Air Products, Geismar SSU Plant - Executive Summary

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Executive Summary 
Air Products and Chemicals, Inc. 
Geismar, LA Syngas Separation Unit 
Louisiana LDEQ Facility Identification Number 30073 
1.  Accidental release prevention and emergency response policies: 
At this facility, we produce gaseous hydrogen and carbon monoxide in the "Syngas Separation Unit".  Flammable gases containing hydrogen, methane, and ethane are present in the process in concentrations and amounts which cause the process to be covered by the EPA RMP regulation.  Other chemicals are produced in processes which are not covered by the RMP regulation. 
It is our policy to adhere to all applicable Federal and state rules and regulations.  Air Products manages the safety of the regulated processes 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 chemical 
s.  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 procedures for the notification of the local fire authority and Hazardous Materials unit 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 substances handled: 
The primary purpose of the covered process located at this facility is the production and purification of gaseous hydrogen and gaseous carbon monoxide.  These gases are used by our customers to manufacture other chemicals. 
A gaseous mixture is recei 
ved by our plant via pipeline.  This gas contains hydrogen and carbon monoxide, but the hydrogen and carbon monoxide are mixed with methane, ethane, and other impurities.  The gas is subjected to a series of steps to remove some of the impurities.  The hydrogen and carbon monoxide are then separated from each other and from the remaining impurities in a "cold box", which purifies the products by cryogenic distillation.  The product gases are compressed and delivered to customers via our pipeline network.  A portion of the product gases are also shipped in over-the-road vehicles. 
This process contains 65,000 lbs of flammable gas in mixtures which have in them 1% or more by weight of hydrogen, methane, or ethane. 
3.  The worst-case release scenario(s) and the alternative release scenario(s), including administrative controls and mitigation measures to limit the distance for each reported scenario: 
The "worst-case scenario" defined by the EPA for flammable substances is a vapor cloud e 
xplosion (VCE).  The entire inventory of a cryogenic distillation column, 8,100 pounds, is assumed to be released and ignited, resulting in a VCE.  The maximum distance to the EPA defined endpoint (1 psi overpressure) for this WCS reaches public receptors.  Although we have active controls directed at preventing such releases and controlling the consequences, no credit for active mitigation measures were taken into account in evaluating this WCS. 
The "alternative case scenario" (ACS)  for flammable substance at this facility is a flash fire resulting from the release of hydrogen from a pipe located near the "cold box".  Up to 8,800 lbs. of flammable gas could be released.  The maximum distance to the EPA defined flammable endpoint of 100% LFL (Low Flammability Limit) for this ACS reaches public receptors.  
4.  The general accidental release prevention program and specific prevention steps: 
The facility developed prevention program elements  based on the Federal EPAs Accidental Rele 
ase 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: 
This facility is new.  There have been no accidents involving or accidental releases of flammable gas 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 HAZWOPER 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 also been coordinated with the Ascension Volunteer Fire Department for fir 
es related to the flammable process.  Periodic drills are to be conducted with agencies to review the effectiveness of our emergency procedures.   
7.  Planned changes to improve safety: 
The facility resolves recommendations from PHAs and Incident Investigations, some of which may result in modifications to the plant design and operating procedures.
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