Huntsman Petrochemical Corporation Dayton Plant - Executive Summary
HUNTSMAN DAYTON - EXECUTIVE SUMMARY |
1. Accidental release prevention and emergency response policies. Huntsman Dayton is committed to providing a safe, healthy and environmentally conscious work place for its employees and neighbors. The Huntsman Dayton 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 Dayton participates with community agencies to develop emergency response plans and participates in cooperative training with these agencies.
2. Regulated Substances Huntsman's Dayton site is located about five miles west of Dayton, Texas. The Dayton 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 Dayton Site has 2 re
gulated substances at the facility:
The two toxic substances are:
7 Ethylene Oxide (EO) - Used to manufacture printed circuit boards and in water treating chemicals.
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 toxic substances is the failure of an ethylene oxide railcar, resulting in the re
lease 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 ethylene oxide is a safety valve leak from an EO railcar, resulting in the release of 6,600 pounds of ethylene oxide over a 720-minute period. This alternative case scenario has the potential to affect offsite receptors. Active mitigation for this scenario includes fire monitors.
The alternative case scenario for propylene oxide is a gasket failure on the feed line to the reactors, resulting in 7,900 pounds of PO released over a 60-minute period. This alternative case scenario has the potential to affect offsite receptors. Active mitigation for this scenario includes fire monitors.
4. General accidental release prevention program and chemical specific prevention steps. Following is a brief summary of the elements that Huntsman's Dayton Site has implemented to comply wit
h 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 Dayton 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 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 instr
umentation, safety systems and design codes.
7 Process Hazard Analysis
Huntsman's Dayton 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 Dayton Site utilizes the HAZOP methodology, a recognized and generally accepted method, for identifying and evaluating hazards in the process. The Dayton 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 Dayton 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 sy
stems, control measures and precautions to prevent exposures to process hazards. The procedures are reviewed and revised periodically to ensure their accuracy and completeness.
Huntsman Dayton 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 Dayton 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
n Dayton 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 Dayton 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 t
o 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 Dayton 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 Dayton investigates any incidents that resulted in, or could reasonably have resulted in, a catastrophic release of covered chemicals. The investigation is pro
mptly conducted, commencing within 48 hours of any incident. To perform the investigation, Huntsman Dayton 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 Dayton 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 Dayton has developed a written action plan for employee participation in all aspects of its process safety management program. Huntsman Dayton consults with employees and their representatives on the conduct and development of PHA's and on the development of othe
r elements of the process safety management program. Huntsman Dayton ensures that all employees have access to PHA's and all other process safety management information.
7 Hot Work Permit
Huntsman Dayton 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 Dayton 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 Dayton has developed procedures for selecting and ensuring that contractors are competent and knowledgeable and can safely perform their work. Huntsman Dayton provides information to them about the hazards that may be present in the work area
and has developed appropriate safe work practices. Huntsman Dayton also evaluates the safety performance and programs of the contractors as a part of their continued employment.
5. 5 Year Accident History
Huntsman Dayton 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 Dayton 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 Dayton provides training to its emergency response employees who perform emergency response duties and to local emergency responde
rs who may be called on to assist in emergency response. Huntsman Dayton actively coordinates emergency response activities with local officials and groups. Huntsman Dayton participates with the Liberty County 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 Dayton Site and the Liberty County Mutual Aid 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, tested and inspected periodically.
7. Planned changes to improve safety. Huntsman Dayton has an on-going commitment to improve safety and protect the environment. In addition to frequently scheduled internal company audits and inspections, the following health, sa
fety and environmental improvements are anticipated during the next five years:
7 Loading Rack Fall Protection Installed
7 Electrical System Upgrade
7 Installing Flame Arrestors on Carbon Canisters
7 Enhance Mitigation System by Installing Fire Water Test Header/Pumper Connection (LEPC Responders)