Westlake Monomers/CA&O Corporation - Executive Summary |
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WESTLAKE CA&O/MONOMERS CORPORATION RISK MANAGEMENT PLAN EXECUTIVE SUMMARY The Westlake CA&O/Monomers Corporation at Calvert City, Kentucky is a program 3 facility under the EPA's Risk Management Plan (RMP). The facility contains eight chemicals on the RMP list of chemicals. The Westlake CA&O/Monomers Plant Manager has the overall responsibility for the facility. The Westlake CA&O/Monomers Environmental Manager reports to the Plant Manager and has overall responsibility for compliance with all aspects of the plant's Risk Management Plan. The Westlake CA&O/Monomers Plant at Calvert City manufactures Vinyl Chloride for use in the plastic industry. The largest quantity feedstock, Propane, is used in the production of Ethylene. The site produces Chlorine and Ethylene used in the production of Vinyl Chloride. The Westlake CA&O/Monomers Corporation is committed to continuous improvement in all aspects of safety and environmental performance. As a site that is under the OSHA Process S afety Management (PSM) regulation, the Calvert City Plant is committed to preventing chemical emergencies. Prevention of chemical emergencies starts with specifying that all equipment, piping, vessels, tanks, and systems meet all applicable design codes and specifications. Documentation of these codes and specifications form the basis of our process information including flow diagrams, piping and instrument diagrams, and process descriptions. Supplementing this information are trained employees working with operating instructions, startup/shutdown instructions and consequences of deviation to keep our processes operating in safe limits that minimize any adverse impact on the employees, the environment and the surrounding community. Under PSM, employees are involved in all aspects of Plant operations and the Safety / Environmental programs. Employees are regularly trained, certified and participate in random substance abuse checks to insure a qualified, alert workforce. Our safety process contains many other elements including Management of Change, hot work procedures and regular process hazards analysis using the hazard and operability (HAZOP) methodology. All contractors at the facility are subject to the same rules and procedures as Westlake employees as well as the Contractor Safety Program. A comprehensive Mechanical Integrity Program includes routine checks of process equipment, tanks, vessels and piping. Auditing of these programs is done at the production unit, Plant and Corporate levels. Key to the Plant's prevention programs is the layers of protection provided in the process. Trained operators working with current operating procedures, control systems, and instrumentation keep the processes operating safely and in environmental compliance. Instrumentation alarms, process trips and interlocks alert the plant operators to deviations and provide early warning to process upsets. In the event an upset leads to an abnormal condition, process safety devices including pressure relief valves, rupture discs, automatic shutdown and critical interlocks will be activated. Fire sprinklers, sensors, monitor nozzles and dry or CO2 chemical extinguishers, cover the process areas. The plant has 24-hour surveillance of operating personnel. Backing up the safety systems are trained emergency responders. The plant has emergency fire equipment including a fire truck and an emergency response vehicle. Each shift is lead by a Shift Supervisor who, in an emergency, assumes the duties as on-scene Commander. Westlake CA&O/Monomers is a member of the Calvert Industrial Mutual Aid Program (CIMAP) and can count on pooled resources from surrounding plants. The Calvert City Fire Department is also a responding party to emergencies if needed. As a member of the Local Emergency Planning Committee (LEPC), Westlake participates in drills with emergency responders. Disaster Emergency Service (DES), LEPC, Calvert City Fire Department members annually tou r the facility to familiarize themselves with the plant, hazardous materials, equipment, layout and personnel. The Westlake CA&O/Monomers Plant has four flammable liquids (Propane, 1,3 Butadiene, Vinyl Chloride and Ethylene) on site. Propane and Ethylene are the flammable materials used in the worse case and alternate scenario The worse case scenario for a flammable is the assumption of an instantaneous failure of the propane cavern pump head 3-ft diameter shaft. The distance to a 1.0 psi overpressure endpoint using the EPA look up tables would exceed the plant boundary. The propane storage cavern design minimizes release potential, and 24-hour surveillance, detailed operating procedures, process hazard analyses and PSM are additional layers of protections. The alternate case scenario is the failure of a > inch pipe nipple in an ethylene line to the process. The distance to the 1.0 psi overpressure endpoint using the EPA look up tables would exceed the plant boundary. System d esign, material of construction, operating procedures, PSM, and 24-hour surveillance are layers of protection to prevent an occurrence. The facility has four chemicals on the toxic chemicals list for RMP. The chemicals are Chlorine, Hydrogen Chloride, Anhydrous Ammonia, and Chloroform. Chlorine is the chemical used in the worse case scenario and the alternate case scenario. The distance to the endpoint using the EPA look up tables would exceed the plant boundary. The worse case for Chlorine is the instantaneous failure of a tank wall of the storage vessel with the failure of all safety systems. The vessel design, relief valves, area monitoring, remote valves, PSM, operator training, operating procedures, empty storage vessel and 24-hour surveillance are layers of protection to prevent an occurrence. The alternate case for Chlorine is the failure of a > inch pipe nipple on a chlorine line to the process. System design, material of construction, operating procedures, operating tr aining, PSM, 24-hour surveillance are layers of protection to prevent occurrence. There have been no releases of any of the listed chemicals at the Westlake Facility in the past five years that have had an adverse impact on the community. There was one incident at the facility that meets the EPA RMP reporting requirements with respect to injuries involving a release of Chlorine. This release occurred prior to Westlake taking ownership. |