Huntsman Petrochemical Corporation Conroe Plant - Executive Summary

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1.  Accidental release prevention and emergency response policies.  Huntsman Conroe is committed to providing a safe, healthy and environmentally conscious work place for its employees and neighbors.  This is exemplified by the Conroe Site having earned the Occupational Health and Safety Administration (OSHA) Star award for excellence in safety performance.  The Huntsman Conroe 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 Conroe participates with community agencies to develop emergency response plans and participates in cooperative training with these agencies.  Since its certification in September 1992, the Conroe Site has been an active participant in the International Standards Organization (ISO) 9002 quality management program. 
2.  Regulated Substances Huntsman's Conroe site is located about five miles east of Conroe, Texas.  The site is 476 acres, of which 100 acres have been developed.  The Conroe Site takes raw materials and uses batch or continuous operations to produce useful chemicals which other companies then process into cosmetics, epoxy coatings and other consumer products.  Huntsman's Conroe Site has 9 regulated substances at the facility.     
The three flammable substances are: 
7 Dimethylamine (DMA) - Used in hair products, gasoline additives, as antistatic agents, fabric softeners and dyes. 
7 Hydrogen - Used to produce fuel additives and epoxy curing agents. 
7 Monomethylamine (MMA) - Used in gas treating of refinery and natural gas streams and as a textile softener. 
The six toxic substances are: 
7 Acrylonitrile - Used in making floor waxes, water treating chemicals and agricultural chemicals. 
7 Ammonia - Used to make printing dyes and as additives for fuels and lube oils.     
7 Ethylene Diamine (EDA 
) - Used in textile softeners and in oil field applications. 
7 Ethylene Oxide (EO) - Used to manufacture printed circuit boards and in water treating chemicals. 
7 Formaldehyde - Used in making insulation for building construction and appliances. 
7 Propylene Oxide (PO) - Used in making non-toxic solvents and in food preservation. 
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.   
Worst Case Release Scenarios 
These worst case scenarios are based on EPA required assumptions, are highly unlikely, and have never occurred at this facility. 
The worst case scenario associated with t 
he release of flammable substances is a vapor cloud explosion (VCE), involving the full inventory of the largest storage tank containing DMA.  The analysis assumes that the maximum possible inventory of 510,000 pounds is released, completely vaporizes and ignites, resulting in a vapor cloud explosion.  The VCE would reach offsite and may affect nearby public receptors. 
The worst case scenario associated with toxic substances is the failure of an ethylene oxide railcar, resulting in the release of 180,000 pounds of ethylene oxide over a 10-minute period.  This worst case scenario has the potential to affect offsite receptors. 
Alternative Case Release Scenarios   
The alternative case scenario for flammable substances is the failure of a sight glass on a knock out pot at the hydrogen compressor, resulting in the release of 3,700 pounds of hydrogen.  This alternative case scenario has the potential to affect offsite receptors. Fire monitors were considered active mitigation. 
The alterna 
tive case scenario for acrylonitrile is a tank overflow resulting in the release of 6,000 pounds of acrylonitrile over a 6-minute period.  This alternative case scenario has the potential to affect offsite receptors.  Active mitigation considered for this scenario is emergency shutdown systems and fire monitors. 
The alternative case scenario for ammonia is a gasket leak resulting in the release of 430 pounds of ammonia over a 6-minute period.  This alternative case scenario has the potential to affect offsite receptors.  Active mitigation considered for this scenario includes emergency shutdown systems and fire monitors.  
The alternative case scenario for ethylenediamine is a hose rupture on the EDA isotainer resulting in the release of 190 pounds of EDA over a 1-minute period.  This alternative case scenario has the potential to affect offsite receptors.  Emergency shutdown systems and fire monitors were active mitigation considered for this scenario.  
The alternative case scenario 
for ethylene oxide is a gasket failure on the feed line to the reactor, resulting in the release of 17,000 pounds of ethylene oxide over a 5-minute period.  This alternative case scenario has the potential to affect offsite receptors.  Active mitigation for this scenario includes emergency shutdown systems, gas detectors, interlocks and fire monitors. 
The alternative case scenario for formaldehyde is a gasket failure on the formaldehyde tank that results in the release of 10 pounds of formaldehyde over a 6-minute period.  This alternative case scenario has the potential to affect offsite receptors.  Fire monitors were considered as active mitigation for this scenario. 
The alternative case scenario for propylene oxide is a flange failure on the feed line to the reactors, resulting in 16,000 pounds of PO released over a 5-minute period.  This alternative case scenario has the potential to affect offsite receptors.  Active mitigation for this scenario includes fire monitors. 
4.   Gene 
ral accidental release prevention program and chemical specific prevention steps. Following is a brief summary of the elements that Huntsman's Conroe 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.   
7 Process Safety Information 
Huntsman's Conroe 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: 
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 t 
emperature 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 Conroe 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 Conroe Site utilizes the HAZOP methodology, a recognized and generally accepted method, for identifying and evaluating hazards in the process.  The Conroe 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 Conroe maintains written operating procedures that were developed in consult 
ation 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 Conroe 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. 
7 Mechanical Integrity 
Huntsman Conroe 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 prog 
ram 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 Conroe 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 operating procedures are updated.   
7 Pre-Startup Review 
Huntsman Conroe performs pre-startup safety reviews when th 
e 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 Conroe 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 Incid 
ent Investigation 
Huntsman Conroe 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 Conroe 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 Conroe 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 Conroe has developed a written action plan for employee participation in all 
aspects of its process safety management program.  Huntsman Conroe consults with employees and their representatives on the conduct and development of PHA's and on the development of other elements of the process safety management program.  Huntsman Conroe ensures that all employees have access to PHA's and all other process safety management information. 
7 Hot Work Permit 
Huntsman Conroe 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 Conroe 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 Conroe has developed procedures for selecting and ensuri 
ng that contractors are competent and knowledgeable and can safely perform their work.  Huntsman Conroe provides information to them about the hazards that may be present in the work area and has developed appropriate safe work practices.  Huntsman Conroe also evaluates the safety performance and programs of the contractors as a part of their continued employment. 
5.    5 Year Accident History 
Huntsman Conroe 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 Conroe 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 tra 
ined emergency response personnel.  In addition, Huntsman Conroe 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 Conroe actively coordinates emergency response activities with local officials and groups.  Huntsman Conroe participates with the Montgomery County Fire Chief's Association and the Montgomery County Mutual Aid 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 Conroe Site and the Montgomery County Fire Chief's Association as well as making available equipment, technical information and supplies for county mutual aid.  The emergency response plan and its procedures are reviewed annually and updated as necessary.  Likewise the emergency response equipment is maintained, teste 
d and inspected periodically. 
7.   Planned changes to improve safety.  Huntsman Conroe has an on-going commitment to improve safety and protect the environment.  In addition to frequently scheduled internal company audits and inspections, Huntsman Conroe has maintained a VPP Star Status for 10 years which requires OSHA audits every 3 years, as well as an annual self-evaluation 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 Improve fall protection at loading facilities 
7 Replace incinerator to improve removal efficiency of air pollutants.
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