McIntosh Power Plant/Northside WWTP - Executive Summary |
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File attached. MCINTOSH POWER PLANT AND NORTHSIDE WASTEWATER TREATMENT PLANT RISK MANAGEMENT PLAN SUBMITTED June 21, 1999 EXECUTIVE SUMMARY 1. Corporate Prevention and Emergency Response Approach The McIntosh Power Plant is part of Lakeland Electric a division of the City of Lakeland, Florida. The Northside Wastewater Treatment Plant is part of the Wastewater Operation Division of the City of Lakeland, Florida. The City of Lakeland requires each site to develop and maintain accident prevention programs and an emergency response plan appropriate to the site. Each site is also responsible for regulatory compliance issues that apply to the site. The City of Lakeland Office of Risk Management provides assistance in training for site employees and in budgeting and procurement of safety and training. 2. Description of Stationary Source The McIntosh Power Plant is located on the north shore of Lake Parker. The plant consist of three steam electric generating units, tw o diesel units and one gas turbine generating unit for use during periods of peak power demand. Th McIntosh facility supplies electric power to the City of Lakeland and the surrounding area. The Northside Wastewater Treatment Plant, located on property adjacent to the McIntosh facility, includes disinfection, filtration, clarification, and aeration process that treat wastewater for the City of Lakeland. Since the McIntosh and Northside facilities are located on one contiguous property and have a common owner, they filed a joint Title V Air Permit. For this reason, they are now submitting on Risk Management Plan Summary to comply with the requirements of 40 CFR Part 68. The facility will therefore be referred to as McIntosh/Northside facility. The Northside Wastewater Treatment Plant adds chlorine to the filtered wastewater as a disinfection agent. The chlorination process is located in a three-walled, covered building at the southwest corner of the site, where liquefied chlorine gas is stored in up to twelve one-ton containers. Six containers are always connected to the chlorination system, and up to six are stored nearby. The total chlorine inventory in the process at any one time ranges from 12,0000 to 24,000 lbs. This exceeds the 2,500-lb. RMP threshold quantity. 3. Description of the Worst Case and Alternative Release Since each of the three processes at the facility use one-ton chlorine containers, the Worst-Case Release Scenario is the same for each process. The Worst-Case release scenario is the rupture of a 2,000 lb. Container, releasing 2,000 lbs. of chlorine gas over a ten-minute period. Under worst case weather conditions, the chlorine gas could travel 7.4 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .0087 mg/L). The same Alternative Release Scenario was chosen for each of the three processes. The Alternative Release Scenario is a leak at a rate of 74 lb./min. f rom the container liquid supply valve due to failure of the fitting that attaches the valve to the container. Under normally expected weather conditions, taking into consideration the alarm system at the facility, the chlorine gas could travel .99 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .0087 mg/L). 4. Prevention Program The RMP regulation requires classification of each process into a Program Level 1, 2, or 3 in order to determine the prevention program requirements. Since the worst case release from both processes would impact a public receptor, the processes cannot be classified as Program 1. Program 3 processes include those that are not Program 1, but are subject to OSHA's Process Safety Management Standard, 1010.119, or are part of an industry in one of the 9 SIC codes listed in the RMP regulation. The McIntosh/Northside facility is not one of the nine listed codes. This means that the McIn tosh/Northside facility processes would be classified as Program 3 only if they are subject to the PSM Standard. The OSHA Act states that states or political subdivisions of states are not employers and are therefore not subject of OSHA regulation. Since the McIntosh/Northside facility is city-owned, it may be considered a political subdivision of a state and therefore not technically subject to Process Safety Management; however, OSHA standard 1975.5, States and Political Subdivisions Therefore, lists public utilities as an example of the type of entity which "would normally not be considered a 'political subdivision of a state'." This means utilities, and therefore the McIntosh/Northside facility, are subject to the PSM Standard. Additionally, the Florida Department of Labor, Division of Safety, which governs state entities, adopts all OSHA Standards, including PSM, and enforces compliance with them. This reasoning has lead the City of Lakeland to consider its processes as subjec t to PSM and to implement a PSM program at all facilities which have PSM listed processes. For RMP compliance purposes, this places the McIntosh/Northside processes in the Program 3 level. The chlorine processes will use their PSM programs as the required Program 3 Prevention Programs. The McIntosh/Northside facility has a program in place to comply with the OSHA Process Safety Management Standard, 29 CFR 1919.119. The PSM Program was established in 1997 for the chlorine processes. Although the programs are equivalent and have several common procedures, the programs must remain separate because the Facilities are part of separate City departments (see the Organization Chart attached). The PSM Programs of each facility receive full support of plant management and involvement of employees at all levels. 5. Accident History The McIntosh/Northside facility has had no accidental releases of chlorine in the past five years. 6. Emergency Response Program As with the Prevention Pr ogram McIntosh/Northside facility has separate Emergency Response Programs in place. The program complies with 29 CFR 1910.38. The site also has some internal emergency response capability and is developing a program to comply with paragraph (q) of 29 CFR 1919.120. The current plans have been coordinated with the Lakeland Fire Department and Hazardous Materials Response Team, and the District 7 Local Emergency Planning Committee. Notification is made locally by dialing 911, and by notifying Florida State Warning Point at (800) 320-0519 or (904) 413-9911. |