Arkansas Eastman Division - Executive Summary

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Eastman Chemical Company, Arkansas Eastman Division: Executive Summary 
Accidental Release Prevention and Response Policies 
Arkansas Eastman, located on a 2200 acre site near Batesville, Arkansas, is a manufacturing division of Eastman Chemical Company.  Arkansas Eastman is a manufacturer of specialty organic chemical intermediates that are used by Eastman's customers in a variety of consumer products ranging from paints and coatings, to prescription medicines, to household detergents.  Arkansas Eastman has RMP regulated flammables consisting of acetaldehyde, ethyl mercaptan, and propylene.  In addition, the facility uses chlorine, crotonaldehyde, oleum, and anhydrous hydrogen chloride, which are RMP regulated toxic substances.  
Arkansas Eastman has a long-standing history of protecting the health and safety of employees, the community, and the environment.  This is evidenced through over 20 years of safe operations and excellent environmental stewardship, through our commitment to th 
e principles of Responsible Care., and through our recognition by OSHA as a "STAR" site in OSHA's Voluntary Protection Program.  To protect people, property, and the environment, we use multiple systems-or layers of protection-where one system is designed to backup another system.  The first layer involves accident prevention by identifying and reducing risks during the design and before startup of new manufacturing processes.  The second layer involves operating and mantaining equipment and processes in a manner that reduces risks and minimizes incidents.  The third layer involves maintaining the capability to respond to and control incidents in a timely manner. 
Hazard Assessment Results 
All covered processes at Arkansas Eastman are regulated as Program 3. 
The worst case scenario associated with the release of a flammable substance at Arkansas Eastman is a vapor cloud explosion involving the full storage tank of propylene (1-propene). Per the Hazard Assessment Guidelines there are  
no off-site consequences associated with this scenario.  
The alternative release scenario for flammable substances at Arkansas Eastman is a vapor cloud explosion resulting from the release of propylene from a 2-inch discharge line. There are no off-site consequences associated with this scenario. To reduce the potential for an incident, several layers of protection are in place to minimize the effects of both the worst case and alternative case propylene scenarios.  These layers of protection include: 1) a water deluge system that provides fire protection for the unloading station and storage tanks, 2) an emergency shutdown switch in the control room, 3) enclosures around the tanks to contain any spills, and 4) sensors to detect any leaks.  
The worst case scenario associated with toxic substance processes at Arkansas Eastman is the instantaneous release of the entire contents of a railcar of chlorine.  There are numerous controls in place that minimize the potential for such an incid 
ent and also to manage consequences if one should occur.  However, no credit for these controls is taken into account in evaluating this scenario.  When such controls are not considered, the effects of this scenario could have an off-site impact based on EPAs OCA Guidence (RMP Comp Ver 1.06). 
The alternative release scenario for chlorine is a failure of the one-inch discharge line between the emergency discharge shutdown valve and the chlorine weigh tank that supplies the production facility. There are no off-site consequences associated with this scenario. Several layers of protection are in place to reduce the potential for and to minimize the effects of both the worst case and alternate case chlorine scenarios.  Some of these layers of protection include: 1) perimeter sensors around the chlorine unloading station which activate alarms and emergency shutoffs, 2) a special discharge shutoff valve that limits the total amount of chlorine released, 3) excess flow valves that stop flow  
in case of a broken line, 4) control room emergency shutdown switches, 5) a caustic scrubber to vent chlorine during emergencies, 6) no bottom drain on chlorine railcars, 7) protected access storage area for chlorine railcars,  8) procedures for exchanging railcars only in daylight hours when maximum number of emergency response personnel are available,  9) welded piping joints to minimize potential leak locations, 10) no bottom drain on chlorine weigh tanks, 11) apprentice trained unloading personnel and 12)  Hazmat teams and equipment on-site. 
The alternate release scenario for crotonaldehyde is a 2-inch leak in the railcar unloading line. There are no off-site consequences associated with this scenario.  Several layers of protection are in place to reduce the potential for and to minimize the effects of this scenario.  Some of these layers of protection include: 1) no bottom drain on railcars, 2) emergency shutdown switches in each control room, 3) trained bulk handling operators w 
ho unload all railcars, 4) a regenerative thermal oxidizer to handle vented vapors from the railcars and the storage tank, 5) catch pans under each railcar that contain and direct any leaks to the facilities waste treatment system, 6) special railcar fittings that minimize leak potential, and 7) above ground, buried tank is in a contained area. 
The alternate release scenario for oleum is a 2-inch leak in a storage tank line. There are no off-site consequences associated with this scenario. Several layers of protection are in place to reduce the potential for and to minimize the effects of this scenario.  Some of these layers of protection include: 1) no bottom drains on railcars, 2) emergency shutdown switches in each control room, 3) trained bulk handling operators unload all railcars, 4) a specially designed venting system that vents vapors from the railcar directly to the storage tank, 5) catch pans under each railcar that contain and direct any leaks to the facilities waste treatm 
ent system, 6) a concrete containment area around the storage tank to retain any possible leaks, 7) a vent scrubber system to prevent vapors from escaping from the storage tank into the atmosphere. 
The alternate release scenario for anhydrous hydrogen chloride is a blown rupture disk.  There are no off-site consequences associated with this scenario. Several layers of protection are in place to reduce the potential for and to minimize the effects of this scenario.  Some of these layers of protection include: 1) protected access around the transfer manifold, 2) a water deluge system, 3) an emergency shutdown switch in each control room, 4) effective dispersion of vented vapors from pressure relief devices, 5) automatic shutdown when pressure relief devices are activated, 6) welded piping to minimize leak potential, 7) a specially designed manifold that minimizes pressure surges to avoid venting of pressure relief devices. 
Five Year Accident History 
Arkansas Eastman is committed to a g 
oal of providing a workplace that is free of accidents.  Our record over the last 5 years indicates good progress toward that goal.  There has been one incident involving a RPM chemical with only minor on-site effects.  There have been zero incidents with off-site effects.  Arkansas Eastman is an OSHA VPP STAR site. 
General Accident Release Prevention Program Steps 
The following is a summary of the general accident prevention program in place at Arkansas Eastman.  Because processes at Arkansas Eastman that are regulated by the EPA RMP regulation are also subject to the OSHA PSM standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. 
Employee Participation 
Arkansas Eastman has management systems in place which meet the requirements of RMP and ensure full employee participation.   Employees participate as members the Safety Key Result Area Team or one of its several subteams.  The Safety K 
RA Team is part of Arkansas Eastman's Total Quality Management Process.  The purpose of the team is to assess and ensure that the company's safety processes and initiatives support its vision of a work place free of unsafe acts, behaviors and conditions. 
Arkansas Eastman encourages employees to participate in all facets of process safety management and accident prevention.  Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team.  Employees have access to extensive information created as part of Arkansas Eastman's accident prevention program.  Specific ways that employees are involved in the accident prevention program are documented in employee participation plans that address each accident prevention program element.  In addition, Arkansas Eastman has a number of initiatives underway that address process and employee safety issues.  These initiatives include 
a program entitled "Employee Development System for Safety".  Each employee works with his immediate supervisor to determine individual and specific opportunities for improving safety performance.  Another initiative is Arkansas Eastman's Safety Concerns Process which is a process for reporting safety concerns and ensuring that such concerns are addressed promptly.  A third initiative is called the Arkansas Safety Awareness Process, a program where employees make random observations of their co-workers to help identify and eliminate at-risk behaviors.. Additionally, Arkansas Eastman participates in OSHA's Voluntary Protection Program (VPP) to supplement its efforts for employee participation. The VPP lists guidelines for employee participation.   
Process Safety Information 
Arkansas Eastman keeps a variety of technical documents that are used to help maintain safe operation of the processes.  These documents address chemical properties and associated hazards, limits for key process pa 
rameters and specific chemical inventories, and equipment design information.  This information is normally compiled in a Process Safety Information (PSI) binder. The PSI and referenced documents are readily available to employees as part of the employee participation plan. 
Process Hazard Analysis 
Arkansas Eastman has a comprehensive Process Hazard Analysis (PHA) program to help ensure that hazards associated with the various processes are identified and controlled.  Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards before the manufacturing process begins. 
Arkansas Eastman uses a PHA technique that is appropriate to the complexity of the process being studied.  There are four techniques in use at Arkansas Eastman.  These are Check List, What If, What If-Check List, and Hazard and Operability Analysis.  The analyses are conducted using a team of people who have operating, maintenance, 
chemical, and engineering expertise and experience.  This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures. 
Implementation of mitigation options in response to PHA findings is based on the relative risk rankings assigned by the PHA Team.  These rankings help ensure  accident scenarios assigned the highest risk receive immediate attention.  All approved mitigation options being implemented in response to PHA Team findings are tracked until they are complete.  The final resolution of each finding is documented and retained for the life of the process. 
All processes undergo a revalidation PHA at least every five years as long as the process is active. 
Operating Procedures 
Arkansas Eastman maintains written procedures that address various modes of process operations, such as: 1) unit startup, 2) normal operations, 3) temporary operations, 4) emergency shutdown, 5) normal shutdown, 6) initial startup of a new process.  These pro 
cedures are used as a reference by experienced operators and provide the basis for consistent training of new operators. The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the Management of Change Process.  Department Superintendents certify these procedures annually as accurate.  The Process Safety Review Committee reviews them at least every five years.   
To compliment written procedures for process operations, Arkansas Eastman has implemented a comprehensive training program for all employees involved in operating a process.  Each new employee receives basic training in department operations.  After successfully completing this training, a new operator is provided training on process-specific duties and tasks.  This is done through an operator apprentice program or by pairing the new operator with an experienced operator for an appropriate period of time.  After operators demonstrate (e.g., through tests, skill  
demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they may work independently.  Refresher training is conducted at least every 3 years.  Training is documented for each operator, including the means used to verify that the operator understood the training. 
Arkansas Eastman uses contractors to supplement its construction, maintenance and related services workforce.  Because some contractors work on or near process equipment, Arkansas Eastman has procedures in place to provide contractors information on the hazards in their work area.  In addition, Arkansas Eastman has a process for the selection of contractors and evaluation of their safety performance. 
Pre-startup Safety Reviews (PSSRs) 
Arkansas Eastman conducts a PSSR for any new process, new facility or facility modification that requires a change in the process safety information.  The purpose of a PSSR is to ensure safety features, procedures, personnel, and equipm 
ent are appropriately prepared for startup.  This review provides one additional check to make sure construction is in accordance with the design specifications and supporting systems are operationally ready.  
Mechanical Integrity 
Arkansas Eastman has well established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition.  The basic aspects of this program include: 1) conducting training, 2) developing written procedures, 3) performing inspections and tests, 4) correcting identified deficiencies, and 5) applying quality assurance measures.  In combination, these activities form a system that maintains the mechanical integrity of the process equipment. 
Safe Work Practices 
Arkansas Eastman has long-standing, documented safe work practices in place to help ensure worker and process safety.  Examples of these include: 1) control of the entry/presence/exi 
t of support personnel, 2) lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, 3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, 4) a permit and procedure to control spark-producing activities (i.e., hot work), and 5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space.  These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. 
Management of Change (MOC) 
Arkansas Eastman has a comprehensive system to manage changes to processes.  This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), operating procedures, and other facility changes be properly reviewed and authorized before being implemented.  Changes are reviewed to ensure that adequate controls  
are in place to manage any new hazards and verify that existing controls have not been compromised by the change.  Affected chemical hazard information, process operating limits, and equipment information, as well as procedures are updated to incorporate these changes.  In addition, operating, maintenance, and contractor personnel are provided  necessary training on the change. 
Incident Investigation 
Arkansas Eastman promptly investigates all incidents that result in, or reasonably could result in; fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury.  The goal of each investigation is to determine the root cause and develop corrective actions to prevent a recurrence of the incident or a similar incident.  The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to company management.  Corrective actions are implemented in response to the investigation team's findings and are 
tracked until they are complete.  The final resolution of each finding or recommendation is documented and the investigation results are reviewed with employees and contractors who could be affected by the findings. 
Compliance Audits 
To help ensure the process safety program is functioning properly, Arkansas Eastman conducts compliance audits at least every three years to determine whether the required procedures and practices are being implemented.  A specialized team from an outside source conducts these compliance audits.  Audit findings are forwarded to company management for resolution.  Corrective actions taken in response to the audit team's findings are tracked until they are complete.  The final resolution of each finding is documented, and the two most recent audit reports are retained. 
In addition to the PSM required audits, Arkansas Eastman conducts numerous internal safety inspections and assessments. 
Chemical Specific Prevention Steps 
The accident prevention program  
summarized previously is applied to all Arkansas Eastman processes, not just RMP covered processes.  Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by either equipment or human failures. 
Arkansas Eastman also has safety features on processing units to help: 1) quickly detect a release, 2) contain and control a release, and 3) reduce the consequences of a release.  Some examples of safety features that compose the layers of protection at Arkansas Eastman are gas detectors/analyzers, relief valves, scrubbers, automatic shutdown systems and containment areas. 
Emergency Response Program Information 
The overall emergency response program for Arkansas Eastman is coordinated with the Independence County Local Emergency Planning Committee (LEPC).  The LEPC includes local emergency response officials, local government officials, and industry representatives.  The committee meets regularly to develop community emergency response 
plans and to conduct community-wide drills.  Arkansas Eastman has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations.  This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident.  Arkansas Eastman also conducts its own periodic emergency drills that involve the LEPC and/or emergency response organizations.  Arkansas Eastman provides annual refresher training (more frequently if necessary) to local emergency responders regarding the hazards of regulated substances at Arkansas Eastman.  
Arkansas Eastman has a written emergency response program in place to protect employees, contractors, the public, and the environment.  The program consists of procedures for responding to a release of a regulated or non-regulated substance.  The procedures address the aspects of emergency response, including proper first-aid and medical treatment for exposures, evacuation  
plans, accounting for personnel after the evacuation, notification of local emergency response agencies and the public if a release occurs, and the post incident cleanup and decontamination requirements.  In addition, Arkansas Eastman has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment.  Employees receive training on these procedures as necessary to perform their specific emergency response duties.  The emergency response program is updated when necessary based on modifications made to Arkansas Eastman processes or other company facilities.  
Planned Changes to Improve Safety 
Arkansas Eastman resolves all findings from PHAs, some of which result in modifications to the process.  The following changes are underway at Arkansas Eastman because of the many safety processes: 
1.  Computerization of the remaining Manufacturing Control Rooms. 
2.  Emphasis of Personal Safe 
ty Accountability through the Company's Employee Development System. 
3.  Upgrade of Material Handling System for Hydrogen Peroxide.
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