HUNTSMAN CORP. - AROMATICS & OLEFINS (A&O) PLANT - Executive Summary |
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HUNTSMAN CORPORATION - Aromatics and Olefins (A&O) Plant - EXECUTIVE SUMMARY 1. Accidental release prevention and emergency response policies. Huntsman Aromatics and Olefins (A&O) Plant is committed to achieving excellence in environmental, health and safety. This is exemplified by the A&O Plant having earned the Occupational Health and Safety Administration (OSHA) Star Award for excellence in safety performance. The Huntsman A&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 A&O Plant participates with the Jefferson County Local Emergency Planning Commission (LEPC), Port Arthur Fire Department and the Sabine Neches Chiefs Association to develop emergency response plans and participates in cooperative training with these agencies. Hunts man participates in the Responsible Care. initiative at the Chemical Manufacturer's Association and are committed to the responsible management of chemicals. The Plant Manager of the A&O Plant is responsible for implementation of the risk management program (RMP). 2. Regulated Substances. The Aromatics and Olefins Plant is located on 230 acres at the corner of State Highway 73 and Savanna Avenue in Port Arthur, Texas and employs 275 people. The site first opened in 1957 and was acquired by Huntsman in 1994. The site produces as primary end products ethylene, propylene, cyclohexane and intermediates. The A&O Plant has four processes: the Light Olefins Unit (LOU) manufactures ethylene and propylene; the Aromatics/Cyclohexane Unit manufactures aromatics extract and cyclohexane; Utilities uses chlorine for water treatment; and the offsite tankage area operated by an adjoining plant, is included in this filing, but adds no additional chemicals other than an increased inventory of exi sting chemicals. Huntsman's A&O Plant has twenty-five (25) regulated substances at the facility. The twenty-four (24) 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 as 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 Propane and Ethane - Products recycled to manufacture propylene and ethylene and are ingredients in natural gas. 7 Methane - Product used for fuel and is an ingredient of natural gas. 7 Isobutane, 2-Methyl Propene, Butane, 1-Butene, 1,3-Butadiene, 2-Butene cis and trans, and Vinyl Acetylene - Products used as raw materials in the manufacture of synthetic rubber for tires, and butyl rubber for films, coatings and carpet. 7 Isopentane, Isoprene, 1-Pentene, 1,3 Pentadiene, 2-Pentene (E) and (Z), 2-Methyl-1-butene, 3-methyl-1-butene, Pentane - Raw and recycled materials used as feed stocks for the manufacture of ethylene and propylene or sold as a product mix. 7 Propyne and Propadiene - Intermediates destroyed in downstream reactors. The one (1) toxic substance is: 7 Chlorine - Added to cooling water for treatment 3. Offsite Consequence Analysis (OCA) 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. 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 A&O Plant involves the failure of a 2000 pound chlorine cylinder with the entire contents released over 10 minutes. This scenario has potential off-site impact. The toxic alternative case 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. Measures for preventing these toxic release scenarios are as follows: Chlorine systems have automatic shut-off devices and operate under vacuum to minimize releases in the event of a pipe/tube break. Chlorine detectors, alarms and procedures are in place to alert of a release. Emergency chlorine cylinder repair kits are also available on site should a leak occ ur. Fixed fire water monitors with trained and drilled fire responders are on site. 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 a storage tank containing a hydrocarbon mixture. The volume of RMP chemicals in the tank is assumed to vaporize, ignite, and result in a vapor cloud explosion. A rigorous inspection program complying with industry codes and standards, effective operator and maintenance training using procedures consistent with safe operation, and adherence to the Process Safety Management program reduce the risk of releasing the entire contents of these tanks. This scenario has potential for offsite impacts. Overfilling the tank has been considered and safeguards implemented to reduce the chance of this scenario. The administrative control for the tank is the maximum fill level whi ch is maintained by procedures and level alarms at below 90% full and gives over an 8-hour response time. The storage tank has level alarms and procedures in response to these alarms. The tanks are diked to contain a spill or leak. Flammable gas detectors exist throughout the plant with alarms and procedures in the event of a release. Fixed fire water monitors with trained and drilled emergency responders are onsite. The representative flammable alternative release scenario is a failure in the discharge piping of a propylene refrigeration compressor resulting in a vapor cloud explosion. This scenario has a potential for offsite impacts. Compressors have manual deluge fire water systems and vibration alarms. Flammable gas detectors exist throughout the plant with alarms and procedures in the event of a release. Fixed fire water monitors with trained and drilled fire responders are onsite. 4. General accidental release prevention program and chemical specific prevention steps . Following is a brief summary of the elements that Huntsman's A&O Plant 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 A&O Plant 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 i n the process: Includes such information as materials of construction, diagrams of the piping and instrumentation, safety systems and design codes. 7 Process Hazard Analysis (PHA) Huntsman's A&O Plant has performed process hazard analysis (PHA) on each process to identify the potential hazards, the adequacy of the engineering and administrative controls and the ways to minimize those hazards. The A&O Plant utilizes the HAZOP methodology, a recognized and generally accepted method for identifying and evaluating hazards in the process. The A&O Plant 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 i nclement weather. 7 Operating Procedures Huntsman A&O Plant 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 A&O Plant 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 A&O Plant 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 A&O 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 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 p rocess safety information and operating procedures are updated. 7 Pre-Startup Review Huntsman A&O Plant 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 A&O Plant 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 A&O Plant 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 A&O Plant 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 A&O Plant has established a system to promptly address and resolve the incident report findings and recommendations and to docum ent their resolution. Finally, incident reports are reviewed with all affected personnel. 7 Employee Participation Huntsman A&O Plant has developed a written action plan for employee participation in all aspects of its Process Safety Management and Risk Management Programs. Huntsman A&O Plant 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 A&O Plant ensures that all employees have access to PHA's and all other process safety management information. 7 Hot Work Permit Huntsman A&O Plant 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 A&O Plant 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 A&O Plant has developed procedures for selecting and ensuring that contractors are competent and knowledgeable and can safely perform their work. Huntsman A&O Plant provides information to contractors about the hazards that may be present in the work area and has developed appropriate safe work practices. Huntsman A&O Plant also evaluates the safety performance and programs of the contractors as a part of their continued employment. 5. 5 Year Accident History. The Huntsman A&O Plant has had one incident in the last five years that resulted in an off site impact for the 5 year accident history. The incident occurred in 1995 and resulted in equipment damage, but with no off site impact. 6. Emergency Response Program. Huntsman has a written emergency response program that contains procedures to b e 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 Arthur 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 Emergenc y Response Coordinator for this plant is the designated alternate. For Huntsman A&O Plant Port Arthur offsite tanks located at MOTIVA, MOTIVA will provide initial response. 7. Planned changes to improve safety. There are several planned improvements at the A&O Plant to reduce the on and offsite impacts. The A&O Plant is planning to upgrade all of the existing process area monitors for flammable gas release detection and alarm. A new deluge system will be included in the AU/Cyclohexane unit. There is an ongoing commitment to implement changes, when identified, that will improve the safety of employees and neighbors of the A&O Plant as well as projects that enhance safety, environmental protection and protect neighbors from exposure to accidental releases. |