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Harbor Generating Station

Parent Companies:
City of Los Angeles Department of Water and Power
EPA Facility ID:
100000139673
Other ID:
CAD000633180
Facility DUNS:
0
Parent Company DUNS:
603080136

Location:

Address:
161 North Island Avenue
Wilmington, CA 90744
County:
LOS ANGELES
Lat / Long:
33.769, -118.267 (Get map)
Method:
Interpolation - Photo
Description:
Storage Tank
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Department of Water and Power
Phone:
(310) 522-1311
Address:
161 North Island Avenue
Wilmington, CA 90744 -6303
Foreign Address:

Person responsible for RMP implementation:

Name:
Wesley Pyle
Title:
Electrical Service Manager

Emergency contact:

Name:
Wesley Pyle
Title:
Electrical Service Manager
Phone:
(310) 522-1311
24-hour phone:
(310) 522-1377
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(213) 367-1361
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
California Region 1 LEPC
Full-Time Equivalent Employees:
67
Covered by OSHA PSM:
No
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
800170
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Sept. 8, 2016
Inspecting Agency:
Fire Department
Using Predictive Filing:
No

Processes:

Ammonia Solution Storage
RMP ID:
1000056575
CBI claimed:
No
Program Level:
2
NAICS:
Fossil Fuel Electric Power Generation (221112)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (conc 20% or greater)
7664-41-7
110,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
July 21, 2014
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000045573

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Ammonia Solution Storage)
CBI claimed:
No
Percent weight:
29.0
Physical state:
Liquid
Model used:
EPA's OCA Guidance Reference Tables or Equations
Release duration (mins):
634.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • Dikes
  • Sumps
not considered:
  • Enclosures
  • Berms
  • Drains

3. Toxics: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Ammonia Solution Storage)
CBI claimed:
No
Percent weight:
29.0
Physical state:
Liquid
Model used:
EPA's OCA Guidance Reference Tables or Equations
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
not considered:
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers

4. Flammables: Worst-case

None

5. Flammables: Alternative release

None

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

No Prevention Program level 3

8. Prevention Program level 2

Ammonia Solution Storage, Fossil Fuel Electric Power Generation (221112)
Prevention Program ID:
1000036189
Safety Review Date
Sept. 13, 2016, since latest RMP submission
PHA Update Date
, since latest RMP submission
Safety Regulations
  • None
Hazards Identified
  • Toxic Release
  • Equipment failure
  • Earthquake
Process Controls
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • None
Training Type
  • Classroom
  • On the Job
Competency Testing
  • Demonstration
  • Observation
Procedure Review Date
Sept. 13, 2016, since latest RMP submission
Training Review Date
Sept. 13, 2016, since latest RMP submission
Maintenance Review Date
Sept. 13, 2016, since latest RMP submission
Maintenance Inspection Date
May 4, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Management of Change Review Date
Pre-startup Review Date
Compliance Audit Date
Sept. 8, 2016
Compliance Audit Change Completion Date
Oct. 25, 2016
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Hot Work Review Date
Contractor Safety Review Date
, since latest RMP submission
Contractor Safety Eval. Date
, since latest RMP submission

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
No
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
No
Plan Review Date:
Response Training Date:
None
Local Response Agency:
Local Response Agency Phone:
(310) 548-7549
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
No
Subject To - CWA:
No
Subject To - RCRA:
No
Subject To - OPA:
No
Subject To - State EPCRA:
No
Subject To - Other:

Executive Summary

Aqueous ammonia (ammonia) is the most commonly used substance for reducing oxides of nitrogen from the electric power generating stations. The Los Angeles Department of Water and Power (LADWP) also uses ammonia for reducing the emissions of oxides of nitrogen from its Harbor Generating Station (HGS). Storing and handling large quantities of ammonia can create hazardous situations. The LADWP takes safety obligations in storing and using ammonia as seriously as it takes in power generation. The LADWP HGS ammonia handling process is subject to the U.S. Environmental Protection Agency (EPA) Risk Management Program and Plan and also to the California Accidental Release Prevention (CalARP) Program. The facilities subject to the EPA and CalARP regulations are required to prepare and update Risk Management Plans (RMPs). The RMP is to include policies and procedures followed to safely operate the facility and the actions which will be taken by the facility in an event of anemergency. LADWP prepared and submitted the original RMP for the HGS in June 1999. This 2014 RMP submittal is the third five-year update of the original RMP. The following information is specifically required in the RMP Update Executive Summary:



* Accidental release prevention and emergency response policies.

* General facility and regulated substances information.

* Summary of the accidental release prevention program and chemical-specific prevention steps.

* Five-year accident history summary.

* Emergency response program summary.

* Planned changes to improve safety.



The above information for the HGS is provided below.



Accidental Release Prevention and Emergency Response Policies



The City of Los Angeles Department of Water and Power accidental release prevention policy involves a unified approach that integrates technologies, procedures, and management practices. All applicable procedures of the CalARP Program and U.S. EPA Prevention Program are adhered to.



The HGS facility is a n
on-responding facility, which means that the facility employees will not respond to ammonia accidental release. Instead, the facility has coordinated with local response agencies (City of Los Angeles Fire Department) to respond to any ammonia release that may occur at the HGS.



General Description of the Stationary Source and Regulated Substance



HGS is located in Wilmington, California. The HGS is a gas-fired electricity generating facility that supplies electrical power to the LADWP system. The facility is managed and operated around the clock. There is a minimum crew of three operators and one shift supervisor. On a normal day shift, there are approximately 67 on-site personnel including Operations, Technical, Maintenance, Clerical, and Warehouse staff.



The facility consists of two main natural gas or distillate fired combustion turbines. These combustion turbines exhaust hot gases through two Heat Recovery Steam Generators (HRSG) to produce steam to drive a conventional 80 MW steam turbine. The HGS facility also installed five additional simple cycle natural gas fired turbines in 2001. These combustion turbines are capable of generating about 47 MW each of power.



The main combustion turbines and the five simple cycle turbines installed in 2001 are equipped with selective catalytic reduction (SCR) units to control emissions of oxides of nitrogen (NOx), a combustion byproduct that is a precursor to ozone. In the presence of a catalyst housed in the SCR, ammonia (NH3) gas, a reducing agent, is injected into the flue gas to react with NOx to form nitrogen gas (N2) and water vapor (H2O) according to the following chemical reactions:



4 NH3 + 6 NO --> 5 N2 + 6 H2O

8 NH3 + 6 NO2 --> 7 N2 + 12 H2O



Ammonia Process Description



The ammonia solution storage and supply system (ammonia process) has the dual function of injecting ammonia for NOx emissions control in each heat recovery steam generator and exhaust from five sim
ple cycle combustion turbines and also for pH control of the boiler feed water. The ammonia process consists of three subsystems:



* Ammonia Handling and Storage.

* Emission Control.

* Chemical Feed.



Ammonia Handling and Storage



The aqueous ammonia handling and storage subsystem supplies ammonia solution to the nitrogen oxide emission control catalyst and to the Chemical Feed subsystem. Aqueous ammonia solution is used instead of anhydrous ammonia because the latter has some serious inherent safety hazards requiring significant precautions and safety equipment in handling and storing. The risks and safety related costs of anhydrous ammonia are found to outweigh the higher costs for transportation and storage of ammonia solution.



Ammonia solution stored in aboveground tanks which are surrounded by a concrete containment system. Two pumps, each fully redundant, dispense ammonia solution to the emission control equipment. Other safety equipment associated with these tanks are: pressure/vacuum relief valves, liquid level alarms, two ammonia vapor scrubbers, quick fill connections, vapor recovery and associated piping, seven strategically-located ammonia vapor detectors, and three emergency eyewash/shower stations.



Ammonia solution is delivered by truck into the storage tanks through a quick fill connection, located behind safety/collision barriers. The truck parks within a sloped containment area, which drains to a sump in the adjacent containment dike. The solution unloading to the storage tanks is done through a quick fill connection. A truck-mounted vapor recovery system is connected to the tank vapor recovery system during the unloading. The storage tanks are equipped with pressure and vacuum relief valves and the tanks are maintained at ambient temperature and atmospheric pressure.



A redundant dispensing pump is placed into service when either the main pumps fails or are out of service for preventative maintenance. The tanks are protected from
direct exposure to the sun and contain remote controls of pump and valve operations. The loading operator is provided with a readily accessible water supply to wash spills quickly into the 8-foot trench for rapid containment. All spills are conveyed to a wastewater sump for treatment prior to discharge. Flashing lights and audible alarms at the tanks and in the main control room are activated when the ammonia gas monitors detect the gas concentration above 20 parts per million in the surrounding area.



Emission Control



Ammonia solution is pumped from storage tanks to two evaporator and air mixing chamber systems, one for each HRSG. These systems are located outside of the Power House building, along the southern wall at the southwestern corner. Heated air is provided to the air-mixing chamber by dilution air fans and heaters. The air/water vapor/ammonia mixture is then piped to the Ammonia Injection Grid (AIG) in the HRSG using an arrangement of nozzles to assure an even distribution throughout the flue gas. The flue gas enters the SCR bed where the catalyst promotes the reaction. Flow control valves operated as a function of combustion turbine load, the turbine exhaust flow rate, and the final stack exhaust nitrogen oxide concentrations control the feed rate of the ammonia solution.



Chemical Feed



Ammonia solution from the storage tanks is automatically fed to a 200-gallon dilution tank where the solution is further diluted to 0.3%. The diluted solution is pumped to the boiler feed water system at a flow rate of up to 3 gallon per hour and 300-psig, based on the specific conductivity measurements of the feed water at the boiler feed pump discharge. Summary of the Accidental Release Prevention Program and Ammonia



Accidental Release Prevention



The general LADWP accidental release prevention program is based on the following key elements:



* High level of training of the operators in safe handling of chemicals.

* Effective preventive maintenance
program.

* Use of state-of-the-art process and safety equipment.

* Use of accurate and effective operating procedures, written with the participation of the operators.

* Performance of a hazard review of equipment and procedures.

* Implementation of an auditing and inspection program.



Other specific steps to prevent accidental ammonia releases include:



* The extensive training of the operators in the safe handling of ammonia, with emphasis on the hazardous and toxic properties of the chemical.

* Required ammonia safe handling training of tank truck drivers from suppliers as well as their equipment preventive maintenance program.

* The installation of tank liquid levels alarm, pressure levels alarm, pressure/vacuum relief valve, vapor recovery system, gas scrubbers, and ammonia gas detectors around the storage area.

* The installation of secondary containment system and sumps.

* Water is used to dilute and wash spilled ammonia solution into the sumps equipped with a high liquid level alarm.



Safety Information



Comprehensive chemical data has been assembled to include regulatory reporting and action thresholds, health hazard, and chemical exposure limitations, as well as detailed physical properties of ammonia. This information includes ammonia background information and MSDS sheets.



Equipment safety information was compiled on the ammonia process. Specifications for the ammonia process are collected and provided in one place for easy reference. Details such as maximum intended inventory; safe upper and lower temperatures; and safe upper and lower pressures for the ammonia handling facility are on file at the facility. LADWP also has procedures in place that are triggered to update safety information if there is a major change that makes existing information inaccurate.



Hazard Review



In 1999, a detailed hazard review was conducted for the ammonia facility equipment and procedures. The hazard review was further reviewed in April 2004, June
2009, and April 2014. This hazard review also included the ammonia injection system for the five simple cycle combustion turbines, which were installed in 2001. The hazard review will be updated again within a five-year period or whenever there is major change in the process.



A seismic assessment and walkthrough was completed in June 2014 based on the LEPC Region 1 guidance document, and recommendations were provided to LADWP staff for their evaluation and implementation.



Operating Procedures



LADWP has prepared written operating procedures for the Harbor Generating Station that provide clear instructions or steps for safely conducting activities relating to ammonia injection process. They are consistent with the ammonia safety information. Written operating procedures included in the facility's Operation and Maintenance Manual include:



* Delivery of Ammonia

* Initial Startup Procedure

* Normal Operation

* Normal Shutdown

* Temporary Operations

* Emergency Operations

* Emergency Shutdown

* Startup Following Emergency Shutdown



Training



The LADWP ensures that each employee operating or maintaining the ammonia process, and each employee newly assigned to this process, is trained and tested for competency in the operating procedures listed above. The LADWP employee training documentation files include training records for each employee assigned to operate or maintain the ammonia injection process. The training ensures that the employee has the required knowledge, skills, and abilities to safely carry out the duties and responsibilities, including ammonia emergency response, as provided in the operating procedures. Employee training includes as a minimum the following elements:



* Safety Information.

* Process Technology and Process Equipment, including safety systems.

* Maintenance Procedures.

* Operating Procedures for the ammonia system.

* RMP Program contents.

* Emergency Response Plan and Procedures.



Refresher training is provide
d at least every three years to each employee operating the ammonia injection process to ensure that the employee understands and adheres to the current operating procedures. In addition, LADWP ensures that operators are trained in any updated or new procedures prior to startup of a process after major modifications. Training programs for the Harbor Generating Station were most recently reviewed on September 13, 2016.



Maintenance



The LADWP operates a MAXIMO System that generates a task order for performance of the preventive maintenance routine after a designated time past the closing of the previous task order for that maintenance. Description of the work to be performed is included with the printed work order.



LADWP documents inspection, testing, and maintenance of ammonia injection equipment and assures the performance is done in accordance with the recommendations of the manufacturer and industry groups.



Internal Compliance Audits



The LADWP certifies every three years (or earlier) that compliance with Program 2 Prevention Program requirements are met and that procedures and practices developed are adequate and being followed.



The compliance audit consists of separating the RMP program elements or sections, and auditing each element to determine compliance and effectiveness. For each internal audit, the audit team completes a Compliance Audit Certification Page and a Compliance Audit Checklist. The Compliance Audit Certification Page provides process identification, the dates of the audit, team members, and certification by the audit leader and the Plant Manager. The Compliance Audit Checklist details the requirements of each RMP element and contains questions that may assist with the auditing process. The audit checklist for each element consists of the following three sections:



* Records Review: A review of the RMP written Prevention Program.

* On-Site Conditions: The audit team reviews the program elements based on observation of the p
lant conditions and safety practices.

* Interviews: The program elements are evaluated by interviewing personnel from appropriate functions including operations, maintenance, management, and contractors.



Team members record RMP program deficiencies identified during the audit on the checklist.



Incident Investigation



The LADWP incident investigation procedures describe incident reporting, investigation, and investigation reporting steps to be followed by plant personnel. The incident investigation is started promptly but no later than 48 hours after the event. The LADWP promptly addresses and resolves all recommendations and implements the recommendations in a timely manner to prevent an incident recurrence. All incident investigation reports are retained on LADWP file for at least a period of five years from the date the reports are completed.



Five-year Accident History Summary



No accidental releases of ammonia gas or solution that meet the reporting requirement of the EPA's RMP have occurred at this facility for the past five years (i.e. from 2009 to 2014.)



Emergency Response Program Summary



The HGS facility is a non-responding facility, which means that the facility employees will not respond to aqueous ammonia accidental release. Instead, the facility has coordinated with local response agencies to respond to any aqueous ammonia release than may occur at the HGS facility.



Planned Changes to Improve Safety



As part of the Risk Management Program update, a hazard review was performed in April 2014 for the ammonia handling system. The hazard review was performed using the Hazard and Operability (HAZOP) technique and covered both equipment and procedures used for the ammonia handling system. Although the review has not identified any equipment and procedural changes to improve ammonia safety at this point, the hazard review will be completed again in the future if there is a system or process change that has a potential impact on the envi
ronmental or surrounding community.