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DP&L - Killen Electric Generating Station

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Facility #1 : DP&L - Killen Electric Generat


Basic Facility Info facility_Basic_Facility_Info help link help link  
Facility ID100000184123
Deregistered (Yes/No)No
Facility NameDP&L - Killen Electric Generating Station
Street Address Line 114869 U.S. Hwy 52
CityManchester
StateOH
Zip Code45144
CountyAdams County
113th Congressional DistrictOH02: Ohio 2
Owner or Operator NameThe Dayton Power and Light Company
Parent CompanyDPL Inc.
Latitude38.683333
Longitude-083.483333
Number of RMP Submissions3

Most Recent Submission Info facility_Most_Recent_Submission_Info help link help link  
RMP ID52722
Submission Typerevised submission for facility
Submission Date10/14/2008
Reason For Submission5-year update (40 CFR 68.190(b)(1))
Process Toxic Amount Total (lbs)322,000
Process Flammable Amount Total (lbs)0
Process Amount Total (lbs)322,000
Number of Potential Offsite Consequence Processes1
Potential Offsite Consequence Toxic Amount Total (lbs)322,000
Potential Offsite Consequence Flammable Amount Total (lbs)0
Potential Offsite Consequence Amount Total (lbs)322,000
All Process NAICS221112
Exec Summary Submission Date10/14/2008

Executive Summary facility_Executive_Summary help link help link (Facility #1 : DP&L - Killen Electric Generat, executive summary: all)

Executive Summary

DP&L Killen Electric Generating Station, Manchester, Ohio.


EXECUTIVE SUMMARY

I. Accidental Release Prevention and Emergency Policies

Environmental protection and enhancement are essential elements of DP&Ls integrated resource management philosophy. DP&L exhibits progressive environmental leadership in managing its generating stations for the public benefit, including the production of reliable, competitively priced power. DP&L also assures that employees are aware of their environmental responsibilities, use effective environmental processes, and are held accountable for performance.

DP&L management and employees will be responsible for maintaining compliance with environmental requirements and striving for environmental excellence in performing their respective duties. We will assure environmental protection and reduce risks to our employees and to the communities in which we operate through review of new developments, safe technologies, operating procedures, and emergency preparedness. All activities are conducted in accordance with current environmental and health and safety regulatory requirements.


II. Stationary Source and Regulated Substances Handled

The affected facility houses a selective catalytic reduction process to reduce the emissions of nitrogen oxides to the atmosphere. The process contains an anhydrous ammonia storage facility, including two 35,450-gallon storage tanks with supporting unloading equipment, vapor compressors, piping to convey the liquid ammonia, vaporizers to convert ammonia from a liquid to a gas, and a gas dilution and injection system to inject ammonia into a selective catalytic reduction emission control system.

There is only one regulated substance at the facility anhydrous ammonia. With two 35,450-gallon storage tanks, the maximum amount of anhydrous ammonia in the storage facility at any time is 322,000 pounds and the maximum amount contained in the largest single vessel is 161,000 pounds.


III. Summary
of Worst Case and Alternative Release Scenarios

The worst-case release scenario and an alternative release scenario were identified and analyzed to determine the distance to endpoint for each assumed release. To perform the required offsite consequence analysis for the facility, the very conservative EPA RMP*Comp model was used.

The worst case release scenario involves the complete rupture of one 35,000-gallon storage tank. A maximum release of 161,000 pounds of anhydrous ammonia over a 10-minute period was considered. The released quantity was not limited by a system of administrative controls. Under worst case meteorological conditions of Class F stability and 1.5 m/s wind speed, ammonia could travel up to 6.9 miles before reaching the specified toxic endpoint level of 0.14 mg/L.

The alternative case release scenario involves the release of 19,400 pounds of ammonia over 30 minutes from the failure of a tank flange gasket. Under typical meteorological conditions of Class D stability and 3 m/s wind speed, ammonia could travel up to 0.5 miles before reaching the specified toxic end point level of 0.14 mg/L.


IV. Description of Release Prevention Program

Process Safety Information DP&L maintains documentation of safety information concerning chemical hazards, operating parameters, and equipment designs and specifications associated with the process.

Process Hazard Analysis DP&L conducted detailed analyses of the process to ensure that hazards associated with the process were identified and controlled effectively. The What-If analysis methodology was used to assess the potential hazards of the process. The study was conducted by a team of qualified personnel with expertise in engineering, control logistics, and process operations. Findings resulting from the analysis were addressed. The initial What-If analysis was conducted on September 5 -6, 2001, and a pre-startup safety review was conducted on April 5, 2002. An update and review of the PHA was
conducted on September 24, 2008.

Operating Procedures DP&L has established and maintains procedures for safely conducting activities within our covered process. The procedures cover various operational phases including initial setup, normal startup, normal shutdown, temporary operations, emergency shutdown, emergency operations, and startup following a turnaround or emergency shutdown. The information is readily available to operators and maintenance personnel involved in the process and the information is periodically reviewed to assure it is current.

Training DP&Ls training program is comprehensive and is implemented to ensure that all personnel involved in the operation and maintenance of the process are properly trained in the safe operation and maintenance of the process and knowledgeable of the hazards of the process. The personnel are provided with refresher training at least every three years or more often if needed.

Mechanical Integrity DP&L conducts well-documented maintenance checks on process equipment to ensure safe and reliable operations. All process equipment routinely checked includes storage tanks and pressure vessels, piping systems, relief and venting systems, controls and pumps, emergency shutdown systems, and monitoring devices. All maintenance operations conducted on the covered process are performed by qualified personnel who have had proper training. Equipment deficiencies identified by the maintenance checks are corrected promptly and safely.

Management of Change DP&L maintains written procedures to manage changes in the process equipment, procedures and monitoring technology. Personnel whose job tasks are affected by a modification in the process are promptly apprised of the modification and provided training to address the modification.

Pre-Startup Review A pre-startup safety review was conducted prior to the startup of the new process. Established pre-startup safety review procedures will assure that construction,
equipment, operating and maintenance procedures are suitable for a safe startup prior to placing equipment into operation.

Compliance Audits DP&L will conduct audits of the risk management plan at least every three years. Any corrective actions required as a result of the audits will be promptly and safely implemented.

Incident Investigations Any incident that results in or could reasonably result in a significant release of a regulated substance is promptly investigated. Procedures ensure that investigations are undertaken to identify the circumstances leading to the incident. Corrective action will be taken to ensure that the situation leading to the incident does not reoccur. All investigation reports will be retained for at least 5 years.

Employee Participation DP&L believes in a team approach to process safety management and accident prevention. Employees are encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information developed through implementation of the RMP, including information resulting from process hazard analyses.

Contractors DP&L develops partnerships with contractors to effectively conduct business and operate generation facilities, especially in maintenance and construction activities. Prior to selecting a contractor, DP&L evaluates the qualifications of the contractor including their safety performance. Procedures are in place to ensure that contractors are properly informed of known potential hazards related to the contractors work and the process involved, including the emergency response procedures in the event of an accidental release of a regulated substance.

V. Five Year Accident History

The ammonia facility has not experienced any events that would meet U.S. EPA's definition of an accident within the last five years.

VI. Emergency Response Program

The Part 68 rule distinguishes between those facilities which will
respond to accidental releases of regulated substances and those which will not. The requirements for non-responding facilities are covered in Section 68.90 of the rule. To determine whether a facility is a responding one, the EPA interpretation of response is commonly used. It is the definition of response used in the OSHA HAZWOPER standard in 29 CFR 1910.120(a)(3).

The standard defines response as a response effort by employees from outside the immediate release area or by other designated responders to an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous substance. This definition specifically excludes responses to incidental releases, which are those where the substance can be absorbed, neutralized, or otherwise controlled at the time of released by employees in the immediate release area, or by maintenance personnel. Also excluded are those releases of hazardous substances where there is no potential safety or health hazard. Such hazards include fire, explosion, or chemical exposure. If the release of chemical is substantial or clearly growing in size, the leak is no longer considered incidental and employees should not respond unless they are specifically trained in response procedures and the facility has an emergency response program that meets the requirements of 40 CFR 68.95.

OSHA Standard 29 CFR 1910.120(q)(1) states that Employers who will evacuate their employees from the danger area when an emergency occurs, and who do not permit any of their employees to assist in handling the emergency, are exempt from the requirements of this paragraph if they provide an emergency action plan in accordance with Section 1910.38(a). . . This part of the standard describes the elements of an emergency action plan. These are (1) emergency escape procedures and emergency escape route assignments; (2) procedures to be followed by employees who remain to operate critical plant operations before they evacuat
e; (3) procedures to account for all employees after emergency evacuation has been completed; (4) rescue and medical duties for those employees who are to perform them; (5) the preferred means of reporting fires and other emergencies; and (6) names or regular job titles of persons or departments who can be contacted for further information or explanation of duties under the plan.

DP&L has an emergency action (not response) plan in place to address and react to accidental releases of hazardous materials. The plan includes such requirements as adequate first aid and medical treatment, notification of local emergency response agencies and the public, and qualified contractor responder for post-incident response and decontamination of affected areas. The plan will be promptly updated to address any pertinent changes within the process that would require a modification of the emergency action plan.

VII. Planned Changes to Improve Safety

DP&L is always receptive to suggestions from employees to improve safety. Employee meetings that focus on safety issues are held regularly. Further, employees are trained to recognize hazards and to present ideas to eliminate them or minimize the potential consequences of those hazards. The recommendations made during the process hazard analysis have been considered for implementation.
Submission - Other Facility Info facility_Submission_-_Other_Facility_Info help link help link  
Number of Full Time Employees135
Owner or Operator NameThe Dayton Power and Light Company
Owner or Operator Address Line 114869 U.S. Hwy 52
Owner or Operator CityManchester
Owner or Operator StateOH
Owner or Operator Zip45144
Parent Dun and Bradstreet Number0
Second Parent Dun and Bradstreet Number0
Number of Full Time Employees135
Number of FTE CBI FlagNo
Other Facility ID45144DYTNP14869
Covered by OSHA PSM StandardYes
Covered by EPCRA Section 302Yes
Covered by CAA Title VYes
CAA Title V Air Operating Permit ID0701000060
Last Safety Inspection Date03/22/2005
Last Safety Inspection ByState environmental agency
OSHA Star or Merit RankingNo
LEPC NameAdams County LEPC

Submission - Contact Info facility_Submission_-_Contact_Info help link help link (Facility #1 : DP&L - Killen Electric Generat, RMP submission #1 : 2008-10-14)
Owner or Operator Phone9375493911
Facility URLwww.dplinc.com
Facility Phone9375493911
Facility Dun and Bradstreet Number7902430
RMP ContactMichael Harrell
RMP Contact TitleStation Manager
RMP Contact Emailmichael.harrell@dplinc.com
RMP Preparer NameEnvironmental Quality Mgmt., Inc.
RMP Preparer Address Line 11800 Carillon Blvd
RMP Preparer CityCincinnati
RMP Preparer StateOH
RMP Preparer Zip45240
RMP Preparer Phone5138257500

Submission - Additional Info facility_Submission_-_Additional_Info help link help link  
RMP Complete FlagYes
Predictive FilingNo
No RMP Accidents Last 5 YearsYes
Complete Check Date10/15/2008
Postmark Date10/10/2008
Anniversary Date10/10/2013
Confidential Business InformationNo

Submission - Lat/Long Info facility_Submission_-_Lat_Long_Info help link help link (Facility #1 : DP&L - Killen Electric Generat, RMP submission #1 : 2008-10-14)
Latitude38.683333
Longitude-083.483333
Valid Lat/LongYes
Lat/Long MethodInterpolation - Map
Lat/Long Location TypeLoading Facility
FRS Latitude38.69
FRS Longitude-83.48

Submission - Counts and Totals facility_Submission_-_Counts_and_Totals help link help link  
Number of RMP Accidents0
RMP Accident Flammable Total (lbs)0
RMP Accident Toxic Total (lbs)0
RMP Accident Amount Total (lbs)0
Number of RMP Accidents0
Number of Processes1
Number of Process Chemicals1
Number of Toxic Worst-case Scenarios1
Number of Toxic Alternate Case Scenarios1
Number of Flammable Worst-case Scenarios0
Number of Flammable Alternate Case Scenarios0
RMP Accident Flammable Total (lbs)0
RMP Accident Toxic Total (lbs)0
RMP Accident Amount Total (lbs)0
Total RMP Accident Deaths0
Total RMP Accident Injuries0
Total RMP Accident Evacuated/Sheltering In Place0
Total RMP Accident Property Damage$0

Processes facility_Processes help link help link (Facility #1 : DP&L - Killen Electric Generat, RMP submission #1 : 2008-10-14, process #1 : SCR Air Pollution Control)
Process DescriptionSCR Air Pollution Control
Program Level3
Confidential Business InformationNo
Toxic Amount Total (lbs)322,000
Flammable Amount Total (lbs)0
Process Amount Total (lbs)322,000
Number of Process Chemicals1
Number of Toxic Worst-Case Scenarios1
Number of Toxic Alternate Scenarios1
Number of Flammable Worst-Case Scenarios0
Number of Flammable Alternate Scenarios0

Process Chemicals facility_Process_Chemicals help link help link  
Process Chemical IDAmmonia (anhydrous)
CAS number007664417
Chemical TypeToxic
Process Chemical Amount (lbs)322,000
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link (Facility #1 : DP&L - Killen Electric Generat, RMP submission #1 : 2008-10-14, process #1 : SCR Air Pollution Control, process chemical #2)
Process Chemical IDPublic OCA Chemical
CAS number000000000
Process Chemical Amount (lbs)0
Confidential Business InformationNo

Worst-Case Toxic Scenarios facility_Worst-Case_Toxic_Scenarios help link help link  
Physical StateGas liquified by pressure
Model UsedEPA's RMP*Comp(TM)
Release Duration (minutes)10
Wind Speed (meters/sec)1.5
Atmospheric Stability ClassF
TopographyRural
Passive Mitigation - DikesNo
Passive Mitigation - EnclosuresNo
Passive Mitigation - BermsNo
Passive Mitigation - DrainsNo
Passive Mitigation - SumpsNo
Confidential Business InformationNo

Alternate Case Toxic Scenarios facility_Alternate_Case_Toxic_Scenarios help link help link (Facility #1 : DP&L - Killen Electric Generat, RMP submission #1 : 2008-10-14, process #1 : SCR Air Pollution Control, process chemical #2, alternate toxic scenario #1)
Physical StateGas liquified by pressure
Model UsedEPA's RMP*Comp(TM)
Wind Speed3
Atmospheric Stability ClassD
TopographyRural
Passive Mitigation - DikesNo
Passive Mitigation - EnclosuresNo
Passive Mitigation - BermsNo
Passive Mitigation - DrainsNo
Passive Mitigation - SumpsNo
Active Mitigation - SprinklersNo
Active Mitigation - Deluge SystemsNo
Active Mitigation - Water CurtainNo
Active Mitigation - NeutralizationNo
Active Mitigation - Excess Flow ValvesNo
Active Mitigation - FlaresNo
Active Mitigation - ScrubbersNo
Active Mitigation - Emergency ShutdownNo
Confidential Business InformationNo

Process NAICS facility_Process_NAICS help link help link (Facility #1 : DP&L - Killen Electric Generat, RMP submission #1 : 2008-10-14, process #1 : SCR Air Pollution Control, process NAICS code #1 : 221112)
NAICS Code221112: Fossil Fuel Electric Power Generation

Prevention Program 3 facility_Prevention_Program_3 help link help link  
Safety Info Review Date05/20/2005
PHA Update Date09/24/2008
PHA Technique - What IfYes
PHA Technique - ChecklistNo
PHA Technique - What If/ChecklistNo
PHA Technique - HAZOPNo
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Change Completion Date12/31/2008
Hazard Identified - Toxic ReleaseYes
Hazard Identified - FireYes
Hazard Identified - ExplosionNo
Hazard Identified - Runaway ReactionNo
Hazard Identified - PolymerizationNo
Hazard Identified - OverpressureYes
Hazard Identified - CorrosionNo
Hazard Identified - OverfillingYes
Hazard Identified - ContaminationYes
Hazard Identified - Equipment FailureYes
Hazard Identified - Cooling LossYes
Hazard Identified - EarthquakeYes
Hazard Identified - FloodYes
Hazard Identified - TornadoYes
Hazard Identified - HurricaneNo
Hazard Identified - Othervehicle collision, line rupture, wrong chemical delivery, theft, sabotage
Process Controls - VentsYes
Process Controls - Relief ValvesYes
Process Controls - Check ValvesYes
Process Controls - ScrubbersNo
Process Controls - FlaresNo
Process Controls - Manual ShutoffsYes
Process Controls - Auto ShutoffsYes
Process Controls - InterlocksYes
Process Controls - AlarmsYes
Process Controls - Keyed BypassNo
Process Controls - Emergency AirNo
Process Controls - Emergency PowerNo
Process Controls - Backup PumpNo
Process Controls - GroundingYes
Process Controls - Inhibitor AdditionNo
Process Controls - Rupture DisksNo
Process Controls - Excess Flow DevicesYes
Process Controls - Quench SystemNo
Process Controls - Purge SystemNo
Process Controls - NoneNo
Mitigation Systems - SprinklersNo
Mitigation Systems - DikesYes
Mitigation Systems - Fire WallsNo
Mitigation Systems - Blast WallsNo
Mitigation Systems - Deluge SystemsNo
Mitigation Systems - Water CurtainsYes
Mitigation Systems - EnclosureNo
Mitigation Systems - NeutralizationNo
Mitigation Systems - NoneNo
Monitoring Systems - Process AreaYes
Monitoring Systems - PerimeterNo
Monitoring Systems - NoneNo
Changes Since PHA - Reduced InventoryNo
Changes Since PHA - Increased InventoryNo
Changes Since PHA - Process ParametersNo
Changes Since PHA - Process ControlsNo
Changes Since PHA - Process DetectionNo
Changes Since PHA - Perimeter MonitoringNo
Changes Since PHA - Mitigation SystemsNo
Changes Since PHA - None RecommendedNo
Changes Since PHA - NoneYes
Procedure Review Date05/20/2005
Training Review Date05/01/2008
Type of Training - ClassroomYes
Type of Training - On the JobNo
Competency Testing - Written TestsNo
Competency Testing - Oral TestsNo
Competency Testing - DemonstrationYes
Competency Testing - ObservationNo
Maintenance Review Date05/20/2005
Maintenance Inspection Date06/27/2008
Equipment Testedtanks, piping, vaporizers
Management of Change Review Date04/05/2002
Pre-startup Review Date10/17/2003
Compliance Audit Date07/01/2008
Compliance Audit Change Completion Date10/31/2008
Incident Investigation Date10/30/2003
Incident Invest. Change Completion Date11/20/2003
Participation Plan Review Date05/20/2005
Hot Work Review Date04/05/2002
Contractor Safety Review Date04/05/2002
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : DP&L - Killen Electric Generat, RMP submission #1 : 2008-10-14, process #1 : SCR Air Pollution Control, process NAICS code #1 : 221112, prev. program 3 #1, prev. program 3 chemical: all)
Process Chemical Record ID
101911

Prevention Program 3 Text facility_Prevention_Program_3_Text help link help link  
Prevention Program Description
DP&L Killen Electric Generating Station, Manchester, Ohio.

Anyhydrous ammonia is received by tanker trucks, stored in two 35,000 gallon tanks and distributed to SCR control equipment to reduce NOx emissions. The prevention program includes assuring all process equipment and materials meet appropriate standards and code requirements, implementation of detailed safe operating procedures, an effective maintenance program, and a training program to assure that all personnel are thoroughly trained in the safe operation and maintenance of the ammonia system. Process controls include relief valves, check valves, automatic and manual shutoffs, excess flow devices, interlocks, alarms and procedures. Sudden surges in flow or pressure will cause automatic shutoff valves, located in the bottom, at the outlet, of each tank, to close and isolate the system. A water spray system located at the unloading station can be manually activated by control room operators or storage facility operators. The surrounding area at the storage facility is diked to contain runoff for treatment.

Emergency Response Plan Info facility_Emergency_Response_Plan_Info help link help link  
Facility In Community PlanYes
Facility Own Response PlanNo
Specific Facility Response PlanNo
Inform. Procedures in Response PlanNo
Emergency Care in Response PlanNo
Local Response AgencyAdams County Emergency Mgmt. Agency
Local Response Agency Phone9375446123
Subject To - OSHA EAPYes
Subject To - OSHA HAZWOPERNo
Subject To - CWAYes
Subject To - RCRAYes
Subject To - OPANo
Subject To - State EPCRAYes


Search Criteria Used
RMP Facility ID100000184123

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