The Valvoline Company - Executive Summary |
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RISK MANAGEMENT PLAN THE VALVOLINE COMPANY PYROIL PLANT HERNANDO, MISSISSIPPI EXECUTIVE SUMMARY The Valvoline Company (Valvoline) has a long-standing commitment to worker and public safety and strives to continuously improve safety and environmental operations of its facilities. This commitment is demonstrated by significant investments of resources to prevent releases of hazardous substances and for accident prevention, such as employee participation and training, and considering safety in the design, installation, operation, and maintenance of processes. Valvoline policy is to implement practical controls to prevent foreseeable releases of hazardous substances. However, if a releases does occur, the Hernando Plant has a well-defined emergency action plan and trained personnel to control and contain the release. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCE The Valvoline Pyroil Plant, located in Hernando, Mississippi, produces a variety of car-care products. The facility consists of an outdoor tank farm and administrative and manufacturing buildings where the finished products are processed and packaged (Please see Valvplant.jpg). These products are well known under the Pyroil brand name and the manufacturing facility is ISO 9002 certified. The plant has an excellent safety and environmental record, with a high level of employee involvement and commitment to operational excellence. The Pyroil plant has one manufacturing process (starting fluid manufacturing process) that uses a flammable substance - ethyl ether - listed in the EPA's Risk Management Program (RMP) rule. There are no toxic or reactive regulated substances involved at the site. The starting fluid manufacturing process involving ethyl ether consists of storage, blending and packaging. The process operations are covered by OSHA's process safety management (PSM) standard and are considered Program Level 3 for the RMP rule. A product distribution center, located on adjoining property (separated by railroad tracks), warehouses the finished products, containing ethyl ether. The warehouse is also included in this RMP as a separate process because the total quantity in small product containers (7.8 and 11 avdp oz. cans) may exceed the threshold quantity sometime during peak storage season. The warehouse is considered eligible for Program Level 1 for the RMP rule because: 1. There are no public receptors within a distance to an endpoint from a worst-case scenario; 2. The warehouse has had no release of a regulated substance in the past five years resulting in offsite exposure or consequences; and 3. The warehouse emergency response activities are coordinated with the local responders. PROCESS 1. STARTING FLUID MANUFACTURING PROCESS ACCIDENTAL RELEASE PREVENTION PROGRAM The following is a summary of the accidental release prevention program in plac e for the starting fluid manufacturing process at the Hernando, MS plant. Because the plant process regulated by the Environmental Protection Agency's (EPA's) risk management program (RMP) regulation is also subject to the Occupational Safety and Health Administration's (OSHA's) process safety management (PSM) standard, this summary addresses each of the OSHA PSM elements and describes the management systems in place to implement the accidental release prevention program. Employee Participation The Pyroil plant conducts its business using a teamwork approach. A number of business and operational teams provide an active forum for employee participation in the implementation of PSM standard elements. Examples of employee involvement range from participation in the initial process hazard analysis in 1993 to recent development of operating procedures. Employees have access to all information created as a part of the prevention program. Specific ways that employees can be involved i n the accidental release prevention program are documented in an employee participation plan in the PSM Manual. In addition, specific employee participation activities include operations teams, plant staff, and business team meetings, and periodic safety meetings to discuss specific safety-related topics. Meeting attendance sheets are maintained as primary documentation. Process Safety Information The Pyroil plant develops and updates a variety of technical documents that are used to help maintain safe operations of the process. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis and configuration information. A table summarizing the reference documents and their locations is readily available along with specific procedures for maintaining current and accurate process safety information in the PSM Manual. Chemical-specific information, including exposure hazards and emergency response exposure treatment considerations, is provided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. The Pyroil plant has established safety-related limits for specific process parameters (e.g., level, composition) in process documentation. The Pyroil plant ensures that the process is maintained within these limits using process controls and monitoring instruments, highly-trained personnel, and protective instrument systems (e.g., automated shutdown). The Pyroil plant also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, and electrical rating of equipment. This information, in combination with written procedures and trained personnel, provides a bas is for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. Process Hazard Analysis (PHA) The Valvoline Pyroil plant has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. The Valvoline Pyroil plant primarily uses a combination of What-If, checklist and hazard and operability (HAZOP) analysis techniques to perform these evaluations. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accidental release prevention and mitigation measures, and the team makes suggestions for additional safeguar ds when the team believes such measures are needed. The PHA team findings are evaluated by local and corporate management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk ranking receive prompt attention. All approved mitigation options in response to PHA team findings are tracked until they are completed. The formal resolution of each finding is documented and retained. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the plant periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every five (5) years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained. Operating Procedures The Pyroil plant maintains written procedures that address various modes of process operations, such as (1) process startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) and normal shutdown. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. These procedures are periodically reviewed and annually certified as current and accurate. The procedures are kept current and accurate by revising them as necessary to reflect changes made through the management of change process. In addition, the Pyroil plant has established documentation requirements for logging key process parameters. This documentation also provides guidance on how to respond to a deviation from upper or lower limits forspecific process or equipment parameters. This information, along with written operating procedures, isreadily available to operators in the process area and for other personnel to use as necessary to safelyperform their tasks. Training To complement the written procedures for process operations, the Pyroil plant has implemented a comprehensive training program for all employees involved in process operations. New employees receive basic training in Pyroil plant operations if they are not already familiar with such operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specificduties and tasks. After operators demonstrate (e.g., through skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every 3 years. All of this training is documented for each operator, including the means used to verify that the operator understood the training. For specific safety (e.g., fork truck operation) and/or regulatory (hazard communications) issues, Valvoline has developed a customized computer-based training (CBT) program that provides interactive training for all employees on a routine basis. Contractors The Pyroil plant uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the Pyroil plant has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what theyshould do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform Pyroilplant personnel of any hazards found during their work. This is accomplished by providing contractors with a thorough site orientation that includes (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices, prior to their beginning work. In addition, the Valvoline Pyroil plant evaluates contractor safety programs and performance during the selection of a contractor. Pyroil plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-startup Safety Review (PSSR) The Pyroil plant conducts a PSSR for any new facility or facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accidental release prevention program requirements are properly implemented. Mechanical Integrity The Valvoline Pyroil plant has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these activities form a system that maintainsthe mechanical integrity of the process. Maintenance personnel receive trai ning on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their jobs in a safe manner. Written procedures help ensure that work is performed in a consistent manner and they provide a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or a management of change team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. Another integral part of the mechanical integrity program is quality assurance. The Valvoline Pyroil plant incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. Safe Work Practices The Pyroil plant has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous substances before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change The Pyro il plant has a comprehensive system to manage changes to all covered processes. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change. Incident Investigation The Pyroil plant promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire or explosion, major property damage, environmental loss, or personal injury. The goal of each investigation is t o determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to Pyroil plant management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are resolved. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained for at least five (5) years so that the reports can be reviewed during future PHAs and PHA revalidations. Compliance Audits To help ensure that the accidental release prevention program is functioning properly, the Valvoline Pyroil plant periodically conducts an audit to determine whether the procedures and practices required by the accidental release prevention program are being implemented. Compliance audits are conducted at least every three (3) years. Both hourly and staff personnel participate as audit team members. The audit team develops findings that are forwarded to Pyroil plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are resolved. The final resolution of each finding is documented, and the two most recent audit reports are retained. PROCESS-SPECIFIC SAFEGUARDS TO PREVENT ACCIDENTAL RELEASE SCENARIOS The regulated process at the Valvoline Pyroil plant has hazards that must be managed to ensure continued safe operation. The Pyroil plant has safety features to help (1) prevent occurrence of a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following is a description of existing process-specific safety features applicable to prevention of accidental releases of regulated substance in the f acility. These safeguards, combined with the general prevention program described in the previous sections, collectively help prevent potential accident scenarios that could be caused by equipment failures and human errors. Release Detection / Prevention Ethyl ether storage tank maximum allowable working pressure (MAWP) is 300 psig and this tank is equipped with a spring-loaded pressure relief device set at 100 psig. The other two smaller ethyl ether blend tanks have a MAWP of 200 psig and 300 psig and their spring-loaded pressure relief devices are set at 100 psig and 140 psig, respectively. The normal operating pressure for all three of these ethyl ether storage tanks is 5-8 psig, providing a significant safety margin before challenging the pressure relief devices. All storage tanks' vapor space is blanketed with nitrogen to keep oxygen out. (The nitrogen supply system has an overpressure relief device set at 12 psig). Low oxygen level in th e ether storage tanks reduces overall corrosion rates. Ether with a stabilizer is purchased to minimize formation of hydrogen peroxide (and other ether decomposition products). Each shipment is received with a Certificate of Analysis for the stabilized contents and hydrogen peroxide levels. Ether contains an extremely low level of water, thus minimizing corrosion rate. Ether and starting fluid storage tanks were initially inspected (e.g., wall thickness, weld inspections) in 1995-96 and were reinspected in February, 1999 and recertified. A program is in place to inspect these tanks on a periodic basis. Administrative practice is implemented to close manual valves on each tank in the event of process shutdown (e.g., during weekends, or at night, when the process is shut down). A visual inspection of the ether tank farm is carried out on a regular basis. Containment wall protects storage tanks from external impact (e.g., from tank trail er). Mechanical integrity inspections include daily visual inspection of piping, pumps and associated systems for leaks. Safe work practices (e.g., hot work practice) include cessation of all traffic and construction activities during ether tank trailer unloading; and All flammable solvent storage tanks are equipped with level indication and high level alarm. Release/Fire Containment / Control Tank farm has a concrete floor and grooves cut in the floor to channel small spills to low point drain. The tank farm area is covered by monitor nozzles to cool flammable solvent tanks (including ether storage tanks) in case of external fire. The Pyroil site is in close proximity to Hernando Fire Department with capability of foam solvent pool type fire suppression system. Dual isolation valves are provided for all ether-containing tanks. A fire-safe valve with fusible link on each tank isolates the tank contents from further release. A manual block valve is provided downstream of the firesafe valve. The valve is normally open during process operations. Separate containment areas for tank trailer unloading and solvent storage tanks are provided. Perimeter security fence provides facility access control and prevents entry of unauthorized personnel FIVE-YEAR ACCIDENT HISTORY The Valvoline Pyroil plant has an excellent record of accidental release prevention over the past five (5) years. There has not been any reportable release or accidents involving ethyl ether at the Pyroil plant over the past 5 years. Every incident (including any near-miss) is thoroughly investigated to determine ways to prevent similar incidents from recurring and this is applied to all relevant processes and operations. PLANNED CHANGES TO IMPROVE SAFETY The Starting Fluid fill room will have upgraded fire detection and suppressant systems including UVIR flame sensors, fixed carbon dioxide spray heads, and an auxiliary fo am suppressant extinguishing system. Changes to the blend room include an improved piping/manifold system, ventilation upgrades, and fire resistant coating for all tank supports. PROCESS 2. PRODUCT DISTRIBUTION CENTER (WAREHOUSE) Valvoline has provided many safeguards to prevent and/or mitigate consequences of accidental releases: automatic fire water sprinkler system segregation of products containing ethyl ether to isolate highly-flammable materials control of ignition sources (e.g., only EE-rated fork trucks are allowed) personnel training, including fork truck driver certification program, special fire detectors and alarms for life safety. The WCS does not take credit for any of these safeguards. (Please see file VALP2WC1.jpg) FIVE-YEAR ACCIDENT HISTORY The Valvoline Product Distribution Center (warehouse) has an excellent record of accidental release prevention over the past five (5) years. There has not been any reportable r elease or accidents involving ethyl ether at the Product Distribution Center over the past 5 years. PLANNED CHANGES TO IMPROVE SAFETY It is planned to install a central fire and security alarm system that will automatically dial into the Ashland, Inc. corporate security office that is manned 24 hours a day. EMERGENCY ACTION PROGRAM INFORMATION The Valvoline Pyroil plant and Product Distribution Center maintain a written emergency action program, which is in place to protect worker and public safety as well as the environment and meets the requirements of OSHA's standard found in 29 CFR 1910.38(a). The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including proper first aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notificatio n of local emergency response agencies and the public if a release occurs, and postincident cleanup and decontamination requirements. In addition, the plant has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency action program is updated when necessary based on modifications made to Pyroil plant processes or other Valvoline facilities. The emergency action program changes are administered through the change management system, which includes informing and/or training affected personnel in the changes. The overall emergency response program for the Valvoline Pyroil plant and Product Distribution Center is coordinated with the Desoto County Emergency Management. This coordination includes periodic meetings of the local emergency planning commis sion (LEPC), with local fire / emergency response officials, local government officials, and industry representatives. The Valvoline Pyroil plant has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, the Valvoline Pyroil plant and Product Distribution Center conduct periodic emergency drills that involve the emergency response organizations, and the Pyroil plant provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the Pyroil plant. RISK MANAGEMENT PLAN THE VALVOLINE COMPANY PYROIL PLANT HERNANDO, MISSISSIPPI EXECUTIVE SUMMARY The Valvoline Company (Valvoline) has a long-standing commitment to worker and publ ic safety and strives to continuously improve safety and environmental operations of its facilities. This commitment is demonstrated by significant investments of resources to prevent releases of hazardous substances and for accident prevention, such as employee participation and training, and considering safety in the design, installation, operation, and maintenance of processes. Valvoline policy is to implement practical controls to prevent foreseeable releases of hazardous substances. However, if a releases does occur, the Hernando Plant has a well-defined emergency action plan and trained personnel to control and contain the release. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCE The Valvoline Pyroil Plant, located in Hernando, Mississippi, produces a variety of car-care products. The facility consists of an outdoor tank farm and administrative and manufacturing buildings where the finished products are processed and packaged (Please see Valvplant.jpg). These products are well known under the Pyroil brand name and the manufacturing facility is ISO 9002 certified. The plant has an excellent safety and environmental record, with a high level of employee involvement and commitment to operational excellence. The Pyroil plant has one manufacturing process (starting fluid manufacturing process) that uses a flammable substance - ethyl ether - listed in the EPA's Risk Management Program (RMP) rule. There are no toxic or reactive regulated substances involved at the site. The starting fluid manufacturing process involving ethyl ether consists of storage, blending and packaging. The process operations are covered by OSHA's process safety management (PSM) standard and are considered Program Level 3 for the RMP rule. A product distribution center, located on adjoining property (separated by railroad tracks), warehouses the finished products, containing ethyl ether. The warehouse is also included in this RMP as a separate pro cess because the total quantity in small product containers (7.8 and 11 avdp oz. cans) may exceed the threshold quantity sometime during peak storage season. The warehouse is considered eligible for Program Level 1 for the RMP rule because: 1. There are no public receptors within a distance to an endpoint from a worst-case scenario; 2. The warehouse has had no release of a regulated substance in the past five years resulting in offsite exposure or consequences; and 3. The warehouse emergency response activities are coordinated with the local responders. PROCESS 1. STARTING FLUID MANUFACTURING PROCESS ACCIDENTAL RELEASE PREVENTION PROGRAM The following is a summary of the accidental release prevention program in place for the starting fluid manufacturing process at the Hernando, MS plant. Because the plant process regulated by the Environmental Protection Agency's (EPA's) risk management program (RMP) regulation is also subject to t he Occupational Safety and Health Administration's (OSHA's) process safety management (PSM) standard, this summary addresses each of the OSHA PSM elements and describes the management systems in place to implement the accidental release prevention program. Employee Participation The Pyroil plant conducts its business using a teamwork approach. A number of business and operational teams provide an active forum for employee participation in the implementation of PSM standard elements. Examples of employee involvement range from participation in the initial process hazard analysis in 1993 to recent development of operating procedures. Employees have access to all information created as a part of the prevention program. Specific ways that employees can be involved in the accidental release prevention program are documented in an employee participation plan in the PSM Manual. In addition, specific employee participation activities include operations teams, plant staff, and business team meetings, and periodic safety meetings to discuss specific safety-related topics. Meeting attendance sheets are maintained as primary documentation. Process Safety Information The Pyroil plant develops and updates a variety of technical documents that are used to help maintain safe operations of the process. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis and configuration information. A table summarizing the reference documents and their locations is readily available along with specific procedures for maintaining current and accurate process safety information in the PSM Manual. Chemical-specific information, including exposure hazards and emergency response exposure treatment considerations, is provided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address known corrosion concer ns and any known hazards associated with the inadvertent mixing of chemicals. The Pyroil plant has established safety-related limits for specific process parameters (e.g., level, composition) in process documentation. The Pyroil plant ensures that the process is maintained within these limits using process controls and monitoring instruments, highly-trained personnel, and protective instrument systems (e.g., automated shutdown). The Pyroil plant also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, and electrical rating of equipment. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. Pr ocess Hazard Analysis (PHA) The Valvoline Pyroil plant has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. The Valvoline Pyroil plant primarily uses a combination of What-If, checklist and hazard and operability (HAZOP) analysis techniques to perform these evaluations. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accidental release prevention and mitigation measures, and the team makes suggestions for additional safeguards when the team believes such measures are needed. The PHA team findings are evaluated by local and corporate management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk ranking receive prompt attention. All approved mitigation options in response to PHA team findings are tracked until they are completed. The formal resolution of each finding is documented and retained. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the plant periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every five (5) years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained. Operating Procedures Th e Pyroil plant maintains written procedures that address various modes of process operations, such as (1) process startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) and normal shutdown. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. These procedures are periodically reviewed and annually certified as current and accurate. The procedures are kept current and accurate by revising them as necessary to reflect changes made through the management of change process. In addition, the Pyroil plant has established documentation requirements for logging key process parameters. This documentation also provides guidance on how to respond to a deviation from upper or lower limits forspecific process or equipment parameters. This information, along with written operating procedures, isreadily available to operators in the process area and for other personnel to use as neces sary to safelyperform their tasks. Training To complement the written procedures for process operations, the Pyroil plant has implemented a comprehensive training program for all employees involved in process operations. New employees receive basic training in Pyroil plant operations if they are not already familiar with such operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specificduties and tasks. After operators demonstrate (e.g., through skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every 3 years. All of this training is documented for each operator, including the means used to verify that the operator understood the training. For specific safety (e.g., fork truck operation) and/or regulatory (hazard communications) issues, Valvoline has developed a customized computer-based training (CBT) program that provides interactive training for all employees on a routine basis. Contractors The Pyroil plant uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the Pyroil plant has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what theyshould do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform Pyroilplant personnel of any hazards found during their work. This is accomplished by providing contractors with a thorough site orientation that includes (1) a process o verview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices, prior to their beginning work. In addition, the Valvoline Pyroil plant evaluates contractor safety programs and performance during the selection of a contractor. Pyroil plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-startup Safety Review (PSSR) The Pyroil plant conducts a PSSR for any new facility or facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accidental release prevention program requirements are properly implemented. Mechanical Integrity The Valvoline Pyroil plant has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these activities form a system that maintainsthe mechanical integrity of the process. Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency resp onse plans, and (5) applicable safe work practices to help ensure that they can perform their jobs in a safe manner. Written procedures help ensure that work is performed in a consistent manner and they provide a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or a management of change team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. Another integral part of the mechanical integrity program is quality assurance. The Valvoline Pyroil plant incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper ma terials and spare parts are used when repairs are made. Safe Work Practices The Pyroil plant has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous substances before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change The Pyroil plant has a comprehensive system to manage changes to all covered processes. This system requires that cha nges to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change. Incident Investigation The Pyroil plant promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire or explosion, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to Pyroil plant management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are resolved. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained for at least five (5) years so that the reports can be reviewed during future PHAs and PHA revalidations. Compliance Audits To help ensure that the accidental release prevention program is functioning properly, the Valvoline Pyroil plant periodically conducts an audit to determine whether the procedures and practices required by the accidental release prevention program are being implemented. Compliance audits are conducted at least every three (3) years. Both hourly and staff personnel participate as audit team members. The audit team develops findings that are forwarded to Pyroil plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are resolved. The final resolution of each finding is documented, and the two most recent audit reports are retained. PROCESS-SPECIFIC SAFEGUARDS TO PREVENT ACCIDENTAL RELEASE SCENARIOS The regulated process at the Valvoline Pyroil plant has hazards that must be managed to ensure continued safe operation. The Pyroil plant has safety features to help (1) prevent occurrence of a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following is a description of existing process-specific safety features applicable to prevention of accidental releases of regulated substance in the facility. These safeguards, combined with the general prevention program descri bed in the previous sections, collectively help prevent potential accident scenarios that could be caused by equipment failures and human errors. Release Detection / Prevention Ethyl ether storage tank maximum allowable working pressure (MAWP) is 300 psig and this tank is equipped with a spring-loaded pressure relief device set at 100 psig. The other two smaller ethyl ether blend tanks have a MAWP of 200 psig and 300 psig and their spring-loaded pressure relief devices are set at 100 psig and 140 psig, respectively. The normal operating pressure for all three of these ethyl ether storage tanks is 5-8 psig, providing a significant safety margin before challenging the pressure relief devices. All storage tanks' vapor space is blanketed with nitrogen to keep oxygen out. (The nitrogen supply system has an overpressure relief device set at 12 psig). Low oxygen level in the ether storage tanks reduces overall corrosion rates. Et her with a stabilizer is purchased to minimize formation of hydrogen peroxide (and other ether decomposition products). Each shipment is received with a Certificate of Analysis for the stabilized contents and hydrogen peroxide levels. Ether contains an extremely low level of water, thus minimizing corrosion rate. Ether and starting fluid storage tanks were initially inspected (e.g., wall thickness, weld inspections) in 1995-96 and were reinspected in February, 1999 and recertified. A program is in place to inspect these tanks on a periodic basis. Administrative practice is implemented to close manual valves on each tank in the event of process shutdown (e.g., during weekends, or at night, when the process is shut down). A visual inspection of the ether tank farm is carried out on a regular basis. Containment wall protects storage tanks from external impact (e.g., from tank trailer). Mechanical integrity inspections in clude daily visual inspection of piping, pumps and associated systems for leaks. Safe work practices (e.g., hot work practice) include cessation of all traffic and construction activities during ether tank trailer unloading; and All flammable solvent storage tanks are equipped with level indication and high level alarm. Release/Fire Containment / Control Tank farm has a concrete floor and grooves cut in the floor to channel small spills to low point drain. The tank farm area is covered by monitor nozzles to cool flammable solvent tanks (including ether storage tanks) in case of external fire. The Pyroil site is in close proximity to Hernando Fire Department with capability of foam solvent pool type fire suppression system. Dual isolation valves are provided for all ether-containing tanks. A fire-safe valve with fusible link on each tank isolates the tank contents from further release. A manual block valve is p rovided downstream of the firesafe valve. The valve is normally open during process operations. Separate containment areas for tank trailer unloading and solvent storage tanks are provided. Perimeter security fence provides facility access control and prevents entry of unauthorized personnel FIVE-YEAR ACCIDENT HISTORY The Valvoline Pyroil plant has an excellent record of accidental release prevention over the past five (5) years. There has not been any reportable release or accidents involving ethyl ether at the Pyroil plant over the past 5 years. Every incident (including any near-miss) is thoroughly investigated to determine ways to prevent similar incidents from recurring and this is applied to all relevant processes and operations. PLANNED CHANGES TO IMPROVE SAFETY The Starting Fluid fill room will have upgraded fire detection and suppressant systems including UVIR flame sensors, fixed carbon dioxide spray heads, and an auxiliary foam suppre ssant extinguishing system. Changes to the blend room include an improved piping/manifold system, ventilation upgrades, and fire resistant coating for all tank supports. PROCESS 2. PRODUCT DISTRIBUTION CENTER (WAREHOUSE) Valvoline has provided many safeguards to prevent and/or mitigate consequences of accidental releases: automatic fire water sprinkler system segregation of products containing ethyl ether to isolate highly-flammable materials control of ignition sources (e.g., only EE-rated fork trucks are allowed) personnel training, including fork truck driver certification program, special fire detectors and alarms for life safety. The WCS does not take credit for any of these safeguards. (Please see file VALP2WC1.jpg) FIVE-YEAR ACCIDENT HISTORY The Valvoline Product Distribution Center (warehouse) has an excellent record of accidental release prevention over the past five (5) years. There has not been any repo rtable release or accidents involving ethyl ether at the Product Distribution Center over the past 5 years. PLANNED CHANGES TO IMPROVE SAFETY It is planned to install a central fire and security alarm system that will automatically dial into the Ashland, Inc. corporate security office that is manned 24 hours a day. EMERGENCY ACTION PROGRAM INFORMATION The Valvoline Pyroil plant and Product Distribution Center maintain a written emergency action program, which is in place to protect worker and public safety as well as the environment and meets the requirements of OSHA's standard found in 29 CFR 1910.38(a). The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including proper first aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacua tion, notification of local emergency response agencies and the public if a release occurs, and postincident cleanup and decontamination requirements. In addition, the plant has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency action program is updated when necessary based on modifications made to Pyroil plant processes or other Valvoline facilities. The emergency action program changes are administered through the change management system, which includes informing and/or training affected personnel in the changes. The overall emergency response program for the Valvoline Pyroil plant and Product Distribution Center is coordinated with the Desoto County Emergency Management. This coordination includes periodic meetings of the local emerge ncy planning commission (LEPC), with local fire / emergency response officials, local government officials, and industry representatives. The Valvoline Pyroil plant has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, the Valvoline Pyroil plant and Product Distribution Center conduct periodic emergency drills that involve the emergency response organizations, and the Pyroil plant provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the Pyroil plant. |