Huntsman Port Neches Tank Farm - Executive Summary |
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HUNTSMAN CORPORATION - Port Neches Tank Farm - EXECUTIVE SUMMARY 1. Accidental release prevention and emergency response policies. Huntsman Port Neches Tank Farm is committed to achieving excellence in environmental, health and safety. The Huntsman Port Neches Tank Farm implements a series of steps to prevent potential hazards associated with the facility and assures a well-trained work force. The program further implements its policies with onsite procedures and manuals. Huntsman Port Neches Tank Farm participates with the Jefferson County Local Emergency Planning Commission (LEPC), 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 Manager of the A&O Plant is responsible for implementation of the risk management program (RMP) for the Huntsman Port Neches Tank Farm. 2. Regulated Substances. The Port Neches Tank Farm consists of five (5) storage tanks owned by Huntsman, but operated by and on property leased from MOTIVA ENTERPRISES LLC (MOTIVA) and is located in Port Neches, Texas. The site stores naphtha unloaded from barges or ships and is used as feedstock for Huntsman's A&O Plant in Port Arthur. The sixteen (16) flammable regulated substances are: 7 Propane - Raw material recycled to manufacture propylene and ethylene and is an ingredient in natural gas. 7 2-Methyl Propene, Butane, 1-Butene, 1,3-Butadiene, 2-Butene cis and trans - 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 propyl ene or sold as product mix. 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. At this facility, there exists no toxics. 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 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 reduce the risk of releasing the entire contents of these tanks. 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 which is maintained by procedures and level alarms at below 95% full and gives approximately a 2-hour response time. The storage tank has redundant and independent level alarms and procedures in response to these alarms. The tanks are diked to contain a spill or leak. The representative flammable alternative release scenario is naphtha leaking from a 3/4" drain resulting in a vapor cloud explosion. This scenario has a potential offsite impact. 4. General accidental release prevention program and chemical s pecific 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 and MOTIVA maintain 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 dev iation. 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 (PHA) MOTIVA has performed initial process hazard analysis (PHA) with review and participation from Huntsman 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 proc edure under the threat of a hurricane and inclement weather. 7 Operating Procedures MOTIVA 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 MOTIVA 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 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 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 MOTIVA, with review and participation of Huntsman, 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 and MOTIVA 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 ye ars 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 and MOTIVA 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 and MOTIVA 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 and MOTIVA has established a system to promptly address and resolve the incident report findi ngs and recommendations and to document their resolution. Finally, incident reports are reviewed with all affected personnel. 7 Employee Participation MOTIVA has developed a written action plan for employee participation in all aspects of its Process Safety Management and Risk Management Programs. MOTIVA 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. MOTIVA ensures that all employees have access to PHA's and all other process safety management information. 7 Hot Work Permit Huntsman and MOTIVA 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 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 and MOTIVA has developed procedures for selecting and ensuring that contractors are competent and knowledgeable and can safely perform their work. Huntsman and MOTIVA provides information to contractors about the hazards that may be present in the work area and has developed appropriate safe work practices. Huntsman and MOTIVA also evaluates the safety performance and programs of the contractors as a part of their continued employment. 5. 5 Year Accident History. The facility has had no incidents in the last five years that resulted in an off site impact for the 5 year accident history. 6. Emergency Response Program. Huntsman and MOTIVA have 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 and MOTIVA are actively involved with informing local stakeholders about hazardous substances stored and processed on site. Huntsman and MOTIVA participate 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 MOTIVA SHE Department Manager is the emergency contact in the event of an emergency. The Port Neches Fire Department will provide initial response. 7. Planned changes to improve safety. There is an ongoing commitment to implement changes, when identified, that will improve the safety of employees and neighbors of this facility as well as projects that enhance safety, environmental protection and protect neighbors from exposure to accidental releases. At this time, no changes are being planned. |