Air Products, Tulsa - Executive Summary |
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Executive Summary Air Products and Chemicals, Inc. Tulsa, Oklahoma 1. Accidental release prevention and emergency response policies: This facility is predominantly an air separation plant producing gaseous nitrogen through the liquefaction and distillation of air. Hydrogen is stored onsite in liquid form and vaporized for use by our customer, Ford Motor Company, in their glass production process. 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 process 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 s afe design of the plant. Our emergency response program is based upon OSHAs 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 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 to manufacture industrial gases and to supply our customer with nitrogen and hydrogen gas. The hydrogen is supplied from a liquid hydrogen storage system consisting of a 25,000 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 15,000 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 25,000 gallons (14,770 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 offsite. Although we have active controls directed at p reventing such releases, no credit for active or passive mitigation systems or measures was 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 tanks 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 (9850 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 16,700 gallons of liquid hydrogen) is drained. The maximum distance to the EPA-defined endpoint (the lower flammable limit of 4% hydrogen in air) for this event reaches receptors offsite. No preventive controls, or ac tive or passive mitigation systems or 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: The liquid hydrogen tank was installed in 1991. 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 facilitys emergency response program is based upon OSHAs HAZWOPER standard. At this site, employees are trained to recognize emergen cies and initiate emergency response from the Pryor, OK. facility 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 Tulsa 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: The facility resolves recommendations from PHAs and Incident Investigations, some of which may result in modifications to the plant design and operating procedures. |