Seadrift Coke, L.P. - Executive Summary |
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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 SUBSTANCES. 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 events. 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. 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. Opportuni 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. Training 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. Contractors 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 release hazards. 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 field 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 deficiencies. 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 uring 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 completion. 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 sses: 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. 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 in 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. |