Air Products, Cleveland OH - Executive Summary |
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Executive Summary Air Products and Chemicals, Inc. Cleveland, Ohio Facility 1. Accidental release prevention and emergency response policies: At this facility, we manufacture gases used in steel making. The annealing gas manufacturing processes use ammonia and hydrogen. Both ammonia, and hydrogen, in the amounts handled by our facility, exceed the threshold quantities 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 OSHAs HAZWOPER regulation. The emerg ency 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 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: One of the main products of this facility is a gaseous mixture of hydrogen and nitrogen in a 3:1 ratio. This "annealing gas" is used by our customer in their steel manufacturing process. Two different manufacturing processes are used by this facility to produce this gas mixture. In the first process, liquid anhydrous ammonia is vaporized and "dissociated" or split into its constituent three parts hydrogen and one part nitrogen in a heated catalytic reactor. In the second process, pure hydrogen and nitrogen gas are blended together in the proper ratio to form the annealing gas. The pure nitrogen gas is produced onsite in an air separation unit. The annealing gas is delivered via pipeline to the nearby steel mill. Liquid anhydrous ammonia is stored onsite in a single tank. The tank is capable of holding 45,000 gallons but is administratively controlled to never exceed an inventory of 10,000 gallons. The liquid ammonia is delivered to the site by tank truck. The liquid ammonia is vaporized by electric vaporizers located beneath the tank, and the gaseous ammonia is piped to the dissociation reactors. Pure liquid hydrogen is stored in two 20,000 gallons tanks. The liquid hydrogen is delivered to the site by tank truck. The liquid hydrogen is vaporized by ambient air vaporizers located adjacent to the tanks, and gaseous hydrogen is piped to the blending process. Gaseous hydrogen is also used onsite in the argon pur ification process, and as a backup gas for the steel mill in the event that annealing gas is unavailable. The regulated processes at this facility are the ammonia storage and dissociation system, and the liquid hydrogen storage, blend skid, and pipeline backup system. Ammonia and hydrogen are the only regulated substances handled at this facility in an amount exceeding a threshold quantity. The maximum amount of ammonia at this facility is 53,000 pounds. The maximum amount of hydrogen at this facility is 24,000 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 toxics "worst-case scenario" (WCS), as defined by the EPA, is a catastrophic failure of the anhydrous ammonia storage tank releasing all 10,000 gallons plus the gas in the vapor space (53,000 pounds) over a ten minute period. The maximum distance to the EPA-defined endpoint (0.14 mg/L or 200 ppm) for this WCS reaches receptors offsite. 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 toxics "alternative case scenario" (ACS) is a break in, or sudden uncoupling of, the transfer hose from an ammonia tank truck while filling the storage tank. Liquid ammonia is assumed to flow from the hose at a rate of 1600 lbs/min for 2 minutes. The ammonia vaporizes to form a cloud which reaches receptors offsite. The EPA-defined endpoint is 0.14 mg/L (200 ppm) for this event. No passive mitigation measures were taken into account in evaluating this ACS. The pump speed control limit (active mitigation) was taken into account. The flammables "worst-case scenario" (WCS), as defined by the EPA, is a catastrophic failure of one of the liquid hydrogen storage tanks, releasing all 20,000 gallons (11,820 pounds) of liquid hydrogen which is assume d 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 offsite. 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 flammables "alternative case scenario" (ACS) is a break in the 1< inch liquid line to the pressure buildup 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 release is expected to continue until the tank (holding, on average, about 13,333 gallons of liquid hydrogen) is drained. The vapor cloud formed is presumed to find a source o f ignition resulting in a vapor cloud explosion . The maximum distance to the EPA-defined endpoint (1 psi overpressure) for this event reaches receptors offsite. 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 EPAs Accidental Release Prevention Plan and OSHAs Process Safety Management (PSM) regulation. This facility was designed and constructed to comply with applicable state and industry codes. 5. Five-year accident history: 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. There have been two (2) small, brief (essent ially puff) releases of ammonia from the trailer hose due to inadequate emptying and purging of the hose after filling the storage tank. These releases were not EPA reportable quantities, however they resulted in evacuation of our nearest industrial neighbor. No injuries, property damage or environmental damage occurred. 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 emergency response from the LEPC and outside agencies. They have been trained to OSHAs 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 Cleveland 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: Th e second liquid hydrogen storage tank was installed in 1998. At this time, there are no major administrative, operational, process, or equipment changes planned for this facility. |