Eastman Chemical Company, Texas Eastman Division - Executive Summary |
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Eastman Chemical Company Texas Eastman Division, Longview Plant Site Executive Summary I. Accidental Release Prevention and Emergency Response Policies Texas Eastman Division's accidental release and emergency response policies are summarized in our company "Principles of Safety" Document: "Eastman will conduct all aspects of its business in a manner that provides for the safety of employees, contractors, communities, customers, and the environment." Our safety process consists of 5 main steps: * Hazard identification, prevention and control * Safe design and construction * Safety and health education and training * Employee involvement, accountability, and responsibility * Systematic evaluation for continual improvement Details of our accident prevention efforts are contained in the Texas Eastman Division General Operating Procedures, the Texas Eastman Authorized Safe Practice Manual and the Standard Operating Procedures of each production unit. These documents specify practi ces and procedures to help ensure the safety of our employees, our contractors, our community, and the environment. Details of Texas Eastman Division's emergency response efforts are contained in the above documents as well as the Texas Eastman Emergency Plan. This plan specifies the responsibilities and duties of Eastman personnel during emergencies and potential emergencies. These responsibilities and duties provide for the prompt mobilization of the Company's resources, including both personnel and equipment in an emergency situation. These plans are updated routinely, and are periodically reviewed in their entirety. II. Description of Stationary Source and Regulated Substances Handled Stationary Source Description Eastman Chemical Company is a leading international chemical company that produces more than 400 chemicals, fibers, and plastics. Founded in 1920 in Kingsport, Tennessee, as a unit of Eastman Kodak Company, Eastman Chemical Company was spun off in 1994 and is no w an independent, publicly held company traded on the New York Stock Exchange (ticker symbol EMN). Eastman has approximately 5300 customers worldwide and posted 1998 sales of $4.48 billion. With corporate headquarters in Kingsport, Eastman employs 16,100 people in more than 30 countries. The Texas Eastman Division of Eastman Chemical Company has its main plant facility located on a 6000-acre site in Harrison County near Longview, Texas. From its beginning in 1950, Texas Eastman has grown into one of the largest petrochemical plants in Texas. The Texas Eastman plant site includes Huntsman Corporation's polypropylene unit within its plant boundaries. The polypropylene unit was purchased from Eastman Chemical Company in 1994. The polypropylene unit is integrated into the Texas Eastman Division safety and emergency response practices and processes and is considered part of the Texas Eastman plant site for purposes of compliance with this regulation. The Texas Eastman plantsite purcha ses propane, ethane and natural gas for its principal raw materials. From these raw materials, Texas Eastman manufactures over 40 different chemical intermediates, solvents, coatings, resins and plastics. No consumer items are made directly at Texas Eastman. Instead, the Texas Eastman and Huntsman products are supplied to industrial customers for use in the manufacture of hundreds of consumer items which enhance the quality of life of millions of people worldwide. These products include automobile interiors, paints, tires, food preservatives, adhesives, furniture, cosmetics, pharmaceutical products, disposable baby diapers, food packaging, toys, soft drink bottles, floor polish and waxes, printing inks, latex paint, fiberglass, fabric and many other consumer and industrial products. Regulated Substances Description Texas Eastman Division's Longview site uses and processes a number of flammable gases and liquids such as acetaldehyde, ethylene, and natural gasoline (a mixture conta ining pentane) listed in 40 CFR Section 68.130 in quantities above the threshold limit. In addition, Texas Eastman has seven toxic substances listed in 40 CFR Section 68.130 in quantities above the threshold limit. These are anhydrous ammonia, aqueous ammonia (30%), chlorine, ethylene oxide, formaldehyde solution, isobutyronitrile and titanium tetrachloride Flammable Gases and Liquids Basic Information: Texas Eastman Division uses flammable gases and liquids in many of its operations. Three examples of flammables used include acetaldehyde, natural gasoline and ethylene. Acetaldehyde is a colorless gas with a pungent choking odor. Natural gasoline is a colorless volatile liquid with a petroleum-like odor. Ethylene is a colorless gas with a sweet odor. All three of these materials are extremely flammable. Leaks of these materials can ignite and create a flash fire or a vapor cloud explosion. Uses: Texas Eastman Division produces acetaldehyde for sale to outside customers who co nvert it into other chemicals found in common household items such as aspirin, mustard, ketchup, dill pickles and Vitamin B-12. Natural gasoline is used as one of the basic feedstocks for the Texas Eastman plant site. Ethylene is produced by Texas Eastman and is used as one of the basic building blocks for most of the other chemicals produced at Texas Eastman Division Anhydrous Ammonia Basic Information: Anhydrous ammonia is a clear, colorless gas with a sharp, intensely irritating odor. The vapors are irritating to the eyes and respiratory tract. Contact with the liquid can cause frostbite. Long-term exposure to low concentrations or short-term exposure to high concentrations can result in adverse health affects from inhalation. It is soluble in water, forming a corrosive liquid. Gaseous ammonia is lighter than air, but vapors from a leak may initially hug the ground. Ammonia gas is normally not considered a serious fire hazard, but at high enough concentration and under the right conditions, it can ignite and burn. Uses: Texas Eastman Division uses anhydrous ammonia as a refrigerant and as a process feed to produce chemical intermediates commonly used in the manufacture of lawn insecticides. Aqueous ammonia (30%) Basic Information: Aqueous ammonia (30%) is a mixture of 30% ammonia and 70% water. It is a clear, colorless liquid with a sharp, irritating odor. The vapors are irritating to the eyes and respiratory tract. Long-term exposure to low concentrations or short-term exposure to high concentrations of ammonia can result in adverse health affects from inhalation. Ammonia vapor coming from the ammonia/water solution is lighter than air, but vapors from a leak may initially hug the ground. Ammonia vapor is normally not considered a serious fire hazard, but at high enough concentration and under the right conditions, it can ignite and burn. Uses: Texas Eastman Division uses aqueous ammonia (30%) as a nutrient for wastewater treatment. Chlor ine Basic Information: Chlorine is a greenish yellow gas with a sharp, irritating, bleach like odor. At low concentrations chlorine becomes colorless but it retains its characteristic odor. It is commonly used to purify water, and to make other chemicals. Long term exposure to low concentrations or short-term exposure to high concentrations may result in adverse health effects from inhalation. In high enough concentrations, chlorine will cause severe irritation to the eyes, coughing, and breathing difficulty. Chlorine does not burn but will support combustion (lets other articles burn). The vapors are much heavier than air and tend to settle in low areas. Uses: Texas Eastman Division uses chlorine primarily for water treatment. A small amount is utilized to produce chemicals used by others in the manufacture of photographic film, fingernail polish remover, inks, pharmaceuticals, and coatings. Ethylene Oxide Basic Information: Ethylene oxide is a clear, colorless, volatile li quid with an ether-like odor. It is commonly used by the chemical industry to make other chemicals and by hospitals to sterilize equipment. The vapors are irritating to the eyes, skin, and respiratory system. Prolonged contact with the skin may result in a chemical burn. Ethylene oxide is soluble in water and extremely flammable. The vapors are much heavier than air and tend to settle in low areas. Uses: Texas Eastman Division produces ethylene oxide as an intermediate in the production of other chemicals including ethylene glycol. Ethylene glycol is used as antifreeze and in the manufacture of PET plastic used in the manufacture of soft drink bottles and other food packaging. A portion of the ethylene oxide produced is converted to chemicals used in the manufacture of coatings and inks. All the ethylene oxide produced at Texas Eastman is used internally. None is shipped outside the plant. Formaldehyde Solution Basic Information: Formaldehyde solution is a colorless solutio n of formaldehyde gas in water. It is totally soluble in water. Its vapors are heavier than air. Formaldehyde is a lacrymator causing eye irritation and tearing of the eyes. Vapors can only be withstood for a few minutes. Long-term exposure to low concentrations or short-term exposure to high concentrations can result in adverse health effects from inhalation. Breathing is difficult in low concentrations, accompanied by cough and severe burning to the nose and throat. Uses: Texas Eastman receives formaldehyde as a 50% solution in water in tank trucks and railcars. It is used as a feedstock to manufacture a product that is used in many consumer items. These include fiberglass shower stalls and boat hulls, imitation marble counter tops and environmentally friendly paints and coatings. Isobutyronitrile Basic Information: Isobutyronitrile is a clear, colorless liquid with a distinct bitter odor resembling almonds. Its rate of evaporation into the atmosphere is about like wa ter. Isobutyronitrile can enter the body by skin contact with the liquid or by inhalation of the vapors. Exposure to liquid or vapor may produce symptoms similar to that of carbon monoxide. This includes dizziness, nausea, vomiting, confusion, and general weakness. Prolonged or high exposure may cause tightness in the chest and breathing difficulty. These effects may be delayed by 30 minutes to one hour after exposure. Uses: Texas Eastman manufactures isobutyronitrile for sale to outside customers. It is used primarily in the manufacture of lawn pesticides. Titanium Tetrachloride Basic Information: Titanium Tetrachloride is a heavy liquid with a yellowish color and a sharp, pungent odor. It is commonly used to make other chemicals. Titanium tetrachloride reacts with water or atmospheric moisture to produce a white cloud of titanium oxide (a pigment used in white paint) and hydrochloric acid vapors. Long-term exposure to low concentrations of hydrochloric acid or short-term exposure to high concentrations of hydrochloric acid may result in adverse health effects from inhalation. In high enough concentrations, the hydrochloric acid may cause severe irritation to the eyes, coughing, and breathing difficulty. Uses: Texas Eastman Division receives titanium tetrachloride in 250-gallon cylinders. It is used in the manufacture of polyethylene plastic. Polyethylene is used in many common items including toys, food containers, automobiles, and garbage bags. III. Worst Case Release Scenarios and Alternative Release Scenarios Toxic Substance Worst Case Scenario Ethylene oxide constitutes the Longview plant site's toxic worst case scenario. In this scenario, the largest vessel containing ethylene oxide was assumed to catastrophically rupture. It was assumed that the entire tank contents evaporated into the atmosphere over a ten-minute period. It was further assumed that all of the active safety systems in place to mitigate and reduce the amount of vapor s in the atmosphere also failed. Under worst case weather conditions this scenario shows potential off-site consequences. Flammable Substance Worst Case Scenarios Natural gasoline constitutes one of the Longview plant site's flammable worst case scenario for the north end of the plant site. In this scenario, the largest vessel containing natural gasoline was assumed to catastrophically rupture and the entire contents immediately vaporized. It was also assumed that all of the safety systems in place to mitigate and reduce the amount of vapor in the atmosphere and prevent ignition also failed. It was assumed that the vapor cloud ignited and exploded. This scenario shows potential off-site consequences. Acetaldehyde constitutes the worst case scenario for the south end of the Longview plant site. In this scenario, the largest vessel containing acetaldehyde was assumed to catastrophically rupture and the entire contents immediately vaporized. It was also assumed that all of the safety systems in place to mitigate and reduce the amount of vapor in the atmosphere and prevent ignition also failed. It was assumed that the vapor cloud ignited and exploded. This scenario shows potential off-site consequences. Toxic Substance Alternate Release Scenarios For each of the seven toxic substances at the Longview site, an alternate release or emergency planning scenario was estimated. Of the seven, only four showed the potential for off-site consequences that could possibly affect people or a designated receptor. The assumed alternate release scenario for anhydrous ammonia was a hypothetical rupture of the 1 1/2 inch liquid transfer hose. The assumed alternate release scenario for chlorine was the hypothetical failure of the 1/2 inch vapor valve on a one-ton chlorine cylinder. The assumed alternate case scenario for all other toxic substances was assume to be the rupture of a 2 inch connection to the largest vessel containing the substance in question. Flammabl e Substance Alternate Release Scenario For flammable substances at the Longview site, an alternate release or emergency planning scenario was estimated. The assumed alternate release scenario was the rupture of a 2-inch pipe in the high pressure Polyethylene Unit. It was assumed that all of the ethylene between the two emergency shutoff valves leaked to the atmosphere, ignited and exploded. This scenario shows potential off-site consequences. IV. General Accidental Release Prevention Program and Chemical Specific Prevention Steps Texas Eastman Division utilizes a "layers of protection" approach to protect people and the environment. This approach includes, but is not limited to the following elements: Designing For Safety * Storage tanks, vessels, and equipment are designed and constructed to strict industry and government standards. * Process design and operations are analyzed for safety prior to their installation, and periodically thereafter, in accordance with the requir ements of OSHA's Process Safety Management standard. * Control systems and instruments provide continuous monitoring of operating conditions and alarm operators of upset conditions. * Emergency shutdown systems automatically shut down operations to a safe state if emergency conditions develop. * Area and equipment are protected by automatic deluge systems to cool the equipment in the event of a fire and disperse flammable or toxic vapors in the event of leaks. * Combustible gas monitors are installed in critical locations to sound an alarm and turn on the deluge systems in the event of leaks. * Remotely operated isolation valves are installed in critical locations to allow quick shutdown and isolation of leaks. * Storage tanks and process equipment including chlorine cylinders are equipped with pressure relief devices to prevent rupture. * Anhydrous Ammonia storage tanks are equipped with excess flow valves and check valves which automatically stop flow in the event of large leaks. * Anhydrous Ammonia gas detectors are installed in critical locations which sound an alarm and turn on the deluge systems if a leak were to occur. * Chlorine cylinders are ruggedly designed and DOT approved. * A protective cap covers chlorine cylinder and titanium tetrachloride cylinder valves at all times when the cylinders are not in use. * Special chlorine regulators are used which automatically shut off the flow of chlorine if a pipe breaks. * Many of the chlorine cylinders are located adjacent to cooling towers. If a leak were to occur, the chlorine gas would be drawn into the cooling tower where it would mix with a large amount of air and discharge high into the atmosphere, significantly reducing the chance of harmful concentrations near the ground. * Chlorine gas detectors are installed in critical locations which sound an alarm if a leak were to occur. Operating Safely * Operators, mechanics, and contractor personnel are trained and qualified in accordance with Occupationa l Safety and Health Administration (OHSA) regulations. * Standard written operating procedures are developed and used by operations personnel. * Anydrous Ammonia is received in dedicated trailers to minimize the risk of contamination. * Chlorine cylinders are unloaded and handled by special equipment designed specifically for cylinder handling. * Chlorine cylinders are stored and used away from flammable liquids and gases. * Two trained people follow established written procedures to connect or disconnect a chlorine cylinder. These people wear safety equipment which would allow them to safely remain and possibly close the cylinder valve if a leak occurred while changing out the cylinder. * Ethylene oxide is not shipped to customers outside Texas Eastman Division. * Ethylene oxide is not handled in open or portable containers. Maintaining Safe Operations/Auditing our Operations * Storage tanks, vessels, and equipment are inspected on a regular basis. * Numerous mechanical integrity a nd preventative maintenance programs are in place to ensure that equipment is in sound working condition. These include an extensive piping and equipment corrosion and vibration inspection and correction program. * Anhydrous Ammonia unloading hoses are replaced on a routine basis regardless of condition * Valves and connections are visually inspected each time a chlorine cylinder is changed * New gaskets are used each time a chlorine cylinder is connected * Chlorine cylinders are inspected on a routine basis and are approved by the Department of Transportation * Both internal and corporate audits are conducted on a regular schedule to help ensure compliance with company safety procedures and regulations * OSHA is invited into the Texas Eastman Division plantsite periodically to conduct VPP inspections to continue Texas Eastman's designation as an OSHA VPP Star Site. Training * Operators are initially trained on the specifics of the process they will be running. Refresher training is supplied at least every three years. * New Operators and Maintenance Mechanics take an extensive apprenticeship-training program. This program covers seven crafts and is registered by the U.S. Department of Labor. Each trainee completes 525 to 950 hours of related instruction and another 500 to 1,000 of on-the-job training, depending on the craft. * Contract employees are required to have OSHA mandated training prior to performing work at Texas Eastman. In addition, Texas Eastman provides a site-specific contractor Safety and Health orientation for all contractors employed at the work site. In addition to the above elements, the Texas Eastman Division of Eastman Chemical Company is an OSHA Volunteer Star site in the federal OSHA Voluntary Protection Program (VPP). VPP is a cooperative program between employers and OSHA to improve worker safety and recognize outstanding safety performance and programs. Texas Eastman Division is one of fewer than 400 sites nationwide to quali fy for Star status. To maintain Star status Texas Eastman Division must meet specific safety performance measures and pass an OSHA VPP inspection every few years. V. Five Year Accident History In the five years previous to the submission of this report, the Texas Eastman Division plant site and the Huntsman Corporation polypropylene unit have had no RMP reportable incidents. VI. Emergency Response Program Texas Eastman Division maintains a comprehensive site emergency response plan. Employees train annually on the plan as they prepare for a plantwide drill. Key elements of the emergency response plan as it relates to community emergency response include, but are not limited to, the following: * Texas Eastman maintains an emergency response team whose members are specially trained and equipped to respond to all types of emergencies such as leaks, spills, fires, etc. * Eastman emergency response personnel use a computerized modeling system to predict the concentration and locati on of any vapor cloud resulting from a hazardous vapor release using real time weather information. * Response is coordinated with emergency response agencies in the community via a Field Command Post and the Eastman emergency operations center. * Eastman maintains a community emergency notification plan. For events which might impact the community, a direct line to the Gregg County sheriff's office dispatcher is utilized. The Gregg County sheriff's office then notifies the City of Longview and Harrison County sheriff's office. * Emergency response personnel are regularly trained to comply with all federal, state, and local requirements. * A community telephone emergency notification system is available to provide quick, concise emergency information to Eastman near neighbors if an event were to occur that could affect them. * Texas Eastman serves on and gives significant support to both the Gregg County and the Harrison County LEPCs * Texas Eastman hosts the Northeast Texas Fire Sch ool where local municipal and volunteer fire fighters from throughout the area receive both classroom and hands-on training for hazardous materials response. VII. Planned Changes to Improve Safety Improvement plans fall into three primary areas: Hazard Analysis-Continual identification of potential hazards, and prompt implementation of corrective action are done in accordance with applicable regulations and as a matter of company policy Incident Investigation-Prompt, thorough investigation of all significant incidents and near-misses are conducted and learnings are shared across the company. Benchmarking-Through our trade association, the Chemical Manufacturers' Association, and through other cooperative efforts, such as the Center for Chemical Process Safety, we continually evaluate our safety programs and processes against the best in the world, with the goal of continual improvement. |