Document 2J5nMaJYO9QOK5nwj28Xxam6r

ft EA~United States ~A Environmental Protection '"' Agency Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 09/11/2018-09/13/2018 Air Clean Air Act Section 112(r) and 40 C.F.R. Part 68 Chemical Accident Prevention Provisions Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Lubrizol Corporation Bayport Plant 12801 Bay Area Blvd. Pasadena, Texas 77507 (same as above) (same as above) Harris Patrick Shannon Patrick.Shannon@lubrizol.com I HSES Manager FRS Number: Identification/Permit Number: Media Number: NAICS: 110000462936 Federal Operating Permit 01582 RMP EPA Facility Identifier: 100000097851 32599 =All Other Chemical Product and Preparation Manufacturing Personnel participating in inspection: Tony Robledo US EPA/6EN-AS Patrick Shannon Lubrizol Corporation Inspector HSES Manager (214) 665-8182 {440) 343-7493 EPA Lead Inspector Signature/Date ,. - 7j ~k _,~ Tony Robledo /0.- z..~ 18 Date Supervisor Signature/Date ~ 1~ Samuel Tates !o/:zI /Lo/8 Date 6ENFORM-019-R6 (10/6/14) 1 Lubrizol BayPort Plant Inspection Dates 09/11/18-09/13/18 Section I - INTRODUCTION PURPOSE OF THE INSPECTION United States Environmental Protection Agency (EPA) Region 6 inspector Tony Robledo arrived at the Lubrizol Corporation, Bayport Plant (Lubrizol) at approximately 9:00a.m. on September 11, 2018, for an announced inspection. I conducted an opening meeting with the following persons in attendance as identified in Table 1. Table 1: Opening Meeting Attendance Name Patrick Shannon Anh-Thy Tran David Sonnier Robert Gessner Dennis Ray Langehennig Mark A. Turvey Troy Merchant Tim Henggeler Kathleen Antoine Fred Gregory Tony Robledo Position HSES Manager Site Manager Health and Safety Specialist Production Superintendent Maintenance Superintendent Facilities Protection Superintendent and Fire Chief HSES Compliance Manager Environmental Engineer Environmental Manager Process Safety Risk Manager Inspector & Enforcement Officer EPA Region 6 I presented my credentials to all attendees at the opening meeting, and informed them that this EPA inspection was to determine compliance with Clean Air Act Sections 112(r)(1) and 112(r)(7). The scope of the inspection was a partial compliance evaluation (PCE) and included evaluation of the compliance with 40 C.F.R. Part 68- Chemical Accident Prevention Provisions. FACILITY DESCRIPTION Lubrizol uses boron trifluoride, hydrazine, and formaldehyde tomanufacture specialty chemical additives for lubricating oil used in gasoline and diesel engines. The process of manufacturing the gasoline additive product is composed of three basic steps- reaction, stripping, and filtration which takes place in Process 3 of the facility. An aromatic solvent is brought into the reactor with polyolefin phenol, a formaldehyde solution, and amine. After amine addition, the batch is distilled to separate the aqueous distillate which is drained to a distillate storage tank and sent for disposal. The gasoline additive product is pumped from the reactor, filtered, and pumped to product storage. Once the product is in storage, it is loaded into a transport vessel for transportation to a customer. The facility has about 113 full-time employees. There are no listed flammable substances, only taxies- boron trifluoride, hydrazine, and formaldehyde which exceed their respective threshold quantities stored at this facility. Section II - OBSERVATIONS I conducted a walk-through of the facility on September 12, 2018, accompanied by Lubrizol personnel to observe the facility process, equipment, pressure vessels, storage tanks, and operation. I observed no visible spills, leaks, or air emissions. The facility grounds appeared to be well maintained. 2 Lubrizol BayPort Plant Inspection Dates 09/11/18-09/13/18 40 C.F.R. Part 68- CHEMICAL ACCIDENT PREVENTION PROVISIONS Subpart A- General 40 C.F.R. 68.10 Applicability- Lubrizol is an owner and operator of a stationary source that has more than a threshold quantity of regulated toxic substances, listed in 40 C.F.R. 68.130, in a process, and as such is subject to these Chemical Accident Prevention Provisions. Lubrizollisted the NAICS code 32599, . (all other chemical product and preparation manufacturing), as the process in its Risk Management Plan (RMP). The Lubrizol facility process is also subject to the Occupational Safety and Health Administration (OSHA) process safety management standard, 29 C.F.R. 1910.119. These factors make the process at th~ Lubrizol facility a Program 3 subject to 40 C.F.R. 68.10(d). 40 C.F.R. 68.12 General Requirements- Lubrizol re-submitted a RMP five-year update on September 4, 2018. This submittal lists a covered process for Program 3. This requires the facility to develop and implement a management system, conduct a hazard assessment, implement the prevention requirements of 40 C.F.R. 68.65- 68.87, develop and implement an emergency response program, and submit the data elements from 40 C.F.R. 68.175 in their RMP. 40 C.F.R. 68.15 Management- Lubrizol has an established management system to oversee the implementation of the risk management program elements, and has assigned a qualified person or position that has the overall responsibility for the development, implementation, and integration of the risk management program elements. Lubrizol facility personnel provided job assignments which documented the persons responsible for implementing individual requirements of the RMP, as required by this subpart. Subpart B - Hazard Assessment 40 C.F.R. 68.20 Applicability- Lubrizol is an owner or operator of a stationary source subject to this subpart with a Program 3 process that must prepare an offsite consequence analysis as provided in 68.25 of this subpart, complete the five-year accident history as provided in 68.42, and comply with all sections iri this subpart for this process. 40 C.F.R. 68.22 Offsite Consequence Analysis Parameters -I requested documentation of the offsite consequences analysis. I reviewed the documentation provided and had a discussion with appropriate Lubrizol facility personnel. Lubrizol applied the offsite consequence analysis parameters as required by this subpart.. 40 C.F.R. 68.25 Worst-Case Release Scenario Analysis- Lubrizol identified and reported a worst-case release scenario analysis for the RMP covered toxic substances. I requested documentation of the worst-case release scenario analysis. I reviewed the documentation provided and had a discussion with appropriate Lubrizol facility personnel. Lubrizol selected a boron trifluoride release for the worst-case release scenario. Lubrizol used EPA's RMP* CompTM to determine the distance to the endpoint in the worst-case release scenario. Lubrizol used the proper endpoints for taxies as required by this subpart. 40 C.F.R. 68.28 Alternative Release Scenario Analysis- Lubrizol identified and reported three alternative release scenarios for each of its RMP covered process toxic substances. I requested documentation of the alternative release scenario analysis. I reviewed the documentation provided and had a discussion with appropriate Lubrizol facility personnel. Lubrizol used EPA's RMP* CompTM to calculate the distance to the endpoint in the taxies alternative release scenario. Lubrizol used the 3 lubrizol BayPort Plant Inspection Dates 09/11/18-09/13/18 proper endpoints for taxies as required by this subpart. No mitigation systems were considered by the facility. The five-year accident history in 40 C.F.R. 68.42, and the failure scenarios identified in 40 C.F.R. 68.50 were considered in selecting the alternate release scenario. 40 C.F.R. 68.30 Defining Offsite Impacts- Population- The documentation I reviewed contained a map with the circles delineating the areas covered by the offsite impact. Population numbers were verified with the latest available U.S. census data. lubrizol reported these numbers to two significant figures. 40 C.F.R. 68.33 Defining Offsite Impacts- Environment- The. maps I reviewed identified the potential offsite impacts and all public receptors. 40 C.F.R. 68.36 Review and Update -lubrizol reviewed and updated its RMP on September 4, 2018. This RMP submittal identified process chemicals of boron trifluoride, hydrazine, and formaldehyde. lubrizol reported no changes, to include any increases or decreases, of its process chemicals. 40 C.F.R. 68.39 Documentation- I reviewed documentation for the worst-case scenarios that contained a description of the vessel or pipeline and substance selected as worst case, assumptions and parameters used, and th.e rationale for selection. The documentation also included the anticipated effect of the controls and mitigation on the release quantity and rate. lubrizol's documentation of the worse-case and alternative release scenarios included a description of the scenario identified, assumptions and parameters used, and the rationale for the selection of the specific scenario. The documentation of estimated quantity released, release rate, duration of release, methodology used to determine distance to endpoints, and data used to estimate population and environmental receptors potentially affected was included in the reviewed materials during this inspection. 40 C.F.R. 68.42 Five Year Accident History -lubrizol reported no accidents for the five-year accident history in its RMP re-submittal, and no accidents were reported up to the date of this inspection. Subpart D- Program 3 Prevention Program 40 C.F.R. 68.65 Process Safety Information -lubrizol indicated that process safety information is managed using an electronic online system. I reviewed. covered process safety information for Process 3 of the facility. I also reviewed facility safety data sheets, block flow diagrams, process flow diagrams, and piping and instrumentation diagrams. 40 C.F.R. 68.67 Process Hazard Analysis -I reviewed lubrizol's Process Hazard Analysis (PHA) process and procedures for Process 3 of the facility. lubrizol used the hazard and operability study (HAZOP) analysis technique to conduct its PHAs. lubrizol reported its initial PHA for Process 3, and conducted an updated and revalidated PHA for this process within a five-year cycle. The PHA for Process 3, was completed on October 5, 2011, and all160 recommendations were corripiE~t~d. The PHA for Process 3, was completed on October 25, 2016, and identified 270 recommendations. lubrizol established a system to promptly address the team's findings and recommendations. lubrizol noted that it recently conducted a layer of Protection Analysis on September 5 and 6, 2018, regarding Process 3 fire equipment. lubrizol personnel also noted that the next PHA is scheduled to start on or before August 29, 2021. 40 C.F.R. 68.69 Operating Procedures- lubrizol used an electronic document management system to maintain its operating procedures. I reviewed and discussed with lubrizol personnel randomly selected 4