Praxair - Niagara Falls, NY - Executive Summary

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The Praxair facility at Niagara Falls, New York is a hydrogen purification plant.  We receive hydrogen gas as a byproduct from nearby chemical plants.  Normally, this hydrogen gas is burned or vented to the atmosphere, but it is collected and transferred to our facility via pipeline.  In our production process, the hydrogen gas is cooled and compressed to remove moisture and other contaminants.  The hydrogen gas is then liquefied using a high-speed turbine process.  The final cryogenic liquid hydrogen product is stored in our insulated storage tanks, and is shipped by truck to customers throughout the northeast.  Hydrogen is listed as a regulated flammable substance in EPA's Risk Management Program rule, with a threshold quantity of 10,000 pounds.  The production and storage process at the Niagara Falls plant contains about 472,000 pounds of hydrogen, and is therefore subject to the RMP rule. 
Under the RMP rule, Praxair is required to report a Worst Case Scenario for the Niagara Falls 
plant, which is defined by the EPA as the release of the entire contents of the largest hydrogen vessel in our process, with essentially none of the safety systems and devices that are in place to prevent such an occurrence functioning as designed.  The release is assumed to ignite, causing a vapor cloud explosion.  Given these conditions, we are then required to estimate the distance to an EPA-specified flammable endpoint, which is defined to be an overpressurization effect of 1 pound per square inch.  At the Niagara Falls facility, the largest hydrogen vessel contains about 236,000 pounds.  Using the criteria listed above, the Worst Case Scenario would result in a maximum impact distance of about 0.68 miles to the EPA-specified endpoint.  To determine this distance, we used the EPA's "Off-site Consequence Analysis Guidelines." 
We are also required to report an Alternative Release Scenario, or planning scenario, under the RMP rule.  While an Alternative Release may never occur at a  
facility, it is generally accepted to be more likely, or more credible, than the Worst Case Scenario, and can be used by the facility and local response organizations to plan community emergency response activities.  The RMP rule assumes more typical atmospheric and weather conditions for an Alternative Release Scenario, and allows a facility to take credit for safety devices and other mitigation systems that are in place to minimize the likelihood and effects of a release.  When selecting an Alternative Release Scenario, EPA suggests a facility consider scenarios such as transfer hose releases, valve and flange leaks, pump seal leaks, and shipping container mishaps, among others.  For the Niagara Falls hydrogen process, a credible release would be through a relief valve on a hydrogen storage tank, with the released hydrogen gas igniting and causing a small vapor cloud explosion.  At the Niagara Falls facility, a release of this type would result in a maximum impact distance of about 0 
.02 miles, or 115 feet.  To determine this distance, we used the EPA's "Off-site Consequence Analysis Guidelines." 
In accordance with OSHA's Process Safety Management standard and EPA's Risk Management Program rule, the Niagara Falls facility has a comprehensive accident prevention program in place to ensure the safety of our employees, our neighbors and the community around us.  On a local level, this prevention program is built around process safety concepts such as: 
7 Documented process safety information to ensure the process design is understood and maintained throughout its life; 
7 Process hazard analysis to identify and control all of the hazards associated with handling hydrogen; 
7 Trained operators, using written operating procedures, to safely operate the process as intended; and 
7 Maintenance programs and procedures to ensure the on-going mechanical integrity of the process. 
The prevention program is audited periodically, by our corporate assessment group, to ensure that  
the process safety concepts and practices are in place and working effectively. 
As a result of our process safety and risk management practices, the Niagara Falls facility has had very few accidents involving hydrogen in its long history, and none that have impacted the community.  In the event of an emergency, the facility has an emergency action plan in place, which contains procedures for employees to follow, including notification of local response agencies.  All facility employees are trained in their role in the emergency action plan, and Praxair policy requires that emergency drills be conducted at least annually. 
Praxair is committed to the continuous improvement of its safety, health and environmental programs. The company operates under an umbrella of global corporate policies with specific program elements defined on a regional basis. As the result of recent acquisitions, detailed process safety audits have been conducted at numerous facilities throughout the company. As w 
e ensure the process safety integrity of our facilities, we are also fine tuning the incident and near miss reporting and investigation processes. Root Cause Analysis training is being targeted within the operations and safety organizations. On a broader scale, the effectiveness, and accessibility of training is being improved. A computerized compliance management system keeps track of plant progress meeting internal and external requirements. 
Praxair is a producer and distributor of industrial gases with almost 100 years of experience.  We are committed to being the best performing industrial gas company in all aspects of our business, including safety, health and environmental affairs.  Praxair is a member the Chemical Manufacturers Association's Responsible Care initiative, which is intended to ensure the safe operation of chemical facilities and enhance the relationships between the chemical industry and the communities in which we operate.  Internally, we use a combination of ext 
ensive engineering standards and design safety work processes, coupled with operational and personnel safety programs, to ensure the safe operation of all of our facilities.  Our company-wide goal of "Zero/Zero" (which means zero accidents and zero injuries or illnesses at every location) reflects the dedication and commitment to safety throughout the entire Praxair organization.
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