Air Products, Marlborough - Executive Summary

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Executive Summary 
Air Products and Chemicals, Inc. 
Marlborough Hydrogen Storage and Fill Plant 
1.  Accidental release prevention and emergency response policies: 
At this facility, we store hydrogen, and transfer the hydrogen into portable cylinders and tube trailers.  Hydrogen, in the amounts handled by our facility, is considered hazardous by the EPA.  It is our policy to adhere to all applicable Federal and State rules and regulations.  Air Products manages the safety of the regulated process by means of operating procedures, equipment testing and inspections, safety devices (e.g., alarms, shutdowns, instrumentation, relief devices) inherent in the design of this facility, and other controls and systems designed to prevent accidental releases of hazardous chemicals.  Safe work practices and training of our personnel supplement the inherent safe design of the plant. 
Our emergency response program is based upon OSHAs HAZWOPER regulation.  The emergency response plan includes proc 
edures for the notification of the local fire authority and hazardous materials unit, if applicable, so that appropriate measures can be taken by local emergency responders to control accidental releases. 
This document has been prepared in accordance with the EPAs Risk Management Plan regulation (40 CFR, Part 68).  The substances and processes considered during the preparation of this RMP and the scenarios described were selected based on criteria established in the regulation. 
2.  The stationary source and regulated substance handled: 
The primary purpose of this facility is the storage of hydrogen and the transfer of same into portable cylinders and tube trailers.  The hydrogen is used by Air Products customers for a variety of applications such as a fuel for heating and metal processing.  The hydrogen is delivered into the hydrogen storage tank as a cryogenic liquid.  By means of a liquid compressor the liquid hydrogen is pumped through 2 high pressure ambient air vaporizer modu 
les which  transform the liquid hydrogen to gaseous hydrogen.  The gaseous hydrogen is then transferred to portable cylinders or tube trailers.  Portable cylinders are filled at 2 charging manifolds containing 24 stations each.  One charging manifold is used to fill portable cylinders with only hydrogen.  The other charging manifold can be used to fill portable cylinders with a mixture of hydrogen and argon or nitrogen in various concentrations.  Tube trailers are filled individually with hydrogen at one of seven tube trailer stanchions.  There is no chemical reaction involved.  The process is strictly the transfer of hydrogen from a large storage container into smaller individual portable cylinders or tube trailers. 
The regulated substance handled at this facility is hydrogen, which is stored as a cryogenic liquid.  The maximum amount of this substance at this facility is: 
7 11,820 pounds of liquid hydrogen  
3.  The worst-case release scenario(s) and the alternative release scenari 
o(s), including administrative controls and mitigation measures to limit the distance for each reported scenario: 
The worst-case scenario (WCS), as defined by the EPA, associated with the hydrogen process at this facility is a catastrophic failure in the liquid hydrogen storage tank, resulting in a vapor cloud explosion (VCE).  The entire liquid hydrogen storage tank inventory of 11,820 pounds is assumed to be released instantaneously into the atmosphere at the tank location, ignited, and resulting in a VCE.  The VCE would reach receptors off-site.  Although we have active mitigation systems directed at preventing such releases and controlling the consequences, no credit for active mitigation measures was taken into account in evaluating this WCS. 
The "alternative case scenario" (ACS) for the hydrogen process at this facility is a flash fire due to the failure of the largest size liquid hydrogen process line coming out of the storage tank, resulting in a release rate of  66 pounds pe 
r minute, based on the tank operating pressure of 100 psig, and a line size of one (1) inch.  This scenario, and all other alternate case scenarios that were evaluated, produce outcomes that do not affect off-site receptors. 
4.  The general accidental release prevention program and specific prevention steps: 
The facility developed prevention program elements based on the Federal EPAs Accidental Release Prevention Plan, and OSHAs Process Safety Management (PSM) regulation.  This facility was designed and constructed to comply with applicable state and industry codes. 
5.  Five-year accident history: 
There have been no accidents involving or accidental releases of hydrogen in the past five years, that resulted in any deaths, injuries or significant property damage on site or known off site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. 
6.  The emergency response program: 
The facilitys emergency response program is based upon OSHAs HA 
ZWOPER standard.  At this site, employees are trained to recognize emergencies and initiate emergency response from outside agencies.  They have been trained to OSHAs First Responder Awareness Level.  The employees receive annual refresher training in their role in the emergency plan.  Emergency response activities have been coordinated with the Marlborough Fire Department for fires related to the hydrogen process.  Periodic drills will be conducted with this agency to review the effectiveness of our emergency procedures. 
7.  Planned changes to improve safety: 
The facility resolves recommendations from PHA's and Incident Investigations, some of which may result in modifications to the plant design and operating procedures.
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