Penreco - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The Penreco Dickinson Facility has a history of commitment to public and employee safety. Our commitment is demonstrated in the resources invested in accident prevention such as safety and operations training of our personnel, incident investigations, and standards for design, installation, operation and maintenance of our processes. Our policy at Penreco is to implement reliable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the release. GENERAL DESCRIPTION The Penreco Plant has been a member of the Dickinson community since 1942 and is in the business to convert refined base oils into food grade mineral oils and petroleum sulfonates. Pennzoil Products Company purchased the plant in 1985 from Marathon Morco Company and made it a part of the Company's Penreco Division. In 1997, Pennzoil Products Company and Conoco, Inc. entered into a joint venture agreement and formed an independently operated Penreco Company. As of 1998, Pennzoil-Quaker State Company and Conoco, Inc. jointly own the Penreco Company. The plant is located at Park Avenue and Nichols Street in Dickinson, Texas. The plant covers an area of approximately 28 acres, which consists of the north and south property and the east Dickinson bayou property. The main plant is located on the north property (10 acres) and consists of all the process units and related tankage. Located on the south property (10 acres) are a modern packaging and distribution facility and a wastewater treatment facility. The distribution center encompasses drum filling and storage, tank truck loading operations, white oil blending and finished white oil bulk storage. The east Dickinson bayou property (8 acres) was purchased in 1989 and is presently undeveloped. The facility has five distinct operating areas: the white oil unit, the yellow refrigeration oil u nit, and the sodium bisulfite unit, crude sulfonate processing and spent salt processing. The average daily throughput for all finished products is approximately 50,000 gallons per day. The plant's feedstock is received by rail and tank truck. Finished products are shipped to customers in bulk and in drums by rail and trucks. There are about 60 employees at the Dickinson facility, including a sales staff. As a company Penreco actively supports and/or participates in numerous local civic organizations, and youth educational and sports programs. REGULATED SUBSTANCES Toxic Substances The plant has one Risk Management Program regulated toxic chemical (oleum - 20% fuming sulfuric acid) over the threshold reporting quantity of 10,000 pounds. Oleum is a chemical raw material used in the manufacturing and processing of many products. Oleum is received by tank truck and stored in two storage tanks. At the Penreco Dickinson Plant, oleum is used in the production of white oils by acid contacting feedstock with oleum. The acid contact process produces a non-reactive white oil approved for human consumption. Penreco's white oils form the basic ingredient in such consumer products as baby oil. cosmetics and pharmaceuticals. Sulfur dioxide, a toxic gas, is also present in the plant, but at quantities well below the threshold quantity of 5,000 pounds. The operational processes containing sulfur dioxide were evaluated and determined to have no potential impact to the community in the event of a release. Flammable Substances The plant has no Risk Management Program (RMP) regulated flammable materials above the threshold quantity of 10,000 pounds. The plant utilizes propane cylinders for forklift operation, but the quantity is well below the threshold quantity of 10,000 pounds and poses no potential off-site impact. WORST CASE SCENARIO EPA defines a worst case scenario as the rapid and complete release of the largest container of the chemical under conditions tha t would maximize its potential impact. It also assumes that none of the site's mechanical controls or safety systems requiring energy or human intervention is operational. The EPA definition requires us to develop a scenario that is actually a series of highly unlikely events, each one reaching its end point before it is followed by the next likely event, until the worst case scenario results. Based on these criteria, a worst case scenario is extremely unlikely to occur. Under EPA's definition, catastrophic failure of one of our oleum tanks would be our Worst Case Release of a regulated toxic chemical. Because an equalization line connects our tanks, the failure of one oleum tank would also empty the contents of another equal size tank. Each tank capacity is 33,800 gallons. However, Company policy limits the maximum inventory at 19,600 gallons or no more than 58% of tank capacity (9,800 gallons) at any given time. In addition, concrete diking around the tanks limits the exposed surface area of a pool and thus reduces the rate of the release of the chemical. In the worst case scenario, both tanks empty their entire contents in a 10-minute period. The escaped fumes from the oleum would rapidly combine with moisture in the air to form a sulfuric acid mist that would be visible as clouds of dense white fumes. The total contents of both tanks equal 221,000 pounds. However, the oleum liquid would remain on-site. Although we have numerous controls to prevent such a release and to manage their consequences, they were not taken into account for evaluating this scenario. We estimate, using EPA's Off-Site Consequence Analysis (OCA) and Look Up Tables that the total release would be 620 pounds in the first 10 minutes, and the maximum distance to the toxic endpoint of 2.5 ppm (0.00025%) for this worst case scenario is 0.19 miles (1,003 feet). Several residences could be impacted by such a release. We believe that an event of this type is extremely unlikely beca use of the preventive controls that are in place and the very low probability that a catastrophic release of the entire tanks' contents could occur. ALTERNATE CASE SCENARIO (A More Realistic Scenario) The EPA also requires that an alternate release scenario be prepared giving a more realistic set of circumstances and events. This scenario can take into account prevention and response systems at the facility, but must still have a potential for off-site impact. We selected a pump packing and/or seal failure while transferring 20% oleum from a storage tank to our white oil processing equipment for the required alternate release scenario. In this scenario, the pump packing and/or seal fails and oleum is released for a 10 minute period before it is detected by an operator and the pump is shut down. The pump rate is 20 gallons per minute resulting in a release of 20 pounds. We estimate, using EPA's Off-Site Consequence Analysis (OCA), Look Up Tables and certain weather conditions, tha t the maximum distance to the toxic endpoint of 2.5 ppm (0.00025%) for this alternate release scenario is 0.06 miles (316 feet). There is one residence within this affected area. Even this event is unlikely. In the event of an actual release, under our established response procedures, the pump would be shut down well within the 10-minute period. Once the pump is shut down, an immediate vacuum would occur in the pump and piping system stopping any further release. Additionally, mitigation equipment in the area consists of remote emergency shut down systems or controls, pump dike or chemical containment area, area and perimeter water monitors for water curtain capability. Moreover, suppression materials such as water, concentrated foam, soda ash and inert clay are readily available to contain and minimize the potential threat to our employees and local residences. In addition, operators routinely monitor all chemical movements or transfers and are trained to take steps necessary to alert, control and mitigate the emergency situation. Finally, we routinely inspect and service process lines and equipment as part of our on-going preventative maintenance program. In the event of an actual release, we would activate our Emergency Operating and Response Plan and notify local agencies and emergency responders. Additional information pertaining to the emergency alerting system is discussed further as part of the emergency response program. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS The following is a summary of the general accident prevention program in place at our Penreco Dickinson Plant. Because the White Oil Oleum Process at the plant that is regulated by the EPA RMP regulation is also subject to the OSHA PSM standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. EMPLOYEE PARTICIPATION The Penreco Dickinson Plant encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents, participation as a member of a process hazard analysis (PHA) team and participation on the Plant Safety Review Committee. In addition, employees participate on monthly safety and housekeeping inspections and also serve as investigation team members for all plant accidents and/or incidents. Employees have access to all information created as part of the plant's accident prevention program. In addition, the plant has a number of initiatives under way that address process safety and employee safety issues. These initiatives include forming teams to promote both process and personal safety. The teams typically have members from various areas of the plant, including operations, maintenance, engineering, shipping, laboratory, and plant management. PROCESS SAFETY INFORMATION The Penreco Dickinson Plant keeps a variety of technical documents that are used to help maintain safe operation of our various processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific departments within the plant are assigned responsibility for maintaining up-to-date process safety information. Information summarizing the reference documents and their location is readily available as part of the written employee participation plan and the plant's process safety manual. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDS's). This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For specific process areas, the plant has documented safety-related limits for sp ecific process parameters (e.g. temperature, level, pressure and composition) and this information is an intricate part of our process operating procedures. The 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 systems). The plant also maintains numerous technical documents that provide information about design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, electrical rating of equipment, etc. 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 or systems in the process are not compromised. PROCESS HAZARD ANALYSIS The Penreco Dickinson Plant has a comp rehensive 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 safeguards or controls are in place to manage these hazards. The plant utilizes the hazard and operability (HAZOP) analysis and the What-If/Checklist technique to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The What-If technique is also utilized for less complicated or hazardous processes. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. The team identified and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes recommendations for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team findings are forwarded to 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 receive immediate attention. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. The final 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 5 years and whenever significant changes in the process so warrant. These reviews continue at this frequency until the process is no longer operating. The results and findings from these updates are documented and retained. Onc e again, the team findings are forwarded to management for consideration and the final resolution of the findings is documented and retained. OPERATING PROCEDURES The Penreco Dickinson Plant maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures can be used as a reference by experienced operators and provides a basis for consistent training of new operators. These procedures are periodically reviewed and annually certified as current and accurate. In addition, the plant maintains process parameter documents that provide guidance on how to respond to upper or lower limit exceedances for specific process or equipment parameters. This information, along with written operating procedures, is readily available to operators in the process unit and for other personnel to use as necessary t o safely perform their job tasks. TRAINING To compliment the written procedures for process operations, the plant has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in 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-specific duties and tasks. After operators demonstrate (e.g. through testing, 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 training is documented for each operator, including the means used to verify that the operator un derstood the training. CONTRACTORS The plant uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the 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 designated work areas, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, (6) notify plant management of any work related incidents, and (7) inform plant personnel of any hazards that they find during their work. This is accomplished by providing contractors with (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, we evaluate contractor safety programs and performance during the selection proc ess of a contractor. Plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. PRE-STARTUP SAFETY REVIEWS (PSSRs) The Penreco Dickinson 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 the equipment are appropriately prepared for startup prior to placing the equipment into service. This review also 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 as a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. MECHANICAL INTEGRITY The Pe nreco Dickinson 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 inspection and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process equipment. Maintenance personnel receive training 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 job in a safe manner. Written procedures help ensure that work is performed in a consistent manner and provides a basis for training. Inspections and tests are perform ed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits (e.g. thickness testing for piping and pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back in service (if possible), or a Management of Change (MOC) 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 plant also 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 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 loc kout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous materials (i.e. draining and purging) before process piping and 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 Penreco Dickinson Plant has a comprehensive system to manage changes to 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 a re 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 changes. INCIDENT INVESTIGATION The Penreco Plant promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, 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 plant management for resolution. Corrective actions taken in response to the investigation team's findings or recommendations are tracked until they are complete. 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. In addition, Investigation reports are shared with other corporate facilities to assist in the prevention of similar incidents at those facilities. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations. COMPLIANCE AUDITS To help ensure that the accident prevention program is functioning properly, the facility periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented and remain current. Compliance audits are conducted at least every three years. These audits are performed by our Corporate Compliance Review Team and outside consultants and/or auditors. The audi t team develops findings that are forwarded to senior management and plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained. CHEMICAL SPECIFIC PREVENTION STEPS The processes at the plant have hazards that must be managed to ensure safe operation. The accident prevention program summarized previously is applied to the White Oil Oleum Process (Program 3) EPA RMP-covered process at the plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failures and (2) human errors. In addition to the accident prevention program, the plant has safety features on process units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety fea tures are used in various processes: (1) Area and perimeter toxic gas detectors with alarms (2) Safety/process controls, including warning alarms, and automatic/remote shutdown systems (3) Continuous monitoring of pressure in vessels quickly identifies potential problems (4) Automatic shut-off and pressure relief devices immediately handle unexpected increase in pressure (5) Only the minimum necessary oleum inventory is maintained on-site (6) Containment dikes for storage tanks prevent uncontrolled releases (7) When unloading oleum, radio communications is provided to maintain contact with operators (8) An emergency oleum transfer system is available in the event of tank leakage (9) A scrubber system controls emissions from tank storage (10) Water and foam suppression system (11) Tank and piping leak repair kits (pipe wraps, plugs, etc.) (12) Materials for containing, neutralizing and absorbing various hazardous materials (13) Hazardous material response vehicle (14 ) Trained emergency response personnel (15) Personal protective equipment (protective clothing, self-contained/supplied air breathing apparatus) FIVE-YEAR ACCIDENT HISTORY In the past five years the Penreco Dickinson Plant has had one very small (less than one pound) release that occurred on 1/26/95. As a precautionary measure, residences in the immediate vicinity of the plant were instructed to shelter in place. One local resident was examined at a local hospital and released without treatment. This release did not adversely affect the community or our employees. EMERGENCY RESPONSE PROGRAM INFORMATION The Penreco Dickinson Plant has an integrated Emergency Response Plan. The plan is coordinated with the Dickinson Emergency Management Office and the Volunteer Fire Department (DVFD). Our Hazardous Materials (HAZMAT) Team members volunteer to serve the plant and the surrounding community in fire prevention and suppression, and hazardous material releases. Our emergency response teams receive both on-site and off-site comprehensive training. The D.V.F.D. and Fire Marshall tour plant operating units, participate in joint emergency drill exercises and pre-plan emergency contingencies. We have 24-hour communication capabilities with local agencies through our mutual aid emergency portable radio. Penreco Emergency communications are tested weekly to maintain their operational readiness. In addition, Penreco allocates funding for several D.V.F.D. personnel to attend the Texas A&M University Industrial Fire and Rescue School. The plant's emergency response programs consists of procedures for responding to all types of emergencies such as, the release of regulated substances, fire/explosion, evacuation, medical treatment, notification of local emergency response agencies and the public if a release occurs, severe weather (e.g. hurricanes, tornadoes) and post-incident clean-up and decontamination requirements. In the event of an accidental release, the plant ta kes the following actions: (1) Alarm is activated and radio announcement made to all personnel (2) Site and area assessment is made and local emergency agencies notified by "911" (3) Emergency protection systems are activated immediately (4) The site area command post is activated (if necessary) (5) Plant management and technical resources assist emergency responders as needed (6) Emergency Commander declares an "All Clear" and local command posts notified as required Equally important, local residents would be notified by the Dickinson Emergency Alert System to shelter in place (effective method for personal protection) and instructed to take the following precautions: (1) Go inside nearest logical structure (home, public building, office, store, etc.) (2) Brings pets inside (3) Stay clam (4) Close all windows and doors (5) Turn off air conditioning and heating systems (6) Close off fireplace vents (7) If instructed, protect breathing by covering nose and mouth with wet towel or cloth (8) Turn on radio or television to a local emergency broadcast station for information as follows: Houston - KTRH 740 AM Radio KPRC-TV Channel 2 KHOU-TV Channel 11 (9) stay indoors and wait for an "all clear" before going outside and ventilating the structure. In addition, the Penreco Dickinson Plant has procedures that address maintenance, inspection, and testing of emergency response equipment. The plant emergency response program is reviewed annually and updated when necessary based on modifications made to plant processes or other plant facilities. The plant also conducts periodic emergency drills that involve emergency response organizations, and the plant provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the plant. PLANNED CHANGES TO IMPROVE SAFETY The Penreco Dickinson Plant resolves all findings from PHAs, some of which result in modifications to the process. The following types of changes are unde r review: (1) installation of seal-less pumps for oleum transfer pumps (2) video-monitoring capabilities for oleum pumps and storage tanks In addition, Penreco management continually researches the best available technology for prevention and mitigation for any potential release of a toxic substance. Administrative and engineering controls are readily addressed throughout our plant processes. The safety of our employees and the local community, in which we work and live, has and continues to be our primary focus. |