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Acadia Power Station

Parent Companies:
Cleco Power, LLC
EPA Facility ID:
100000179656
Other ID:
Facility DUNS:
1723878
Parent Company DUNS:
112710876

Location:

Address:
30385 Crowley-Eunice HWY.
Eunice, LA 70535
County:
ACADIA
Lat / Long:
30.430, -92.412 (Get map)
Method:
Classical Surveying Techniques
Description:
Process Unit Area Centroid
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
Cleco Power, LLC
Phone:
(337) 546-1500
Address:
30385 Crowley-Eunice HWY.
Eunice, LA 70535
Foreign Address:

Person responsible for RMP implementation:

Name:
Cory Andrus
Title:
Senior Environmental Specialist

Emergency contact:

Name:
Cory Andrus
Title:
Senior Environmental Specialist
Phone:
(337) 546-1505
24-hour phone:
(337) 546-1511
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(318) 484-7742
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Acadia Parish LEPC
Full-Time Equivalent Employees:
35
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
0040-00105-V0
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Nov. 5, 2014
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Anhydrous Ammonia
RMP ID:
1000084353
CBI claimed:
No
Program Level:
3
NAICS:
Electric Power Generation (22111)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
160,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Gregory J. Barbier, CDI-AECOM
Address:
1515 Poydras St.
New Orleans, LA 70112
Foreign Address:

Phone:
(504) 722-3758

Latest RMP Submission:

Date:
Dec. 18, 2017
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000067213

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

Anhydrous Ammonia, Electric Power Generation (22111)
Prevention Program ID:
1000071148
Safety Review Date
July 27, 2017, since latest RMP submission
PHA Update Date
Sept. 12, 2017, since latest RMP submission
PHA Techniques
  • What if
Hazards Identified
  • Toxic release
  • Fire
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Tornado
  • Hurricanes
Process Controls
  • Relief Valves
  • Check Valves
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Power
  • Grounding Equipment
  • Excess Flow Device
Mitigation Systems
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Observation
Procedure Review Date
July 27, 2017, since latest RMP submission
Training Review Date
July 27, 2017, since latest RMP submission
Maintenance Review Date
July 27, 2017, since latest RMP submission
Maintenance Inspection Date
Feb. 13, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Sept. 24, 2012
Management of Change Review Date
Jan. 1, 2015
Pre-startup Review Date
Nov. 2, 2012
Compliance Audit Date
July 27, 2017
Compliance Audit Change Completion Date
July 27, 2017
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
July 26, 2017
Hot Work Review Date
July 26, 2017
Contractor Safety Review Date
Aug. 21, 2017, since latest RMP submission
Contractor Safety Eval. Date
March 15, 2017, 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:
July 26, 2017
Local Response Agency:
Local Response Agency Phone:
(318) 783-4357
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
No
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

Executive Summary



The Acadia Power Station (APS) is committed to operating in a manner that is safe for APS workers, the public, and the environment. It is APS's policy that in the conduct of its activities it will strive to protect and promote the health and safety of its employees, customers, and others who may be affected by these activities, and to limit adverse effects on the physical environment in which its activities are carried out. As part of this policy, APS has established systems to help ensure safe operation of the processes at this facility. One part of these systems is a risk management program (RMP) Plan that helps manage the risks at APS and that complies with the requirements of the Environmental Protection Agency's (EPA's) rule 40 CFR part 68.



Description of the Stationary Source and Regulated Substances



APS, which is located in Eunice, Louisiana, is a gas-fired combustion turbine power plant that produces electricity. As a means of reducing nitrogen oxide emissions from the four gas-fired combustion turbines, anhydrous ammonia is injected into the turbine exhaust streams. Anhydrous ammonia is stored onsite in two dedicated, specially designed storage tanks. The storage capacity of each tank exceeds the threshold quantity for RMP applicability. There are no other toxic or flammable substances on-site that exceed RMP thresholds. APS is subject to OSHA's PSM standard as well as Program 3 of EPA's RMP rule.



Off-site Consequence Analysis



As required by the RMP rule, the worst case scenario is the highly unlikely catastrophic rupture of one of the anhydrous ammonia storage tanks. The release duration is ten minutes. The 18,000-gallon tank is limited to 85% of the storage capacity (15,300-gallons) by administrative controls, including operating procedures and high level alarms. The EPA's RMP*Comp was used in the analysis. Passive mitigation exists in the form of a dike around the tank, which limits the spread of ammonia. Based on the
analysis, public and environmental receptors would be affected by the worst case scenario.



The alternative release scenario, although unlikely, is a more realistic scenario than the worst-case scenario. It was analyzed as the failure of a 2-inch unloading hose at the delivery truck unloading point. The release would be mitigated via an excess flow valve on the delivery truck and by automatic shut off valves on the ammonia loading header.



The EPA's RMP*Comp software was used in the analysis. Based on the analysis, there are no that public receptors would be affected by the alternative release scenario (2010 U.S.Census data used with MARPLOT).



Accidental Release Prevention Program



APS has a long-standing commitment to the safety of the general public, of APS 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. APS utilizes engineering controls, inspection programs, and detailed procedures as a means to prevent accidental releases. In the event of a release, the facility has well trained emergency response teams to contain, mitigate, monitor, and 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. In conjunction with the local emergency planning committee (LEPC), the facility has ability to notify the local community through cable override systems, radio broadcasts, and/or through an automated telephone notification system.



Employee Participation



Employee Participation has always been a goal at APS. Keeping employees informed and involved creates a team unity atmosphere. Employees have participated on Process Hazards Analysis Teams and have access to all safety information. This information along with updated Operation Manuals are kept in the plant document control room. Operation ma
nuals are developed, updated and reviewed by operations personnel and the training department. These operation manuals assist employees in refresher training and operator recertification programs.



Safety meetings are held on a regular basis for Operations, Maintenance, Administration and Contract personnel. Regulations updates and safety procedures are the main topics during these safety meetings. All meetings are documented and kept on file. Administration also has safety meetings as necessary. Safety concerns, programs, audits, employee participation and other safety ideas are discussed during the meetings.



Process Safety Information



APS maintains a variety of technical documents to ensure that process hazards are understood and that the plant 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 material safety data sheets. This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For specific process areas, APS has documented safety-related upper and lower process limits for specific process parameters (e.g., temperature, level, composition) in the operation manuals for each process unit. APS ensures that the process is maintained within these limits by using process controls and monitoring instruments, operating procedures, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems).



APS also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, piping and instrumentation dia
grams, 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 process and facility changes to ensure that safety features in the process are not compromised.



Process Hazard Analysis (PHA)



APS has a comprehensive process hazard analysis (PHA) program to help ensure that hazards associated with the ammonia processes are identified and controlled. Within this program, each existing covered process and future processes are systematically examined to identify hazards and ensure that adequate controls are in place to manage those hazards. The analysis is conducted in accordance with regulatory requirements generally accepted industry standards, and guidance from safety organizations such as the Center for Chemical Process Safety. APS has a system in place to ensure that PHA recommendations are resolved in a timely manner.



The PHA team recommendations are forwarded to management for resolution. Implementation of safety improvements in response to PHA findings is completed within six months if feasible. Any item that cannot be taken care of within six months is documented and justified. 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 Safety Manager.



To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, APS periodically updates and revalidates its process hazard analyses 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 results and recommendations from these updates are documented and retained
. Once again, the team findings are forwarded to management for consideration, and the final resolution of the recommendations is documented and retained.



Operating Procedures



APS 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 annually certified by the Safety Manager as current and accurate. Procedures are maintained current by revising them as necessary to reflect changes made to the process. In addition, the APS 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.



Training



To complement the written procedures for process operations, APS has implemented a training program for all employees involved in operating a process. New employees receive basic training in APS operations if they are not already familiar with such operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. 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 refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted every th
ree years. Operators are given the opportunity to take part in more frequent refresher training if desired. All of this training is documented for each operator, including the means used to verify that the operator understood the training.



Contractors



APS uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, APS 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 APS personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, (4) safe work practices, and (5) a work permit process (i.e., for hot work, confined space, etc.) prior to their beginning work. In addition, APS pre-qualifies contractors based on their safety record and evaluates contractor safety programs and performance during the selection of a contractor. APS personnel periodically monitors contractor performance to ensure that contractors are fulfilling their safety obligations.



Pre-Startup Safety Reviews (PSSR)



APS conducts a pre-startup safety review for any new facility or facility modification that requires 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 one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The review t
eam uses checklists to verify all aspects of readiness. A review involves field verification of the construction and serves a quality assurance function.



Mechanical Integrity



APS has 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 basic aspects of this program include: (1) the development of a maintenance schedule for equipment in the ammonia process and critical safety equipment, (2) developing written maintenance 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.



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 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). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or a management of change team 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. APS incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and tha
t proper materials and spare parts are used when repairs are made.



Safe Work Practices



APS has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedure to control welding and other spark-producing activities, and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely.



Management of Change



APS has a comprehensive system to manage changes to processes. This 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. 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.



Incident Investigation



APS promptly investigates 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. 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 inv
estigation team, which often includes contractors, documents its findings, develops recommendations to prevent a recurrence, and forwards these results to APS 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 all employees (including contractors) 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.



Compliance Audits



To help ensure that the accident prevention program is functioning properly, APS 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 contractor with assistance by APS employees as required. The findings are forwarded to APS 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, and the two most recent audit reports are retained.



Additional Safety Systems



APS has additional systems in place to prevent accidental releases of ammonia, as well as systems to lessen the impact of accidental releases.



These systems include:

? Automated shutdown systems

? Pressure relief valves

? Process relief valves that discharge to a flare to capture and incinerate process materials to prevent overpressure damage to equipment;

? Scrubbers to neutralize chemical releases;

? Manual and automatic valves to permit isolation of the process;

? Automated shutdown systems for specific process parameters (e.g., high level, high temperature);

? Curbing or diking to contain liquid releases;

? Redundant equipment an
d instrumentation where needed (e.g., uninterruptible power supply for some critical process control system, redundant firewater pumps, electrical and diesel);

? Release mitigation systems (water spray systems);

? Fire suppression and extinguishing systems (dry and liquid);

? Trained emergency response personnel;

? Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus); and

? Blast-resistant control buildings to help protect control systems and personnel.



Five Year Accident History



No releases of regulated substances from regulated processes have occurred from APS in the last 5 years that have resulted in deaths, injuries, or significant property damage on site, or known deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage off site.



Emergency Response Program



APS maintains a written Emergency Procedures Manual, which is in place to protect worker and public safety as well as the environment. The manual includes procedures for responding to a release of a regulated substance. The procedures address all aspects of emergency response, including proper 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, APS 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. The Emergency Procedures Manual is updated when necessary based on modifications made to processes. Any changes approved are updated in the manual and affected personnel are trained in regards to the changes during periodic safety meetings and/or through the Management of Change process,
on shift training meetings.



The overall emergency response program for APS is coordinated with the Acadia Parish Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. APS has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, APS conducts periodic emergency drills that involve the LEPC and emergency response organizations. Additionally, APS provides periodic refresher training to local emergency responders regarding the hazards of regulated substances at the facility.