Huntsman Expandable Polymers Company, L.L.C. - Executive Summary |
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Summary of RMP Elements All of the information submitted to the USEPA is accurate as of March 31, 1999. 1. Accidental release prevention and emergency response policies. Huntsman Peru is committed to providing a safe, healthy and environmentally conscious work-place for its employees and neighbors. The Huntsman Peru facility 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 Peru coordinates all of the emergency response activities with the La Salle County LEPC, City of Peru Fire Department, and City of La Salle Fire Department. Huntsman assists local officials in the development of emergency procedures to identify resources, chemicals, contacts and material safety data sheets for participating companies. Other community activities include cooperative training between the Per u facility and the Illinois Valley Community Hospital (IVCH). Since its certification in November 1993, the Peru Site has been an active participant in the International Standards Organization (ISO) 9002 quality management program. 2. Regulated Substances. The Peru site manufactures polystyrene-based products consisting of two main process areas where expandable polystyrene (EPS) and performance resins (PR) are produced and a tank farm where the regulated substance is stored. The polymers and resins are produced in batch processes. Huntsman's Peru Site has 1 regulated substance, pentane (flammable liquid), at the facility. The pentane is impregnated inside the polystyrene to expand the beads. The maximum inventories of the regulated substance is summarized below: iso-pentane - Used as a blowing agent in the production of expandable polystyrene (EPS) n-pentane - Used as a blowing agent in the production of expandable polystyrene (EPS) 3. Offsite Consequence Analysis. The RM P 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 flammable substances. The OCA allows for the consideration of administrative controls in estimating potential scenario impacts. Worst Case Release Scenario The worst case scenario is based on EPA required assumptions, is highly unlikely, and has never occurred at this facility. The flammable worst case scenario for Huntsman's Peru facility involves the instantaneous failure of the three-pentane storage tanks located on the south side of the site. 100% of the pentane inside the tanks are assumed to form a vapor cloud within the upper and lower flammability limits, and the cloud is assumed to detonate. As a conservative assumption, 10 percent of the flammable vapor in the cloud is assumed to participate in the explosion. This scenario results in off-site impacts to residences, public recreational areas and industrial areas. There were no administrative controls or passive mitigation considered for this scenario. Alternative Case Release Scenarios The first flammable alternative release scenario involves a leak from the pentane railcar. All of the pentane inside of the railcar is released onto the ground surface forming a pool, which is assumed to ignite. The consequence distance endpoint is a radiant heat level capable of causing second degree burns from a 40-second exposure. There were no administrative controls or passive mitigation considered for this scenario. This scenario results in offsite impacts to residences, public recreational areas and industrial areas. The second flammable alternative release scenario (included in RMP*Submit) involves a leak from the pentane railcar. 100% of the pentane inside the railcar is assumed to form a vapor cloud within the uppe r and lower flammability limits, and the cloud is assumed to detonate. As a more realistic assumption then the worst case scenario, 3 percent of the flammable vapor in the cloud is assumed to participate in the explosion. There were no administrative controls or passive mitigation considered for this scenario. This scenario results in off-site impacts to residences, public recreational areas and industrial areas. 4. General accidental release prevention program and chemical specific prevention steps. Following is a brief summary of the elements that Huntsman's Peru Site has implemented to comply with the accidental release prevention requirements outlined by the EPA as well as with the Occupational Health and Safety Administration (OSHA) process safety management (PSM) standard. 7 Process Safety Information Huntsman's Peru Site maintains a compilation of current and accurate written safety information to identify and understand the hazards of the process. This includes informa tion pertaining to: 7 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 exposure. 7 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. 7 Equipment in the process: Includes such information as materials of construction, diagrams of the piping and instrumentation, safety systems and design codes. 7 Process Hazard Analysis Huntsman's Peru 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 Peru Site utilizes the HAZOP methodology, a recognized and generally accepted method, for identifyi ng and evaluating hazards in the process. The Peru 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 within a reasonable period of time. 7 Operating Procedures Huntsman Peru maintains written operating procedures that were developed in consultation with 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. 7 Training Huntsman Peru 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 haza rds, emergency operations, and safe work practices. All operators receive periodic refresher training. 7 Mechanical Integrity Huntsman Peru has developed written procedures for maintaining the operating components of the process (including pressure vessels, storage tanks, piping systems, relief 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. 7 Management of Change Huntsman Peru 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 procedur es, 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 operating procedures are updated. 7 Pre-Startup Review Huntsman Peru 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. 7 Compliance Audit Huntsman Peru 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. 7 Incident Investigation Huntsman Peru 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 Peru has established an incident investigation 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 Peru 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. 7 Employee Participation Huntsman Peru has developed a written action plan for employee participation in all aspects of its process safety management program. Huntsman Peru consults with employees and their representatives on the conduct and development of PHAs and on the development of other elements of the process safety management program. Huntsman Peru ensures that all employees have access to PHAs and all other process safety management information. 7 Hot Work Permit Huntsman Peru 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 Peru 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. 7 Contractors Huntsman Peru has developed procedures for selecting and ensuring that contractors are competent and knowledgeable and can safely perform their work. Huntsman Peru provides information to them about the hazards that may be present in the work area and has developed appropriate safe work practices. Huntsman Peru also evaluates the safety performance and programs of the contractors as a part of their continued employment. 5. 5 Year Accident History. There has been one accidental release of pentane at the Huntsman Peru Site that qualifies for the 5-Year Accident History under the RMP rule. The incident occurred on July 28, 1997 at about 7:15 A.M. Pentane Tank (I- VP-200) emissions occurred during tank filling operations from a railcar. Approximately 237 pounds of pentane were released based on AP-42 loading calculations. The pentane emissions tank during tank loading is permitted under the current operating permit. The pentane vapors overcame a maintenance technician while he was working on the tank as a result of inadequate work standards and inadequate engineering. The technician was taken to the local hospital for observation and did not suffer any major injuries. It should be noted that the tanks have been modified and administrative controls implemented to ensure that this event does no re-occur. 6. Emergency Response Program. Huntsman Peru has a written emergency response program that contains procedures to be followed in the case of an accidental release of a regulated substance. These procedures include steps for informing the public, proper first aid and medical treatment, the proper use of emergency equipment and emergenc y response training. The emergency response plan is reviewed annually and updated as necessary. Likewise the emergency response equipment is maintained, tested, and inspected periodically. Huntsman Peru is actively involved with informing local stakeholders about hazardous substances stored and processed on site. Huntsman Peru participates with the City of La Salle Fire Department, City of Peru Fire Department, and La Salle County LEPC in assisting local officials in the development of emergency procedures to identify resources, chemicals, contacts and material safety data sheets for participating companies. Other community activities include cooperative training between the Peru Site and the Illinois Valley Community Hospital (IVCH). 7. Planned changes to improve safety. Huntsman Peru has an on-going commitment to improve safety and protect the environment. In addition to frequently scheduled internal company audits and inspections, Huntsman Peru performs an annual self-ev aluation as part of the Chemical Manufacturers' Association (CMA) Responsible Care process safety code. The following health, safety and environmental improvements are anticipated during the next five years: 7 Fire system improvements, including storage capacity, distribution, increased monitoring locations, and alarm panels; 7 Reduction of plant noise; 7 Electronic training system; 7 Upgrade to WWTP to remove organic materials; 7 Vapor containment projects; 7 Facility wide asbestos abatement. |