Document QgnqZw64Ena7GyLoezo0BOQqo

Contact Information Name: Edward M. Cox Address. Ethyl Petroleum Additives, Inc. 501 Monsanto Avenue Sauget, IL 62201 Phone No.: 618/583-1078 E-Mail: Ed_Cox@Ethyl.com Ethyl Petroleum Additives, Inc. Company Information ' Ethyl Petroleum Additives, inc. is a leading manufacturer of petroleum additive products used in transportation and industrial equipment. Our Sauget, Illinois plant produces a wide variety of lubricant detergents, dispersants, oxidation and corrosion inhibitors and anti-wear products. These products are blended and packaged to meet the strict performance standards of our customers. Ethyl markets its products worldwide to oil companies and lubricant manufacturers. These companies use Ethyl additives to produce common consumer products such as motor oil, automatic transmission fluid, hydraulic fluid and gear oil. Petroleum refiners and blenders rely on Ethyl additives to enable their products to meet increasingly challenging performance standards established by original equipment manufacturers (OEM) and regulators. Risk Management Planning The Environmental Protection Agency (EPA) Risk Management Plan (RMP) Rule created a regulation called Risk Management Program as required by an amendment to the Clean Air Act. The RMP rule requires facilities with certain quantities of chemicals and other regulated substances on a specific EPA list to disclose certain information. Those facilities must make publicly available their emergency response programs, which include plans to prevent and minimize the effect of incidents; five-year accident histories for the listed chemicals; and "worst-case" and "alternative case" scenarios related to potential releases. This information will be written in a risk management plan. The scenarios take into account potential quantities released, weather, wind direction, and wind speed. The worst case scenarios assume complete failure of all safety controls and systems and no emergency response. It is important to note that these scenarios are highly unlikely. The deadline for submitting risk management plans to the EPA is June 21, 1999. The Ethyl Petroleum Additives, Inc. Sauget, Illinois plant has only three of the 140 chemicals identified by the EPA above the threshold quantity. The Ethyl Petroleum Additives, Inc. Sauget, Illinois plant has compiled its accident release history for the RMP listed chemical for the last five years. According to the RMP rule, the accident release history must include all accidental releases from covered processes that resulted in death, injuries, property damage, evacuations, sheltering-in-place, or environmental damage. Accidental releases as defined by the EPA means an unanticipated emission of a regulated chemical into the environment from a stationary source. The five year accident history, as defined by the RMP, for the Ethyl Petroleum Additives, Inc. Sauget, Illinois plant is as follows: YEAR19941995199619971998 Number of RMP Releases 0 0 0 0 0 ' Revised 5/7/99 DSW 138161 STLCOPCB4038118 cample RMP Accidental Release Scenarios for the Ethyl Petroleum Additives, Inc., Sauget, Illinois Plant 2 RMP rule defines a worst case release as the hypothetical, entire release of the largest quantity container of an RMl'-listed material within 10 minutes. It assumes weather conditions that would maximize its impact, nplcle failure of all safety controls and systems, and no emergency response. Because these worst case scenarios arc extremely unlikely, the RMP rule also provides for the development of an alternative release scenario, ese alternative release scenarios depict a more credible release of an RMP listed chemical and consider safety systems that are in place. Chemical About the Chemical Accident Prevention In-Place Example Event Scenario Distance of Concern (1) Emergency Response Measures sobutyfene Isobutylene Liquefied Petroleum Gas (1 .PO) with an unpleasant odor. Isobutylene a a gas at ambient temperature and atmospheric pressure, but exists as a liquid when kept under pressure. Ethyl uses Isobutylene to manufacture "sulfurized isobutylene" used as a wear inhibitor in lubricants See above - tinloading, Isobutylene railcar unloading is monitored by operators via video camera. - Storage, Dedicated storage tanks are diked to contain leaked material. - Deluge System, In the event of a leak or fire, the storage tank and raikar is flooded with water. Water Flooding System, Enables material to be quickly transferred from one storage vtssel to another if needed. - Automatic Valves, An automated control system to shutdown and isolate the tanks and the process feed system in case of an upset. Isobutylene Detectors, 12 fixed-point sensors located at the storage tanks automatically detect releases and shutdown and isolate the system, while also activating the deluge system. - Relief System and Emergency Flare, Relief devices vit to a flare to ensure that material is contained and treated in the event of an upset. Manual Shutdown Switch, Backup to automated shutdown system* - System Design, Operation and Maintenance, Ethyl's Isobutylene handling system meets applicable codes and standards and is operated and maintained in accordance with generally accepted practices for equipment in isobutylene service. The Isobutylene process is also regulated under OSHA'x Process Safctv Management standard as well as EPA's Risk Management Program. See above Worst-Case Flammable Release Example Alternative Case Flammable Release Example - - Instantaneous failure of isobutylene ' railcar. Failure of all active safety systems Worst possible weather conditions, stable air Entire contents released (80 tons) in 10 minutes Vapor cloud explosion ensues CS Failure of railcar unloading line releases 3.40(1 pounds < minute AH active and passive safety systems fail 15 mmufc response time in isolating release Most common weather conditions Pool fire ensues 0.20 miles Alarms and alert systems. The isobutylene system has alarms for carh warning of operators, in case of a release. Ethyl also has a community alert siren in the unlikely event of a release. Trained emergency response and fire brigade team, Ethyl's own emergency response team is on site. 24 hours per day. Fixed and Mobile Fire Protection Equipment Ethyl slocks and maintains a variety of fixed and mobile fire protection and specialised hazardous materials response equipment on-site. Preplanning. Ethyl facilitates exercises, training, and preplanning activities with local emergency response agencies, the St. Clair County Local F-mcrgcncy Planning Committee (I.F.PC) and other local industry. See above I) RMP Distance of Concern: The distance a toxic vapor cloud, fire, or explosion from an accidental release will travel before dissipating to the point that serious injuries from short-term exposures w ill no longer occur, fata developed bv IiPA or computer models were used to simulate conditions and arrive at the distance. The sharing of this information Is intended to improve community understanding of local industries and promote an informed dialogue on their chemical accident prev ention practices, it is not a prediction of the probability that any scenarios discussed w ill ever occur. The information Is based upon the Risk Management Plan being prepared for Ethyl Petroleum Additives, Inc. Sauget, Illinois plant. Descriptions in the final Risk Management Plan submitted in June, 1999 may differ from these descriptions due to revisions. O Co a: u 00 l~ O' fo Revised 5/7/99 ample RMP Accidental Release Scenarios for the Ethyl Petroleum Additives, Inc. Sauget, Illinois Plant RMP mtc defines a worst case release as the hypothetical, entire release ol'the largest quantity container of an RMI'-listed material within 10 minutes. It assumes w eather conditions that w ould maximize its impact, lplelc failure of all safety controls and systems, and no emergency response. Because these worst case scenarios are extremely unlikely, the RM1' rule also provides for the development of an alternative release scenario. :se alternative release scenarios depict a more credible release of an RMP listed chemical and consider safety systems that arc in place. Chemical arbon faulfidc 'S2) Carbon Disulfide About the Chemical A clear, colorless lo yellow liquid. CS2 has a disagreeable sulfide odor. Ethyl uses carbon disulfide to manufacture "tfiiodiazofcs" for use as a corrosion inhibitor in lubricants. See above Accident Prevention In-Place - Unloading, Dry disconnect hoses ensure no spilling during unloading. - Storage, A dedicated storage tank is diked to contain any leakage beneath a water layer for cover. - Deluge System. In the event of a leak or fire, the tank exterior is flooded with water. - Automatic Valves, Shutdown and isolate tank and feed system m case of upset. - OS2 l>otector, A remote CS2 detcetor senses the presence of released material and alerts the operator. - Relief System and Flare. Pressure relief, containment and combustion of released materia! is in place. - Manual Shutdown Switch. Backup to automated shutdown systems. - System Design, Operation and Maintenance, Ethyl's CS2 handling system meets applicable codes and standards and is operated and maintained in accordance with generally accepted practices for equipment in CS2 service. The CS2 process is also regulated under OS1 EVs Process Safety Management standard as well as EPA's Risk Management Program. Sec abovu Example Event Worst-Case Toxic Release Example Alternative Case Toxic Release Example - - Scenario Instantaneous failure of CS2 railcar. Failure of all active safety systems Worst possible weather conditions, stable air Entire contents released (77 tons) in 10 minutes Distance of Concent (1) 10 miles Emergency Response Measures Alarms and alert systems. The 0S2 system has alarms for early warning to operators, of a release. Ethyl also has a community alert sirens in the unlikely event of a release. Trained emergency response and fire brigade team. Ethyl s own emergency response team is on site. 24 hours per day. Fixed and Mobile Fire Protection F.qulpntenl on-hand. Ethyl stocks a variety of fire protection and specialized hazardous materials response equipment on-site. Preplanning. Ethyl facilitates exercises, training, and preplanning activities with local emergency response agencies, the St. Clair County Focal Emergency Planning Committee (1 .EPC) and other local industry. Failure of 2 inch CS2 feed line to reaction vessel releases 720 pounds minute. All active and passive accident prevention systems work Operator isolates leak within l hour Most common weather conditions 0.35 miles Sec above Chlorine Chlorine A greenish-yellow gas at room temperature and pressure. Chlorine smells like household bleach at low concentration, but may be strong and irritating at high concentrations. Ethyl uses Chlorine as an "ashlcss dispersant' additive for motor oil. See above - Storage, Chlorine is stored in a specially designed railcar equipped with pressure relief and excess flow check valves on a dedicated hold track, which is barricaded to prevent unplanned access. - Automatic Valves, A fully automated control system to shutdown and isolate the railcar in case of an upset - Chlorine Sensors, Automatic sensors near the chlorine handling system to detect the presence of leaks and shutdown the system - Relief System and Emergency Scrubber, Numerous relief devices, expansion chambers and an emergency scrubber system to ensure containment and treatment of released material. - Manual Shutdown Switch, Backup to automated shutdown systems - System Design, Operation and Maintenance, Ethyl's Chlorine handling system meets applicable codes and standards and is operated and maintained in accordance with generally accepted practices for equipment in chlorine service. The chlorine process is also regulated under OSH.Vs Process Safety Management standard as well as EVA'* Risk Management Program. Sec above Worst-Case Toxic Release Example Alternative Case Toxic Release Example * - Instantaneous failure of chlorine railcar. Failure of all active safety systems Worst possible weather conditions, stable air Entire contents released (90 tons) in 10 minutes * Failure of chlorine vaporizer results in release of 38 pounds AH active and passive accident prevention systems work Emergency shutdown system isolates release Most common weather conditions 0.1 miles Alarms and alert systems. The chlorine system has alarms for early warning lo operators, of a release Ethyl also has a community alert siren in the unlikely event of a release. Trained emergency response and fire brigade team. Ethyl's own emergency response team is on site. 24 hours per day. Specialized repair equipment. Ethyl stocks and maintains a variety of specialized hazardous materials response equipment including a specialized railcar repair kit. on-sitc. Preplanning. Ethyl facilitates exercises, training, and preplanning activities with lfK.il emergency response agencies, the St. Clair County 1 ocal Emergency Planning Committee (I..RFC) and other local industry. See above (I) RMP Distance of Concern: Hie distance a toxic vapor cloud, fire, or explosion from an accidental release will travel before dissipating to the point that serious injuries from short-term exposures will no longer occur. 1 Xata developed bv EPA or computer models were used to simulate conditions and arrive at the distance. The sharing of this information is intended to improve community understanding of local industries and promote an informed dialogue on their chemical accident prevention practices. It is not a prediction of the probability that any scenarios discussed will ever occur. The information Is based upon the Risk Management Plan being prepared for Ethyl Petroleum Additives, Inc., Sauget, Illinois plant. Descriptions in the final Risk Management Plan submitted in June, 1999 may differ from these descriptions due to revisions. DSM 138163 Revised 5/7/99