Saguaro Power Company - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

This Executive Summary includes a brief summary of the following elements of the Risk Management Plan (RMP) prepared by Saguaro Power Company (SPC) for the facility located at 8000 W. Lake Mead Drive, Henderson, Nevada: 
 
* Accidental release prevention and Emergency Response Plan 
* Station source and regulated substances handled 
* Worst-case scenarios and alternative release scenarios including administrative controls and mitigation measures 
* General accidental release prevention program and chemical-specific prevention steps 
* Five-year accident history 
* Emergency Response Program 
* Planned changes to improve safety 
 
1.0 Accidental Release Prevention and Emergency Response Policies 
 
Saguaro Power Company has the following policies in place to prevent or minimize accidental releases and to respond to emergencies: 
 
* Designation of a Emergency Response team including emergency contacts and numbers. 
* A description of the facility, emergency contacts, and emergency procedures. 
* Step-b 
y-step procedures for the following activities involving ammonia: 
  - Opening process equipment or piping 
  - Controlled access into facility 
* Control measures to be taken in the event of physical contact or airborne exposures. 
* Procedures to ensure the mechanical integrity of systems that handle anhydrous ammonia that include designating responsibility, inspection and testing, deficiency management, and quality assurance.   
* All employees involved in receiving, handling, operation or maintenance of ammonia receive initial and annual refresher training.   
* Contractors who work on or near a process that presents known potential fire, explosive, toxic release or other hazard are informed of such hazards and are required to train their employees to work safely at the facility.  Contractors are required to perform all work in accordance with SPC policy and Nevada-OSHA Process Safety Regulation regulations. 
* Clearance and Hot Work policies and procedures. 
* Accident Investigation pro 
cedures and documentation. 
 
2.0 Stationary Source and Regulated Substances 
 
This facility produces electricity and steam.   This facility handles the following substances that are subject to the RMP requirements  
 
   Substance                                             Use                                            Maximum Quantity Onsite 
Anhydrous ammonia       Selective catalytic reduction / NOx emissions        51,237 pounds 
 
3.0 Worst-Case Release Scenarios / Alternative Release Scenarios and Administrative Controls and Mitigation Measures 
 
3.1  Worst-Case Release Scenarios 
Use of the look-up tables provided in the USEPA Ammonia Guidance Document for the worst-case scenario (51,237 lb. release, 5,120 lb/min release rate, 10-minute duration, 1.5 meters per second wind speed, F stability class), assuming an urban environment, indicate a toxic endpoint distance of 2.8 miles using USEPA Lookup Tables and 3.5 miles using the ALOHA Dispersion Modeling Program. 
 
3.2  Alternative Releas 
e Scenarios and Administrative Controls and Mitigation Measures 
In the implementation of the ARTAH and Process Safety Management Programs for this facility.  SPC has performed AIChE Guide-Word HAZOPS and analyzed Offsite Consequences using the AFTOX and ALOHA air dispersion models and evaluated the following scenarios: 
 
* Human error 
* Vandalism/sabotage 
* Mechanical / electrical failure 
* Physical damage 
* Natural disaster 
* Fire / explosion. 
 
The USEPA recommended Alternative Release Scenario (ARS) is the release of ammonia at the storage tank through a < inch orifice.  The quantities of ammonia associated with this ARS are expected to extend beyond the property boundaries given the ARS meteorological conditions recommended in the USEPA Model Risk Management Program and Plan for Ammonia Refrigeration. 
 
Use of the look-up tables provided in the USEPA Ammonia Guidance Document for the recommended Alternative Release-Scenario (10,000 lb. release, 10-minute duration, 3.0 meters per secon 
d wind speed, D stability class), assuming an urban environment, indicate a toxic endpoint distance of 0.1 miles (and a toxic endpoint of 0.14 miles using the ALOHA Dispersion Modeling Program.) 
 
The more likely Alternative Release Scenario identified during the Process Hazard Analysis and Offsite Consequence Analysis is the release of a small residual quantity of ammonia (i.e., less than one pound) during the disconnection of the fill hose after delivery of ammonia by bulk tank truck. The quantities of ammonia associated with this ARS are NOT expected to extend beyond the property boundaries. 
 
4.0 General Accidental Release Prevention Program and Chemical-Specific Prevention Steps 
This facility is in compliance with the OSHA PSM and USEPA RMP rules.  Specific steps that are key to the SPC Process Safety Management Program (Plant Order HC-E-100) include: 
 
* Developing and maintaining written Process Safety Information identifying workplace chemical and process hazards, equipment used i 
n the process, and technology used in the process. 
* Developing and maintaining Process Hazard Analysis used to identify potential failure scenarios and conditions of the process and facility that could result in the release of ammonia. 
* Developing and maintaining Operating Procedures that are specifically designed to address the handling and maintenance of materials and equipment associated with direct or indirect use of ammonia. 
* Providing and maintaining Training Programs that are specifically designed to address all operational, maintenance, and emergency aspects of processes associated with the ammonia system. 
* Developing and maintaining a Pre-Start up Safety Review of equipment and process associated with the ammonia system. 
* Developing and maintaining a program that ensures the Mechanical Integrity of equipment associated with the ammonia system. 
*Developing and maintaining a Hot Work Permit system to address any hot work that may directly or indirectly affect the ammonia sy 
stem. 
* Establishing and maintaining a Management of Change program to address any equipment or process changes associated with the ammonia system. 
* Developing and maintaining an Accident Investigation program that addresses all types of incidents (e.g., actual releases, fires, near occurrences, etc.) in a timely manner in an effort to prevent the reoccurrence of such incidents. 
* Maintaining an Emergency Response capability that can address small quantity releases of ammonia and extinguish incipient fires. 
SPC has the following chemical-specific emergency procedures: 
 - Anhydrous ammonia 
* Establishing and maintaining a comprehensive Chemical Accident Prevention Program in accordance with State of Nevada Department of Environmental Protection regulations. 
* Ensuring that there is Employee Participation at all levels of the organization (e.g., operators, supervisors, etc.). 
* Establishing an on-going Audit component of the RMP that ensures periodic re-evaluation of SPC's prevention p 
rogram elements. 
 
5.0 Five-year Accident History 
There have been no ammonia-related incidents resulting in the release of ammonia that has extended beyond the property boundaries of this facility, during the history of this facility. 
 
6.0 Emergency Response Program 
This facility has an Emergency Response Guide that addresses: 
 
* Escape procedures and routes; post-evacuation employee accounting 
* Duties and procedures of employees who remain behind  
* Emergency contact names and numbers 
* Training 
* Handling of small releases 
* Alarm systems 
* Outside party coordination, including coordination with LEPC and other BMI Complex tenants. 
* Personnel roles, lines of authority and communication 
* Emergency recognition and prevention 
* Safe distances and places of refuge 
* Site security and control 
* Evacuation routes and procedures 
* Decontamination 
* Emergency medical treatment and first aid 
* Emergency alerting and response procedures 
* Critique of response and follow-up 
* PPE and emergency 
equipment. 
 
7.0 Planned Changes to Improve Safety 
 
Possible changes that could affect the potential for ammonia release and the overall safety of the ammonia system include: 
 
* Consideration of Dry-Lo NOx burners to replace the current SCR (ammonia catalytic reductions system). 
 
* Consideration of using a 19% solution of aqueous ammonia to replace the anhydrous ammonia source.
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