Houston Plant - Executive Summary

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I.  Accidental Release Prevention and Emergency Response Policies 
Safety receives the highest priority at the Ethyl Corporation-Houston Plant manufacturing facility in Pasadena, Texas.  Ethyl's believes that effective safety management requires the concurrent implementation of three basic concepts: 
1. Each individual is responsible and accountable for his or her own safety, 
2. Ethyl Corporation has the responsibility to provide a safe work environment, 
3. As a responsible individual, each employee has a duty to also care for the safety of his coworkers and appropriately discuss safety behavior with each other. 
Management wants to have one of the safest manufacturing facilities in the chemical industry and has set its goal to be "zero OSHA recordable injuries".  Integral to zero OSHA recordable injuries is preventing accidental chemical releases that could potentially harm employees or members of the public. 
The plant maintains detailed manuals with information and 
procedures for its safe operation.  Frequent training sessions provide the employees and contractors the knowledge and skills needed for conducting safe operations.  The manuals also contain detailed information on the nature of the chemicals and equipment present in the plant, the safe modes for operating the equipment and handling the chemicals, and the procedures to be followed in the event of accidental release or other emergency event.   Management supports the active participation of employees in the Channel Industries Mutual Aid organization comprised of the areas neighboring chemical manufacturers.  Routine drills are carried out at various members' facilities to practice emergency responses to hypothetical fire, explosion and chemical release scenarios.  Members of our emergency response teams receive annual training at the Texas A&M Fire School and annual refresher training as Hazmat Technicians.  Many members are certified Emergency Medical Technicians and Fire Fighters wit 
h many years of chemical plant experience. 
II. RMP Regulated Substances at the Ethyl Corporation-Houston Plant 
The Ethyl Corporation-Houston Plant is located approximately one mile north of Highway 225 on N. South Street in Pasadena, Texas.  The plant began operation in 1952.  In 1993 Ethyl sold major portions of the plant to another company.  The present Ethyl plant manufactures over 90,000,000 gallons annually of specialty lubricant additives and serves as a distribution terminal for fuel additives.  None of the chemicals in the fuel additives are covered by the EPA Risk Management Plan rule.  The lubricant additives are oil-based polyalkylphenols, polyaklylphenylamines, and polyisobutylene compounds.  The plant uses three chemicals above the threshold quantities listed the EPA Risk Management Plan rule to carry out the chemical reactions that are part of producing the lubricant additives; chlorine, boron triflruoride, and formaldehyde. 
A 90-ton capacity rail car of chl 
orine is positioned inside the plant to feed the polyisobutylene process where it serves as a reaction promoter. The polyisobutylene process produces oil-based lubricant additives.  The process uses approximately 4 rail cars of chlorine per year.  This annual usage makes it impractical to use the smaller, 1-ton chlorine cylinders.  As a passive mitigation control, only one chlorine rail car is allowed in the plant at any time. 
Boron Trifluoride 
Boron trifluoride is transported to the plant in a truck trailer, which has 8 unitized, 1,650-pound capacity cylinders.  The trailer is positioned at the polyalkylphenol process.  Boron trifluoride is used at a low concentration, as an intermediate reactant in the phenol alkylation process.  The daily usage rate of boron trifluoride per pound of alkylphenol produced is low, so the boron trifluoride truck trailer remains in position for many weeks.  Annual boron trifluoride usage requires about 4 trailer shipments per year.  No back up inventor 
y of boron trifluoride truck trailers are kept at the plant.   
Formaldehyde is brought into the plant by rail car.  The formaldehyde is a solution composed of 44% formaldehyde, 6% methanol, and 50% water.  It is unloaded from the rail car to a 61,000-gallon capacity storage tank (T-1203) in the Mannich dispersant area.  Formaldehyde is one of four materials reacted in oil to produce specialty oil dispersants. 
III.  Worst Case Scenario 
The worst case scenario for chlorine is the structural failure of one, full rail car that releases the 90 tons (180,000 pounds) of gas over a ten-minute period.  The wind speed is assumed to be low at 1.5 meters/second (3.4 miles/hour) with an F-Stability class meteorological condition.  An F-Stability class is a meteorological condition that gives little air turbulence and therefore a low level of mixing and dilution of the released gas. The EPA established the Toxic Endpoint for chlorine, based on the Emergency Response Plan 
ning Guideline-2, to be 0.0087 mg/l.  Using the Look-Up Tables from the EPA Off- Site Consequences Guidance Document the distance to the toxic end point is estimated to be 14 miles. 
The amount of chlorine present at the plant site is limited to one, 90-ton capacity rail car.  The rail car is unloaded in an area of the plant that is isolated from routine rail traffic.  A derailer is placed across the rail tracks and locked on to prevent accidental movement by a train while the rail car is being unloaded.  The rail car is not connected to any other cars and its wheels are chocked. 
IV.  Alternative Release Scenarios 
Boron Trifluoride 
The Alternative Release Scenario for boron trifluoride is the release of a full cylinder because of the failure of a connector at the end of the 3 foot, < inch diameter, stainless steal tubing that leads from the main valve on the cylinder to the valve on the header pipe.   It is estimated that boron trifluoride would be released at an average rate of 10 
8 pounds per minute over a 15 minute period. The wind speed is assumed to be 3.0 meters/second (6.8 miles/hour) with a  
D-Stability class meteorological condition.  A D-Stability class is a meteorological condition that gives little air turbulence and therefore a low level of mixing and dilution of the released gas.  The EPA established the Toxic Endpoint for boron trifluoride, based on the Level of Concern for Extremely Hazardous Substances, to be 0.028 mg/l.  Using the Look-Up Tables from the EPA Off-Site Consequences Guidance Document the distance to the toxic end point is estimated to be 0.60 miles. 
The boron trifluoride unloading area is equipped with a water deluge system designed to generate a water curtain around the trailer.  The high water flow rate from the elevated nozzles creates a water curtain around the trailer that would absorb much of the escaping gas.  The deluge system is activated manually when a significant leak is observed.  The deluge system can be started loca 
lly from multiple locations around the trailer and remotely from the process control room.  A surveillance camera monitors the trailer area 24 hours per day.   
The Alternative Release Scenario for chlorine is a gasket failure at a flanged joint, upstream of the remote operated shutoff valve, in the one-inch unloading line connected to the rail car.  The release rate is assumed to be 240 pounds per minute, which is just below the setting of the rail car's automatic, excess flow, shutoff valve.  It is assumed the leak lasts 20 minutes before the emergency response crew stops it.  The wind speed is assumed to be at 3.0 meters/second (6.8 miles/hour) with a D-Stability class meteorological condition.  A D-Stability class is a meteorological condition that gives little air turbulence and therefore a low level of mixing and dilution of the released gas. The EPA established the Toxic Endpoint for chlorine, based on the Emergency Response Planning Guideline-2, to be 0.0087 mg/l.  Us 
ing the Look-Up Tables from the EPA Off- Site Consequences Guidance Document the distance to the toxic end point is estimated to be 1.86 miles. 
An emergency Chlorine Repair Kit is maintained at the walkway of the chlorine rail car unloading rack.  It has the materials needed to do an emergency-shutoff of the rail car.  Fire fighting equipment on site would spray the downwind area to absorb and disperse the escaping gas.  Five ambient air-monitoring detectors, which surround the rail car, sound an alarm if chlorine above 1 ppm is detected. A surveillance camera monitors the unloading spot 24 hours per day.  Detailed written response procedures are in place.  Operators and emergency response personnel train periodically on the chlorine response procedures. 
The Alternative Release Scenario for formaldehyde is the failure of the 4-inch rubber hose during the unloading of a full rail car.  It is estimated that the 4,400 pounds per minute for a period of 10 minutes would be  
spilled to the curbed concrete pan that is beneath the rail before the valve on the rail car would be closed. The wind speed is assumed to be 3.0 meters/second (6.8 miles/hour) with a D-stability class meteorological condition.  A D-stability class is a meteorological condition that gives little air turbulence and therefore a low level of mixing and dilution of the released gas. The EPA established the Toxic Endpoint for formaldehyde, based on the Emergency Response Planning Guideline-2, to be 0.012 mg/l.  Using the Look-Up Tables from the EPA Off- Site Consequences Guidance Document the distance to the toxic end point is estimated to be 0.19 miles. 
V. General Accidental Release Prevention Program and Chemical Specific Prevention Steps 
The Ethyl Corporation-Houston Plant uses the Process Hazards Analysis method as one means of identifying potential chemical process hazards.  A well-documented ISO style system is in place to track the progress of resolving any potential hazards ident 
ified and to document their final engineered resolution.  A corporate policy for Employee participation in the PHA process written in 1993 is followed.  Employees have full access to the computer based PHA progress tracking system. 
Specific PHA reviews have been conducted for the Chlorine Unloading System, the Boron Trifluoride Unloading System, and the Formaldehyde Unloading and Storage system.   These reviews are periodically renewed as needed for planned process changes, in response to process incidents, or as required by schedule renewal dates. 
Another element of the plant's accidental release prevention is it inspection and maintenance program.  The program is designed to fulfill the requirements of the OSHA Process Safety Management rules. 
A spill reduction team, comprised of employees and management representing all areas of the plant, reviews all releases and spills that occur and evaluates potential release or spill situations.  These reviews provide a second level response 
to correcting and preventing releases or spills through engineered or administrative changes. 
Over arching these programs is plant management's commitment to safe operations.  Constant attention is given to see that the resources and individuals needed for the various prevention programs are available to insure the chemical accident prevention programs, such as the ones mentioned previously, are in place and current. 
VI.  Five Year Accident History 
There have been no accidental releases of chlorine, boron trifluoride, or formaldehyde at the Houston plant during the past five years that have resulted in death, injury, or property damage on-site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. 
VII.  Emergency Response Program 
The Ethyl Houston plant's emergency response program is carried out at three levels.  First, there is a program internal to the Ethyl facilities.  The written emergency response program covers all 
of the plant's facilities and the chemicals used.  All employees and contract personnel receive periodic, mandatory training in the emergency response procedures.  The program is under the leadership of the plant manager and a full time, qualified safety professional.  Second, the plant purchases its security and emergency response equipment from its adjacent neighbor, the Albemarle Corporation.  In the event of an emergency release, fire, or explosion trained security and emergency response personnel respond from Albemarle, MEMC, and Amoco in proportion to the level of need.  Albemarle, MEMC, and Amoco are less than = of a mile away and has both external and internal access to the Ethyl plant at all times.  Finally, Ethyl participates as a member of the Channel Industries Mutual Aid organization (CIMA).  This organizations is composed of over 100 local chemical and petrochemical plants who have an extensive array of fire fighting and emergency rescue equipment which can be quickly mo 
bilized to deal with the all levels of emergency events that range from chemical releases, fires, or explosions.  Semiannual drills are held which cover a wide range of emergency scenarios.  The locations for the drills are rotated among the member's plants to build a broad depth of knowledge among the response personnel.  All of the responders are employees at the member plants who have received training in the various aspects of emergency response (e.g. fire fighting, hazardous materials, first aid, emergency medical treatment, personnel rescue). 
IX. Overview of Plans to Improve Safety 
The plan to improve safety is based on improving the current safety systems and adding carefully selected new programs.  The current safety programs include the Joint Labor and Management Safety Committee, Process Hazard Analyses (initial and periodic renewals), OSHA Process Safety Management systems, employee safety training, and Safety, Health and Environmental Incident Investigations.  A current  
program under improvement is the Incident Investigation Program.  In the past, investigations were directed at recordable incidents and safety performance was measured by tracking the number of OSHA recordable and lost time injuries.  This is being expanded to include minor injuries that do not qualify as OSHA recordable.  Investigating these incidents will allow corrective actions that may preempt more serious injuries.  Including them in the performance measure will help to prevent complacency that might result from just observing very low recordable and lost time injury rates.   
Two new programs planned for the plant are involvement in the OSHA Voluntary Protection Program (VPP) and the development of a Near-Miss Incident Database.  Plant management has committed to the submission of an application for participation in the OSHA Voluntary Protection Program (VPP).  The program requires the joint efforts of labor and management.  Many companies have gained improved safety systems, im 
proved safety performance, and fuller participation by labor in plant safety through their participation in VPP.  Another new program currently planned is the development of a Near-Miss Incident Database.  As currently conceived, the Near-Miss Incident Database will include the basic facts of the incident, the factors that led to the near miss incident, and the corrective actions planned.  The safety improvement is expected from allowing those not involved with the near-miss incidents learning how to prevent themselves from becoming involved in similar near-miss incidents.  The database will be part of the existing wide array of Lotus Notes b databases that cover policies, procedures, and information.  These databases are available to all Houston Plant employees on the plant-wide computer network.
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