J. B. Sims Generating Station - Executive Summary

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J. B. Sims Generating Station is a coal-fired generating station.  The Sims plant is located at 1231 Third Street in Grand Haven, Michigan. 
 
As required by the U.S. Environmental Protection Agency (EPA) Clean Air Act Risk Management Program contained in 40 CFR Part 68, this document contains information intended to prevent and minimize the impacts or accidental releases of extremely hazardous substances.  The intent of the rule is to reduce the likelihood of a chemical release and the consequences of a release if one were to occur. The water treatment processes at the Grand Haven BLP uses chlorine which is a regulated substance.  
 
Grand Haven BLP has a maximum inventory of 8,000 pounds of chlorine, which surpasses the EPA threshold of 2,500 pounds. The facility is also subject to the Occupational Health and Safety Association (OSHA) Process Safety Management (PSM) program.  Modeling results indicate the worst-case release would cause an offsite impact. Due to these factors, Grand Haven 
BLP is subject to Program 3 requirements under 40 CFR Part 68. 
 
During the past five years, Grand Haven BLP has not had an accidental release that met the criteria of 40 CFR Part 68.  
 
Because of the potential hazards when using chlorine, it is of paramount importance that steps be taken to minimize the risk of a catastrophic release.  Consequently, to minimize the risk of release, Grand Haven BLP has in place a Prevention Program that is based on the following four key elements: 
 
1. Grand Haven BLP has purchased, installed, and maintains high-quality equipment. 
 
2. Grand Haven BLP has developed plans and programs to ensure safe operation of the system 
 
3. Grand Haven BLP has provided process information and training to affected employees, and requires contractors to verify knowledge of training and Grand Haven BLP's procedures. 
 
4. Grand Haven BLP conducts audits to ensure adherence to plans and programs as well as to continue the  minimization of risk. 
 
To predict the offsite impact 
in the event of an emergency, a hazard analysis was conducted according to the procedures outlined in the rule.  The worst-case release quantity for toxic gases is assumed to be released to the atmosphere over a period of 10 minutes.  The maximum quantity of chlorine  stored in any one container at Grand Haven BLP is 2,000 pounds.  Therefore, the release rate used in the consequence modeling was 200 pounds per minute for the entire 10-minute release period.  No mitigation or administrative controls were considered.  Due to the extensive preventative maintenance procedures, training, and emergency response procedures that have been implemented at Grand Haven BLP, it is highly unlikely that this scenario would occur. 
 
For Program 3 processes, the rule requires that at least one alternative release scenario be analyzed for each regulated toxic substance.  The alternative release scenario is more likely to occur than the worst-case release. It is very unlikely that the entire amount of ch 
lorine would be released in one event.  Potential alternative release scenarios for Grand Haven BLP include a regulator break, valve leaks, gasket leaks, and pipe breaks.  It was determined that the most likely alternative release scenario would be breaking off the pressure regulator valve on the chlorine tank.  Monitoring equipment located inside Grand Haven BLP will detect low levels of chlorine and alert staff of a possible leak.  In the event of a release inside the facility, there would be prompt response and proper control measures would be implemented. 
 
The quantity that was assumed to be released was 2,000 pounds over a one-hour period.  The chlorine containers are stored in an enclosed room which would provide mitigation of a release should one occur.  The RMP Offsite Consequence Analysis Guidance published by the EPA recommends applying a 55% mitigation factor to the release rate for releases in enclosures.  This factor was used in the alternative release scenario for Grand H 
aven BLP. 
 
Grand Haven BLP has been actively involved in emergency response planning for many years.  They have worked closely with the Ottawa County Local Emergency Planning Committee (LEPC) over the past several years.  Grand Haven BLP is a Program 3 source and  a non-responding facility.  The Grand Haven BLP Emergency Response Plan outlines procedures for internal response to incidental releases and notification and coordination with the local emergency response organizations in the event of an incidental release which cannot be contained and will have offsite impacts.   
 
Currently, Grand Haven BLP is evaluating the addition of a scrubber system to control a catastrophic release of chlorine.  This evaluation will be complete later this year.  In the event of a change of equipment, the RMP submission will be amended accordingly.
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