Modesto Energy Limited Partnership - Executive Summary |
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The Modesto Energy Limited Partnership (MELP), Westley, California Facility ("the facility") is managed by UAE Energy Operations Corp. ("UAE Energy"). UAE Energy is committed to being a responsible member of any community in which it has operations by giving top priority to operating in a safe and environmentally sound manner. This commitment to safe and environmentally sound operations is documented in UAE Energy's procedures and compliance manuals, which are available to all employees. The primary purpose of the facility is to produce electricity by utilizing whole waste tires for energy. The facility consists of two boilers that produce steam to drive a single turbine/generator. Air pollution controls with combustion modifications are built into the boiler design. For controlling oxides of nitrogen (NOx), an anhydrous ammonia ("ammonia") injection process is used. The ammonia process at the facility consists of an ammonia storage tank, three ammonia evaporators, an air mix ing station, air injection nozzles, and associated piping and controls. Ammonia is a toxic gas stored as a liquid under pressure at atmospheric temperature. Ammonia is regulated under the California Accidental Release Prevention (CalARP) regulations (Appendix A). The worst-case release scenario associated with the release of toxic substances at the facility is the release of the total contents of the ammonia storage tank (54,200 pounds). The alternative-case release scenario is a transfer-line release at the fill station caused by disconnecting a hose before all fill-station valves were shut off. Such a release could result in a 10-minute release of 43,300 pounds of ammonia. Safeguards to prevent, detect, or mitigate accidental releases of regulated substances are described in the facility's Industrial Safety and Operations and Maintenance manuals. All covered processes have control systems designed to maintain operating parameters within allowable limits. The covered processes are also equipped with alarms to alert personnel when the operating parameters exceed the allowable limits. The facility developed procedures and conducted training of personnel to familiarize them with the consequences of exceeding allowable limits to ensure the correct response to the alarms. Personnel at the facility reviewed all incident investigation reports from January 1994 to present to identify accidental releases of extremely hazardous substances that resulted in deaths, injuries, or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. No accidental releases were identified. Overall safety at the facility is governed not only by the ability to prevent accidental releases of regulated substances, but also by the ability to mitigate any accidental releases. The facility therefore developed an emergency response program to minimize the effects of accidental releases of regulated substances on employees, the public, and the environment. The facility has a trained First Response team, appropriate equipment and supplies, and a detailed emergency preparedness plan. Personnel reviewed the following documents to identify all action items that were formulated to reduce the risk of an incident that could have plausibly resulted in an off-site consequence: piping and instrument diagrams, operating procedures, contractor safety procedures, Hot Work Permit procedures, the employee participation program, and the mechanical integrity program. The following action items were identified: 7 Redline piping and instrument diagrams to indicate the location of isolation valves around the pressure control valves on the ammonia storage tank 7 Install a valve in the drain in the ammonia-storage-tank berm 7 Update the ammonia filling procedure in the Operating Procedures 7 Update the ammonia storage tank low level alarm procedure in the Operating Procedures 7 Update the contractor safety standard in the Industrial Safety Manual 7 Finalize implementation of preventive maintenance program All of these action items are complete, and the major items are summarized in the Prevention Program section of the RMP. This document has been prepared to satisfy the Program Level 3 requirements of the CalARP Program (Appendix A) and the EPA Risk Management Program regulations as stated in CCR, Title 19, Division 2, Chapter 4.5 and Title 40 of the Code of Federal Regulations (CFR) Part 68, respectively. |