Pennzoil Wax Partner Company, Rouseville Refinery - Executive Summary

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PENNZOIL WAX PARTNER COMPANY, ROUSEVILLE REFINERY 
RISK MANAGEMENT PLAN - EXECUTIVE SUMMARY 
 
I. Accidental Release Prevention and Emergency Response Policy 
 Pennzoil-Quaker State and it's subsidiaries, including Pennzoil Wax Partner Company, Rouseville Refinery (hence refered to as Rouseville Refinery) are committed to maintaining comprehensive accident prevention and emergency response programs which meet and or exceed all federal and state requirements.    Injury and Incident Free is Pennzoil - Quaker State's motto.  The corporation's environmental, safety and health policy is as follows: 
 Protecting the environment and the safety and health of employees, customers, contractors, communities and the public is fundamental to the way Pennzoil - Quaker State and it's subsidiaries conduct their business. To integrate environmental, safety and health management into business activities worldwide, Pennzoil - Quaker State and it's subsidiaries will: 
 Pursue excellence in the design, constr 
uction, operation and restoration of all properties and facilities; 
 Assess the potential risks of business activities; 
 Be a responsible steward of all products and services; 
 Comply with all applicable laws and regulations; 
 Prepare for emergencies and other contingencies; 
 Participate in the development of new laws, regulations and technologies; 
 Communicate openly regarding business activities; 
 Review performance and communicate progress; and 
 Assign clear responsibilities to all employees and contractors 
 Expect continuous improvement. 
 Provide employees with resources and training to meet assigned responsibilities; 
 
This document provides a brief overview of the comprehensive risk management activities that Rouseville refinery has designed and implemented, including: 
 A description of the facility and use of regulated substances as defined by EPA's RMP regulation. 
 A summary of the potential offsite release scenarios and potential offsite consequences. 
 An overview  
of the accidental release program. 
 A five-year history. 
 
II. Facility Description and Regulated Substances 
Rouseville Refinery was designed as a lube oil refinery whose primary objective was to refine base stocks for motor oil.  By-products of the process include fuels and waxes.  Over the years the refinery has been modified to produce a variety of specialty products.   
The refinery is divided into two areas, Plant #1 located adjacent to the Borough of Rouseville and Plant #2, located approximately 1 mile south of Plant #1 in Cornplanter Township.  Plant #2 is situated in a less populated area than Plant #1.   
 Plant #1 is the larger of the two operating areas and it contains the majority of our operations.  It is located on the east bank of Oil Creek and occupies approximately 33 acres.  Part of this facility includes a remotely located tank farm in Cornplanter Township, occupying 43 acres, situated approximately 1/4 mile east of Plant #1. There are eight oil storage tanks at the 
tank farm with four of these tanks currently inactive. 
The following gives a short description of each of the process units in Plant #1.   
 The Crude Unit utilizes a distillation process to separate raw crude oil into various fractions providing feed stocks to other process units. There are no EPA listed materials use in this process above the threshold limit.   
 The Hydrotreater Unit "hydofinishes" waxy feedstock to improve color and quality.  The Hydrotreating process reacts oil with hydrogen in the presence of a catalyst to change molecular structure, giving the oil more desirable characteristics.  Hydrogen is an EPA listed substance but is not present above the listed threshold quantity.   
 The Propane Deresining Unit "de-resins" the heaviest fraction of crude oil employing a separation process using propane.  Propane is used to promote separation of the heavy material into two fractions, resin and oil.  Propane is an EPA listed material and is present above the listed threshol 
d.  
 The Dewaxing Unit, "de-waxes" or separates it's feedstock into two fractions, oil and wax.  The Dewaxing Unit uses propane as a refrigerant to freeze the waxy portion of the material separating it from the oil. Propane is present in quantities above the listed threshold quantity at the Dewaxing Unit.   
 The Wax Filterhouse improves the quality of waxes by passing the wax through bauxite filled filters, which absorbs impurities. There are no EPA listed materials used in this process above the threshold limit.   
 The remaining units at Plant #1 are the Boilerhouse and Waste Water Treatment, both of which provide services to the process units.  The Boilerhouse produces steam to be used for heating systems and steam driven equipment.  The Wastewater Treatment Plant processes oily water from throughout the plant suitable to return to Oil Creek. There are no EPA listed materials use in these processes above the threshold limit.  
  Plant #2 is located on the west bank of Oil Creek an 
d occupies approximately 24 acres in Cornplanter Township.  This area consists primarily of a Reformer Unit, which produces gasoline.  Straight run gasoline from the crude unit at Plant #1 is pumped to Plant #2 as the reformer unit feed stock.  The straight run is "reformed" to produce three grades of gasoline. There is no EPA listed materials use in this process above the threshold limit. 
 Other facilities at Plant #2 include tanks for the blending of finished gasoline and fuel oils, and a loading rack for loading fuel oils produced at Plant #1, and three grades of gasoline. In addition, five storage tanks are located on a 36-acre plot on the east bank of Oil Creek.  Both Plant #1 and #2 are connected to these hillside tanks by pipelines.  These tanks generally store straight run gasoline, kerosene, fuel oil distillate, and reformate. There are no EPA listed materials used in these processes above the threshold limit. 
 As noted above, several of our processes use chemicals listed by 
EPA.  A hazard assessment of all our processes was conducted by an outside consultant to determine our utilization of chemicals covered by the RMP standard.  The following is a list of covered chemical used in the refinery: 
 TOXICS - Rouseville Refinery uses no toxic materials at or above RMP threshold.   Only two toxic chemicals have been identified: 
 Ammonia - this was used to control pH in some process towers to prevent corrosion.  Use of this toxic has been discontinued. 
 Chlorine - this was used for cooling tower water treatment.  Use of this toxic has been discontinued. 
 Hydrogen Sulfide (H2S) - this is a by-product of refining crude oil.  Rouseville Refinery refines "sweet" crude, which has a lower content of H2S than, does other "sour" crude oil.  H2S is not present above EPA's listed threshold quantity.   
 FLAMMABLES - Rouseville Refinery uses or produces five flammable gases listed by EPA.  Propane is the only listed gaseous material in a quantity above the RMP threshol 
d limit.  Listed flammable gases that are present on site include:    
 Hydrogen - a by-product of the Reformer unit and a product of our hydrogen unit.  Hydrogen is used at the Hydrotreater as explained in the unit overview above.  Hydrogen is not present above the threshold quantity. 
 Hydrogen rich refinery gas - is a by-product of the Hydrotreater.  It is used, along with hydrogen rich sour gas and natural gas to supply a variety of furnaces and boilers used in the process.  Hydrogen rich refinery gas is not present above the threshold quantity. 
 Hydrogen-rich sour refinery gas - is a by-product of the Catalytic Reforming unit.  Excess sour fuel gas is used as indicated above. 
 Purchased natural gas - is used to supplement the gas produced by the refinery. Natural gas contains the listed flammable methane.   
 Propane - described in the process overviews is used in the Deresining and Dewaxing units above the threshold quantity.   
 
III. Key Offsite Consequence Analysis Scenarios 
 
EPA's RMP rule requires information about the worst-case release scenario and alternate release scenario for our facility.  To provide an impartial selection of these cases, a third party consultant was hired to evaluate and select the worst-case and alternate-case scenarios.  The following are summaries of the scenarios for flammable gases.  Included are the key administrative controls and mitigation measures, which would be used in any actual release scenario to limit the exposure.  As indicated, the refinery uses no toxic substances above the listed threshold quantity and is therefore not required to develop scenarios for toxic substance release. 
Worst-case Release Scenario Regulated Flammable Chemical 
 A total of six worst-case scenarios were evaluated.  The case chosen contains the greatest quantity of propane and results in the largest endpoint radius.  Our worst case scenario involves a railcar used to store propane during maintenance shutdown of our Propane Deresining Unit.   
Propane is evacuated from the Deresining unit to the railcar to prevent the potential for incidents while maintenance crews are working on equipment in the unit.  The railcar is spotted on a rail spur generally used for loading and unloading material.  The maximum permitted level is 88% of the maximum vessel (railcar) capacity.  This capacity limit is based on storage requirements per NFPA 58 LP-Gas Code.   The worst-case release is based on EPA requirements of an instantaneous release over a 10 minute period of all the propane in the railcar (29,744 gallons / 124,925 pounds), assuming it is all vaporized, an ignition source is found and the propane explodes.  It is assumed that 10% of the total energy of the propane release is involved in the explosion and actually contributes to the formation of shock or blast waves.  Using EPA guidance for weather conditions the resulting vapor cloud explosion would reach off site.  The release would affect our industrial and residential neighbors h 
owever no schools hospitals or environmental receptors would be affected.   
 EPA requires us to develop the worst-case scenario as if no mitigation measures were in place.  Therefore, we have developed our worst-case scenario in full knowledge that the event is extremely unlikely to occur.  Prevention systems, in addition to our emergency response and mutual aid plans, are currently in place designed to safeguard from this type of event.  For example, railcars that are used are designed for storage of propane and meet inspection requirements of DOT E-12095 (180.509).  Railcars are used only during Deresining unit shutdown.  Planned shutdowns occur every three or four years for a period of approximately two weeks.  Although unlikely, it is possible to have an unplanned shutdown of the Deresining unit in between the 3 - 4 year cycle, however this is unlikely.  This is the only time that propane would be evacuated from the unit and stored in this fashion.   Mitigation equipment in the ar 
ea consists of firewater hydrant/monitors, hydrocarbon detection monitors, operator monitoring of level, pressure and temperature of the railcar.   
Alternate-case Release Scenario Regulated Flammable Chemical 
 A total of five alternate-case release scenarios were evaluated based on the scenario categories listed in the RMP regulation (section 68.28(b)(2)).   The case selected is categorized by EPA as "Process piping release from failures at flanges, joints, welds, valves and valve seals, and drains or bleeds, (section 68.28b)(2)(ii).  The alternate release scenario takes place at our Dewaxing Unit and involves a break in a propane line connecting two vessels.  This scenario was selected due to the pipeline size, high transfer pressure, and quantity of propane that could be released.  The line connects a propane storage vessel and an economizer vessel, which cools and condenses propane vapors to be used in the process.   The line is six inches in diameter and has one valve at the inlet 
to the economizer.  The valve controls the level in the economizer and is operated remotely by operations personnel.   The scenario calls for a line breakage between the valve and the storage vessel, which could potentially allow the entire contents of the storage drum to be released.  The World Bank, an office of the Environmental and Scientific Affairs, suggest that a reasonable scenario is a 20% piping breech in cases where a low probability of a non-mechanical breech (i.e. corrosion, vehicle impacts) could occur.  This scenario would be considered low probability due to its location.   An EPA model ARCHIE was used to calculate a maximum discharge flow rate from the break in the line.  The break was assumed to occur in the six-inch line, accounting for a 20% breech (1.2 inches), under 165 psia of pressure.  ARCHIE estimated a maximum flow rate of about 1,004 lbs./min, from the 1.2-inch diameter hole.  The total quantity of propane released at the break would be 24,794 lbs. over a t 
wenty-five minute period.  Following the EPA requirement for meteorological parameters and assuming the resulting vapor cloud is ignited (potential ignition source exists in area) ARCHIE predicted a distance to 1 psi endpoint for a vapor cloud explosion would reach off site.  The release would affect our residential neighbors however no other industry, schools, hospitals or environmental receptors would be affected.  
 We believe a vapor cloud as described in this scenario would be contained within the unit through operator response, unit mitigation systems and emergency response.  Hydrocarbon detectors in the area and process control parameters would alert operations of the leak immediately.  The fire alarm would be set off and our emergency response and mutual aid plans activated.  An automated water sprinkler system on top of the storage drum can be remotely activated as well as a local fire monitor to disperse the vapor cloud and knock down the release.  
 
IV. General Accident Relea 
se Prevention Program  
 Accident prevention is accomplished through implementation of OSHA's Process Safety Management of Highly Hazardous Chemicals (PSM) standard, 1910.119.  Subpart D of the RMP standard, Program 3 Prevention Program, requires facilities to comply with a list of program elements, which mirror OSHA's PSM standard.  The Rouseville Refinery is committed to maintaining a comprehensive safety program that meets and or exceeds OSHA's PSM standard.  The refinery has undergone extensive PSM audits, both internal and external, which ensure continuous improvement and compliance.   Our PSM program includes the following programs: 
  Process Safety Information 
  Process Operating Procedures 
  Management of Change 
  Training 
  Pre-Startup Safety Review 
  Emergency Planning and Response    
  Mechanical Integrity 
  Compliance Audits 
  Hot Work Permit 
  Trade Secrets 
  Incident investigation 
  Employee Participation 
  Process Hazards Analysis 
  Contractor Safety 
In add 
ition to our PSM programs, many other layers of protection are designed into our process units.  These layers are independent of one another so that a failure in one will not trigger another.  These safety features have been engineered to protect our employees, the community and the environment.  These systems are tested on a regular basis to ensure reliability. 
 
V. Five Year Accident History 
 The refinery has not had any incidents, which meet the EPA criteria for reporting.  However the facility has had one incident in the past five years which merits discussion.   On October 16, 1995 at approximately 10:15 a.m. the refinery experience a fire resulting in the death of two employees and three contractors.  No root cause has ever been determined and the sequence of events remains unclear.  A ground fire may have initiated in the area, leading to an over-pressurization of one of our oily wastewater tanks.  Within seconds, the other oily wastewater tank also over-pressured.  At some poin 
t, either before or after the over-pressurization of the oil wastewater tanks, a tank of naphtha and a tank of burning oil failed contributing to the pool fire.  The result was a large pool fire, which damaged a total of twenty tanks in the area and several trailers being used by contractors, one of which was occupied.  The contractors were involved in a project installation in the area.  The fire was contained within the refinery.  The emergency response plan was activated and the fire brought under control within two and one half-hours.  Some of our community neighbors found debris around their homes and black smoke covered much of the plant area. The Rouseville refinery did not order a community evacuation however a partial evacuation took place, ordered by the borough fire department.  An elementary school located remote from the refinery was evacuated by order of the school's administration. The company conducted a study to determine any known or anticipated health effects, which  
may have been caused by the release.  Based on the findings, it was concluded that the gases (SO2, NO and NO2) were released at levels which did not cause irritation or pulmonary symptoms in either the general community or in asthmatics. 
 Rouseville Refinery maintains an extensive accident investigation program.  A joint committee investigates all reportable environmental incidents, recordable and first aid injuries, fires, and any serious near miss incidents.  The investigation process utilizes fault tree analysis for determining root cause and corrective actions.  Although this incident was investigated by OSHA as well as Pennzoil - Quaker State Company, no root cause was found. However, many areas for improvement were identified and have been addressed. 
VI. Emergency Response Program 
 The refinery utilizes a unified incident command system and mutual aid plan for plant emergencies.  Our mutual aid plan is coordinated with state and county emergency management agencies, municipal a 
nd volunteer fire departments.  The refinery has an extensive volunteer emergency responder team, with over twenty percent of our employees serving as members of our response team.  Team members respond 24 hours a day via a pager system.  Responders receive off-site fire fighting training on a rotating basis at nationally recognized facilities (i.e., Texas A&M, University of Nevada at Reno, or State Fire Academy at Dover Delaware).  In-house training is performed once per quarter with refinery fire chiefs selecting and directing different training exercises.  Two of our five fire chiefs are from the hourly employee group.  In addition to quarterly exercises, an annual drill/training exercise is held with all local fire companies and emergency response agencies (approximately 25 agencies).  In 1998, the Rouseville refinery and Venango County Emergency Management, hosted a joint training session.  The training was open to all county fire departments.  Fire fighters were trained on propan 
e fires, liquid fires and water retrieval systems.  The refinery also supports an in-house volunteer rescue team.  Three of the seven members are hourly.  The Roco Corporation, nationally recognized for their rescue training has trained our rescue team members to level three.  The team meets monthly for in-house training.  We are very proud of our emergency response preparedness. 
The refinery is actively involved in several community groups.  We are an active member of the Venango County Local Emergency Planning Committee (LEPC).  We are a sponsor company of the local Venango County Industry, Community, Advisory Panel (I-CAP), Venango County Fire Chiefs Association, and we meet regularly with the Rouseville Borough Council. 
VII. Planned Changes to Improve Safety 
 The following is a list of key improvements the facility has or is committed to implementing: 
 1. Inform community of Rouseville on emergency preparedness and steps to take in the event of an emergency. 
 2. Performed a comp 
rehensive external Process Safety Management audit to enhance and improve the PSM system.  
 3. Performed a plant wide study to control the use of vehicles in the plant.   
 4. Performed a comprehensive tank siting study to ensure storage tanks met NFPA, OSHA and API regulations and or practices. 
 5. Developed a comprehensive mechanical integrity program to ensure equipment deficiencies are prevented or detected before a failure occurs. 
 6. Minimized the amount of propane storage. 
 7. Training for all employees on propane safety conducted by a propane expert. 
 8. Co-sponsored a training session with Venango County Emergency Management Association for all local fire companies, which included hands on fire fighting of propane. 
 9. Participate in developing a comprehensive emergency alert system with Venango County Emergency Management Association, Local Emergency Planning Committee (LEPC) and local Industry, Community, Advisory Panel (I-CAP). 
 10. Coordinate a training session with 
Venango County Emergency Management and all local fire companies on emergency response and mutual aid developed for RMP. 
 11. Develop a vapor release emergency response plan for Emergency Response Mutual Aid planning. 
 12. Develop a refinery wide emergency procedure for a vapor release. 
 13. Sponsor a community day for the citizens of Rouseville and affected section of Cornplanter Township to explain our RMP plans and provide an opportunity to speck with representatives from various community support groups. 
 14. Develop and distribute an informational brochure explaining our risk management plans and distribute them to each affected citizen.
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