Pratt & Whitney - Executive Summary

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PRATT & WHITNEY- JUPITER FACILITY 
RISK MANAGEMENT PLAN 
 
 
EXECUTIVE SUMMARY 
 
 
1. Corporate Prevention  and Emergency Response Approach 
 
United Technologies Corporation (UTC)-Pratt & Whitney is located at 17900 Beeline Highway (SR 710), Jupiter, Palm Beach County, Florida.  Pratt & Whitney requires each facility to develop and maintain accident prevention programs and an emergency response plan appropriate to the site.  Each site is also responsible for regulatory compliance issues that apply to the site.  Pratt & Whitney's corporate and division environmental and safety personnel provide assistance in training for site employees and in budgeting and procurement of safety and training services. 
 
Pratt & Whitney West Palm Beach has a very active Environmental, Health and Safety (EHS) program.  Continuous improvement of the EHS program and its effectiveness is one of the goals at the Pratt & Whitney West Palm Beach site.  Establishment of aggressive improvement goals for all EHS metrics ha 
ve lead to continued improvement in the EHS program performance at the site.  Performance against these goals is not just locally monitored but they are reviewed at the United Technologies Corporation level, the parent company of Pratt & Whitney.  Efforts are currently being made to achieve ISO 14001 certification for the site.  
 
Extensive EHS related training is conducted at the site so that employees and contractors are familiar with the correct operating procedures and necessary precautions to be taken.  This training includes discussion of and exercises in emergency response in case of a failure and release.  Additionally, Pratt & Whitney continually evaluates and reviews the hazards which exist on its West Palm Beach site.  As a hazard is identified, the necessary actions to eliminate or minimize the hazard are defined and implemented.  Whenever possible the hazard is eliminated by improved control or design, improved training of personnel, or even elimination of the process or ma 
terial which is the key component of the risk.  A good example of eliminating an identified hazard involved the use of gaseous chlorine.  The facility has its own potable water treatment plant which used gaseous chlorine to disinfect the water prior to use. The chlorine was used from one ton containers and ten or more containers were stored together to allow for rapid changeover when the supply cylinder was consumed.  Pratt & Whitney identified the usage of the gaseous chlorine as a potential hazard. In the event a cylinder failed there was a significant potential danger for site personnel and any near site population.  Although there was no history of this occurring at the site, the decision was made to eliminate the hazard.  To alleviate the hazard, a new purification system has been installed which uses a safe powdered chemical in place of the gaseous chlorine.  This has eliminated the need for gaseous chlorine on site and has therefor eliminated the hazard of a gaseous chlorine rel 
ease.  
 
The Pratt & Whitney WPB site EHS program not only looks at the daily operations and the actions of the employees on site but extends out into the community.  Community activities include participation in the Palm Beach County Pollution Prevention Coalition, the LEPC (Local Emergency Preparedness Committee), sponsorship and participation in the annual Palm Beach County Envirothon and other activities and assistance whenever possible. 
 
2. Description of Stationary Source 
 
Pratt & Whitney is a research and development facility that designs gas turbines and rocket engines for the Department of Defense and the National Aeronautics and Space Administration.  Gas turbine engine operations include engineering, manufacturing, and testing of prototype engines and parts.  Rocket engine operations include engineering, manufacturing, and testing prototype and commercial engines.  A Materials Laboratory that develops and tests materials supports both operations. 
 
The Pratt & Whitney facilit 
y has propane and hydrogen systems, which exceed the 10,000 lb. RMP threshold quantity.  The location and quantity of propane and hydrogen are described below: 
 
 
Chemical     
Location    Amount (lb)     
Stored condition 
            
Hydrogen    E6.5    53,190    Single vessel; liquid stored under pressure (65 psi) and refrigerated (-420 0F) 
   PSA    29,550    Single vessel; liquid stored under pressure (75 psi) and refrigerated (-420 0F) 
   E8    13,002    Single vessel; liquid stored under pressure (275 psi) and refrigerated (-420 0F) 
   E8    14,986    Single vessel; gas stored under pressure (9,900 psi)  
Propane    E8    27,300    Single vessel; gas stored under pressure (75 psi)  
 
For the purposes of this analysis the only propane vessel and the largest capacity hydrogen vessel in area E-6.5 and the vessel in area E-8 store under the highest pressure were chosen.  
 
3. Description of the Worst Case and Alternative Release Scenarios 
 
Propane: The Worst Case release scenario is the rupture of the propane vessel, releasing 27,300 lbs. of propa 
ne.  Under worst case weather conditions, the end point of an overpressure of 1 psia is 0.21 miles. 
 
The Alternative Release Scenario is characterized by a vapor cloud fire, where the emissions were assumed to be release through a 2 inch diameter opening due to a rupture resulting in a an assumed pressure of 264.7 psia. Vessel temperature was assumed to be at ambient and a Gas Factor of 22 was used based on information presented in the OCA Guidance document. Under normally expected whether conditions, the end point distances were evaluated assuming four scenarios: 
7 Vapor cloud fire using a lower flammability limit of 36 mg/L 
7 Boiling liquid evaporating explosion (BLEVE) using a radiant heat dose of 5 kW/m2. 
7 Pool fire 
7 Flash fire (vapor cloud explosion) 
 
The BLEVE scenario produced the longest end point of 0.23 miles. 
A worst case for the propane system indicated no off-site consequence from a complete failure of the propane storage tank. 
 
Hydrogen: For the hydrogen processes a wor 
st case analysis was done for the process containing the largest quantity of hydrogen located in Area E6.5 and the highest pressure vessel located in Area E-8, releasing 53,190 lbs. and 14,996 lbs of hydrogen, respectively.  Under worst case weather conditions, the end point of an overpressure of 1 psia is 0.40 miles for the E 6.5 vessel and 0.26 miles for the E-8 vessel.  
 
As an Alternative Release Scenario, hydrogen was assumed to be released during a vapor cloud explosion, similar to the worst case scenario analysis.  However, a yield factor of 3 percent instead of 10 percent factor used in the worst case analysis.  The yield factor corresponds to the amount of energy available that is assumed to contribute to the explosion. 
 
As another alternative analysis, hydrogen was considered to be released during a BLEVE.  For this assessment the entire amount of hydrogen was assumed to be released from Area E 6.5 and E-8. 
 
Under normally expected whether conditions, the end point distances f 
or the vapor cloud explosion and the BLEVE for area E 6.5 are 0.27 miles and 0.48 miles, respectively.  Since Area E 6.5 contains a sparkler system that can be considered as active mitigation, the end point distances for a vapor cloud explosion and a BLEVE are 0.18 and 0.23 miles, respectively.  
 
The worst case analysis for the failure of this system, resulting in a total release of the largest single hydrogen source, demonstrates no off-site consequences.  Due to the worst case release indicating no off-site consequences, worst case analysis of the other hydrogen processes were not conducted. 
 
4. Prevention Program 
 
This facility exceeds the hydrogen threshold quantity for the OSHA Process Safety Management (PSM) Standard, 1910.119, and is therefore subject to the PSM requirements.  Offsite consequence analysis for propane and hydrogen have no offsite impacts and in accordance with the RMP regulations, these processes are classified as Program 1 processes and as such, will not requir 
e Prevention Program under RMP. 
 
The RMP for the hydrogen processes includes a process safety management review, PSM, conducted on the hydrogen usage and storage operations.  The hydrogen is in gaseous or liquid form and is stored on site to be available during the frequent testing which occurs.  Hydrogen is the fuel used in the testing.  The PSM included an extensive review of the operating procedures, maintenance procedures and the processes themselves.  All hazards identified during this review have been addressed and changes in procedures and equipment have been made, where possible, to mitigate the hazard(s).  If a hazard could not be eliminated through procedure and equipment changes, engineering and/or administrative controls have been put into place to mitigate the hazard.   
 
The propane's use only as a boiler fuel also exempts this system from the PSM requirement.  With no regulatory requirement and due to the simplicity of the system, the propane system RMP does not include  
a PSM.  Both RMPs include, in addition to the review of operating and maintenance procedures and the processes, worst case analysis based on the failure of these processes resulting in a release.  
 
Pratt & Whitney has a number of programs and procedures in place to prevent accidental releases of materials from the site processes and how to respond to such release in the event they occur.   All of these programs and procedures have been incorporated into an Integrated Contingency Plan.  This integrated plan contains sections on: 
 
Section    Information Contained 
Response Management    Management of an emergency response 
General Response Guidelines    Guidelines to be followed during an emergency response 
Notification    What notifications to make and who to notify 
Emergency Contacts    Contacts to be called during an emergency for assistance, to put the emergency plan into effect and who to notify. 
Release Reporting    Reporting requirements when a release to the environment occurs 
Equipment and Supplies 
   Emergency equipment and supply locations and items 
Evacuation    How to conduct an evacuation of the site and, if ever necessary, surrounding areas 
Medical     Summary of medical support and mutual aid agreements which are available 
Oil & Petroleum Spills    Summary of actions to be taken in the event of an oil or petroleum spill.  A separate full action plan also exists for oil or petroleum spill response. 
 
 
 
5. Accident History 
 
The UTC-Pratt & Whitney Facility has had no accidental releases of propane or hydrogen in the past five years. 
 
6. Emergency Response Program 
 
The Pratt & Whitney Jupiter Facility has internal response capability in place.  The program complies with 29 CFR 1910.120.  The current plan has been coordinated with the City of West Palm Beach Fire Department and Hazardous Materials Response Team, and the Local Emergency Planning Committee.  Notification is made locally by dialing 911, and by notifying Florida State Warning Point at (800) 320-0519 or (904) 413-9911.
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