| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

1.    Accidental release prevention and emergency response policies.  Huntsman Oxides and Olefins (O&O) Plant is committed to achieving excellence in environmental, health and safety.  The Huntsman O&O Plant  maintains a working 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.  Huntsman O&O Plant participates with the Jefferson County Local Emergency Planning Commission, Port Neches Fire Department and the Sabine Neches Chiefs Association to develop emergency response plans and participates in cooperative training with these agencies. Huntsman participates in the Responsible Care. initiative at the Chemical Manufacturer's Association and are committed to the responsible management of chemicals. The Plant Ma 
nager of the O&O Plant is responsible for implementation of the risk management program (RMP). 
2.    Regulated Substances . The Oxides and Olefins Plant is located in Port Neches, Texas, on 2,400 acres bound by Highway 366 and Hogaboom Road.  The site began production in 1948 and was acquired by Huntsman in 1994. The site produces olefins, ethylene oxide, propylene oxide, MTBE, ethylene glycol, ethanolamines, and surfactants derived from ethylene oxide.  The O&O Plant is divided into seven (7) process areas.  The first area contains units E2, E4 and E7.  The second area contains the Oxide Specialty process units E3 and E6.  the third area contains ethylene oxide units F2, F4 and F6 and glycol units G1, G2, G3, G4 and G6.  The fourth area contains the ethylene plant (A3).  The Receiving and shipping is the fifth area.  The PO/MTBE unit is the sixth area known as F5.  And lastly, the seventh area is Utilities.  Huntsman's O&O Plant  has twenty-one (21) regulated flammables and seven (7) re 
gulated toxics at the facility. 
The twenty-one (21) flammable substances are: 
7 Ethylene - Product used to manufacture polyethylene grocery bags, wraps and machine parts, and as a raw material for other ethylene based products (ethylene glycol-antifreeze, ethanol amines-shaving creams, hand lotions, furniture polishes, and dry-cleaning preparations, etc.) 
7 Propylene - Product used to manufacture polypropylene materials such  films, clothesline and other kinds of rope and, in turn, is used as a raw material for other propylene based materials (propylene glycol-factory fill antifreeze and propylene oxide). 
7 Isobutane - Raw material used to  manufacture propylene oxide and MTBE. 
7 Propane and Ethane - Raw materials used to manufacture propylene and ethylene and are ingredients in natural gas. 
7 Hydrogen and Methane - Raw materials used for fuel and are ingredients of fuel used in plant 
7 Butane, 1-Butene, 1,3-Butadiene, 2-Butene cis and trans, and Isoprene - Products used as raw mater 
ials in the manufacture of synthetic rubber for tires, and butyl rubber for films, coatings and carpet. 
7 Isopentane, 1-Pentene, 2-Pentene (E) and (Z), 2-Methyl-1-butene, 3-methyl-1-butene - Products used as feed stocks for the manufacture of ethylene 
7 Methyl Ether and Methyl Formate - Intermediates used as fuel. 
The seven (7) toxic substances are: 
7 Anhydrous and Aqueous Ammonia - Raw material used in water treatment and in the manufacture of amines. 
7 Ethylene Diamine (EDA) - Product used to treat water. 
7 Boron Trifluroide - Catalyst used to manufacture nonylphenols. 
7 Propylene Oxide (PO) - Product used in making polyurethane foams (cushions and dashboards) 
7 Chlorine - Added to cooling water for treatment 
7 Ethylene Oxide - Product used to manufacture ethylene glycol which is used for automotive antifreeze and polyester clothing. 
3.    Offsite Consequence Analysis   
The RMP Rule requires that offsite consequence analysis (OCA) be performed to estimate the potential for an accide 
ntal 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.  EPA's computer program, RMP Comp, Ver. 1.06, was used to model the release scenarios 
Toxic Release Scenarios 
The Toxic Worst Case Scenario is based on EPA required assumptions, and is highly unlikely, and has never occurred at this facility. 
   The toxic worst case scenario for the O&O Plant involves the failure of an ethylene oxide (EO) storage tank with the entire contents released over 10 minutes.  This scenario results in off-site impacts. A rigorous inspection program complying with industry codes and standards, effective operator and maintenance training using procedures consistent with safe operation, and adherence to Process Safety Management reduce the risk of releas 
ing the entire contents of the EO tanks.  Overfilling the tank has been considered and safeguards implemented to reduce the chance of this scenario.  Measures preventing this scenario include the existence of multiple independent alarms and an administrative control to prevent overfilling the EO tank set at 86% of the maximum fill level giving 3-hour response time by operators. Relief valves exist on storage vessels to protect vessel integrity in the event of overfill. Equipment is rigorously tested for corrosion and cracking. The ethylene oxide tanks have dikes and drains to contain spills. For ethylene oxide (EO) there exists flammable gas detection systems with deluge systems, alarms, and procedures addressing these alarms.  In all toxic release locations there exists fire water monitors.  There are trained and drilled emergency responders onsite. 
   The alternative case scenario for boron trifluoride involves a tubing failure which empties an entire boron trifluoride cylinder.  The  
alternative case scenario for chlorine involves a 5/16" diameter leak from a cylinder for 30 minutes (vapor release). The opening of a relief valve releasing gas describes the anhydrous ammonia alternative release scenario.  The alternative case scenario for ethylene oxide is a result of a >" bleeder leaking for 10 minutes. The propylene oxide alternative case scenario is an overfill of a tank.  The ethylene diamine alternative case scenario involves spillage and subsequent evaporation of a storage tank.   The aqueous ammonia alternative case scenario is a release from an opened > " bleeder for 10 minutes.  Of these toxic alternative release scenarios, only ethylene oxide, propylene oxide and anhydrous ammonia may have potential offsite impacts. Measures preventing/ mitigating these scenarios are as follows. The ethylene oxide and propylene oxide tanks have dikes and drains to contain spills. For ethylene oxide (EO) and propylene oxide there exists flammable gas detection systems with  
deluge systems, alarms, and procedures addressing these alarms. For chlorine cylinders, there exists onsite emergency repair kits. For anhydrous ammonia systems there are ammonia gas detectors, alarms and procedures addressing these alarms. In all toxic release locations there exists fire water monitors. There are trained and drilled emergency responders onsite. 
Flammable Release Scenarios   
   The Flammable Worst Case Scenario is based on EPA required assumption and is highly unlikely and has never occurred at this facility. 
   The flammable worst case scenario involves the complete failure of an isobutane tank.  The entire volume  in the isobutane tank  is assumed to vaporize and result in a vapor cloud explosion.  This  scenario has offsite impacts.   A rigorous inspection program complying with industry codes and standards, effective operator and maintenance training using procedures consistent with safe operation, and adherence to Process Safety management reduce the risk of re 
leasing the entire contents of these tanks.  Overfilling the tanks has been considered and safeguards implemented to reduce the chance of this scenario.  Measures, mitigation and controls for these events include process controls, alarms and procedures addressing these alarms.  An administrative control for the isobutane tank is at 87% of the maximum fill level giving a 6-hour response time.   Relief valves exist on storage vessels to protect vessel integrity in the event of overfill. The equipment is rigorously tested and inspected for corrosion and cracking.  There exists flammable gas detection systems with alarms and fixed fire water monitors with trained and drilled emergency responders onsite. 
   The representative flammable alternative release scenario is a flow of a mixture of isobutane and propylene to a flare line leaking to the atmosphere resulting in a vapor cloud explosion. This scenario has potential offsite impacts, but does not effect schools, hospitals, recreational are 
as, or any environmental receptors.  Mitigation and controls for these releases include process controls, alarms and procedures addressing these alarms. Rupture disks with release notification exist on relief valves.  The equipment is rigorously tested and inspected.  There exists flammable gas detection systems with alarms and fixed fire water monitors with trained and drilled emergency responders onsite. 
4.   General accidental release prevention program and chemical specific prevention steps.  Following is a brief summary of the elements that Huntsman's O&O 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) PSM standard: 
7 Process Safety Information 
        Huntsman's O&O 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 regula 
ted 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 O&O 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 O&O Site utilizes the HAZOP methodology, a recognized and generally accepted method, for identifying and evaluating hazards in the process 
.  The O&O 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.  Hurricanes and inclement weather are not investigated in the PHAs; however, Huntsman does have a Hurricane Procedure and implements this procedure under the threat of a hurricane and inclement weather. 
7 Operating Procedures 
        Huntsman O&O 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 O&O 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 O&O 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 O&O 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 t 
o any change, the following issues are considered:  the technical basis for the proposed change, its impact on safety and health, any  modification 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 O&O 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 or is deemed as requiring more review than a Management of Change modification.  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; and training of employees affected by modifications is complete. 
7 Compliance Audit 
        Huntsman O&O 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 O&O 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 O&O has established a procedure to appoint an incident investigation team consisting of persons wit 
h 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 O&O 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 O&O has developed a written action plan for employee participation in all aspects of its Process Safety Management and Risk Management Programs.  Huntsman O&O 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 O&O ensures that all employees have access to PHA's and all other process safety management informatio 
7 Hot Work Permit 
        Huntsman O&O 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 O&O 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 O&O has developed procedures for selecting and ensuring that contractors are competent and knowledgeable and can safely perform their work.  Huntsman O&O provides information to contractors about the hazards that may be present in the work area and has developed appropriate safe work practices.  Huntsman O&O also evaluates the safety performance and programs of the contractors as a part of their continued employm 
5.    5 Year Accident History  The O&O Plant has had six reportable RMP incidents in the last five years One was reported due to a precautionary road closing and would consequently be considered an off site impact for the 5 year accident history.  This event occurred in 1995 and was an explosion in a portable tank. The tank was damaged, but there were no injuries and no release of chemicals.  Other than closing the road, there were no off-site effects. The second occurred in.  Damage was limited to the flare line and there were no offsite effects. This release was reported to all the proper authorities. In 1998, the O&O Plant also had three onsite injuries associated with ethylene oxide, none of which involved a lost day of work.  In 1997 the O&O Plant had an injury associated with boron trifluoride, which did not involve a lost day of work. 
6.     Emergency Response Program.  Huntsman 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 emergency response training for emergency response employees who perform emergency response duties and to local emergency responders who may be called to assist in emergency response.   The emergency response plan is reviewed annually and updated as necessary.  Huntsman is actively involved with informing local stakeholders about hazardous substances stored and processed on site.  Huntsman  participates with the Jefferson County LEPC, Sabine Neches Chiefs Association and 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 emergency contact in the event of an emergency. The Emergency Response Coordinator for th 
is plant is the designated alternate.  The initial response will be provided by Huntsman's on-site fire department. 
7.   Planned changes to improve safety.  There are several planned improvements at the O&O Plant to reduce the on and offsite impacts.  Selected projects include adding refrigeration systems for ethylene oxide storage tanks; upgrading/adding pressure relief valves, flammable gas and flame detection devices, and fire water supply piping, throughout the plant; and upgrading the ethylene oxide scrubber.  There is an on-going commitment to implement changes, when identified, that will improve the safety of employees and neighbors of the O&O Plant as well as projects that enhance safety, environmental protection and protect neighbors from exposure to accidental releases.
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