Westlake Polymers Corp, Poly 1 & 2 - Executive Summary |
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6164 LDEQ Facility ID Number This Executive Summary contains the following brief descriptions of the Westlake Polymers Risk Management Program: - Accidental release prevention and emergency response policies A. Description of the stationary source and regulated substances B. Offsite consequence analyses summary C. General accidental release prevention program and chemical-specific prevention steps (Management System for Process Safety/Risk Management) D.Emergency response program E. Five-year accident history F. Planned changes ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The Westlake Polymers Corporation in Sulphur LA has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regul ated substances. However, if a release does occur, our trained personnel will respond to control and contain the release. A. DESCRIPTION OF FACILITY Westlake Polymers is located in an industrial complex in Sulphur Louisiana. It operates 5 low-density polyethylene units using minor variants of one process. The polyethylene product is sold to other companies who make a wide variety of things, from plastic films and bags to the little clear plastic shaker-caps on hot-sauce bottles. The first units were built in 1966, and the last major change, a re-start of an existing unit, occurred in 1993. Westlake uses several listed flammable chemicals as essential ingredients (they all react to form part of the final product) in its process: ethylene, propylene, isobutane, as well as one listed toxic chemical: vinyl acetate. B. OFFSITE CONSEQUENCE ANALYSES (HAZARD ASSESSMENT) SUMMARY The Worst-Case Scenario for flammables on site involves an instantaneous release/evaporation/dispersion and exp losion of the contents of a propylene storage vessel. No credit is taken for any of the existing mitigation systems. This is a physically impossible event, but at least represents an "upper bound" as no accident involving flammable could possibly lead to a bigger result. The Worst-Case Scenario for a Toxic release on site involves a rupture of a vinyl acetate storage tank. This is a Liquid at ambient conditions and the dike around the vessel is an existing passive mitigation system that would certainly limit the consequence of such a scenario. In accordance with federal and state guidelines for calculation, this release is assumed to occur at the worst case weather conditions of 'F' Pasquill stability class and 1.5meters/second. Which occurs only on still, cloudy nights. The Planning Case (Alternate Release) Scenario for a flammable involves a release and flash fire of ethylene gas from the incoming pipeline metering area. A >" drain line was assumed to be knocked off completely, and it was assumed that no one would be able to shut off the flow for 15 minutes. No other active or passive mitigation was considered even though such systems exist. This is a very conservative assumption as there are remote-controlled valves in this area as well as detection capability, alarms, and fire-water monitors which our operators are trained to use to disperse leaks. This case was analyzed at average weather conditions for our area. There are other conditions that could lead to larger release rates, but these are a long way from the edge of the property. The analysis showed these other cases would have no offsite impact. The Planning Case (Alternate Release) Scenario for the only toxic material involves a release of vinyl acetate liquid from the incoming pipeline metering area. A >" drain line was assumed to be knocked off completely, with the liquid pouring out and spreading across the concrete pad. It was assumed that no one would be able to shut off the flow for 15 minutes. This is a very conservative assumption as there are valves in this area as well as detection capability, alarms, and fire-water monitors with foam injection capability to blanket the leak. This case was analyzed at average weather conditions for our area. C. MANAGEMENT SYSTEM FOR PROCESS SAFETY/RISK MANAGEMENT C1. SCOPE: The following is a summary of the general accident prevention program in place at the Westlake Polymers Corporation. Because the processes at the site that are covered by the EPA RMP regulation are 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. Westlake believes the requirements of the two regulations are so similar, or so complimentary, that only one management system is required to comply with all of them. And because our site is an OSHA Star worksite, (denoting the highest safety designation a plant can receive from OSHA), our p rograms are frequently reviewed by OSHA to ensure continuous improvements The Management System for controlling process safety at the site includes a broad range of management programs as outlined in the Procedures Section below. This procedure describes the management system in general terms. Most of the detailed requirements are contained in more specific Safety, Process Safety, Operations and Maintenance policies and procedures as referred to below. C2. EMPLOYEE PARTICIPATION Westlake Polymers 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 and chemical information to participating as a member of a process hazard analysis (PHA) team. Employees have access to all information created as part of the site accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in an employe e participation plan that is maintained at the site and addresses each program element. In addition, the site has five committees onsite dedicated to safety (including one specifically dedicated to process safety issues) that include members from various areas of the plant, including operations, maintenance, engineering, and plant management. C3. PROCESS SAFETY INFORMATION The Petrochemicals site keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents are available to all personnel onsite In paper form or through our computerized document management system. 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. A list of reference documents and their location is readi ly available as part of the written employee participation plan to help employees locate any necessary process safety information. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs) that are available to employees through the computerized document management system and in the central MSDS file. This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with inadvertent mixing of chemicals. The plant ensures that the process is maintained within safe limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems). The site also maintains numerous technical documents that provide information about the design and construction of process equipment. This information materials of construction, design pressure and tem perature ratings, electrical rating of equipment, etc. This information in combinations with written procedures and trained personnel, provides a basis for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. C4. PROCESS HAZARD ANALYSIS Westlake Polymers has a comprehensive 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 controls are in place to manage these hazards. The site primarily uses the hazard and operability (HAZOP) and checklists analysis techniques to perform these evaluations. The combination of HAZOP and checklists analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The analyses are conducted using a team of people who have operating, maintenance, and engineering expertise, as well as knowledge of the ana lysis technique being used. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team findings are forwarded to local 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 findings are tracked until they are completed. 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 feature, the site periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every five years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained. C.5 OPERATING PROCEDURES The site maintains written procedures that address various modes of process operations, such as unit startup, normal operations, temporary operations, normal shutdown, and emergency shutdown. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. These procedures provide guidance on how to respond to upper or lower limit exceedences for specific process or equipment parameters. All this information is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks. These pr ocedures are regularly reviewed and certified as current and accurate. The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change and ISO 9002 (quality) process. C6. TRAINING To complement the written procedures for process operations, the site has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in plant 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 (through tests, 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 three years. All of this training is documented for each operator, including the means used to verify that the operator understood the training. C7. CONTRACTORS Westlake uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the site 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 workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform site 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, the site evaluates contractor safety and performance during the selection of a contractor. Site personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. C8.PRE-STARTUP SAFETY REVIEWS The site conducts PSSR's for new facilities or facility modifications 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 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 a quality assurance function by requiring verification that accident prevention program requirements are proper ly implemented. C9.MECHANICAL INTEGRITY Westlake 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 inspections 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 provide a basis for training. I nspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or a 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 site incorporates quality assurance measures into equipment purchases and repairs. This action helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. The Mechanical Integrity (MI) program is the responsibility of the Maintenance and Reliability Managers. Details are contained in the Mechanical Integrity Program procedures developed by Maintenance and Reliabi lity. The following items are covered by the MI procedures: 7 Periodic inspection of all pressure vessels and tanks 7 Periodic inspection of process piping 7 Periodic inspection and testing of all Relief Devices including "safety" Relief Valves. Rupture Disks, "emergency" Tank Vent Hatches. This program also includes the Flame and Deflagration Arrestors on site. 7 Periodic testing of critical rotating equipment 7 Periodic testing of Safety Critical Systems such as emergency shut-downs and controls. Westlake Engineering Department conducts Quality Assurance reviews on new construction projects per their project procedures. Westlake trains each maintenance employee in: 7 an overview of the process and its hazards 7 the procedures applicable to the employee's job tasks to assure that the employee can perform the tasks in a safe manner C10.SAFE WORK PRACTICES Westlake has long-standing safe work practices in place to help ensure worker and process safety. Examples of the se include (1) control of the entry/presence/exit of support personnel in the units, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous materials before process piping or 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. C11.MANAGEMENT OF CHANGE Westlake 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. Change s are reviewed to (1) ensure that adequate controls are 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 change. C12.INCIDENT INVESTIGATION The site 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 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 site management for resolution. Corrective actions taken in res ponse to the investigation team's findings and 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. Incident investigation reports are retained for at least five years so that the reports can be reviewed during future PHAs and PHA revalidations. C13.COMPLIANCE AUDITS To help ensure that the accident prevention program is functioning properly, the site periodically conducts an audit to determine whether the procedures and practices required by the accident prevention programs are being implemented. Compliance audits are conducted at least every three years. The audit team develops findings that are forwarded to site 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 docume nted, and the two most recent audit reports are retained. C14. CHEMICAL-SPECIFIC PREVENTION STEPS The processes at Westlake Polymers have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to the RMP covered processes at the site. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failure and human errors. In addition to the accident prevention program activities, the site has safety features on many 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 features are used in various processes: Release Detection 7 Hydrocarbon detectors with alarms Release Containment/Control 7 Process relief valves on applicable vessels/tanks 7 A flare-system to capture and incinerate episodic releases 7 Valves to permit isola tion of the process (manual or automated) 7 Automated shutdown systems for specific process parameters (e.g., high pressure, high temperature, high level) 7 Curbing or diking around applicable tanks to contain liquid releases 7 Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump, etc.) 7 Flanges, gaskets, and fittings that meet or exceed design code requirements 7 Appropriate corrosion allowances in piping and equipment 7 Fail-safe positions for control valves on loss of power source Release Mitigation 7 Fire suppression and extinguishing systems 7 Deluge system for specific equipment 7 Foam-application systems for specific equipment to limit the vapors given off from spills 7 Trained emergency response personnel 7 Personal protective equipment (e.g., self-contained breathing apparatus, respirators, etc.) 7 Blast-resistant buildings to help protect control systems and personnel so they can bring a process to a safe condition after an emergency D. EMERGENCY RESPONSE PROGRAM INFORMATION Westlake maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consist 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 procedures address all aspects of emergency response, including evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies, and post incident cleanup requirements. In addition, the site has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions 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 response program is updat ed when necessary based on modifications made to the processes or other facilities. Affected personnel are informed of changes and trained appropriately. The overall emergency response program for the site is coordinated with the Lake Charles, LA 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. The site has around the clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This capability 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, the site conducts periodic emergency drills that may involve the LEPC and emergency response organizations, and the site provides regular refresher training to our emergency responders regarding hazards o f regulated substances at the site. E. FIVE-YEAR ACCIDENT HISTORY Westlake Polymers keeps records of all significant accidental chemical releases that occur at our facility. Every incident is investigated very carefully to determine ways to prevent similar incidents from occurring. The following is a brief summary of accidental chemical releases involving material covered under EPA/s RMP rule since June 1994. This incident history considers offsite impact such as shelter-in-place of the public and injuries to the public, and onsite impacts such as injuries or significant equipment damage. 7 May 1995, a low-order decomposition occurred, causing a pipe to fail suddenly, which lead to a flash fire. There was one indirect injury and property damage exceeded $100,000. No off-site impact occurred. 7 November 1995, A flash ethylene fire occurred in the F-line extrusion hopper. An employee standing nearby received thermal burns, but was able to return to work. No off-site impact occurr ed. F. PLANNED CHANGES Westlake Polymers is committed to the concept of continuous improvement, and has a number of active programs (as outlined in section C above) to identify opportunities for improvement, including reducing the possible impact of an incident on the community or the environment. For example, Westlake Polymers has reduced the use toxic chemicals by substituting a less hazardous water treatment chemical. File: EXECSUM2.DOC |