The Lubrizol Corporation - Bayport Plant - Executive Summary |
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EXECUTIVE SUMMARY BAYPORT 6/4/99 Accidental release prevention and emergency response policies: The Lubrizol Corporation is committed to improving our products and processes. As part of Lubrizol's philosophy, we believe in maintaining the health and safety of our employees, customers and neighbors and in protecting the environment. Lubrizol's attention begins very early in the life of a product with their New Chemical Introduction Process (NCIP) that evaluates and manages all aspects of new chemical introduction from inception to production. A second process, New Chemical Issues Assessment (NCIA), ensures that pollution prevention, inherent safety, and Product Stewardship consideration are addressed starting at invention and continuing through development. Additionally, any new process for the Deer Park plant would under go further safety analysis. A Process Hazard Analysis is performed on all expansion or modifications to a manufacturing process costing more than $200,000 dollars before being put into service, whether they are covered under OSHA PSM or EPA RMP. We emphasize prevention of incidents, however, we do have a very proactive Emergency Response Program. We have emergency response teams in the plant 24 hours a day. The plant has more than 50 people trained in emergency response and a staff of over ninety people who are on an emergency response paging system. Emergency response personnel at Lubrizol's Bayport facility receive more than 3,500 hours of training annually. In addition, Lubrizol is a active member of Channel Industries Mutual Aide (CIMA), the largest chemical plant mutual aide organization in the world, in the event assistance from neighboring chemical plants should be required. We work closely with our Local Emergency Planning committee (LEPC) and Community Advisory Council (CAC). We are also active members of the Chemical Manufactures Association (CMA) Responsible Careb program. Facility and regulated substances handled: Lubrizo l's Bayport facility was founded in 1967 and is located on 190 acres in the Bayport Industrial Complex near the city of LaPorte. The plant is staffed by more than 100 full-time Lubrizol employees and more than 30 contractors. Each year the plant is recognized for community involvement in such areas as Partners in Education, Junior Achievement, Texas Scholars, D.A.R.E., Boy Scouts and Girl Scouts, YMCA and YWCA, Boys and Girls Harbor, and various charitable events. The Lubrizol Bayport plant manufactures specialty chemical additives for lubricating oils used in gasoline and diesel engines, automatic transmissions, gear drives, marine engines and two stroke engine oils. It also manufactures specialty chemicals used in fiber dyes, water treatment chemicals and personal care products. One of the manufacturing processes at the Bayport plant uses Boron Trifluoride and Hydrazine as raw materials. Both of these chemicals are covered under the RMP rule and both are toxics. Boron Trifluo ride is the Worst-case Scenario toxic chemical at the facility. It is received in tube trailers. The worst case is a rupture of one tubes, spilling the entire contents. Hydrazine is another toxic chemical used in the same process. Lubrizol Bayport handles this material on-site and inventories it in a storage tank. Another manufacturing process at the Bayport plant uses 2-Methylpropene, Oleum and Acrylonitrile. 2-Methylpropene is listed as a flammable and Oleum and Acrylonitrile are considered toxic chemicals. 2- Methylpropene is the flammable Worst-case Scenario for the Bayport plant. 2-Methylpropene is contained in a large storage tanks. The flammable Worst-case Scenario for the Bayport plant would be a catastrophic failure of this tank releasing the entire contents, resulting in a vapor cloud explosion. Oleum, a toxic chemical, is also used in this process. Oleum is also contained ina large storage tank. The other RMP listed chemical used in this process is Acrylonitrile. Acryl onitrile is a liquid at atmospheric conditions and is contained in a tank farm. Lubrizol is always looking for opportunities to reduce risk by reducing inventory. When reviewing Acrylonitrile we realized that we had more inventory that we had to have, so we have taken the largest Acrylonitrile tank out of service. The current storage tank holds less than half of the amount held in the original tank. We also raised the containment dike walls to minimize the surface area of the pool that would form, and thus reducing the impact distance of a spill, if it should occur. Worst-case scenarios and alternate release scenarios: The Bayport plant receives Boron Trifluoride in a tube trailer. The Worst-case Scenario for this listed toxic chemical is the rupture of a tube, releasing the entire contents in 10 minutes. This event would have an off-site consequence and would impact the community. For this scenario active and passive safeguards were not considered. The OCA Guidance document was used to determine this end point. The Bayport plant receives 2-Methylpropene, a listed flammable chemical, by rail car and stores it in a large storage tank. The flammable Worst-case Scenario presented in the RMP is the catastrophic failure of this storage tank, releasing the entire contents and resulting in a vapor cloud explosion. This event would have an off-site impact that would primarily impact our industrial neighbors. The OCA Guidance document was used to determine this end-point. The Alternate Release Scenario for Boron Trifluoride is a failure of one of the high pressure fittings on the trailer. This event would have an off-site impact that would primarily impact our industrial neighbors. An Alternate Release Scenario was developed Hydrazine, also a toxic. The Hydrazine we have on site is a 64% solution in water. Hydrazine is contained on site in a stored tank. The event chosen was the failure of a hose during transfer from a tank truck to the storage tank. This event would have an off-site impact, that would just barely make it off-site. An Alternate Release Scenario was developed for Oleum, also a toxic. We contain Oleum on site in a storage tank. The event chosen was the failure of a hose during the unloading of a rail car. This event would have an off-site impact, that would just barely make it off-site. An Alternate Release Scenario was developed for Acrylonitrile, also a toxic. The event chosen was the failure of a hose during the unloading of a tank truck. This event would have an off-site impact, that would just barely make it off-site. General accidental release prevention program and chemical specific-prevention steps: Lubrizol's Bayport plant emphasizes prevention of incidents while maintaining an exceptional Emergency Response Program, cooperation with its neighboring chemical plants through Channel Industries Mutual Aide (CIMA) and open dialog with the community through participation in the La Porte Local Emergency Planning Committee (LEPC) and the local Community Advisory Council (CAC). Our accidental release prevention program starts with hazard identification and risk minimization by our corporate offices at the research and development stages of a product life cycle. The Bayport plant also has a very active Process Hazard Analysis (PHA) program. In addition to following the requirements of the OSHA PSM regulation requirements for PHAs, the plant has extended the use of PHAs beyond those requirements to include non-covered processes. For new facilities or modifications, the Bayport plant uses generally accepted industry standards and practices. In addition, the plant has developed a multi-discipline set of Texas Standards for engineering, design, and construction standards and practices to be followed when industry standards and practices are not available. To insure that any new facility or facility modification is constructed according to good standards and practices the plant has a contractor qualification program. All contractor craftsmen must receive training from the Houston Area Contractors Safety Council (HACSC). Part of the training received at the HACSC is site specific to the Lubrizol facility. Hot Work Permits are required before any welding, braising, or any other activity that could generate a source of ignition. The Hot Work Permit documents that fire prevention and protection have been considered prior to beginning hot work. A key component of the Hot Work Permit is the requirement to have a "Face to Face" meeting at the work site between the craftsman doing the work and the operator representative authorizing the work. Permits are required for any type of work, including "Tank Entry", Line Breaking" or just "General Work". Before a new or modified facility is put into operation, a Pre-Startup Safety Review (PSSR) is conducted. The PSSR is a review, by a multi-discipline team, to confirm that the equipment is in accordance with design specifications and t hat adequate safety, operating, maintenance, and emergency procedures are in place. Operating procedures have been written for all of our processes, and they identify safe operating limits, consequences of deviation from those limits and corrective action to be taken if there is a deviation from limits. In addition, operating personnel receive training on the safe operation of their processes and are trained on process modifications as they occur as part of the Management of Change process. There are also some prevention programs that focus on keeping an existing operating process safe as changes are made. The Lubrizol Bayport plant follows a formal Management of Change (MOC) procedure. The purpose of the MOC procedure is to assure that the technical basis of the change is understood and that the impact of safety and health is considered prior to the change. Inspection and testing of existing pipe and equipment is a key part of the plants Mechanical Integrity program. Piping and eq uipment are periodically inspected or tested to assure that they meet the design specifications. If deterioration is detected, the piping or piece of equipment is repaired or replaced. This program identifies potential failures before they occur and is a very important part of operating the plant safely. The Lubrizol Bayport plant has a very active PSM Compliance Audit Program. The purpose of the audit is to make sure that all of the prevention programs are working and to provide a tool to stimulate improvement. A procedure has been established to audit the entire plant once a year, and to conduct an audit on a different process unit each quarter. An employee safety program that we feel is very effective in reducing risk is called Safety Through Employee Participation (STEP). This is a voluntary observation and feed-back program. Approximately 85% of our employees have elected to participate. The STEP program identifies many near misses. Plant safety teams will then discuss and make recommendations to resolve potential problem areas. There is a heavy emphasis on "Near miss investigations" to prevent safety problems from occurring. Boron Trifluoride is one of the Bayport plant's RMP plan chemicals. It is a listed toxic chemical. All the prevention programs discussed above are followed in the processing unit that uses this chemical. However, there are specific preventative measures that apply to the Boron Trifluoride area. The piping used to handle Boron Trifluoride is designed and built to handle very high pressures. If there were a leak, water is very effective in knocking down Boron Trifluoride vapors. The tube trailer is surrounded by a sprinkler system and there are fire monitors near by. The tube trailer is also housed under a protective roof and the valves on the tubes are also protected. 2-Methylpropene is another of the Bayport plant's RMP plan chemicals. It is a listed flammable chemical. All the standard, prevention programs listed above, except thos e that apply specifically to Boron Trifuoride, are followed in the process where 2-Methylpropene is used. However, there are some specific preventative measures which apply to the 2-methylpropene area. This unit has a fugitive emissions monitoring program to check for leaks, not only because of the 2-Methylpropene, but because the presence of Acrylonitrile. Fugitive emissions checks are conducted every three months. If leaks are detected they are repaired. Also, we have strategically placed flammable gas detectors with alarms to detect leaks should they occur. Because this material is flammable, the storage tanks and rail car area are covered with sprinkler systems. There are also fire water curtains to assist in isolating the storage tanks from the rest of the plant in the event a release should occur. This unit is also equipped with a flare that can be used to flare off (burn) excess material should an upset condition occur. Five year accident history: There have been no releases of EPA covered chemicals at Lubrizol's Bayport plant in the past five years that have had an adverse impact on the community or that would meet the EPA requirements for reporting. Emergency response program: In the event of an accidental release, the plant alarm system activates the Emergency Response Team to mitigate the incident. Security, through our alpha-numeric paging system, immediately sends out information to be provided to the public through our local LEPC, and uses our hotline to advise our immediate neighbors. Training is provided throughout the year on various aspects of our Emergency Response Program, and drills are conducted on-site, with our mutual aid organization, and our local LEPC. Planned changes to improve safety: The Lubrizol Corporation has developed "Safety Excellence", a code of 17 management practices designed to make Lubrizol a leader in safety & health performance. Each practice was identified by benchmarking with 11 world class safety and health performers. Safety Excellence, scheduled for rollout worldwide in early 2000, will be fully integrated with the Responsible Care Code of Management Practices. Practices will feature specific criteria, levels of performance that reflect the sophistication of process implementation, suggested measurements, and auditing requirements. The Lubrizol Safety & Health Safety Excellence process is a corporate wide initiative that will move progressive and innovative safety & health practices into all Lubrizol operations including the Deer Park and Bayport plants. |