Burney Forest Power Cogeneration Plant - Executive Summary

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    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 
         Burney, CA. 
         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. 
         - Int 
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) 
    Attachments 8-1(Emergenc 
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.
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