Air Products, Port Arthur - Executive Summary |
|
Federal RMP Executive Summary Air Products and Chemicals, Inc. Port Arthur, Texas Hydrogen Facility 1. Accidental release prevention and emergency response policies: At this facility, we manufacture gaseous hydrogen. Flammable gases containing hydrogen and methane 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 and/or consumed 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, as well as other controls and systems designed to prevent accidental releases of hazardous chemicals. Safe work practices and training of our personnel supplement the inh erent 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 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 this facility to manufacture of gaseous hydrogen and electrical power for export to customers. Steam is also produced as a by-product of process waste heat recovery, which is also exported to a customer. The Hydrogen is used primarily by our refinery customers to manufacture "clean fuels." The stationary source is best d escribed in the following three (3) operating units: 1.) Steam Methane Reformer (SMR) /Pressure Swing Adsorption (PSA) unit: A high-pressure hydrocarbon based gas (natural gas) is received by our plant via pipeline and used as a feedstock and reformer furnace fuel. The feedstock is processed in four basic process steps: (1) feedstock pre-heat and desulfurization, (2) stream-methane reforming, (3) water-gas shift conversion, and (4) PSA product purification. The pure hydrogen is compressed and delivered to customers via our pipeline network. Steam is produced by waste heat recovery of the hot process gases, and is used for internal plant use as well as export to a refinery customer. 2.) Gas Turbine Generating unit: Pre-heated natural gas fuel is flowed to the gas turbine and combusted, and the resultant energy is used to drive a generator to make electrical power. The power is used for internal plant use as well as export to a refinery customer. Gas turbine exhaust is ducted to t he steam methane reformer furnace and used as pre-heated combustion air. 3.) Spill Gas Pressure Swing Adsorption (PSA) unit: A hydrogen rich offgas is received from a refinery customer, and is conditioned and processed through a PSA unit to separate the hydrogen from the impurities (purgegas). The hydrogen and purgegas are then compressed and exported back to the refinery customer is separate streams. The regulated substance handled at this facility is the flammable gas mixture. The maximum amount of this substance at this facility is 48,000 pounds of flammable gas containing hydrogen and methane. 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" (WCS), as defined by the EPA, associated with a release of flammable substances in the hydrogen process at this facility is a vapor cloud explosion (VCE) involving a maximum inventory of a SMR PSA vessel containing a flammable mixture. A full SMR PSA Absorber vessel inventory of 16,000 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 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 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 the Spill Gas PSA Absorber vessel due to hydrogen sulfide stress corrosion cracking. The inventory of 655 pounds of a flammable mixture is assumed to be released. The maximum distance to the EPA defined endpoint (the lower flammability limit of 4% flammable mixture in air) for this ACS reaches a neighboring o il refinery (Premcor), 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 recognize 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 Premcor Fire Brigade and the Port Arthur Fire Department 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 Hazard Analysis (PHAs) and Incident Investigations, some of which may result in modifications to the plant design and operating procedures. Plant equipment changes require the completion of Management of Change documentation and operator training in accordance with company procedures and PSM requirements. |