Document zQZqY2bQEwEvGzY4X4JEZDwKR

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10 1200 Sixth Avenue, Suite 155 Seattle, WA 98101 ENFORCEMENT & COMPLIANCE ASSURANCE DIVISION Clean Air Act - Section 112(r) Risk Management Program and EPCRA 312 - Tier II Facility Inspection Report FACILITY INFORMATION: Corporate Name: Chugach Electric Association, Inc. Facility Name: South Central Power Project Physical Address: 6075 Electron Drive Anchorage, Alaska 99518 Phone Number: (907) 762-4835 Latitude/Longitude: 61.166667, -149.904444 RMP Facility ID# 100000219051 FRS ID#: 110046491854 EJ Concerns: Yes (above 80%) CONTACT INFORMATION (RMP Implementation): Name: Chrissi Radeski Title: Environmental Compliance Manager Phone Number: (907) 602-9192 E-mail: chrissi_radeski@chugachelectic.com EMERGENCY CONTACT INFORMATION: Name: Christina Radeski Phone (24-hr): (907) 602-9192 E-mail: chrissi_radeski@chugachelectric.com Website: https://www.chugachelectric.com/ TRIP DETAILS: Inspection Date: September 14, 2023 Inspection Time: 09:00 through 14:15 EPA Inspectors Team: Edward Johannes, US EPA Region 10 SEE Grantee, Lead RMP Inspector Terry Garcia, US EPA Region 10 SEE Grantee, RMP Inspector Peter Phillips, US EPA Region 10 SEE Grantee, RMP Inspector Erin Williams, US EPA Region 10, EPCRA/RMP Inspector DATE AND PROGRAM LEVELS OF SUBMITTED RMP: Initial Submission Date: September 19, 2012 Date of Latest Update: August 5, 2022 Page 1 of 6 Process (Program 1, 2, 3) as reported in RMP: Process ID Description Process Chemical ID 1000126073 SCR Aqueous Ammonia 100157719 NAICS Code 221112 Program Level 2 Chemical Name CAS Number Ammonia, Aqueous (7664-41-7) Quantity (lbs) 53,000 PURPOSE: The purpose of this inspection was to determine whether this facility is in compliance with Section 112(r) of the Clean Air Act and Title 40 Code of Federal Regulations (CFR) Part 68, Chemical Accident Prevention Provisions. The facility has been previously inspected in the past 5 years: No Yes If Yes, Date of Last Inspection: The facility is High Risk: Joint EPCRA inspection: No Yes No Yes CAA TITLE V AIR PERMIT: Does the facility have a CAA Title V Permit? If Yes, Permit Number No Yes RELEASE/ACCIDENT HISTORY: Did the facility have a reportable release in the past 5 years? If Yes, Date and Description of the Release: No Yes EPCRA TIER II REPORTING: Did the facility submit the [Enter Year] Tier II report to the SERC? No Yes If Yes, Date the Tier II was submitted: February 14, 2023 If No, calendar year of the most recent Tier II: Did the facility submit a Tier II to the LEPC and local fire department? No Yes If Yes, Date the Tier II was submitted: February 14, 2023 INSPECTION ENTRY: The EPA Inspection Team, led by Edward Johannes, met with facility representatives at the South Central Power Project (facility) in Anchorage, AK. EPA arrived at the facility at 0900 hours and was joined by the following facility personnel: Christina Radeski Brian Goodman Joshua Travis Aaron Love Eugene Ori Nathaniel Lewis Name Title CEA CEA CEA Plant Manager UP Power Production Plant Manager, Sullivan Was a state/county/or local emergency representative present? If Yes, Name and Title of Representative: No Yes Page 2 of 6 The facility is a first responder: No Yes If No, Responding Agency Anchorage Fire Department and NRC Alaska, Inc. The inspection team was escorted to a conference room located in the facility's office building. Introductions were made by Edward Johannes, who provided a summary of the risk management program (RMP) and explained the purpose of the visit. Each team member presented his/her credentials. EPA then requested an explanation of the facility's operations and any additional safety measures that should be taken during the site tour. Aaron Love, Brian Goodman, and Christina Radeski, gave a brief description of the facility, operations, and personal protective equipment required for the tour. Prior to the inspection, EPA sent a certified notice of inspection letter to the facility informing them of the CAA Section 112(r)(6)(L) requirement that facility employees and employee representatives (such as a union representative) have the right to participate in the RMP inspection, and that a copy of the letter must be provided to the employee representative(s) and the letter posted in a manner accessible to employees in the facility. The facility is unionized: If Yes, Name of Union IBEW Local 1547 No Yes An employee representative present during the facility visit: If Yes, Name/Title Brian Goodman, IBEW representative No Yes GENERAL INFORMATION: The facility is regulated under the Risk Management Program as a Program Level 2 and is owned and operated by Chugach Electric Association, Inc. (CEA). It was incorporated in Alaska on March 1, 1948, with funding under the Rural Electrification Act of 1936, as amended. CEA is the largest cooperative utility (co-op) in Alaska. The facility was placed into commercial service on February 1, 2013, and is Alaska's third-largest power plant. The utility provides wholesale and retail power to customers in southcentral Alaska, from the Kenai Peninsula to the south and as far north as Fairbanks. The facility has very high levels of automation and operates 24/7 with a minimum of two operators per 10 hour shifts and a six-man maintenance staff. There are sixteen full-time employees on site. The facility has three natural gas-powered General Electric (GE) LM6000PF combustion turbines (CTs) rated at 48 MW, the three once-through turbine generators (OTSG) manufactured by IST, and a 57-MW steam turbine-generator from Mitsubishi Power Systems Americas, a 3 x 1 combined cycle system. In combined-cycle, the 800-degree hot exhaust of the CTs is used to make steam which powers the steam turbine-generator, thereby producing extra electricity with no additional fuel needed. Duct firing two of the three OTSGs will produce maximum steam turbine output for peak load purposes. Also included within each OTSG are selective catalytic reduction (using 29% aqueous ammonia) and CO catalysts to further reduce emissions. Presently, the plant operates with 11 ppm NOx from the CT and 4.5 ppm from the boiler stack. The official power plant rating is 182.5 MW with a heat rate of 6,382 Btu/kWh (LHV) at an average annual ambient temperature of 36 F. The facility uses 29% aqueous ammonia at a rate of approximately 10,000 pounds every six weeks which is trucked to the facility by Univar. The 29% aqueous ammonia is stored in two 12,000-gallon horizontal aboveground storage tanks (ASTs) located outside the facility's power plant. The amount of ammonia in solution is approximately 53,000 pounds (exceeds the threshold quantity of 20,000 pounds for aqueous ammonia (concentration 20% or greater). The Ammonia Flow Control and Selective Page 3 of 6 Catalytic Reduction (SCR) Systems are located inside the facility's power plant. The aqueous ammonia is piped from the ASTs to each of the three SCR systems locations in the facility. The Ammonia Flow Control and SCR unit consists of two primary systems: 1) Ammonia Flow Control, Dilution Air Blower, and Ammonia vaporizer, and 2) Ammonia Injection Grid (AIG) and SCR Catalyst Reactor Housing. The SCR Systems are designed to reduce oxides of nitrogen (NOx) from combustion turbine exhaust gases produced by the CTs. Aqueous ammonia (29%) is injected in 13 points to the exhaust stream above the SCR catalyst bed after going thru the Ammonia Flow Control, Ammonia Vaporizer, and AIG systems. All these systems are monitored either by flow, pressure gradient, or temperature sensors and will activate alarms in the control center if certain conditions are not met. The exhaust gas mixed with the aqueous ammonia, or process gas, flows through the SCR catalyst bed, a chemical reaction occurs with the titanium/rubidium in the bed that reduces the NOx emissions to nitrogen (N2) gas and water (H2O) vapor. As part of the emergency response program, the facility has contracted NRC Alaska, Inc. to respond to aqueous ammonia spills. During the facility inspection, CEA representatives stated that no modifications to the NOx aqua ammonia system have been made in the past 5 years; none are currently planned or underway. ON-SITE OBSERVATIONS: The facility tour was conducted from approximately 09:00 to 11:15. The inspection team was escorted by Christina Radeski, Joshua Travis, Aaron Love, Nathaniel Lewis, Eugene Ori, and Brian Goodman. The inspection team observed the area with the turbine generators, the two aqueous ammonia storage tanks, the pump used to offload aqueous ammonia from the tanker trucks to the aqueous ammonia storage tanks, and aqueous ammonia injection skid, aqueous ammonia injection stack, and in the control room the E-stops, ammonia emergency alarms, and Ammonia Transfer System (ATS) computer screen. The photographs that were taken at the facility are included in Attachment A to this report. The tour began with a walk thru in the power plant building where CT 11 (Unit 1), 12 (Unit 2), and 13 (Unit 3) are located (Photo 1 and 2). The tour moved outside to the south end of the power plant building where the 29% aqueous ammonia is stored in two 12,000-gallon ASTs located in a covered concrete dike containment area (Photo 3, 7, 11, and 12). The NFPA 704 hazard identifier placards were plainly posted at both bullet tanks and 29% aqueous ammonia labels were adhered on both of their sides (Photo 3, 5, and 7). The ammonia detector located at the ASTs is set to alarm at 25 ppm locally and at the Plant Control Room. Other safety features observed during the inspection were an Ammonia Horn Light Panel that indicates if the ASTs are overfilled or if ammonia vapor has been detected (Photo 8), a windsock on an adjacent building (Photo 4), an outside emergency shower station and an enclosed heated emergency eyewash and shower station (Photo 6, 11, and 12), pressure relief valves (Photo 7), grounding cable for the delivery tanker trucks (Photo 7 and 10), and pipelines that were clearly marked as to content and flow direction and all run above ground allowing for easier inspections and maintenance (Photo 3, 6, 7, and 9). The loading rack area where tanker trucks connect hoses to off-load aqueous ammonia to the ASTs was also observed (Photo 9). The ammonia pump is used to transfer of aqua ammonia from the delivery tanker trucks to the ASTs (Photo 13). This is securely kept inside the power plant building until needed. The aqueous ammonia skid (Photo 14) and aqueous ammonia injection stack (Photo 15) were observed. All piping were clearly marked as to content and flow direction. Page 4 of 6 In the Plant Control Room (Photo 16) the ammonia warning strobe light above the control room door (Photo 17), the E-stops (Photo 18), and Ammonia Transfer System (ATS) computer screen (Photo 19) were observed. After touring the RMP-covered process areas at CEA, the inspection team returned to the conference room to review the RMP documentation. Upon completion of the document review, EPA provided a debriefing to Christina Radeski, Aaron Love, Eugene Ori, Joshua Travis, and Nathaniel Lewis. INFORMATION COLLECTED FROM FACILITY: 1. SCR Operation and Maintenance Manual. 2. Ammonia Loading Area Material Response Map. 3. Operators Training Records. 4. Alternate Release Scenario and Worst Case Scenario Maximum Distance to Toxic Endpoint Map. 5. Emergency Evacuation Plan Map. AREAS OF CONCERNS ADDRESSED IN CLOSING CONFERENCE: 1. CEA Safety Information does not identify the codes or standards used to design, build, or operate the process. [68.48(a)(5)]. This issue was previously identified in a 2014 EPA inspection. 2. CEA did not provide initial and refresher training documents for their operators. [68.54(a), (b), and (d)]. 3. CEA did not prepare and implement procedures for maintaining process equipment. [68.56(a)]. 4. CEA did not provide maintenance training records for employees involved in the process. [68.56(b)]. 5. CEA did not provide documents that they performed or caused to be performed inspections or the frequency of inspections and test on process equipment [68,56(d)]. 6. CEA did not certify their 2017 and 2020 compliance audit reports. [68.58(a)]. 7. CEA did not provide an incident investigation policy. [68.60]. 8. CEA did not provide written records or documented they performed annual emergency response coordination with local authorities in the last five years. [68.90(b)(4), 68.93(c), 68.96(a)]. DOCUMENTS REQUESTED NOT INCLUDED IN REPORT: The following documents were requested during the inspection but are not included in this report. Documents received were reviewed to determine compliance with Section 112(r) of the Clean Air Act. 1. Refresher Training for all operators and maintenance employees. 2. Certification signature page for both the 2017 and 2020 Compliance Audits. 3. Incident Investigation Policy. 4. MI-policy and standards used for inspections and maintenance of the aqueous ammonia process. 5. MI-training records for maintenance and inspections of the aqueous ammonia process. 6. MI-Explain basis for inspections and maintenance of the aqueous ammonia process. CEA provided some of the requested follow-up documentation listed above via email on September 27, 2023. Page 5 of 6 INSPECTION REPORT CERTIFICATION: This is to certify that I, Edward Johannes, was the lead inspector at this facility and that I have verified the accuracy of the observations in this inspection report: __________________________________________________________ Inspector Signature __________________________________________________________ RMP Coordinator/Approval __________________________________________________________ EPCRA Coordinator/Approval __________________________________________________________ Land Enforcement Section Chief/Approval Page 6 of 6 Attachment A - Photo Log Site Name: South Central Power Project City, State: Anchorage, AK Photographer: Peter Phillips Flle Date 1 9/14/2023 2 9/14/2023 3 9/14/2023 4 9/14/2023 5 9/14/2023 6 9/14/2023 7 9/14/2023 8 9/14/2023 9 9/14/2023 10 9/14/2023 11 9/14/2023 12 9/14/2023 13 9/14/2023 14 9/14/2023 15 9/14/2023 16 9/14/2023 17 9/14/2023 18 9/14/2023 19 9/14/2023 Time 10:26 AM 10:26 AM 10:29 AM 10:29 AM 10:29 AM 10:30 AM 10:30 AM 10:31 AM 10:31 AM 10:32 AM 10:33 AM 10:33 AM 10:37 AM 10:39 AM 10:39 AM 10:43 AM 10:44 AM 10:45 AM 10:45 AM Description Turbine 13 (1 of 3) Turbines 12 and 11 Vessel overview Windsock 29% aqua ammonia and NFPA 704 Placard Heated emergency shower Vessel and grounding cable Ammonia control panel Ammonia fill station Truck grounding reel Emergency shower fogger Emergency shower fogger Ammonia pump Aqua ammonia injection skid Aqua ammonia injection stack Control room Control room door and ammonia stobe Emergency stop in control room Ammonia process monitoring panel