Ethyl Petroleum Aditives, Inc. - Executive Summary |
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Ethyl Petroleum Additives, Inc. Risk Management Program Executive Summary 1.0 Introduction Ethyl Petroleum Additives, Inc., operates a petroleum additives manufacturing facility at 151 L.E. Barry Road, in Natchez, Adams County, Mississippi. Ammonia and oleum are among the raw materials used in the manufacturing process at the facility. Due to the quantity of these chemicals stored at the facility, the facility is subject to the United States Environmental Protection Agency's Risk Management Program. The purpose of the Risk Management Program is to prevent or reduce the severity of an accidental release of a hazardous chemical. Among the requirements of the Risk Management Program is the submission of a Risk Management Plan (RMP) summarizing the overall program. The following information is an Executive Summary of the information contained in the Risk Management Program. This Executive Summary includes a description of the company's accidental release prevent ion and safety policies, a facility and process description, an explanation of the accidental release scenarios studied, a five-year accident history, and details of the facility's accidental release prevention program. 2.0 Accidental Release Prevention and Emergency Response Policies Ethyl Petroleum Additives takes great care to ensure the safety of its employees, visitors, and the surrounding community. Corporate and facility policies and safety programs are stressed in all aspects of facility operations. 2.1 Ethyl Corporate Policies Ethyl Petroleum Additives adheres to corporate environmental and safety policies established by its corporate parent, Ethyl Corporation, of Richmond, Virginia. These policies advocate safety from the design process through actual production. Ethyl Corporation's Process Technology Program is intended to ensure technical adequacy and safety while developing new products or revising existing products. For each new or modified pr oduct or process, the program includes an evaluation of materials of construction, an evaluation of process chemistry, management of change orders, and adequate management of the final manufacturing process. The program is implemented through written approvals from involved parties-safety, engineering, management, and production- and training at each step of the design and implementation process. Ethyl Corporation's Process Safety Manual is intended as a guide for Ethyl facilities in the development of Process Safety Management (PSM) Programs required by OSHA. The manual describes each required element of the PSM Program, its background policy, and program requirements. Policies and procedures for confined space entry, process safety and contractor qualification procedures, and incident investigation procedures are included. Each facility then develops its PSM Program based on this guidance. A corporate team audits the facility's compliance with the PSM Program every three years. 2.2 Facility Policies Based upon the guidance offered by the corporate policies, Ethyl Petroleum Additives Natchez facility has developed site-specific environmental and safety programs and procedures to further ensure safe operations. The facility's Hazard Communication program was developed to provide employees with information on the chemical hazards of the workplace. With this awareness, employees can make informed decisions when handling and processing the chemicals used at the facility. A Material Safety Data Sheet (MSDS) is required for any new chemical introduced into the facility and is accessible to anyone requesting it. Containers holding hazardous chemicals are clearly labeled accordingly to protect employees. Employees are trained on the potential hazards of the chemicals used in the workplace and offsite contractors are notified of the hazards present during orientation sessions. The role of the facility's Chemical Hygiene Plan i s to describe laboratory safety procedures including personal protective equipment to be used, control equipment inventories, employee training programs, medical programs, and safety inspections. The Emergency Response Program is intended to identify the duties and responsibilities of facility personnel in the event of a facility emergency. The program includes notification procedures for offsite responders and the public, a description of the responsibilities of facility personnel, procedures for communicating with the public, locations and quantities of hazardous chemicals present, medical and first aid procedures, personal protective equipment required, procedures for hazardous materials disposition and decontamination, and a critique of the response and incident investigation. Ethyl Petroleum Additives' Safety Manual describes the facility's comprehensive safety program and provides rules and guidance for safe working methods in the operation, maintenance, and construction of the facility. The manual includes administrative procedures for blood borne pathogen control, housekeeping, traffic, and smoking and procedures for the safe use of facility equipment such as ladders, compressed gases, and cranes. Also, the Safety Manual explains the required personal protective equipment and details safe work practices including lockout and tagout, hot work permitting, confined space entry, forklift operation, and flammable and toxic chemical handling. Employees are trained in the safe operation of the facility. 3.0 Facility and Process Description Ethyl Petroleum Additives' Natchez facility is located in Adams County Industrial Park, approximately 2 miles southwest of downtown Natchez and 3 miles west of U.S. Highway 61. The property elevation is approximately 85 feet above sea level. Improvements on the property include an office, 3 warehouses, 3 motor control buildings, a maintenance building and shop, a boiler building, a contro l building and lab, a break room, multiple aboveground storage tanks, and chemical process vessels and piping. The facility employs approximately 40 people engaged in the production of motor oil and lubricating oil additives. The processes involving the chemicals subject to the Risk Management Program are the Sulfonation process and the Ammonia Neutralization process. In Sulfonation, alkylate (alphaolefin alkylbenzene) is mixed with oleum (20 percent fuming sulfuric acid) in an in-line static mixer where the alkylate is reacted with sulfur trioxide to form sulfonic acid. Unreacted oleum is separated from the sulfonic acid in settlers and returned to the oleum producer for regeneration. In Ammonia Neutralization, after the spent acid has been removed, the sulfonic acid is treated (neutralized) with ammonia using an in-line static mixer to produce ammonium sulfonate. The ammonium sulfonate is a raw material in the petroleum additives production. 4.0 Regulated Sub stances Present As discussed in the previous section, there are two substances used at the facility that are subject to the Risk Management Program regulations. Oleum is stored and used at the facility with a maximum inventory of 436,800 pounds. Ammonia is stored and used at the facility with a maximum inventory of 51,000 pounds. 5.0 Release Scenarios As required by the Risk Management Program regulations, Ethyl Petroleum Additives determined the offsite impact of an accidental release for four release scenarios-a worst case release for each chemical and an alternate release scenario for each chemical. The regulations define the worst case release for each chemical as the loss of the entire maximum inventory over a 10-minute period. The regulations require that the offsite impact of the worst case release be calculated using very conservative, worst case, weather conditions. Specifically, a wind speed of 1.5 meters/second and an F atmospheric stability class. USEPA has published reference tables to be used in calculating the distance offsite that an accidental release would travel. These tables employ very conservative assumptions and therefore provide conservative estimates of the offsite distance that an accidental release would travel. Ethyl Petroleum Additives used the USEPA reference tables to calculate a worst-case offsite impact radius of 0.43 miles for oleum and 7.50 miles for ammonia. It is estimated that no residential receptors would reside within the 0.43-mile radius of the oleum release. Ethyl Petroleum Additives also calculated offsite impact distances for alternate, more realistic accidental release scenarios. These release scenarios took into consideration safety systems and controls in place to reduce the severity of an accidental release and considered a more realistic release rate of the hazardous chemicals. For oleum, overfilling the storage vessel was determined to be the most likely accidental releas e scenario even though no serious accidental oleum releases have occurred at the facility during the five-year accident history period. An oleum offsite impact radius of 0.19 miles was calculated using the USEPA reference tables and a quantity of 9,828 pounds released over a 10- minute period. It is estimated that no residential receptors would reside within the 0.19-mile radius of the oleum release. For ammonia, a rupture disk or relief valve failure was the most likely accidental release scenario even though no serious accidental ammonia releases have ever occurred at the facility. An ammonia offsite impact radius of 0.31 miles was calculated using the USEPA reference tables and a quantity of 500 pounds released over a 5-minute period. It is estimated that no residential receptors would reside within the 0.31-mile radius of the ammonia release. 6.0 Accidental Release Prevention Program The facility's accident prevention program includes each of the elements required by the Risk Management Program regulations. Since the facility is also subject to OSHA's PSM Program requirements, most of the prevention program elements were in place prior to the development of the Risk Management Program. The key ingredients of the accident prevention program are described below. 6.1 Process Safety Information Ethyl Petroleum Additives has gathered the necessary documentation of safety information on the covered processes including the maximum/minimum pressure, temperature, and inventory in covered tanks, the tank and piping materials of construction, documentation of design codes and standards used for the tanks and piping, and a description of safety systems in place. This information is periodically reviewed to ensure that the processes are constructed according to good engineering practices. 6.2 Process Hazard Analysis A Process Hazard Analysis (PHA) has been conducted on the covered processes to determine the potential hazar ds of the processes and to determine the possible equipment failures or human errors that could lead to a release. The results of the PHA were used to determine the appropriate safeguards needed to prevent failures or errors that could lead to a release. 6.3 Operating Procedures Written operating procedures have been developed for normal operations and for emergency shutdown in the event of an impending accidental release. The purpose of the written operating procedures is to make sure that each employee before operating a process is knowledgeable of the correct operating methods, is aware of the chemical hazards present, and is qualified to respond correctly in an emergency situation. 6.4 Training New employees are trained in the safe operation of plant processes and their performance is periodically evaluated. As needed, refresher training is provided. Employees are given safety training and are trained in the emergency response procedures discussed in Sec tion 8.0. 6.5 Maintenance Written maintenance procedures and training reinforce the safe work practices of maintenance employees and ensure that they are made aware of the potential hazards of the plant processes. A hot work permitting program, lockout tagout procedures, and confined space entry procedures are in place to protect maintenance workers while servicing equipment. Preventive maintenance inspections and testing are scheduled based on manufacturers' recommendations so that aging equipment can be replaced before failing and possibly causing an accidental release. 7.0 Five Year Accident History No serious accidents have occurred at the facility in the last five years. 8.0 Emergency Response Program The Emergency Response Program identifies the duties and responsibilities of facility personnel in the event of a facility emergency. The program includes notification procedures for offsite responders and the public, a description of the respons ibilities of facility personnel, procedures for communicating with the public, locations and quantities of hazardous chemicals present, medical and first aid procedures, personal protective equipment required, procedures for hazardous materials disposition and decontamination, and a critique of the response and incident investigation. Periodically, the facility stages a mock disaster drill that is coordinated with local emergency response agencies and nearby industries. Plant fire alarms are tested every other week, plant chemical alarms are tested every other week, fire extinguishers are tested monthly, and air packs are tested weekly to ensure that if an emergency occurs, the facility can respond quickly and effectively. 9.0 Planned Future Safety Enhancements Planned safety enhancements include the continued development of the facility's preventive maintenance program, ongoing safety training and new employee orientation, and emergency response drills and mo ck emergency coordination with local emergency responders. Together, these programs will continue to ensure the safety of employees and the community. |