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Evangeline Power Station

Parent Companies:
CLECO Evangeline, LLC
CLECO Mid Stream Resources, LLC
EPA Facility ID:
100000167696
Other ID:
LAD985192970
Facility DUNS:
0
Parent Company #1 DUNS:
0
Parent Company #2 DUNS:
0

Location:

Address:
2180 St. Landry Highway
St. Landry, LA 71367
County:
EVANGELINE
Lat / Long:
30.844, -92.261 (Get map)
Method:
Census Block - 1990 - Centroid
Description:
Plant Entrance (General)
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1927
Source map scale:

Owner/Operator:

Name:
CLECO Evangeline, LLC
Phone:
(318) 838-3172
Address:
2180 St. Landry Highway
St. Landry, LA 71367
Foreign Address:

Person responsible for RMP implementation:

Name:
Joseph Sepulvado
Title:
Plant Manager

Emergency contact:

Name:
Michael Bishoff
Title:
Operations/Maintenance Supervisor
Phone:
(318) 838-3300
24-hour phone:
(318) 838-3172
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Evangeline Parish LEPC
Full-Time Equivalent Employees:
34
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
0920-000002-V3
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
July 30, 2003
Inspecting Agency:
State Environmental Agency
Using Predictive Filing:
No

Processes:

Unspecified process
RMP ID:
1000049112
CBI claimed:
No
Program Level:
3
NAICS:
Electric Power Transmission, Control, and Distribution (22112)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
140,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Providence Engineering & Environmental Group LLC
Address:
1201 Main Street
Baton Rouge, LA 70802
Foreign Address:

Phone:
(225) 766-7400

Latest RMP Submission:

Date:
June 10, 2014
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000039864

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 Unspecified process)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Rural
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps

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 Unspecified process)
CBI claimed:
No
Percent weight:
Physical state:
Gas
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Rural
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown

4. Flammables: Worst-case

None

5. Flammables: Alternative release

None

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

, Electric Power Transmission, Control, and Distribution (22112)
Prevention Program ID:
1000042462
Safety Review Date
Nov. 1, 2012, since latest RMP submission
PHA Update Date
Dec. 16, 2011, since latest RMP submission
PHA Techniques
  • What if/Checklist
Hazards Identified
  • Toxic release
  • Fire
  • Overpressurization
  • Overfilling
  • Equipment failure
Process Controls
  • Relief Valves
  • Check Valves
  • Manual Shutoffs
  • Alarms
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • Classrom
Competency Testing
  • None
Procedure Review Date
July 1, 2013, since latest RMP submission
Training Review Date
Dec. 1, 2013, since latest RMP submission
Maintenance Review Date
May 31, 2012, since latest RMP submission
Maintenance Inspection Date
Oct. 24, 2011, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
May 5, 2010
Management of Change Review Date
May 31, 2012
Pre-startup Review Date
May 26, 2000
Compliance Audit Date
Nov. 1, 2012
Compliance Audit Change Completion Date
May 31, 2013
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
May 31, 2012
Hot Work Review Date
May 31, 2012
Contractor Safety Review Date
Nov. 10, 2003, since latest RMP submission
Contractor Safety Eval. Date
Oct. 1, 2013, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
Dec. 1, 2013
Local Response Agency:
Local Response Agency Phone:
(337) 363-2161
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

INTRODUCTION



The Coughlin Power Station, which is operated by Cleco Power, LLC Evangeline, LLC is located in St. Landry, Evangeline Parish, Louisiana. This facility is required to implement a Risk Management Program due to the type and quantity of toxic chemical that is located onsite.



The Coughlin Power Station's environmental, safety, and health policies empha the importance of safeguarding our employees, contractors, the environment and the community from potential exposures to chemical materials, by-products and end products, and to limit adverse effects on the physical environment, in which its activities are carried out. The Coughlin Power Station has implemented programs to ensure compliance with regulations and continued improvement of environmental, health and safety performance over the years. One part of these programs is a risk management plan (RMP) that helps manage the risks at the facility and that complies with the requirements of the Environmental Protection Agency's (EPA) Rule 40 CFR Part 68.

Anhydrous ammonia is the only RMP regulated toxic substance stored onsite above the applicable threshold quantity. There are no RMP regulated chemicals that exceed RMP thresholds.



Chlorine is also stored on site; however it is stored in quantities below the threshold quantity for chlorine. It should be noted however that chlorine is stored in quantities above the threshold quantity under the Occupational Safety and Health Administration's (OSHA's) Process Safety Management (PSM) standard.



The Coughlin Power Station has a long-standing commitment to the safety of the general public, to its employees, and to the preservation of the environment. One primary portion of this commitment is the prevention of accidental releases of hazardous substances in and around the facility. The Coughlin Power Station utilizes engineering controls, inspection programs, and detailed procedures as a means to prevent accidental releases. The Coughlin Power Station's
policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. In the event of a release, trained emergency response teams will make necessary efforts to contain, mitigate, monitor, and/or stop the release. In addition to handling the release, the facility has also established a wide variety of communication systems to alert the community in the event of a significant release.









OFF-SITE CONSEQUENCE ANALYSIS



The USEPA has defined a worst-case release as "the release of the largest quantity of a regulated substance from a vessel or process line failure that results in the greatest distance to a specified endpoint." A Worst-Case Release Scenario (WCS) analysis is required for each toxic substance in a covered process. WCSs are assumed to occur at ground level with meteorological conditions defined as atmospheric stability class F (stable atmosphere), wind speed of 1.5 meters per second, and an ambient air temperature of 25?C (77?F). Topography for WCSs is distinguished between rural and urban. Rural terrain was chosen as a conservative input.



Toxic gases include all regulated toxic substances that are gases at ambient temperature (temperature 25? C, 77?F), even if they are stored as liquids under pressure or refrigeration. For the consequence analysis, a gaseous release of the total quantity is assumed to occur in 10 minutes, regardless of storage conditions.



For toxic liquids, the total quantity in a vessel is assumed spilled onto a flat, non-absorbing surface. For toxic liquids carried in pipelines, the quantity that might be released for the pipeline is assumed to form a pool. Passive mitigation systems may be taken into account in the consequence analysis for both toxic gases and liquids. In this scenario, the Toxic Endpoint was determined to be 0.14 mg/L using the RMP*Comp program.



Anhydrous ammonia, being the only toxic substance exceeding the threshold quantity, was determined to result in the WCS for re
gulated toxic substances. There is currently no release mitigation planned for the tanks. The distance to the endpoint of a 10-minute release of the entire quantity of the anhydrous ammonia was calculated using the RMP*Compprogram and determined to be 3.6 miles. Based on this distance, a WCS of this toxic would affect a population of approximately 721 individuals. The approximated affected population data was obtained from the Circular Area Profiling System (CAPS) Version 10C.



An Alternative Release Scenario (ARS) describes an incident that is more likely to occur than those cited for a WCS. One ARS analysis is required for each listed toxic substance in a covered process that exceedsthreshold quantity. For ARSs, both active and passive mitigation systems can be considered.



Alternative release scenarios for toxic substances should be those that lead to concentrations above the toxic endpoint beyond the process fence line. Those releases that have the potential to reach the public are of the greatest concern.

A single ARS for the anhydrous ammonia is required under Risk Management; however two separate hypothetical but likely to occur release scenarios were identified for the anhydrous ammonia and the more conservative scenario with the greater Distance to Toxic Endpoint was chosen for use.



As per the regulations at 40 CFR 68.28, COPS considered the following scenarios as alternative scenarios:

Transfer hose releases due to splits or sudden hose uncoupling

Process piping releases from failures at flanges, joints, welds, valves and valve seals, and drains or bleeds
Process vessel or pump releases due to cracks, seal failure, or drain, bleed, or plug failure

Vessel overfilling and spill, or overpressurization and venting through relief valves or rupture disks
Shipping container mishandling and breakage or puncturing leading to a spill

Other failure scenarios identified under 40 CFR 68.67 [Process Hazard Analysis (PHA)]



However, all of the
se scenarios were ruled out due to the likelihood being relatively low since these items are routinely inspected, there are alarm systems in place, etc.



The Alternative Release Scenario chosen as the likely alternative scenario is as follows. A 1-inch hole in the vessel causes an airborne release from a one-inch opening at a pressure of 145 psia. The release is assumed to continue for 10 minutes as the liquid vaporizes immediately. The height of the liquid column above the hole is approximately two feet. The release rate of the anhydrous ammonia was determined to be approximately 2,400 lbs/minute. The distance to the endpoint of a 10-minute release at a rate of 2,400 lbs/minute of anhydrous ammonia was calculated using the RMP*Comp program and determined to be 0.9 miles. Based on this distance, an ARS of this toxic would affect a population of approximately 180 individuals. The approximated affected population data was obtained from the Circular Area Profiling System (CAPS) Version 10C.



PREVENTION PROGRAM



The processes at the facility have hazards that must be managed for continued safe operation. The facility has existing safety features in place applicable to prevention of accidental releases of regulated substances in the facility. These safety features help to prevent potential accident scenarios that could be caused by equipment failures and human error. These features include but are not limited to: (1) employee participation in all facets of process safety management and accident prevention, (2) a variety of technical documents that are used to help maintain safe operation of the processes, (3) a comprehensive Process Hazard Analysis (PHA) program to help ensure that hazards associated with the various processes are identified and controlled (4) a comprehensive training program for all employees involved in operating a process, (5) pre-startup safety reviews for any facility modification that requires a change in the process safety information, (6
) well established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition.



The facility has developed a comprehensive accidental release prevention program based on the elements of OSHA's PSM. The elements are recognized as being fully implemented and integrated into the standard operating practices of the facility.Summarized below are brief descriptions of each part of the prevention program along with details of the emergency response program and trade secrets:



Process Safety Information



The Coughlin Power Station maintains a variety of documents to ensure that process hazards are understood and that the facility is operated and maintained in a safe manner. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information.

Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in Safety Data Sheets (SDSs.) The SDSs include information on the toxicity, permissible exposure limits, physical data, reactivity, corrosivity, thermal and chemical stability of the produced and processed materials and chemicals used at the facility.



The Coughlin Power Station also maintains documents that provide information about the design and construction of process equipment. Equipment specifications and vendor manufacturing information are used for equipment and system designs. The facility maintains information on materials of construction, piping and instrumentation diagrams, design pressure and temperature ratings, electrical rating of equipment, etc. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed proc
ess and facility changes to ensure that safety features in the process are not compromised.



For specific process areas, the facility has documented safety-related upper and lower process limits for specific process parameters (e.g., temperature, level, composition) in the operating procedures for each process unit. The facility ensures that the process is maintained within these limits by using process controls and monitoring instruments, operating procedures, trained personnel, and protective instrument systems (e.g., automated shutdown systems).



Process Hazard Analysis



The facility has a comprehensive Process Hazard Analysis (PHA) program to help ensure that hazards associated with processes are identified and controlled. PHAs are performed on an established schedule for RMP processes. A trained team with a certified PHA Leader performs PHAs on the RMP process and other process modes not regulated by the standard. The analysis is conducted in accordance with regulatory requirements and generally accepted industry standards. The PHA requirement is met by the HAZOP Studies conducted at the facility.



The PHA team recommendations are forwarded to management for resolution. The recommendations are then prioritized and implemented accordingly. Implementation of safety improvements in response to PHA findings is completed in a timely manner. All approved safety improvements being implemented in response to PHA team recommendations are tracked until they are complete. The final resolution of each recommendation is documented and retained by the PSM Supervisor.



To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the facility periodically updates and revalidates its PHAs of affected units. These periodic reviews are conducted at least every five years and will be conducted at this frequency until the process is no longer operating. The team findings are forwarded
to management for consideration, and are documented and retained. The final resolution of the recommendations is also documented and retained.



Operating Procedures



The facility maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. Procedures are periodically reviewed and are maintained current by revising them as necessary to reflect changes made to the process. In addition, the operating procedures discuss consequences of deviating from the safe limits and provide guidance on how to respond to events that result in exceeding safe operating limits for specific process or equipment parameters. The written operating procedures are readily available to operators in the process units and for other personnel to use as necessary to safely perform their job tasks. Changes to operating procedures are tracked through the management of change (MOC) process.



Training



To complement the written procedures for process operations, the facility has implemented a training program for all employees involved in operating a process. New employees receive basic training in facility operations if they are not already familiar with such operations. After operators demonstrate (e.g., through tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive ongoing training and refresher courses on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level and to continually enhance the capabilities of the employees. This refresher training is conducted every three years. Training in operating
procedures is confirmed with a written test. All of this training is documented for each operator, including the means used to verify that the operator understood the training.



Mechanical Integrity



The Coughlin Power Station has implemented practices and procedures to ensure that facility equipment is in a safe operating condition. The mechanical integrity program is designed to ensure that plant equipment is maintained in/at the minimum designed specification. The basic aspects of this program include (1) the development of a maintenance schedule for equipment, (2) developing written mechanical integrity procedures, (3) conducting training, (4) performing and documenting inspections and tests, (5) correcting identified deficiencies, and (6) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process equipment.



The Coughlin Power Station has a documented inspection program that enhances the integrity of critical equipment and systems at the facility. Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their job in a safe manner. Written procedures help to ensure that work is performed in a consistent manner and provide a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). Recommendations from equipment inspections are then prioritized and implemented accordingly. If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service or facility personnel will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment.




Another integral part of the mechanical integrity program is quality assurance. The facility incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made.



Management of Change



The Coughlin Power Station has a comprehensive system to manage changes to processes. Written procedures are in place to ensure that all process changes at the facility undergo several levels of review at the planning stage. The system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Systems are also in place to assure that communications of the changes will be made to all affected personnel before changes are implemented. Affected chemical hazard information, process technology information, and equipment information, as well as procedures are updated to incorporate these changes. In addition, operating and maintenance personnel are provided with any necessary training on the change.



Pre Start Up Safety Reviews



The Coughlin Power Station conducts a pre-startup safety review for RMP regulated systems that require a change in the process safety information (not required for replacement in kind). The purpose of the review is to ensure that safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides additional checks to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The reviewer uses checklists to ve
rify all aspects of readiness. A review involves field verification of the construction and serves a quality assurance function.



Compliance Audits



To help ensure that the accident prevention program is functioning properly, the facility periodically conducts audits to confirm the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. These audits are led by a third party with assistance by facility employees as required. The findings are forwarded to Cleco Power, LLC management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented.



Incident Investigation



Within 48 hours, Coughlin Power Station initiates an investigation of all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. Employees and contractors are required to report all incidents regardless of their severity immediately to their supervisor or Safety Supervisor as soon as feasibly possible. After an interview with the injured party is established, an incident report is completed with complete details of the incident.



An investigation starts within 48 hours to determine the cause of the incident. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team, which may include contractors, documents the findings, develops recommendations to prevent a recurrence, and forwards these results to management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with
facility personnel who could be affected by the findings. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations.



Employee Participation



As employee participation is required by both PSM and RMP, the Coughlin Power Station encourages employees to participate in process safety management and accident prevention. Operators, maintenance technicians, and engineers, as well as supervisors and managers participate in Hazard and Operability (HAZOP) Studies, procedure development, trainings, and incident investigations. Facility personnel also participate in a wide range of safety related activities. Every employee has access to documentation and files related to the PSM and RMP programs, and every employee is responsible for complying with all aspects of these programs.



Hot Work & Work Permits



The facility's hot work procedure requires that detailed permitting activities take place before, during, and after any job that has the potential to provide a source of ignition. The permit is followed through to completion of the work and those permits are maintained onsite. The facilityimplements other work permits as necessary to assure safe work conditions are communicated to maintenance and contract personnel.



Contractor Safety



The Coughlin Power Station uses contractors to supplement its work force. Some contractors work on or near process equipment; therefore, the facility has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform facility personnel of any hazards that they find during their work. The contractor safety program places stringent qualification requirements on contracting firms before entering into the facili
ty to perform work. Contractors provide training documentation of their employees that meet or exceed the requirement of the job scope. Contractors are provided with (1) information about safety and health hazards, (2) emergency response plan requirements, (3) safe work practices, and (4) a work permit process (i.e., for hot work, confined space, etc.) prior to their beginning work.



It is the responsibility of the facility to (1) inform contract employers of potential hazards related to the work,(2) explain Cleco Power, LLC's emergency action plan,and (3) control contract employers entrance and exit to and from the facility,

It is the responsibility of Cleco Power, LLC to (1) evaluate contract employer's safety performance and programs, and (2) periodically evaluate contractor's safety performance and maintain an injury and illness log of the contractor's work at the facility.



It is the contractor's employer's responsibility to ensure that the employee is (1) trained in safe work practices of his/her job, (2) informed on potential hazards of the job or process, (3) aware that he/she must inform a plant representative of potential hazards in the contractor's work.



Emergency Response Program



The Coughlin Power Station maintains a comprehensive written emergency response program, to protect the safety of workers and the public, as well as, the environment. The plan provides for 24 hour/day, 365 day/year response capabilities. The plan includes procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance would accidentally be released. The procedures address all aspects of emergency response, including first aid and medical treatment, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post incident cleanup and decontamination requirements. In addition, the plan has procedures
that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. Facility responders are trained and qualified on the proper response techniques for the chemicals associated with the facility and are equipped with the necessary equipment to perform critical response procedures.

As part of the ongoing training program for responders, routine drills are conducted onsite. At the Coughlin Power Station, emergency planning and response includes: (1) procedures for handling small releases, (2) staging areas at the plant, (3) emergency equipment available at the plant, (4) emergency medical transportation, (5) a Spill Control and Countermeasure Plan (SPCC), and (6) a Contingency Plan.



The facility is equipped with a facility-wide alarm system. The activated alarm system notifies personnel to proceed to the muster stations until they are given additional instructions or an "all clear" notice is given. Current emergency phone numbers are maintained in the control room of the facility and in the Facility Response Plan, which is immediately available in several critical areas of the plant so that timely notifications can be made.

The emergency response program is updated as necessary.



Trade Secrets



The Coughlin Power Station operates under North American Industrial Classification System (NAICS) code 221112 (Fossil Fuel Electric Power Generation). There are currently no chemicals or components at the facility that carry the Trade Secret label.



FIVE-YEAR HISTORY



The Coughlin Power Station is committed to minimizing potential risks to the public, employees and environment. A fundamental part of this commitment is the prevention of accidental releases of hazardous substances in and around the facility. Within the past five years, there have been no releases
of a regulated substance from a regulated process that have occurred and have resulted in deaths, injuries, or significant property damage. If any incidents were to occur, the facility will investigate to determine ways to prevent similar incidents from recurring. As a result of any incidents, changes would be introduced as necessary to decrease the probability of the incident reoccurring. If another incident would occur, as per the procedure, a thorough investigation would be initiated to determine the causes of the incident. In addition, the incidents would be reported to the appropriate agencies.



SAFETY IMPROVEMENTS

The Coughlin Power Station believes that continuous improvement is the key to success in the future. This is especially true in the safety, health, and environmental areas. The facility constantly strives to improve the safety of its operations through periodic safety reviews and the incident investigation program.

Management continuously looks for opportunities to improve our abilities in protecting our people and our community. The Coughlin Power Station management actively solicits and implements safety and process improvement suggestions through our safety committee and our employee participation program to solve problems and implement solutions.