Air Products, New Orleans HCL Plant - Executive Summary

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Executive Summary 
Air Products and Chemicals, Inc. 
New Orleans, Louisiana Hydrogen Chloride Plant 
Louisiana LDEQ Facility Identification Number 30592 
1.  Accidental release prevention and emergency response policies: 
At this facility, we transfill anhydrous hydrogen chloride.  The hydrogen chloride, in amounts handled by our facility, are considered hazardous by the EPA.  It is our policy to adhere to all applicable Federal and state rules and regulations.  Air Products manages the safety of the regulated process by means of operating procedures, equipment testing and inspections, safety devices (e.g., alarms, shutdowns, instrumentation, and 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 supplements the inherent safe design of the plant. 
Our emergency response program is based upon OSHAs HAZWOPER regulation.  The emergency re 
sponse plan includes procedures for the notification of the local fire authority and Hazardous Materials unit. 
This document has been prepared in accordance with EPAs 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 the transfilling of anhydrous hydrogen chloride.  The hydrogen chloride is brought on site by railcar.  From the railcar, the regulated substance is transferred through a series of heat exchangers and pumps to the tube trailers and cylinders.  Also, tube trailers and cylinder storage of hydrogen chloride are maintained. 
The regulated substance handled at this facility is the anhydrous hydrogen chloride.  The maximum amount of this substance contained in the transfill process is 360,00 pounds of anhydrous  
hydrogen chloride. 
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 EPA, associated with anhydrous hydrogen chloride is a catastrophic failure in the hydrogen chloride railcar.  The entire anhydrous chloride inventory of 160,000 pounds is assumed to be released and to vaporize. The maximum distance to the EPA defined toxic endpoint of ERG-2 for this WCS reaches receptors off-site.  Although we have other "active mitigation" systems directed at preventing such releases and controlling the consequences, no credit for active mitigation measures were taken into account in evaluating this WCS. 
The "alternative case scenario" (ACS) for the anhydrous hydrogen chloride is failure of the relief devices located on the tube of the tube trailer, resulting in a release of 3,000 pounds of anhydrous hydrogen chlori 
de over a 10 minute period.  The maximum distance to the EPA defined toxic endpoint of ERPG-2 for this ACS reaches receptors off-site. 
4.  The general accidental release prevention program and specific prevention steps: 
The facility complies with the Federal EPAs Accidental Release Prevention Plan, and OSHAs Process Safety Management (PSM) regulation.  The design and construction of the facility complies with applicable state and industry codes. 
5.  Five-year accident history: 
This facility came on line in 1995.  There have been no accidents involving or accidental releases of toxic substance 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 facilitys emergency response program is based upon OSHAs HAZWOPER standard.  At this site, employees are trained to recognize emergencies and initiate emergenc 
y response from outside agencies.  They have been trained to OSHAs Specialist or Technician Level.  The employees receive annual refresher training in their role in the emergency plan.  Emergency response activities have also been coordinated with the New Orleans Fire Department and its Hazmat Team for releases related to the toxic process.  Periodic drills are conducted with these agencies to review the effectiveness of our emergency procedures.  
7.  Planned changes to improve safety: 
This facility resolves recommendations from PHAs and Incident Investigations, some of which may result in modifications to the plant design and operating procedures.
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