Huntsman Polymers Corporation - Odessa Facility - Executive Summary

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1.  Accidental release prevention and emergency response policies.  Huntsman Odessa is committed to providing a safe, healthy and environmentally conscious work place for its employees and neighbors.  This is exemplified by the Odessa site having earned the Texas Chemical Council award for excellence in safety performance.  The Huntsman Odessa site maintains a working PSM program, which implements a series of steps to prevent potential hazards associated with the process and assures a well-trained work force.   The PSM program further implements its policies with onsite procedures and manuals.  Huntsman Odessa participates with community agencies to develop emergency response plans and participates in cooperative training with these agencies.  Since its certification in January 1993, the Odessa Site has been an active participant in the International Standards Organization (ISO) 9002 quality management program. 
The Odessa site is subject to numerous safety and environmental regulation 
s at both the state and federal levels.  The Odessa site is subject to Clear Air Act (CAA) Title V, but has not yet received an identifier for the air operating permit. 
2.  Regulated Substances Huntsman's Odessa site is located in Odessa, Texas.  The Odessa site operates six Program Level 3 processes.  These processes receive, handle and store flammable hydrocarbon feedstocks for the production of olefins, styrene monomer and specialty grade polymers.  End uses for the products include medical and personal care products, electronic cable coatings, adhesives and sealants as well as boat and vehicle trims.  Huntsman's Odessa site has large volumes of several regulated flammable substances, such as ethane, ethylene, propane, propylene, butene and butane.  The Odessa site uses small volumes of toxic chemicals, which are consumed in the process.  The toxic chemicals are:     
-  Boron Trifluoride - Used in the manufacture of styrene monomer. 
-  Hydrogen Chloride - Used in the manufacture of p 
-  Chlorine - Used for microbiological control in cooling tower water. 
-  Vinyl Acetate - Used as a co-monomer in the manufacture of polyethylene. 
3.  Offsite Consequence Analysis   
The RMP Rule requires that offsite consequence analysis (OCA) be performed to estimate the potential for an accidental release of a regulated substance to affect the public or the environment.  This OCA includes the development of worst and alternative release scenarios for the release of toxic and flammable substances.  The OCA allows for the consideration of administrative controls in estimating potential scenario impacts.   
Distances for worst case and alternative release scenarios in this RMP have been calculated using the methods described in EPA's OCA Guidance Document.  The population within the circles defined by these distances has been calculated using the Landview III program.  For release scenarios where there are no public residences inside the circle, the reported population is 
These worst case scenarios are based on EPA required assumptions, are highly unlikely, and have not occurred at this facility. 
The worst case scenario associated with the release of flammable substances is a vapor cloud explosion (VCE), involving an underground hydrocarbon storage well (#9).  The well stores Y-grade, a mixture of light hydrocarbons, principally, ethane, propane and butane.  As the storage well is 2,000 feet underground, the worst case release is an above ground piping failure rather than the loss of the entire inventory of the well.  The selected release scenario is a situation that completely shears off the well head.  The casing annulus tubing then telescopes into the bottom of the well.  The analysis assumes that all of the material released in a 10 minute period vaporizes and ignites, resulting in a vapor cloud explosion.  The basis for using a 10 minute release from a piping failure instead of the entire underground hydrocarbo 
n storage well's contents is given in the preamble to the RMP rule and in the American Petroleum Institute's (API) standard API 760, "Model Risk management Plan Guidance for Petroleum Refineries - Guidance for Complying with EPA's RMP Rule."  Using these conservative assumptions, 1,800,000 pounds of hydrocarbons are released.  The VCE would reach offsite and may affect nearby public receptors, but no environmental receptors. 
The worst case scenario associated with toxic substances is the failure of a single tube of boron trifluoride held on a 6-tube trailer.  The entire tube contents, 3,500 lbs are released over a 10 minute period.  This worst case scenario has the potential to affect public receptors, but no environmental receptors. 
The alternative case scenarios used in this RMP do not take credit for existing safety systems and process controls, thus making them extremely conservative.  The one active mitigation measure considered is isolation  
of releases after 10 to 20 minutes. 
The alternative case scenario for flammable substances is a complete seal failure on the LPG Pump (P-55C) in the Utilities area.  This alternative case scenario would reach offsite but would not affect public or environmental receptors. 
The alternative case scenario for boron trifluoride is from a failure of the < inch inside diameter tubing which connects the tube trailer to the process.  In this scenario, 3,300 lbs of boron trifluoride are estimated to be released.  The release continues for 20 minutes until isolated by operations.  No credit is taken for the water spray system that has been recently installed to protect against this specific scenario.  This alternative case scenario has the potential to affect one industrial neighbor.  However, it does not impact the public or the environment. 
The alternative case scenario for anhydrous hydrogen chloride is a vapor release from a failure of the < inch piping off the 600-pound cylinder, resultin 
g in the release of 410 pounds of hydrogen chloride.  The release continues for 10 minutes until isolated by operations.  This alternative case scenario does not affect the public or the environment.  However, one industrial neighbor is impacted.  
The alternative case scenario for chlorine is a release of vapor from a failure of the 3/8 inch tubing off a 1 ton container of chlorine resulting in the release of 210 pounds of chlorine.  The release continues for 10 minutes until isolated by operations.  This alternative case scenario does not affect the public.  However, one or more industrial neighbors are impacted by chlorine releases from two of the six processes.  No environmental receptors are affected.  
The alternative case scenario for vinyl chloride is a pump seal failure on the pump used for unloading vinyl acetate from a truck into a storage tank. For this scenario, 2,400 pounds of vinyl acetate is released.  The release forms a pool that slowly evaporates.  This alternative c 
ase scenario does not affect public or environmental receptors.  However, one industrial neighbor is impacted. 
4.   General accidental release prevention program and chemical specific prevention steps. Following is a brief summary of the elements that Huntsman's Odessa site has implemented to comply with the accidental release prevention requirements outlined by EPA as well as with the Occupational Health and Safety Administration (OSHA) process safety management (PSM) standard.   
Huntsman's Odessa site maintains a compilation of current and accurate written safety information to identify and understand the hazards of the process.  This includes information pertaining to: 
-  Hazards of regulated substances:  For each regulated substance, there is a Material Safety Data Sheet (MSDS) which discusses the physical properties of the chemicals, exposure hazards, the required personal protective equipment and the appropriate first aid and emergency treatment for  
-  The technology of the process:  Includes a discussion of process chemistry, safe upper and lower limits of temperature and pressure and analysis of consequences of deviation. 
-  Equipment in the process:  Includes such information as materials of construction, diagrams of the piping and instrumentation, safety systems and design codes. 
Huntsman's Odessa site has performed process hazard analysis on each process to identify the potential hazards, the adequacy of the engineering and administrative controls and the ways to minimize those hazards.  The Odessa site utilizes the HAZOP and What-if/Checklist methodologies, recognized and generally accepted methods for identifying and evaluating hazards in the process.  The Odessa site assigns employees to the HAZOP team who are knowledgeable in the HAZOP methodology and the specific process.  The HAZOP team develops recommendations to reduce the potential hazards which, if approved, are implemented withi 
n a reasonable period of time. 
Huntsman Odessa maintains written operating procedures that were developed by the operators to provide clear instructions for safely conducting activities associated with a covered process.  The procedures address steps for all operating phases, safety systems, control measures and precautions to prevent exposures to process hazards.  The procedures are reviewed and revised periodically to ensure their accuracy and completeness. 
Huntsman Odessa provides initial training as well as refresher training to employees to assure that the required level of skills and knowledge are maintained.  The training emphasizes safety and health hazards, emergency operations, and safe work practices.  All operators receive periodic refresher training. 
Huntsman Odessa has developed written procedures for maintaining the operating components of the process (including pressure vessels, storage tanks, piping systems, reli 
ef and vent systems, emergency shutdown system controls, and pumps) through the mechanical integrity program.  The program is comprised of well-trained personnel who follow maintenance, testing and inspection procedures that ensure proper function of process equipment. 
Huntsman Odessa has established and implemented written procedures to manage changes to process chemicals, technology, equipment, procedures, and any changes to the facility that affect a covered process.  The procedures assure that, prior to any change, the following issues are considered: the technical basis for the proposed change, its impact on safety and health, any modifications to operating procedures, the necessary time period for the change, and any authorization requirements.  Employees involved in operating a process, as well as maintenance and contract employees whose job will be affected, are informed of and trained in the change.  If necessary, the process safety information and opera 
ting procedures are updated.   
Huntsman Odessa performs pre-startup safety reviews when the addition of or a modification to the facility is made that is significant enough to require a change in the process safety information.  The pre-startup safety review confirms, prior to the introduction of highly hazardous chemicals, that construction and equipment is in accordance with design specifications; safety, operating, maintenance and emergency procedures are in place; management-of-change requirements are met; and training of employees affected by modifications is complete. 
Huntsman Odessa performs audits of its compliance with the provisions of its process safety management program.  Teams comprised of employees, with appropriate knowledge of audit techniques, process safety and operating experience, conduct audits every three years to verify that the procedures and practices developed are adequate and being followed.  The findings of the audit  
team are reviewed and appropriate corrective actions are implemented and tracked until resolved. 
Huntsman Odessa investigates any incidents that resulted in, or could reasonably have resulted in, a catastrophic release of covered chemicals.  The investigation is promptly conducted, commencing within 48 hours of any incident.  To perform the investigation, Huntsman Odessa utilizes a team consisting of persons with the appropriate knowledge and experience to thoroughly investigate and analyze the incident.  A report is prepared at the conclusion of the incident investigation that addresses the incident, the factors that contributed to it, and recommendations resulting from the incident investigation.  Huntsman Odessa has established a system to promptly address and resolve the incident report findings and recommendations and to document their resolution.  Finally, incident reports are reviewed with all affected personnel. 
Huntsman Odessa  
has developed a written action plan for employee participation in all aspects of its process safety management program.  Huntsman Odessa consults with employees on the conduct and development of PHA's and on the development of other elements of the process safety management program.  Huntsman Odessa ensures that all employees have access to PHA's and all other process safety management information. 
Huntsman Odessa employs a hot work permit program for hot work operations conducted on or near a covered process (hot work generally involves electric or gas welding, cutting, brazing or similar spark-producing operations).  If any hot work is performed near a covered process, Huntsman Odessa issues a permit that documents the fire prevention and protection requirements for the operation, the date authorized for hot work, and the object on which the work is performed.  Hot work permits are kept on file until the work is complete.   
Huntsman Odessa has develope 
d procedures for selecting and ensuring that contractors are competent and knowledgeable and can safely perform their work.  Huntsman Odessa provides information to them about the hazards that may be present in the work area and has developed appropriate safe work practices.  Huntsman Odessa also evaluates the safety performance and programs of the contractors as a part of their continued employment. 
5.    5 Year Accident History 
Huntsman Odessa has no accidental releases to report for the 5-Year Accident History that resulted in on-site deaths, injuries or significant property damage or known off-site deaths, injuries, evacuation, shelter in place, property damage or environmental damage. 
6.   Emergency Response Program.  Huntsman Odessa has a written emergency response program that contains procedures to be followed in the case of an accidental release.  These procedures include steps for informing local emergency response agencies and the public and ensuring the correct use of  
emergency equipment with properly trained emergency response personnel.  In addition, Huntsman Odessa provides training to its emergency response employees who perform emergency response duties and to local emergency responders who may be called on to assist in emergency response.  Huntsman Odessa actively coordinates emergency response activities with local officials and groups.  Huntsman Odessa participates with the Odessa Mutual Aid (OMA) organization and the Ector County Local Emergency Planning Committee (LEPC) to develop emergency response procedures that identify resources, chemicals, contacts and material safety data sheets for participating companies.  Other community activities include cooperative training between the Odessa site and the Odessa Fire Department as well as making available equipment, technical information and supplies for county mutual aid.  The emergency response plan and its procedures are reviewed periodically and updated as necessary.  Likewise the emergenc 
y response equipment is maintained, tested and inspected periodically. 
7. Planned changes to improve safety.  Huntsman Odessa has an on-going commitment to improve safety and protect the environment.  In addition to frequently scheduled internal company audits and inspections, the site undergoes an annual self-evaluation as part of the Chemical Manufacturers' Association (CMA) Responsible Care process safety code.  Improving safety is an evergreen process at Huntsman, and a number of significant safety improvements have been made.  Recent safety improvements include: 
-  Routing additional Pressure Safety Valves to a flare system 
-  Installation of additional gas detection systems 
-  Installation of distributed control systems 
-  Installation of additional Automatic Emergency Isolation Valves 
The following health, safety and environmental improvements are anticipated during the next five years: 
-  The addition or a pressurized brine system for the underground hydrocarbon storage wel 
-  Upgrade of additional pumps in the Olefin area to tandem seal design 
-  Upgrade of existing flare systems 
-  Improvements to the fire water distribution system 
-  Upgrades to existing fire fighting equipment
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