Seadrift Coke, L.P. - Executive Summary

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  Seadrift Coke, L.P. is committed to worker and public 
safety as demonstrated by the resources invested in accident 
prevention, such as training personnel and considering 
safety in the design, operation, and maintenance of our 
processes. Our policy is to implement reasonable 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. 
  Seadrift Coke, L.P. is located on Texas Highway 185 
South, one (1) mile south of the intersection of Texas State 
Highway 185 and Highway 35, North Seadrift, Texas 77983. 
Our facility consists of one delayed coker and a rotary 
kiln. The primary product is calcined petroleum needle coke 
produced from decant oil feedstock. Byproducts from the 
coking process are gas oil, naphtha, light coker naphtha and 
fuel gas. Naphtha, light co 
ker naphtha and fuel gas are 
regulated flammable substances. The other regulated 
substance is chlorine, which is used for water treatment. 
  The worst-case scenario (WCS) associated with a toxic 
substance at our facility involves a catastrophic release of 
the entire content of a full chlorine cylinder due to broken 
nipple or valve.  This scenario assumes release duration of 
10 minutes, a wind speed of 3.4 miles per hour and ambient 
air temperature of 77 degrees Fahrenheit. While the maximum 
quantity of chlorine stored per site is limited to 2000 
pounds, which is less than the RMP threshold quantity for 
chlorine, we have developed numerous controls to prevent 
such releases and managed their consequence. No credit for 
administrative controls was into account in evaluating this 
scenario. The maximum distance to the endpoint of 3ppm 
(0.0087 milligrams per liter) for the WCS is 3.0 miles. 
  The alternative release scenario (ARS) involves the 
failure of a therm 
al plug on a chlorine cylinder, resulting 
in the release of 2000 pounds of chlorine over a 3-minute 
period from a cylinder. The 3-minute period is the 
approximate time to discharge all the chlorine in the 
cylinder. This scenario assumes a wind speed of 7 miles per 
hour. No other mitigation measures are taken into 
consideration in evaluating this scenario. The maximum 
distance the toxic endpoint of 3 ppm (0.0087 milligrams per 
liter for this ARS is 1.3 miles. 
  The WCS associated with a release of flammable substances 
in Program 3 processes at this facility is a vapor cloud 
explosion (VCE) involving the full inventory of a storage 
tank containing naphtha.  The full inventory of 3,500,000.00 
lb. is assumed released, completely vaporize, and ignite 
resulting in a VCE. The maximum distance to the 1-psi 
endpoint for this WCS is 1.2 miles. Although we have several 
controls to prevent such releases and to manage their 
consequences, no credit for passive mitigation measures was 
taken into con 
sideration in evaluating this WCS. 
  The ARS for flammable substances for this facility is a 
VCE involving caused by a leaking light coker naphtha 
transfer line. The maximum distance to the 1-psi endpoint is 
0.1 miles. Emergency planning and responses have been 
developed for these cases. Figures 1 and 2 graphically 
depict the hazard assessment for the toxic and flammable WCS 
  The following is a summary of the general accidental 
prevention program in place at Seadrift Coke, LP. Since all 
the processes subject to the EPA RMP regulation are 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: 
  It is the policy of Seadrift Coke, LP to encourage and 
provide opportunities for all employees to participate in 
the design, implementation of our Loss Control effort. 
ties for participation range from updating and 
compilation of technical documents, participating as members 
of process hazard analysis (PHA) team, Behavioral Science 
Technology (BST) team, and Loss Control Steering Committee. 
These teams typically consists of employees from various 
areas of the plant, including production, maintenance, 
safety, and plant management. While participation is 
voluntary, to provide the broadest possible involvement team 
membership may be required as a condition of employment. 
  All information gathered and developed, as part of the 
accident prevention program is readily available to all 
employees. The employee participation policy is maintained 
and accessible to all employees on the plant computer. 
Process Safety Information: 
  Seadrift Coke, L.P. maintains technical documents that 
are used in maintaining a safe operation. These documents 
address key process parameters, equipment design 
basis/configuration, chemical properties and associated 
hazards. Pro 
cesses are maintained within limits using 
process controls and monitoring instruments, highly trained 
personnel, and protective instruments systems (e.g. 
automated shutdowns systems). 
  Chemical-specific information, including emergency 
response/exposure treatment considerations is provided in 
material safety data sheets (MSDS), which are available 
throughout the plant and on plant computers. Technical 
documents on design and construction of process equipment 
provide information about materials of construction, design 
pressure and temperature ratings, electrical rating, etc. 
This information is used as a basis for inspection and 
maintenance activities, and to evaluate proposed process and 
facility changes to ensure that process safety features are 
not compromised. 
Process Hazard Analysis: 
  Seadrift Coke, LP is committed to an organized and 
systematic effort to identify and analyze potential hazards 
associated with the processing and handling of materials. 
All covered processes ar 
e evaluated and prioritized based on 
the extent of the hazards, age and history of the process, 
location (facility citing), consequences of failure of 
controls, human factors and potential impact of accidents. 
  Seadrift Coke, LP uses the "What If " technique and 
checklists to identify and evaluate hazards of the process 
as well as accident prevention and mitigation measures. 
Analyses are conducted using a team of employees and 
managers who have operating, maintenance, and engineering 
experience and expertise. 
  PHA team findings and recommendations are presented to 
our Loss Control Steering Committee for resolution. The 
final resolution of each finding is documented, retained and 
communicated to all affected employees. Approved mitigation 
options are tracked until completion. Each analysis is 
revalidated at least every five years. 
Operating Procedures: 
  Seadrift Coke, L.P. maintains written procedures which 
address various operating modes such as (1) initial startup, 
(2) normal o 
perations, (3) normal shutdown, (4) temporary 
operations, (5) emergency operations, (6) emergency shutdown 
and (7) startups following turnaround or emergency shutdown. 
  The procedures emphasize operating limits and 
consequences of deviations. Operating procedures are 
reviewed as needed and updated annually to ensure safety and 
consistency with actual practice. 
Safe Work Practices 
  Seadrift Coke, LP has written operating procedures to 
ensure worker and process safety. Procedures cover such 
specific tasks as: (1) lockout/tagout to isolate energy 
sources for equipment undergoing maintenance, (2) confined 
space entry to ensure adequate precautions are in place 
before entry into a confined space, (3) control of entry 
into an area, (4) hot work permit to control spark-producing 
activities, (5) opening of process equipment to control safe 
removal of hazardous materials before process piping or 
equipment is opened. The procedures along with the training 
of affected personnel provide a sy 
stem for ensuring that 
operation and maintenance activities are performed safely. 
    It is the policy of Seadrift Coke, LP that all 
employees receive adequate training and demonstrated 
proficiency before being assigned to a task. Training is 
effected through the use of written task analyses and 
standard operating procedures, audio/visual aids, hands-on 
training through pairing with senior operators for process- 
specific duties and tasks. Proficiency is verified through 
job observations, oral and written examinations before 
operators can work independently. 
  Upgrade or refresher training is provided to ensure that 
employees' knowledge and awareness of hazards, proper 
methods and procedures remain at an acceptable level. All 
affected employees receive refresher on mandated training no 
longer than every three years. 
  Seadrift Coke, LP is committed to a program of selection, 
training, and monitoring of temporary and contract employees 
that will ensure the  
safe and efficient completion of their 
work. Prior to the selection of contract firms for 
maintenance, repairs, turnaround, major renovation, or 
specialty jobs on covered processes, an evaluation of the 
firm's safety program and performance is conducted. All 
contractors are informed of known fire, explosion and toxic 
  Seadrift Coke, LP personnel periodically evaluate 
contractors and contract employees to ensure they are 
trained in safe work practices, properly informed of all 
known hazards and emergency procedures, and to ensure that 
Seadrift Coke, LP is advised of any unique hazards their 
work may present. 
Pre-startup Safety Reviews (PSSRs) 
  Seadrift Coke, LP conducts pre-startup safety review for 
all changes to equipment, materials, and operating 
parameters. PSSR is to ensure that safety feature; 
procedures, personnel, and the equipment are appropriately 
prepared for startup prior to placing equipment into 
service. Checklist and other methods are used for 
verification of the proper implementation of all aspects of 
accident prevention program such as training, communication, 
drawing reviews, design and construction specifications. 
Mechanical Integrity: 
  Seadrift Coke, LP has developed practices and procedures 
for identifying and categorizing process equipment and 
instrumentation to ensure the safe operation of pressure 
vessels, piping systems, relief and vent systems, controls, 
pumps and compressors, and emergency shutdowns systems. The 
mechanical integrity program involves personnel training, 
developing written maintenance procedures, inspecting and 
testing process equipment, and correcting identified 
  Maintenance personnel receive training on (1) process 
overview, (2) safety and health hazards, (3) applicable 
maintenance procedures, (4) emergency response procedures, 
and (5) applicable safe work practices to ensure that they 
perform their job safely. 
  Inspections and tests are conducted at least as often as 
recommended by the manufacturer or in accordance with good 
engineering practices. When possible, identified 
deficiencies are corrected before placing equipment back in 
service or an MOC team is assigned to review the use of the 
equipment and determine actions needed to ensure continued 
safe operation of the equipment. The mechanical integrity 
program is evaluated periodically for compliance with 
company policy. 
Management of Change: 
  It is the policy of Seadrift Coke, LP that all changes to 
equipment, materials, chemistry, operating parameters or 
other aspects of a covered process be subjected to a formal 
management of change program. This requires that changes be 
thoroughly reviewed and documented, that all affected 
personnel be informed, trained and certified if needed, and 
that all plant drawings, operating procedures, emergency 
procedures and records be updated and kept current. 
  A team of employees from maintenance, production, and 
Loss Control departments evaluates propose 
d changes. The 
team determines the impact of planned changes on process 
hazard, material specification, safety, operating, 
maintenance and emergency procedures, and required training 
for affected employees. 
Incident Investigation 
  Seadrift Coke, L.P. investigates all accidents, 
incidents, and near misses.  From these investigations 
remedial actions are developed.  The Loss Control Program 
Steering Committee reviews the remedial actions and the 
approved list of remedial actions is entered into the 
remedial action tracking system in the computer.  All 
approved remedial actions are followed up to completion, 
before the Accident/Incident Report is closed.   These 
incident reports are kept on file in the computer for at 
least 5 years.  The reports are available to all employees 
on the computer. 
Compliance Audits 
  To ensure that accident prevention program continues to 
be effective, a team of plant personnel conducts a quarterly 
evaluation on all Accident/Incident Reports entered d 
the previous quarter.  These evaluation reports are sent to 
the Loss Control Program Steering Committee for review and 
discussion.  The audit team's effectiveness and the entire 
Accident/Incident Reporting Program are audited at least 
annually to verify compliance with the established program. 
Remedial actions from this audit, approved by the Loss 
Control Program Steering Committee, are followed up to 
  The processes at Seadrift Coke, L.P. have hazards that 
must be managed to ensure continued safe operation. The 
accident prevention program summarized above is applied to 
all RMP-covered processes. The prevention activities help 
prevent potential accident scenarios that could be caused by 
(1) equipment failures and (2) human errors. 
  However, we have safety features on process units to help 
(1) contain/control a release, and (2) reduce the 
consequence of (mitigate) a release. The following types of 
safety features are used in various proce 
Release Containment/Control 
z  Process relief valves that discharge to a flare. 
z  Valves to permit isolation of the process 
z  Automated shutdown systems for specific process 
 parameters (e.g. high level, high temperatures , low flow) 
z  Diking to contain liquid releases 
z  Redundant equipment and instrumentation (e.g., 
 interruptible power supply for process control, backup 
 firewater pump truck) 
Release Mitigation 
z  Fire suppression and extinguishing systems 
z  Deluge system on storage tanks 
z  Trained emergency response personnel 
z  Personal protective equipment (protective clothing, self- 
 contained breathing apparatus) 
Five-year Accident History 
  Seadrift Coke, L.P. has an excellent record of accidents 
over the past 5 years.  Frequency of accidents is continuing 
to decline.  No significant releases of hazardous materials 
have occurred in the past 5 years.  All accidents/incidents 
and near misses are investigated.  Pre plans are in place 
for any incident considere 
d a reasonable probability. 
Monthly drills are conducted with our on site emergency 
response teams on these and other pertinent scenarios. 
  Seadrift Coke, L.P. maintains a written emergency manual, 
which is in place to protect worker and public safety as 
well as the environment.  The program consists of procedures 
for responding to a release of a regulated substance, 
including the possibility of a fire or explosion if a 
flammable substance is accidentally released.  The procedure 
address all aspects of emergency response, including proper 
first-aid and medical treatment for exposures, evacuation 
plans and accounting for personnel after an evacuation, 
notification of local emergency response agencies and the 
public if a release occurs, and post-incident cleanup and 
decontamination requirements.  In addition, Seadrift Coke, 
L.P. has procedures that address maintenance, inspection, 
and testing of emergency response equipment, as well as 
struction that address the use of emergency response 
equipment.  Employees receive training in these procedures 
as necessary to perform their specific emergency response 
duties.  The emergency manual is updated when necessary 
based on modifications made to a process or equipment.  The 
emergency response program changes are administered through 
the MOC process, which includes informing and/or training 
affected personnel in the changes. 
  The overall emergency response program for Seadrift Coke, 
L.P. is coordinated with the Calhoun County Local Emergency 
Planning Committee (LEPC).  This coordination includes 
periodic meetings of the committee, which includes local 
emergency response officials, local government officials and 
industry representatives.  Seadrift Coke, L.P. has around- 
the-clock communications capability with appropriate LEPC 
officials and emergency response organizations (e.g., fire 
department).  This provides a means of notifying the public 
of an incident, if necessary,  
as well as facilitating quick 
response to an incident.  In addition to periodic LEPC 
meetings, Seadrift Coke, L.P. conducts periodic emergency 
drills that involve the LEPC and emergency response 
organizations.  A CAN system (Community Alert Network) is in 
place to notify the public of any potential releases.  It 
uses a telephone system to notify all neighbors including 
industry.  It is tested periodically to check its readiness. 
  Seadrift Coke, L.P. maintains a contract with two large 
spill response organizations to help mitigate any spill.
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