The Lubrizol Corporation - Deer Park Plant - Executive Summary |
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EXECUTIVE SUMMARY DEER PARK 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 undergo further safety analysis. A Process Hazard Analysis is performed on all expansions or modifications to a manufacturing process costing more than $200,000 befor e being put into service, whether or not, they are covered under OSHA PSM or EPA RMP. We practice inherent safety principles emphasizing prevention of incidents. Additionally, 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 100 people trained in emergency response and an additional staff of over ninety people on our emergency response paging system. Emergency response personnel at Lubrizol's Deer Park facility receive more than 6,000 hours of training annually. In addition, Lubrizol is an active member of Channel Industries Mutual Aide (CIMA), the largest chemical plant mutual aide organization in the world, in the event that assistance from neighboring chemical plants should be required. We work closely with our Local Emergency Planning Committee (LEPC) and Community Advisory Council (CAC). We also are active supporters of the Chemical Manufactures Association (CMA) Responsible Careb progr am and have received the Management System Verification from CMA. Facility and regulated substances handled: Lubrizol's Deer Park facility was founded in 1951 and is located on 180 acres on Tidal Road. The plant is staffed by more than 500 full-time Lubrizol employees and more than 100 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 numerous other charitable events. The Lubrizol Deer Park plant manufactures specialty chemical additives for lubricating oils used in gasoline and diesel engines, automatic transmissions, gear drives, marine engines and tractors. One of the largest, by volume, products at the plant uses 2-methylpropene (a flammable) as a raw material. The flammable Worst-case Scenario presented in the RMP is the catastrophic failure of a large storage vessel. The Deer Park facility looks for ways to minimize on site inventory and at present time this vessel is not in service and the material is received by pipeline. Several of the specialty chemicals used to manufacture additives for lubricating oils use Chlorine in the process. Chlorine does not remain in the products except in trace amounts. Chlorine is no longer stored on site, but is, received in a 3 inch pipeline and is distributed to dedicated processing units. The toxic Worst-case Scenario is the rupture of the 3 inch Chlorine pipeline releasing. The amount of chlorine on site has been greatly reduced. In 1993, we removed the three Chlorine storage tanks, that had the capability of storing approximately 180,000 pounds and converted them to safeguards by turning them into containment tanks for a potential Chlorine release. Propylene Oxide is also a covered toxic chemical which is handled on site. Propylene Oxide is used in the manufacture of passenger car motor oils, heavy-duty engine oils and automotive and industrial gear oils. It is received in rail cars and Lubrizol Deer Park has a storage tank on site storage. Pentane, a covered flammable chemical is managed at this site. It is used in the manufacturing process of marine diesel engine oils, automatic transmission fluids and other lubricating additive packages. Lubrizol Deer Park has a storage tank that contains this material. Worst-case scenarios and alternate release scenarios: The Worst-case Scenario flammable is 2-methylpropene, a flammable raw material used in one of Lubrizol's processes. The flammable Worst-case Scenario presented in the RMP is the catastrophic failure of a large storage vessel, releasing the entire contents, and results in a vapor cloud explosion. This event would have an off-site impact that would impact our industrial neighbors. The OCA Guidance document was used to determine this end-point. The flammable Alternate Release Scenario is a leak of 2-methylpropene in the process unit, resulting in a sp ill. The spill would vaporize and ignite, resulting in a vapor cloud explosion. This event would result in a minimal off-site consequence, impacting our industrial neighbors. The OCA Guidance document was used to determine this end-point. The Deer Park plant receives Chlorine, via pipeline, from a nearby company. Chlorine, a toxic chemical, is distributed on the plant site, as a liquid, through a 3" pipeline. The Worst-case Scenario is the rupture of this 3" pipeline, releasing the entire contents in10 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 Alternate Release Scenario is a < inch hole in the Chlorine pipeline. The chlorine is released under full line pressure for 20 minutes at which time the flow is stopped. 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. An Alternate Release Scenario was also developed for Propylene Oxide, a toxic chemical. The event chosen was a < inch leak under full line pressure for 20 minutes. This event would have an off-site impact that would primarily impact our industrial neighbors. General accidental release prevention program and chemical specific-prevention steps: Lubrizol's Deer Park plant emphasizes prevention of incidents, while maintaining an excellent emergency response program, good cooperation with its neighboring chemical plants through Channel Industries Mutual Aide (CIMA) and open dialog with the community through participation in the Deer Park Local Emergency Planning Committee (LEPC) and the local Community Advisory Council (CAC). Lubrizol has established Hot Lines direct to neighboring Shell and Oxychem plants. Our accidental release prevention program starts with hazard identification and risk minimization by our corporat e offices at the research and development stages of a product life cycle. The Deer Park 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 these requirements to include non-covered processes. For new facilities or modifications the Deer Park 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 sit e 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 is done. 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 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 that adequate safety, operating, maintenance, and emergency procedures are in place. Operating procedures, which identify safe operating limits, consequences of deviation from th ose limits and corrective action to be taken in the event a deviation from limits occurs, have been written for all of our processes. 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. have been written for all of our process There are also some prevention programs which focus on keeping an existing operating process safe when changes are made. The Lubrizol Deer Park 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. The plant processes approximately forty MOCs per month. Inspection and testing of existing pipe and equipment is a key part of the plants Mechanical Integrity program. Piping and equipment are periodically inspected or tested to assure that they mee t the design specifications. If deterioration is detected, the piping or piece of equipment will be repaired or replaced. This program identifies potential failures before they occur and is an integral part of operating a safe facility. The Lubrizol Deer Park plant has a very active PSM Compliance Audit Program. The purpose of the audit is to make sure that all the prevention programs are working and to provide a tool to stimulate improvement. We have established a procedure where we audit the entire plant once a year, and we perform an audit on a different processing 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. 2-Methylpropene is one of the Deer Park plant RMP plan chemicals. It is a listed flammable chemical. All of the standard prevention programs listed above are followed in the process area where 2-methylpropene is used. Additionally, there are some specific preventative measures which apply to the 2-methylpropene area. Over 2,200 points are checked every three month in this processing unit to determine if there are any leaks. If leaks are detected they are repaired. Also, we have strategically placed 28 flammable gas detectors, with alarms, around the area to detect leaks should they occur. Due to the flammability of this material, the entire area is protected with sprinkler systems. Fire water curtains have also been engineered to assist in isolating the area from the rest of the plant in the event a release should occur. To insure a rapid response in the event of an emergency, a single button a ctivation Emergency Shut-down system has been engineered into this unit. This unit is also equipped with a flare that would be used to flare off (burn) excess material should there be an upset condition. Chlorine is another of the Deer Park plant RMP plan chemicals. It is a listed toxic chemical. All prevention programs discussed above (not those that apply specifically to 2-methylpropene) , are followed in the processing unit which uses this chemical. Additionally, there are specific preventative measures that apply to specifically to the Chlorine area. The Chlorine Institute has recommended practices on how to handle Chlorine safely. These practices are followed in this facility. Emergency pressure relieving devices that are designed to protect equipment from over pressure, relieve into containment tanks, rather than relieving directly to the atmosphere which is more common practice in industry. Another preventative measure in the processing units that use Chlorine is the requirem ent for operators to do a chlorine line inspection every six hours to insure there are no leaks and there are numerous Chlorine gas detectors that would alarm if Chlorine was detected. Several Emergency Shut-down stations are located throughout the processing area where, by activation of a single push button, the Chlorine can be isolated. We have also had our Chlorine supplier visit the plant site and review our handling methods. Five year accident history: There have been no releases of EPA covered chemicals at Lubrizol's Deer Park plant in the past five years which have had an adverse impact on the community. There have been two incidents at the facility that meet the EPA Risk Management Program (RMP) reporting requirements with respect to employee injuries. The chemical involved in both cases was Chlorine and both events occurred in 1996. One in January and the other in November. The release of chlorine in both cases was estimated at 1 pound and was released during a maintenan ce operation. Three Lubrizol employees were treated for Chlorine inhalation. In one of the cases, the doctor recommended a day of rest following the incident, resulting in one lost work day. Ad-hoc committees were formed to study, identify the root cause, and make recommendations for improvement, for both of these incidents and necessary revisions were made. 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 c ode 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 which will move progressive and innovative safety & health practices into all Lubrizol operations including the Deer Park and Bayport plants. |