Huntsman Petrochemical Corporation - Executive Summary |
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HUNTSMAN PETROCHEMICAL CORPORATION - EXECUTIVE SUMMARY 1. Accidental release prevention and emergency response policies. Huntsman Petrochemical Corporation's Austin Laboratories is committed to providing a safe, healthy and environmentally conscious work place for its employees, immediate neighbors, and the community at large. This is exemplified by the Huntsman Austin Laboratories site having earned and maintained since 1989 the Occupational Health and Safety Administration (OSHA) Star award for excellence in safety performance. Huntsman Austin Laboratories 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 Austin Laboratories participates with community agencies to develop emergency response plans and participates in cooperative training with t hese agencies. Since its certification in March 1993, Austin Laboratories has also been an active participant in the International Standards Organization (ISO) 9002 quality management program. 2. Regulated Substances. Huntsman's Austin Laboratories is located at 7114 North Lamar Boulevard in north central Austin, Texas. Austin Laboratories performs product development and process demonstration work for surfactants, specialty amines, and other specialty products which are used in the manufacture of a variety of consumer goods. As raw material for its processes, Huntsman Austin Laboratories uses five regulated toxic substances : acrylonitrile, ammonia, ethylene oxide, formaldehyde and propylene oxide. Common industry uses for these materials are listed below. Acrylonitrile is used in the manufacture of consumer goods such as textiles, food containers, toys, luggage, and automotive parts. Ammonia is commonly used in the manufacture of household cleaners, pharmaceuticals, and fertilizers. Ethylene oxide is used as a sterilant and fumigant for equipment in the medical field and in food processing plants; it is also used in the production of detergents, antifreeze, urethane foam, and fuel additives. Formaldehyde is used in the manufacture of textile products and as a disinfectant in medical, personal care, and food handling applications . Propylene oxide is commonly used for the production of packaged foods, cosmetics, plastics, polyurethane foam, and antifreeze. 3. Offsite Consequence Analysis The RMP Rule requires that offsite consequence analysis (OCA) be performed to estimate the potential impact of 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 (ex: self-imposed maximum vessel inventory) in estimating potential w orst case scenario impacts. Other safety controls may be considered in alternative release scenarios. Worst Case Release Scenarios Huntsman Austin Laboratories uses no regulated flammable substances as defined by the RMP Rule. The worst case scenario associated with toxic substances used at Huntsman Austin Laboratories is represented by the failure of an ethylene oxide storage tank, resulting in the release of 180,000 pounds of ethylene oxide over a 10-minute period. This worst case scenario has the potential to affect offsite receptors. This worst case scenario is based on EPA required assumptions (i.e., the simultaneous failure of all active safety and emergency response systems) and is highly unlikely. No accidental release having environmental impacts approaching those associated with the worst case scenario has ever occurred at the facility. Alternative Case Release Scenarios The alternative case scenario for acrylonitrile is a pump leak resulting in the release of 400 pounds of acrylonitrile over a 5-minute period. This alternative case scenario has the potential to affect offsite receptors. Active mitigation for this scenario includes fire monitors and a leak detection system with a water-deluge. The alternative case scenario for ammonia is a gasket leak resulting in the release of 270 pounds of ammonia over a 2-minute period. This alternative case scenario has the potential to affect offsite receptors. Active mitigation for this scenario includes excess flow valves, fire monitors, and a leak detection system with a water-deluge. The alternative case scenario for ethylene oxide is a valve packing leak, resulting in the release of 60 pounds of ethylene oxide over a 5-minute period. This alternative case scenario has the potential to affect offsite receptors. Active mitigation for this scenario includes fire monitors and a leak detection system with a water-deluge. The alternative case scenario for formaldehyde is a pump leak that results in the release of 830 pounds of formaldehyde over a 10-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 pump leak, resulting in 530 pounds of propylene oxide released over a 10-minute period. This alternative case scenario does not have the potential to affect offsite receptors. Active mitigation for this scenario includes fire monitors and a leak detection system with a water-deluge. 4. General accidental release prevention program and chemical specific prevention steps. Following is a brief summary of the elements that Huntsman Austin Laboratories 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 Austin Laboratories maint ains a compilation of current and accurately 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 instrumentation, safety systems and design codes. 7 Process Hazard Analysis (PHA) Huntsman Austin Laboratories has performed process hazard analysis on each process to identify the potential hazards, the adequacy of the engineering and admin istrative controls and the ways to minimize those hazards. Huntsman Austin Laboratories utilizes the HAZOP methodology, a recognized and generally accepted method, for identifying and evaluating hazards in the process. Huntsman Austin Laboratories assigns employees to the HAZOP team who are knowledgeable in the HAZOP methodology and the specific process. The HAZOP team makes recommendations to reduce the potential hazards; after management review and approval, these recommendations are implemented within a reasonable period of time. 7 Operating Procedures Huntsman Austin Laboratories 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 Austin Laboratories provides comprehensive training and testing of 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 process operators receive periodic refresher training. 7 Mechanical Integrity Through the Mechanical Integrity program, Huntsman Austin Laboratories 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). 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 Austin Laboratories has established and implemented written procedures to manage changes to process chemicals, technology, eq uipment, 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: a) the technical basis for the proposed change, b) its impact on safety, health, and the environment, c) any modifications to operating procedures, d) the necessary time period for the change, and e) any third-party or other 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 Austin Laboratories 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 to the introduction of highly hazardous chemical s, 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 Austin Laboratories 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 at least 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 Austin Laboratories investigates any incidents that resulted in, or could reasonably have resulted in, a catastrophic release of covered chemicals. The investigation is promptly conduc ted, commencing within 48 hours of any incident. To perform the investigation, Huntsman Austin Laboratories has established an incident investigation team consisting of persons with the appropriate knowledge and experience to thoroughly and systematically 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 Austin Laboratories 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 Austin Laboratories has developed a written action plan for employee participation in all aspects of its process safety management program. Huntsman Austin Laboratories consults with employees and their representatives on the cond uct and development of PHA's and on the development of other elements of the process safety management program. Huntsman Austin Laboratories ensures that all employees have access to PHA's and all other process safety management information. 7 Hot Work Permit Huntsman Austin Laboratories 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 Austin Laboratories 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 Austin Laboratories has developed procedures for selecting and ensuring that contractors are competent and knowledgeable and can safely perf orm their work. Huntsman Austin Laboratories provides contractors with information and training about the hazards that may be present in the work area and has developed appropriate safe work practices which contractors must follow while working inside the facility. Huntsman Austin Laboratories also evaluates the safety performance and programs of the contractors as a part of their continued employment at the facility. 5. 5 Year Accident History Huntsman Austin Laboratories has one accidental release to report for the 5-Year Accident History. This release of about six pounds of ammonia resulted in minor injury to an employee, but was not of a severity that required the employee to miss time away from work beyond the day of the injury. Huntsman Austin Laboratories has not had an accidental release which resulted in known off-site deaths, injuries, evacuation, shelter in place, property damage or environmental damage. 6. Emergency Response Program. Huntsman Austin Laborat ories 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 Austin Laboratories provides training to its emergency responders and onsite medical employees who perform emergency response duties. Emergency response activities are actively coordinated with local officials and groups, including periodic joint training with local emergency responders who may be called on to assist in emergency response situations at the facility. Huntsman Austin Laboratories participates with the Austin Fire Department and the Travis County Local Emergency Planning Committee to develop emergency response procedures that identify resources, chemicals, contacts and material safety data sheets to be used in the event of an acc idental release. 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 Austin Laboratories has an on-going commitment to improve the safety and health of its employees and to protect the environment. In addition to frequently scheduled internal company audits and inspections, Huntsman Austin Laboratories has maintained a Voluntary Protection Program (VPP) Star Status for 10 years which requires OSHA audits every 3 years, as well as an annual self-evaluation as part of the Chemical Manufacturers' Association (CMA) Responsible Care Process Safety Code. The following health, safety and environmental improvements are anticipated during the next five years: 7 Installation of additional mitigation systems (ex: water-deluge system, leak detectors) for formaldehyde use and storage. 7 Replacement of process equipment (ex: transfer pumps) to reduce fugitive emission levels for regulated chemicals. 7 Modifications to process equipment to reduce the amount of ammonia vented to the fume abator for destruction. |