Burney Forest Power Cogeneration Plant - Executive Summary
1.0 EXECUTIVE SUMMARY |
This document represents the Risk Management Plan (RMP) for the cogeneration facility
owned by Burney Forest Products and operated by Conectiv Operating Services Co., located in
Burney, CA. This document has been prepared in order to address the following issues:
- Promulgation of the Federal RMP Program per 40 CFR 68.
- Adoption of the Federal RMP Program by the State of California per Title 19 of the
California Code of Regulations.
- Compliance with the General Duty clause of Title III, Section 112(r), CAA.
Both federal and state RMP programs require preparation and submittal of the RMP
document no later than June 21, 1999. The generally accepted approach to fulfilling the RMP
requirements is to have a documented risk management and prevention program which outlines all
the steps and procedures a facility will take to prevent and mitigate accidental releases. Burney Forest
Products (BFP) has chosen to prepare and imple
ment its RMP in advance of the federal and state
mandated due dates in order to fulfill its obligations with respect to the General Duty clause and to
protect its employees and the surrounding community from the effects of accidental releases.
Pursuant to 40 CFR 68.155 the following summary is given:
The accidental release prevention and emergency response policies at BFP are
delineated in Sections 7.0 and 8.0.
The RMP applies to the cogeneration facility located at 35586-C Hwy 299E in
Substance: Anhydrous Ammonia
The worst case release scenario is the failure of the anhydrous ammonia tank. The
tank is surrounded by a containment berm capable of holding the entire contents of
the tank. In addition, the tank and metering area are equipped with a water deluge
system designed to mitigate a major portion of any tank related release. This scenario
results in a spill of appr
oximately 51000 lbs. of ammonia. The toxic endpoint occurs
at 3.73 miles and affects approximately 6120 individuals.
The alternative release scenario is the rupture of the main distribution pipe used to
transfer ammonia (gas) from the vaporizers to the steam mixing area inside the main
boiler building. Two release scenarios were evaluated: (1) pipe rupture outside, and
(2) pipe rupture inside. Loss of ammonia is limited to pipe contents due to safety
valves subsequent to the vaporizers and prior to the steam mixing section. This
scenario results in a spill of approximately 100 lbs. of ammonia. The toxic endpoint
occurs on-site and affects no off-site receptor locations.
The general accidental release prevention program is comprised of the following
- Proper maintenance of all system equipment.
- Proper operation of all system equipment.
ernal operating policies with respect to ammonia tank capacity.
- Comprehensive personnel training.
- A written emergency response plan.
- A written hazardous materials management plan.
- Documented safety procedures for employees and contractors.
- Inclusion of ammonia specific health, safety, and response data in the RMP.
- Use of site specific monitors and chemical specific mitigation systems to detect and
mitigate potential releases.
The facility has not experienced an accidental release of ammonia in the last five years.
In addition, the facility has never experienced an accidental release of ammonia since
the system was installed.
The facility ERP is delineated in Section 8.0 (Attachments 8-1 and 8-3).
Both the federal and state RMP regulations require that the emergency response plan portion
of the RMP include a delineation of the actions to be taken to protect hum
an health and the
environment in response to a release, including informing the public and local agencies, emergency
health care, and employee training. More specifically, the emergency response plan must include the
following data elements:
- Procedures for informing the public and local agencies about accidental releases.
- Documentation of proper first aid and medical treatment necessary to treat accidental human
- Procedures and measures for emergency response after an accidental release of a regulated
- Procedures for use of emergency response equipment and for its inspection, testing, and
- Training for all employees in relevant safety and emergency response procedures.
- Procedures to review and update, as appropriate, the emergency response plan to reflect
changes at the facility and to ensure employees are informed of such changes.
Emergency Response Plan (ERP)
y Response Plan) and 8-3 (Chemical Preparedness, Prevention,
and Contingency Plan) make up the ERP for purposes of the RMP. These two documents together
contain all the required elements of a standard ERP.
Hazardous Materials Business Plan
BFP currently has a valid hazardous materials business plan on file with the Shasta County
Dept. of Environmental Health as well as the Burney Fire Dept. Attachment 8-2 is the most recent
update to the "business plan".
Existing Data included in this Section:
Attachment 8-1 Emergency Response Plan
Attachment 8-2 Hazardous Materials Plan Update for 1999
Attachment 8-3 Chemical Preparedness and Contingency Plan
Note: These attachments were not available in electronic format.
The facility is constantly striving for improved performance and reliability from all its
processes. As specific process and safety improvements are identified, they will be
evaluated by site operational and management sta
ff for appropriateness and
Data used in RMP Preparation
This RMP was prepared using as much existing data as was available from the plant site
records. Each element of the RMP was evaluated as to data needs, and the existing data was
evaluated as to its accuracy and appropriateness for use. If the existing data was deemed appropriate
for use it was used and is given in its entirety within the body of the RMP. Incorporation of existing
data, not presented in the RMP, was used in several instances, as follows:
- The plant maintains a voluminous series of operational and maintenance manuals covering
all aspects of the cogeneration facility. These manuals are referred to as "Balance of Plant
Service Manuals". The Standard Operating Procedures (SOPs) and maintenance procedures
outlined in these manuals are hereby incorporated by reference. These manuals are located
in the plant office conference room and are readily available to pl
ant staff and agency staff for
review. These manuals, with applicable sections relating to any and all aspects of the ammonia
system are incorporated by reference herein.
- The ammonia system is specifically delineated in "Balance of Plant Service Manual, Volume
II-H, Section 1". This section is specifically incorporated by reference into the RMP.
- Incorporation by reference of the Conectiv Operating Services Co. Safety Manual, Revised
on January 1, 1999.