HUNTSMAN PETROCHEMICAL CORP. C4 PLANT - Executive Summary |
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HUNTSMAN CORPORATION C4 PLANT - EXECUTIVE SUMMARY 1. Accidental release prevention and emergency response policies. Huntsman's C4 Plant is committed to providing a safe, healthy and environmentally conscious work place for its associates and neighbors. This is exemplified by the C4 Plant having earned the Occupational Health and Safety Administration (OSHA) VPP Star award for excellence in safety performance. The C4 Plant maintains a working OSHA Process Safety Management (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. The EPA Risk Management Program (RMP) has been built upon this existing PSM program. The C-4 Plant participates with the Jefferson County Local Emergency Planning Commission (LEPC) Sabine-Neches Chiefs Association and the Port Neches Fire Department in assisting local officials in the development of emergency response plans and participates in cooperative training with them. The facility complies with all applicable codes and standards regarding operating and equipment safety. Huntsman participates in the Responsible Care. initiative of the Chemical Manufacturer's Association, is committed to the responsible management of chemicals and is an active participant in the International Standards Organization (ISO) 9002 quality management program. In addition, the C4 Plant maintains a Hurricane Preparedness Plan which is implemented in the event of a hurricane approaching the plant. 2. The stationary source and regulated substances handled. The C4 Plant is located at the corner of Highway 136 and Highway 366 in Port Neches, Texas. The site began production in 1943 and was acquired by Huntsman in 1994. The site produces as primary end products butadiene and Methyl Tertiary Butyl Ether (MTBE). Butadiene is a monomer used in the production of butadiene rubber and various butadiene co-polymers. MTBE is a gasoline additive that increases the oxygen content in order to reduce emissions and improves the octane rating. MTBE is not an RMP chemical. The C4 Plant processes or stores volumes of the following regulated flammable substances greater than the threshold amounts: 1,3-butadiene, 1-butene, 2-methyl-1-butene, 2-methylpropene, 3-methyl-1-butene, 2-butene-cis, butane, ethane, isobutane, isopentane, methane, pentane, propane, propylene, propyne, 2-butene-trans, vinyl acetylene and ethyl acetylene. The only regulated toxic substance, in a quantity greater than the threshold amount, at the time of the initial submittal of the Risk Management Plan is chlorine. At some time during the summer of 1999 another regulated toxic substance, aqueous ammonia, (ammonia concentration = 30% wt) will be added to the facility. Consequently, this RMP submission will contain predictive filing for 30% wt aqueous ammonia. The C4 stationary source is composed of four processes. They are identified as the Butadiene Process, the MTBE Process, Receiving, Storage, and Transfer (RS&T) and Steam, Power and Water (SP&W). The Butadiene Process produces butadiene by extraction and distillation of crude butadiene purchased from various olefin plants. This process also produces a by-product stream (Raffinate-1) which contains isobutylene and is used as a feedstock for the MTBE process. The MTBE Process uses a catalytic method to react isobutylene with methanol to produce MTBE. The feeds to the MTBE Process are the Raffinate-1 stream from the Butadiene Process and butane/butylene streams from several refinery operations. The MTBE is then puified by distillation and sold to refineries. The Receiving, Storage & Transfer (RS&T) Process consists of storage tanks, marine docks, and railcar facilities for, loading, unloading and storage of raw materials, intermediates, by-products and finished products. The SP&W Process consists of utilities, includ ing raw water treatment, steam boilers, wastewater treatment and cooling towers. The only part of the SP&W Process which is covered by PSM and RMP is that area which contains chlorine. Chlorine is stored in cylinders and utilized for water treatment. The wastewater treatment facility will be adding a regulated toxic chemical, aqueous ammonia (30% wt ammonia), during the summer of 1999 for the control of BOD. Although the bulk of the SP&W process is not "covered", the C4 Plant is in the process of implementing various elements of PSM/RMP for this area, including Management of Change, Operating Procedures and Mechanical Integrity. 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 and mitigation measures in estimating potential scenario impacts. The EPA computer program, RMPComp version 1.06, was used to model the release scenarios. Worst Case Release Scenarios These worst case scenarios are based on EPA required assumptions which are highly unlikely and have never occurred at this facility. The C4 Plant has one worst case release scenario to represent all toxics and one worst case release scenario to represent all flammables. The representative toxic worst case scenario for C4 Plant involves the failure of a chlorine cylinder with the entire contents released over 10 minutes. This scenario results in off-site impacts. The flammable worst case scenario involves the complete failure of a storage sphere containing butadiene. The entire volume in the tank is assumed to vaporize and result in a vapor cloud explosion. This scenario results in offsite impacts. Failure of a tank can be caused by overpressure. In order to protect against overpressure, this sphere contains Pressure Relief Valves which will reduce the pressure in the tank in a controlled manner long before failure of the tank occurs. The fact that the system was designed to operate safely under the conditions which it is now operating, a rigorous inspection program complying with industry codes and standards, effective operation and maintenance of this system using procedures consistent with safe operation, and adherence to the PSM Rule all work together to reduce the risk of releasing the entire contents of the butadiene tank. The amount of butadiene which is stored in this tank (this directly impacts the amount of butadiene which would be released in this scenario) is controlled administratively by procedures which state the maximum fill level and alarms which alert operators when the tank reaches 80% of the maximum fill level. Alternative Case Release Scenarios The C4 Plant has one alternativ e release scenario for the toxic substance currently on site (chlorine) and one for the toxic substance that is being predictively included (aqueous ammonia). The C4 Plant has one alternative release scenario to represent all flammables. The first toxic alternative release scenario involves a 5/16" diameter leak from a chlorine cylinder for 30 minutes (vapor release). This scenario results in no offsite impacts to public or environmental receptors. Controls and mitigation measures for chlorine scenarios include testing and inspections, chlorine detectors, alarms, procedures, trained emergency responders, emergency chlorine cylinder repair kits and fixed firewater monitors. The second toxic alternative release scenario (being submitted predictively) involves a leak from a tank that contains 30% wt aqueous ammonia. The leak is a result of a leak from a >" line break for 30 minutes. This scenario results in no offsite impacts to public or environmental receptors. The representat ive flammable alternative release scenario is a leak from a 3/4" bleeder valve for 30 minutes resulting in a vapor cloud explosion of butadiene. This scenario results in potential offsite impacts. Controls and mitigation measures for all flammable scenarios include system design and overpressure protection, testing and inspection, area and perimeter detectors for hydrocarbons, alarms, procedures, dikes, fixed fire water monitors and trained emergency responders. 4. General accidental release prevention program and chemical specific prevention steps. Following is a brief summary of the elements that the C4 Plant has implemented to comply with the accidental release prevention requirements outlined by the EPA in the RMP Rule, as well as, with the OSHA PSM standard. 7 Process Safety Information The C4 Plant maintains a compilation of written safety information. This includes information pertaining to hazards of regulated substances, the technology of the covered process and the equipment in the covered process. 7 Process Hazard Analysis (PHA) The C4 Plant has performed initial process hazard analysis to comply with 29 CFR 1910.119(e) and these hazard analysis apply to processes covered by RMP. The C4 Plant utilizes the HAZOP methodology, a recognized and generally accepted method, for identifying, evaluating, and addressing hazards in the process. Employees are assigned to the HAZOP team who are knowledgeable in the HAZOP methodology and the specific process. The team develops recommendations to reduce the potential hazards which are further evaluated and implemented where beneficial. Recommendations are tracked until they are resolved. The hazards imposed by hurricanes and inclement weather are minimally discussed during PHA's since this issue is well-covered by our Hurricane Preparedness Plan and Corporate Standards require designing equipment/structures to withstand high winds. 7 Operating Procedures The C4 Plant maintains written operating proc edures, that were developed by operations, and provide clear instructions for safely operating covered processes. These operating procedures are available to all employees who work in the processes. The procedures are reviewed annually and modified whenever needed to accommodate operational and process changes. 7 Training The C4 Plant provides initial training as well as refresher training to employees who operate the processes to assure that the required level of skills and knowledge are maintained. Training documentation provides records of when training was received and whether or not the training was understood. All operators receive periodic refresher training. 7 Mechanical Integrity The C4 Plant has developed written procedures for maintaining the mechanical integrity of equipment in the covered process, including pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown system controls, and pumps. The program is comprised of well-tra ined personnel who follow maintenance, testing and inspection procedures that ensure proper function of process equipment. This program includes the periodic inspection and testing of process equipment, as well as, the documentation of the results of these activities. 7 Management of Change The C4 Plant 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 ope rating procedures are updated. 7 Pre-Startup Review The C4 Plant performs pre-startup reviews for major changes in a process that require modification to process safety information. 7 Compliance Audit The C4 Plant performs audits of its compliance with the provisions of 29CFR1910.119 (PSM), and will now include 40 CFR part 68 (RMP), every three years. Audit teams are comprised of employees with appropriate knowledge of audit techniques and process safety, as well as, operating experience. Audits are conducted 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 tracked until resolved. Appropriate corrective actions are implemented. 7 Incident Investigation The C4 Plant conducts an incident investigation for every incident that resulted in, or could reasonably have resulted in, a catastrophic release of a covered chemical. The investigation is promptly conducted. It is perfo rmed by a 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. The recommendations are then tracked to completion. 7 Employee Participation The C4 Plant has a written employee participation plan that allows input from employees on the development and analysis of process safety management. PHA's and all other RMP information is available to all employees. 7 Hot Work Permit The C4 Plant has a procedure for the issuance of hot work permits for hot work 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, a permit is issued that documents the fire prevention and protec tion requirements for the operation, the date authorized for hot work, and the object on which the work is performed. 7 Contractors The C4 Plant has developed procedures for selecting and ensuring that contractors are competent and knowledgeable and can safely perform their work. The C4 Plant provides information to contractors about the hazards that may be present in the work area and has developed appropriate safe work practices. The safety performance and programs of the contractors are evaluated annually by Huntsman as a part of their continued employment. 5. 5 Year Accident History The C4 Plant has had no incidents in the last five years that have resulted in an off site impact. 6. Emergency Response Program. Huntsman has a written emergency response program which encompasses the C4 Plant and contains procedures to be followed in the case of an accidental release of a hazardous chemical. These procedures include steps for informing the public, proper first aid and medical treatment, the proper use of emergency equipment and emergency response training for emergency response employees who perform emergency response duties and local emergency responders who may be called to assist in emergency response. The emergency response plan is reviewed annually and updated as necessary. Likewise the emergency response equipment is maintained, tested and inspected periodically. Huntsman is actively involved with informing local officials about hazardous substances stored and processed on site. Huntsman participates with the Jefferson County LEPC and the Port Neches Fire Department in assisting local officials in the development of emergency procedures to identify resources, chemicals, contacts and material safety data sheets for participating companies. The Supervisor of Emergency Response is the person to contact in the event of an emergency. The Emergency Response Coordinator for the plant is the designated alternate contact. Initial response will b e provided by Huntsman on-site fire department. 7. Planned changes to improve safety. At this time, plans to enhance the safety of the C4 Plant include upgrading fire water monitors and adding emergency block valves at various locations throughout the plant. In addition, numerous projects are being considered as a result of recommendations from HAZOP studies, employee suggestions, incident investigations, and other continuous improvement efforts supporting the Responsible Care. Process Safety Code. There is an ongoing commitment to implement changes, when identified, that will improve the safety and protection of associates and neighbors from accidental releases of hazardous chemicals. |