Seadrift Coke, L.P. - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES |
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.
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED
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.
HAZARD ASSESSMENT RESULTS.
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
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS.
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.
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
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
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.
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.
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
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.
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.
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
SPECIFIC PREVENTION STEPS
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
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)
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.
EMERGENCY RESPONSE PROGRAM INFORMATION
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.