Air Products, Baytown - Executive Summary |
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Federal RMP Executive Summary Air Products and Chemicals, Inc. Baytown, TX Syngas Separation Rectisol Unit 1. Accidental release prevention and emergency response policies: At this facility, we produce gaseous hydrogen and carbon monoxide in the "Rectisol Syngas Separation Unit". Flammable gases containing hydrogen and propylene 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 chemicals. Safe work practices and training of our personnel supplement the inherent safe design of the plant. Our emergency response program is based upon OSHA?s HAZWOPER regulation. The emergency response plan includes procedures for the notification of the local fire authority and Baytown LEPC so that appropriate measures can be taken by local emergency responders to control accidental releases. This document has been prepared in accordance with the EPA?s 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 received by our plant via an aboveground pipe line from a neighboring oil refinery (Exxon) gasifier. This gas already contains hydrogen and carbon monoxide, but the hydrogen and carbon monoxide are mixed with methane, ethane, carbon dioxide and hydrogen sulfide 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 methane impurity in a "cold box", which purifies the products by cryogenic distillation. The product gases are compressed and delivered to customers via our underground pipeline network. This process contains 183,000 pounds of flammable material. Most of this is gaseous mixtures which have in them 1% or more by weight of hydrogen. Of the 183,000 pounds of flammable material, propylene comprises 59,700 pounds which is used as a closed loop refrigeration system. 3. The worst-case release scenario and the alternative release scenario, including administrative controls and mitigation measures to limit the distance for each reported scenario: The "worst-case scenario" (WCS) defined by the EPA for flammable substances is a vapor cloud explosion (VCE). The entire gaseous inventory of the Absorber column, 44,100 pounds, is assumed to be released and ignite, resulting in a VCE. The maximum distance to the EPA defined endpoint (1 psi overpressure) for this WCS will reach public receptors off site. 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 in accordance with EPA guidelines. The "alternative case scenario" (ACS) for flammable substance at this facility is a flash fire resulting from the release of a flammable gas mixture from the failure of part of a manway on the Absorber column. The inventory of 7280 pounds is assumed to be released. The maximum distance to the EPA defined end point (the lower flammability limit of 6.1% flammable mixture in air) for this ACS reaches a neighboring oil refinery (Exxon), identified as a major industrial area in the EPA guidelines. 4. The general accidental release prevention program and specific prevention steps: The facility developed prevention program elements based on the Federal EPA?s Accidental Release Prevention Plan, and OSHA?s 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 facility?s emergency response program is based upon OSHA?s HAZWOPER standard. At this site, employees are trained to recogniz e emergencies and initiate emergency response from outside agencies. They have been trained to OSHA?s 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 neighboring oil refinery (Exxon) for fires related to the flammable process. Periodic drills are conducted with agencies to review the effectiveness of our emergency procedures. 7. Planned changes to improve safety: The facility resolves recommendations from Process Hazards Analysis (PHAs) and Incident Investigations, some of which may result in modifications to the plant design and operating procedures. Plant equipment changes requires the completion of Management of Change documentation and operator training in accordance with company procedures and PSM requirements. |