Praxair - Whiting, IN - Executive Summary

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The Praxair facility at Whiting, Indiana is an industrial gas plant that produces, handles and/or stores the following substance that is regulated by the EPA's Risk Management Program rule, in excess of its threshold quantity: 
7 Hydrogen. 
The Whiting facility operates three hydrogen production units and a carbon dioxide purification plant.  In the hydrogen process, we react steam and methane (natural gas) to form hydrogen gas, which we then purify and distribute through a pipeline to nearby customers.  We also pump some of the hydrogen gas into tube trailers for delivery by truck.  In addition to the hydrogen gas that we produce on-site, we also have six cryogenic liquid hydrogen storage vessels that are connected to the pipeline, which supplement the hydrogen supply to our customer.  Hydrogen is listed as a regulated flammable substance in EPA's Risk Management Program rule, with a threshold quantity of 10,000 pounds.  The overall hydrogen production and storage process at the Whiti 
ng plant contains about 40,000 pounds of hydrogen, and is therefore subject to the RMP rule. 
Under the RMP rule, Praxair is required to report one Worst Case Scenario that represents all regulated flammable substances at the Whiting facility. For regulated flammable substances (hydrogen), the Worst Case Scenario is defined by the EPA as the release of the entire contents of the largest vessel in the process, with essentially none of the safety systems and devices that are in place to prevent such an occurrence functioning as designed.  The released gas is assumed to ignite, causing a vapor cloud explosion.  Given these conditions, we are then required to estimate the distance to an EPA-specified flammable endpoint, which is defined to be an overpressurization effect of 1 pound per square inch.  At the Whiting facility, the largest vessel containing a regulated flammable substance holds about 11,000 pounds of hydrogen.  Using the criteria listed above, the Worst Case Scenario would res 
ult in a maximum impact distance of about 0.25 miles to the EPA-specified endpoint.  To determine this distance, we used the Compressed Gas Association's "Risk Management Plan Guidance Document for Bulk Liquid Hydrogen Systems." 
We are also required to report an Alternative Release Scenario, or planning scenario, that represents all flammable substances on-site.  While an Alternative Release may never occur at a facility, it is generally accepted to be more likely, or more credible, than the Worst Case Scenario, and can be used by the facility and local response organizations to plan community emergency response activities.  The RMP rule assumes more typical atmospheric and weather conditions for an Alternative Release Scenario, and allows a facility to take credit for safety devices and other mitigation systems that are in place to minimize the likelihood and effects of a release.  When selecting an Alternative Release Scenario, EPA suggests a facility consider scenarios such as tran 
sfer hose releases, valve and flange leaks, pump seal leaks, and shipping container mishaps, among others. 
For the flammable processes at the Whiting facility, a credible release would be the failure of a liquid line on a cryogenic liquid hydrogen tank, with the released hydrogen gas igniting and causing a small vapor cloud explosion.  A release of this type would result in a maximum impact distance of about 0.1 miles, or 520 feet.  To determine this distance, we used the Compressed Gas Association's "Risk Management Plan Guidance Document for Bulk Liquid Hydrogen Systems." 
In accordance with OSHA's Process Safety Management standard and EPA's Risk Management Program rule, the Whiting facility has a comprehensive accident prevention program in place to ensure the safety of our employees, our neighbors and the community around us.  On a local level, this prevention program is built around process safety concepts such as: 
7 Documented process safety information to ensure the process d 
esign is understood and maintained throughout its life; 
7 Process hazard analysis to identify and control all of the hazards associated with handling toxic and flammable substances; 
7 Trained operators, using written operating procedures, to safely operate the process as intended; and 
7 Maintenance programs and procedures to ensure the on-going mechanical integrity of the process. 
The prevention program is audited periodically, by our corporate assessment group, to ensure that the process safety concepts and practices are in place and working effectively. 
As a result of our process safety and risk management practices, the Whiting facility has not had an accident involving hydrogen in the last five years.  In the event of an emergency, the facility has an emergency action plan in place, which contains procedures for employees to follow, including notification of local response agencies.  All facility employees are trained in their role in the emergency action plan, and Praxair policy 
requires that emergency drills be conducted at least annually. 
Praxair is committed to the continuous improvement of its safety, health and environmental programs. Due to recent expansions, the Whiting facility has upgraded its firewater system.  The facility has also enhanced its process alarm and shutdown system.  Additionally, the entire Whiting site is continuously monitored by camera from the control room to help ensure early detection of any safety or security hazards.  
Praxair is a producer and distributor of industrial gases with almost 100 years of experience.  We are committed to being the best performing industrial gas company in all aspects of our business, including safety, health and environmental affairs.  Praxair is a member the Chemical Manufacturers Association's Responsible Care initiative, which is intended to ensure the safe operation of chemical facilities and enhance the relationships between the chemical industry and the communities in which we operate.  Inte 
rnally, we use a combination of extensive engineering standards and design safety work processes, coupled with operational and personnel safety programs, to ensure the safe operation of all of our facilities.  Our company-wide goal of "Zero/Zero" (which means zero accidents and zero injuries or illnesses at every location) reflects the dedication and commitment to safety throughout the entire Praxair organization.
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