Company Lansing Smith Electric Generating Plant (Plant Smith) has a long standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training of personnel and considerations of safety in the design, installation, operation, and maintenance of our processes. The company's emergency response policy involves the implementation of response plans which are specific to Plant Smith and to the emergency response services available in the community. It is Gulf Powers' policy to adhere to all applicable federal, state, and local laws, rules, and regulations. Safety depends upon our management commitment, the manner in which we handle and use hazardous substances, the safety devices inherent to our process designs, our operating procedures and philosophies, and the training o f our workers. We believe that accountability for safety reaches throughout all levels of management at Gulf Power. Senior management's commitment and dedication to continued safe operating practices is evident in the organization structure and employee empowerment. We have made extensive improvements to safety and health programs including emergency preparedness and response and worker training to make Plant Smith a safe worksite. Gulf Power maintains policies and procedures covering response teams that make up the overall emergency preparedness and response program for the plant. The plant has created an emergency response team to respond to various emergencies including fire, medical, spill, and rescue emergencies at the plant. In addition, Gulf Power participates in local fire and industrial mutual aid systems and is an active member of the Bay County Emergency Management and the District 1 Local Emegency Planning Council (LEPC). Description of the Facilty and Regulated S ubstances Handled Plant Smith is a coal-fired electric generating facility that is owned and operated by Gulf Power Company (Gulf Power), an investor-owned utility located in Pensacola, Florida. Plant Smith is located in Section 25, Township 2 South, Range 15 West, Bay County, west of the city of Southport, Florida. The plant's physical address is 6804 Highway 2300, Southport, Florida. Plant Smith employs approximately 90 personnel and operates 24 hours per day, seven days a week. Plant Smith presently handles one regulated chemcial which is considered hazardous by EPA and is present in quantities greater than the threshold quantity identified by the RMP regulation. Chlorine is included in our risk management program as a Program 2 process under the Accidental Release Prevention (ARP) Program. The facility uses chlorine as a biocide in the treatment of once through cooling water for the plant. The chlorine is contained in a chlorine house as a liquified gas in 10-one ton cylinder s containing 1450 pounds each. Only one cylinder is connected at a time. Worst-Case Release Scenario and Alternate Release Scenario The RMP rule requirements for identification and selection of a worst-case hazard scenario are prescriptive and negate most safety systems designed to mitigate an incidental release. Based on EPA defined Offsite Consequence Analysis (OCA) parameters, Gulf Power has one worst-case hazard scenario for the toxic material handled on-site. It involves chlorine. This scenario is estimated to create the greatest distance in any direction to an EPA defined concentration (endpoint) resulting in an accidental release. Worst-Case Scenario The worst-case scenario is a hypothetical release of the largest quantity of any of the hazardous materials listed under the RMP rule as identified by EPA. The EPA mandates companies presume the release of the entire quantity of the substance. Only passive mitigation efforts such as those controls in place that do not r equire action by an employee to initiate are allowed to be considered. An example of passive mitigation is storage in an enclosed building. Toxic Substances: Toxic endpoints are listed in Appendix A to 40 CFR part 68 (Table of Endpoints). Based on the EPA lookup tables, a worst-case release of chlorine results in a distance to the toxic endpoint of 8.1 miles. The worst-case scenario for chlorine assumes the total failure of all 10 cylinders contained in the chlorine house with the maximum possible amount of 14,500 pounds. Flammable Substances: None Alternate Release Scenario The EPA rule also prescribes that alternate or more likely accident scenarios involving regulated chemicals are identified. The alternate case scenario is a more credible scenario that is closer to a real-world incident. Facilities are allowed to include active mitigation. Active mitigation includes procedures and equipment which are used to contain or mimimize the impact of an accidental release. Exa mples of active mitigation are an employee turning off a valve or using a spray hose to knock down vapors. Toxic Substances: The alternate release scenario for chlorine at Plant Smith is the failure of a 1/4" relief valve from a single ton container filled to 1450 pounds. The total amount released is less than one pound due to vaccum. The distance from the source of the plume to its end point is .01 miles. Flammable Substances: None Accidental Release Program and Chemical-Specific Prevention Steps Gulf Power's accidental release prevention program for Plant Smith includes safety features applicable to prevention of accidental releases of regulated substances at the facility and is based on the following key elements: 1) High level of training of the operators 2) Prevention maintenance program 3) Use of state-of-the-art process safety equipment 4) Use of accurate and effective operating procedures, written with the participation of the operators 5) Performance of a hazard review of equipment and procedures 6) Implementation of an auditing and inspection program 7) Hazardous Materials Team: the Plant Smith HAZMAT team is called upon for assistance during hazardous materials incidents and has all of the equipment necessary to secure a leaking chlorine cylinder. 8) A leak detection system under 24-hour monitoring system providing early detection of a problem. Chemical-specific prevention steps for the use and handling of chlorine include availability of self-contained breathing apparatus (SCBA), worn by the operators during connection/disconnection of chlorine supply, awareness of the hazards and toxic properties of chlorine, and presence of chlorine detectors. When cylinders are changed out, procedures require two operators on hand during cylinder change out. One operator hooks up the tubing while the other observes. Procedure also calls for verification of leak free operation after each cylinder change out. There is a manually oper ated "suppresion system" in place at the chlorine house. The suppresion system is structured such that if a release should occur, a manual swich activates a curtain which surrounds the house; a fog is activated inside the house and a sprinkler system is activated in the outside area surround the house. A written emergency response plan specific to chlorine is also maintained at Plant Smith to protect worker and public safety as well as the environment during an emergency. Five Year Accident History Gulf Power has not had any accidental releases during the past 5 years which meet the criteria for an accidental release per 40 CFR 68.42. Emergency Response Program Gulf Power maintains a written emergency response plan at Plant Smith to protect worker and public safety as well as the environment during an emergency. The plan consists of procedures for responding to a release of a regulated substance, including the possbility of a fire or explosion. The procedures address al l aspects of emergency response, including first aid and medical treatment, evacuation and accounting for personnel, notification of local emergency response agencies and the public if a release occurs, incident mitigation and post-incident cleanup and decontamination requirements. The plant routinely performs maintenance on emergency equipment including tests and inspections and provides employee training on equipment use. Employees receive training as necessary to perform their specific emergency response duties. The emergency response plan updated when necessary based on modifications made to plant processes or for changes in personnel. The overall emergency response program for Plant Smith is coordinated with the Bay County emergency management officials, the District 1 Local Emergency Planning Council, and the Lynn Haven Fire Department. Periodic meetings with response agency personnel are conducted to discuss needs and concerns in the event of an incident at the plant. Gu lf Power has around-the-clock communications capability with State and Federal agencies and with local emergency agencies to access additional emergency equipment and services (i.e., firefighting equipment, manpower, ambulances, hospitals, law enforcement, and HAZMAT operations). Notification of the public by local officials can also be accomplished through hotline notifications. Gulf Power conducts periodic emergency drills at the plant to test the effectiveness of their response program. Planned Changes to Improve Safety Gulf Power has several elements of the management system of the accident prevention program in place to improve safety throughout the facility. These elements are part of an ongoing safety improvement process at Plant Smith. |