Burney Forest Power Cogeneration Plant - Executive Summary |
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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 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 elements: - 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 exposures. - Procedures and measures for emergency response after an accidental release of a regulated substance. - Procedures for use of emergency response equipment and for its inspection, testing, and maintenance. - 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 implementation. 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. |