Tenaska Washington Partners, LP - Executive Summary |
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EXECUTIVE SUMMARY PER 40CFR 68.155(a) ACCIDENTAL RELEASE PREVENTION PROGRAM 1. Accidental Release Prevention and Emergency Response The Tenaska Washington Partners, LP cogeneration facility in Ferndale, Washington handles anhydrous ammonia which is considered hazardous by EPA. The toxicity of ammonia at high concentrations make it necessary to observe certain safety precautions to prevent unnecessary human exposure, and to reduce the threat to the personal health of our employees as well as nearby members of the community. It is our policy to adhere to all applicable Federal and state rules and regulations. Safety depends upon the manner in which we handle ammonia, the safety devices inherent in the design of the facility, combined with the safe handling procedures that we use and the training of our personnel. Tenaska's emergency response program is designed to effectively respond to an accidental release of ammonia. The emergency response plan includes procedures for noti fication of the Local Emergency Planning Commission (LEPC), the Washington State Emergency Management Division, and the National Response Center. 2. The Stationary Source and Regulated Substances The primary purpose of the Tenaska cogeneration facility is to produce electric power from combustion of natural gas. Diesel may be used as an alternative fuel. Anhydrous ammonia is used at the facility to reduce the formation of oxides of nitrogen (N0x) produced during combustion. Anhydrous ammonia is received by truck and stored as a liquid under pressure in a single storage tank. The ammonia is transported by pipeline, from storage and injected into the combustion system where it reacts with the natural gas combustion products to minimize N0x formation. Access to the site is restricted to authorized facility employees, authorized management personnel and authorized contractors. The regulated substance handled at this facility is anhydrous ammonia. The maximum amount of ammonia that can be stored at this plant is 52,000 pounds. 3. The Worst-Case and Alternative Release Scenarios Worst-Case Scenario 7 The worst-case release scenario as defined by EPA is the release of the full contents of the largest ammonia storage vessel within 10 minutes with simultaneous failure of all control and mitigation systems and at a time when weather conditions would cause the maximum downwind transport distance. At Tenaska, the worst-case release would be a catastrophic failure of the anhydrous ammonia storage tank when filled to capacity. This worst-case scenario would release 52,000 pounds of ammonia. It is assumed that the entire contents are released as vapor within 10 minutes of the failure. 7 The distance to the end-point concentration of 0.14 mg/l ammonia for this worst-case scenario is 4.0 miles. Alternative Scenario 7 The more realistic alternative-case release would be the failure of a 2-inch diameter anhydrous ammonia fill pipeline. This scenario would result in a to tal release of 36 pounds of ammonia. 7 The distance to the end-point concentration of 0.14 mg/l ammonia for this alternative release scenario is 0.1 miles. 4. Accidental Release Prevention Program The Tenaska cogeneration facility complies with EPA's Accidental Release Prevention Rule and with all applicable state codes and regulations. This facility was designed and constructed in accordance with all applicable ammonia storage and handling codes. All employees involved with the operation or maintenance of the anhydrous ammonia system are thoroughly trained using Tenaska's documented training program. 5. Five-Year Accident History No accidental releases of ammonia causing on-site or off-site injury or damage have occurred during the life of this facility. 6. Emergency Response Program Tenaska's emergency response program is based upon an accidental release of ammonia. We have discussed this program with the Whatcom County Local Emergency Planning Committee and the Ferndale F ire Department. |