Air Products, Gallatin - Executive Summary

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Executive Summary 
 
 
Air Products and Chemicals, Inc. 
Gallatin Tennessee, Hydrogen Facility 
 
 
1.  Accidental release prevention and emergency response policies: 
 
At this facility, we manufacture gaseous hydrogen.  Hydrogen, in the amounts handled by our facility, exceeds the threshold quantity set by EPA.  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 release 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 authori 
ty and Hazardous Materials unit so that appropriate measures can be taken by local 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 is to manufacture hydrogen gas.  Hydrogen is used by our customer in their manufacturing process.  Natural gas is received by our plant via pipeline and used as our feedstock.  The feed stock is mixed with steam and sent to the reformer furnace.  In the reformer furnace, the feedstock and steam are heated in the presence of a catalyst to approximately 1500 degrees F, where a chemical reaction takes place that converts the mixture into hydrogen, carbon monoxide, and carbon dioxide.  The carb 
on monoxide and carbon dioxide are then separated from the hydrogen in adsorbers.  The pure hydrogen is then delivered to the customer via our pipeline.   Backup is provided by two storage tanks; (1) 20,000 gallon and (1) 15,000 gallon liquid hydrogen tank(s).  The regulated process at this facility is the hydrogen production (reformer) plant and the backup system. 
 
Hydrogen is the only regulated substance handled at this facility in an amount exceeding the threshold quantity.  The combined maximum amount of hydrogen and hydrogen-containing flammable mixtures at this facility is 21,660 pounds. 
 
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, is a catastrophic failure of the liquid hydrogen storage tank, releasing all 20,000 gallons (12,000 pounds) of liquid hydrogen which is assumed to form  
a vapor cloud and ignite resulting in a vapor cloud explosion (VCE).  The maximum distance to the EPA-defined endpoint (1 psi overpressure) for this WCS reaches receptors off site.  Although we have active controls directed at preventing such releases no credit for active or passive mitigation measures were taken into account in evaluating this WCS. 
 
The "alternative case scenario" (ACS) is a liquid hydrogen transfer line breaks by trailer pull-way while still connected.  The flow area of the break results in a flow rate equal to 20% of the full-bore (guillotine break) flow rate.  Liquid hydrogen is assumed to flow from the tank continuously, forming a steady-state vapor cloud.  All of the liquid hydrogen released (7900 pounds) is assumed to vaporize quickly without producing any appreciable liquid pool.  The vapor cloud formed is presumed to find a source of ignition resulting in a vapor cloud fire or flash fire. The maximum distance to the EPA-defined endpoint (the lower flammable li 
mit of 4% hydrogen in air) for this event reaches receptors off site.  No preventive controls, or active or passive mitigation measures were accounted for in evaluating this ACS.  
 
 
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 came on line in June of 1999. In the last five years 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 Hoeganeaes Security and Safety Department for fires related to the flammable process.  Periodic drills are conducted to review the effectiveness of our emergency procedures.   
 
7.  Planned changes to improve safety: 
 
This facility was constructed in 1999.
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