The Lubrizol Corporation, Painesville Facility - Executive Summary
EXECUTIVE SUMMARY: |
The accidental release prevention and emergency response policies at our facility:
Lubrizol's policy on accidental release prevention and emergency response reflects management's commitment to the guiding principles of the Chemical Manufacture Association (CMA) Responsible Care codes of management practices. This includes a dedicated environmental, health and safety department that works together with plant operations to ensure that a program is in place such that safety and preparedness is maintained for all plant employees and the surrounding community. In addition, Lubrizol complies with all applicable federal, state and local laws pertaining to environmental, safety and health.
As part of the safety program, all new employees go through a safety orientation program. This includes but is not limited to the correct use of personal protection equipment, safe practices on the job and awareness and use of emergency equipment.
A training program is in place to tra
in all employees to reach and maintain proficiency in safe work practices and maintain the skills and knowledge necessary to perform their jobs. All contractors are also required to be a part of the same safety and training programs.
Many layers of protection are developed and put in place on all processes to prevent accidental releases. Equipment is expertly designed according to strict engineering standards. Safety reviews are conducted on new and modified processes and equipment during design and before start-up. A maintenance and inspection program is conducted and documented to ensure facility soundness.
Lubrizol's ongoing process safety program includes a measurement of performance, audits and implementation of corrective actions. This continuous management of the system assures that safety is always the top priority.
If an emergency were to occur, we have a trained and certified emergency response organization staffed 24 hours a day to immediately react and mitigate the emerg
ency. In addition, if we need additional assistance we have an established working relationship and direct communication with the local Lake County Fire Departments. Also, we are in compliance with all applicable federal, state, and local emergency response regulations.
The facility and the regulated substances handled:
Lubrizol Painesville is a specialty manufacturing facility. We are a leading supplier of performance chemicals to international lubricant, fuel and industrial markets.Our process area consists of vessels and associated piping, valves and other miscellaneous equipment.
All of the chemicals listed below are used in processes to manufacture these products. The maximum quantity represents the maximum amount stored in a vessel at any time governed by administrative control through standard operating procedures.
The stationary source, the Lubrizol Corporation's (Lubrizol's) Painesville Plant facility I.D. number 0243000024, handles the following regulated substances:
CAS No. Chemical name Max.Qty. (Lbs.)
302-01-2 Propylene oxide [Oxirane, methyl-] 185,220
108-05-4 Hydrazine 87,080
7783-06-4 Hydrogen sulfide 22,000
75-56-9 Vinyl acetate monomer [Acetic acid ethenyl ester] 56,932
7782-50-5 Chlorine 2,000
75-15-0 Carbon disulfide 119,250
CAS No. Chemical name Max.Qty. (Lbs.)
109-66-0 Pentane 68,485
115-11-7 2-Methylpropene (IOB) 394,830
106-99-0 1,3-Butadiene 160,000
case and alternate release scenario's:
We have one worst-case scenario representing toxins and one worst-case representing flammables. In addition, we have six alternate release scenarios representing the toxins and one representing the flammables. All the toxic scenarios were modeled using the EPA accepted CAMEO/ALOHA air dispersion computer model. The flammable scenarios were conducted by using the EPA's RMP Comp modeling program.
Our worst-case scenario representing the toxins is failure of the storage tank of 22,000 pounds of hydrogen sulfide resulting in direct release over a ten-minute period. Written operating procedures and high-level alarms prevent more than 22,000 pounds from being present in the storage tank. The resulting distance to the endpoint extends offsite, and public receptors are within the distance to the endpoint.
Our worst-case scenario representing the flammables is the simultaneous failure of three 29,000-gallon storage tanks of 2-methylpropene when filled t
o their greatest amount allowed (90%), resulting in a vapor cloud explosion. Written operating procedures and high-level alarms prevent more than a 90% level in any of the three tanks. The resulting distance to the endpoint extends offsite, and public receptors are within the distance to the endpoint.
Because of all the layers of protection in place such as the safe design of the tanks, pressure and level detectors, and safe operating instructions it is highly unlikely that these worst-case scenario's would ever occur.
Our alternate release scenario's are as follows:
Hydrogen sulfide: a gasket failure at a flange on a two-inch pipe. With active measures in place such as excess flow valves, hydrogen sulfide sensor's surrounding the process piping and vessel, and the high odor detection of hydrogen sulfide the release duration would most likely be limited to 10 minutes or less. The resulting distance to the endpoint extends offsite, and public receptors are within the distance t
o the endpoint.
Carbon disulfide: release from opening valve prior to maintenance without the line being cleared out ahead of time. The liquid forms a puddle that vaporizes to the atmosphere over a one-hour period. The resulting distance to the endpoint does not extend offsite; therefore no public receptors are within the distance to the endpoint. This scenario was based on a real incident.
Propylene Oxide: failure of a transfer line from off-loading a tank car to the storage tank. Chemical escapes as a liquid and forms an evaporating puddle that vaporizes over a one-hour period. The resulting distance to the endpoint does not extend offsite; therefore no public receptors are within the distance to the endpoint.
Vinyl acetate: pump seal failure in an enclosed dike area. Puddle is formed and evaporates over a one-hour period. The resulting distance to the endpoint does not extend offsite; therefore no public receptors are within the distance to the endpoint.
Hydrazine: misvalving du
ring loading of material to a weigh tank resulting in a spill contained within an enclosed dike. Puddle is formed and evaporates over a one-hour period. The resulting distance to the endpoint does not extend offsite; therefore no public receptors are within the distance to the endpoint.
Chlorine: gasket failure at the flexible hose connection to the valve of the cylinder. Vapor release duration limited due to area sensors, strong odor and emergency response. The resulting distance to the endpoint extends offsite, and public receptors are within the distance to the endpoint.
2-Methylpropene: pump seal failure resulting in release of vapor limited to five minutes due to excess flow valve slamming shut. A vapor cloud fire results that is suppressed by a water deluge system. The resulting distance to the endpoint does not extend offsite; therefore no public receptors are within the distance to the endpoint.
The general accidental release prevention program and chemical-specific prevent
Lubrizol's Painesville's facility is in compliance with the OSHA's Process Safety Management (PSM) rule and EPA's accident prevention rule. Some of the key elements are as follows:
For each covered process, there are on hand all associated process safety information, many layers of protection in place including safe design of equipment, emergency and control devices and instrumentation, safe operational procedures, monitoring equipment, back-up systems, maintenance and inspection programs and an improved training system for all employees. All of these mechanisms are continuously being reviewed and revised to assure that our facility operates in the safest and most efficient manner.
The five-year accident history:
There was one incident at the facility in the past five years that meets the definition of the EPA Risk Management Program (RMP) reporting requirements. There was a two-pound release of chlorine gas on 7/23/98. An employee inhaled some vapors and was treated at
a local hospital. There were no offsite impacts involved with this release.
The emergency response program:
Lubrizol maintains an emergency response policy at its stationary site located at 155 Freedom Rd., Painesville, Ohio 44077. There is an emergency response organization (ERO) in place twenty-four hours a day. This consists of an incident commander and trained emergency responders. There are also certified hazardous material technicians, EMT's and paramedics on staff. The emergency response policy is documented within Lubrizol Painesville's "Emergency Response Plan" manual. The emergency response plan includes procedures for the notification of the local fire authorities and the local emergency planning committee (LEPC). There is a public notification and alert system in place that will notify the surrounding community as needed. There is continuous training of personnel on and offsite and in conjunction with the local emergency responders. The emergency response plan is curre
ntly and continuosly being updated as changes are needed.
Planned changes to improve safety:
A new environmental, health and safety corrective action system was recently put in place to address all odors, spills and injuries that may occur at our facility. This system identifies the root cause of the problem and a responsible party to put immediate corrective actions in place to prevent the incident from occurring again. A system is in place to review the progress and check the effectiveness of the corrective actions.
From this there has been new training developed plant-wide that addresses a multitude of areas that will improve the overall environmental, health and safety of our facility and surrounding community. In addition, all the RMP covered processes undergo a process hazard analysis on a routine basis to identify any poten
tial hazards. If there are any concerns, projects are initiated to address the concerns as part of our continuous capital improvement process.
Some recent projects completed related to RMP regulated processes include upgrades to fire suppressant systems, level transmitters on vessels, replacement of liquid and vent piping, installation of safety barricades surrounding storage vessels, replacement of metering devices on material feed lines and installation of additional emergency equipment.
These are some examples of Lubrizol's philosophy of responsibly maintaining a safe environment for its employees and the surrounding community.