Air Products, Butler, IN - Executive Summary

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Executive Summary 
Air Products and Chemicals, Inc. 
Butler, Indiana Facility 
1.  Accidental release prevention and emergency response policies: 
This facility is predominantly an air separation plant producing pure liquid and gaseous nitrogen, liquid and gaseous oxygen, and liquid argon through the liquefaction and distillation of air.  Hydrogen is stored onsite in liquid form and vaporized for use in the argon purification process.  Gaseous hydrogen is also supplied as a product to our customer, Steel Dynamics, Inc., for use in steel making.  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 s 
ystems 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 authority 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 industrial gases and to supply our customer with oxygen, argon, and hydrogen gas.  The hydrogen is supplied from a liquid hydrogen storag 
e system consisting of a 20,000 gallon liquid hydrogen tank and a bank of ambient air vaporizers.  The liquid hydrogen is delivered to our site by tank truck, and the gaseous hydrogen is delivered to our customer by pipeline.  
The regulated process at this facility is the liquid hydrogen storage system and associated gaseous hydrogen piping.  
Hydrogen is the only  regulated substance handled at this facility in an amount exceeding the threshold quantity.  The maximum amount of hydrogen at this facility is 12,000 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 (11,820 pounds) of liquid hydrogen which is assumed to form a vapor cloud and ignite resulting in a vapor cloud explosion (VCE).  The m 
aximum 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 partial or crushing break in the 1? inch liquid line to the tank?s pressure build-up coil. 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 (7880 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 flash fire .  The release is expected to continue until the tank (holding, on average, about 13,333 gallons of liquid hydrogen) is drained.  The maximum distance to th 
e EPA-defined endpoint (the lower flammable limit of 4% hydrogen in air) for this event reaches off site receptors.  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: 
The liquid hydrogen tank was installed in April, 1997.  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 Butler Fire Department and 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 Butler Fire 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:
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