Westlake Petrochemicals Corporation - Executive Summary |
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12409 LDEQ Facility ID Number Westlake Petrochemicals Corporation, Sulphur, LA Risk Management Plan Executive Summary The RMP rule requires that this site provide an executive summary in the RMPlan. This summary provides the following items: 7 Accidental release prevention and emergency response policies 7 Description of the stationary source and regulated substances handled 7 Worse case and alternative release scenarios 7 General accident release prevention program and chemical-specific prevention steps 7 Five year accident history 7 Emergency response program 7 Planned changes to improve safety ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The Westlake Petrochemicals Company in Sulphur LA has a long-standing commitment to worker and public safety. Our injury/illness rate is far below the national average. We have received awards from the government and industrial groups for our efforts to maintain the safest possible operations. As an OSHA Star site, we have been recognized by the federal government as a company that puts the highest priority on safety. We also received the 1997 Distinguished Safety Award from the National Petroleum Refiners Association, only one of two companies in the nation to receive this prestigious award. Our primary focus is to provide safe operations without upset. We do this through prevention and planning during all phases of operation: design, production, and maintenance. Examples of equipment that we have include automatic fire water systems, emergency shutdown systems, containment systems, and monitors to detect leaks. Our processes are controlled by a sophisticated computer control system. We also have well trained personnel to oversee our operations and prevent accidents. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our personnel will respond to control and contain the release. DESCRIPTION OF THE STATIONARY SOURCE AND RE GULATED SUBSTANCES The Westlake Petrochemicals site is located in Carlyss, Louisiana, south of Sulphur. It is comprised of three separate permitted operating facilities under Clean Air Act and Clean Water Act. All facilities are located on a contiguous site. There are two petrochemical units that receive ethane feedstock and produce ethylene and various other petroleum products that are used to form plastics, rubber, and fuels. There is also a Styrene unit that takes ethylene and produces styrene for use in Styrofoam and automotive products. There is a Polyethylene unit that takes ethylene and produces polyethylene plastics. The Petrochemicals site has regulated flammables such as ethane, ethylene, and pentane. The site also uses chlorine and ammonia during processing; however, the quantities are below the RMP threshold quantities. WORSE CASE (WCS) AND ALTERNATIVE RELEASE SCENARIOS (ARS) The WCS associated with a release of flammable substances in Program 2 and 3 processes at the si te is a vapor cloud explosion (VCE) of the largest storage tank containing pentane. It involves an instantaneous/evaporation dispersion and explosion of the contents of the tank. Written operating procedures and high-high level alarms prevent the level in the tank from exceeding 44 feet. This scenario has the potential for offsite impacts. The scenario is considered very unlikely as it assumes the failure of all safeguards (including equipment and personnel) and the entire mixture is assumed to have the properties of pentane, when, actually only about 20% of the mixture is pentane, the residual is heavier material not on the RMP list. There are no toxic materials at threshold quantities requiring a WCS analysis. The ARS associated with a release of flammable substances at the site is the radiant heat effects of a release of ethylene from an overhead line of a vessel. This scenario has the potential for offsite impact due to release of radiant heat that may cause blistering of bare ski n, similar to a severe sunburn if exposed for a long period of time. This scenario is still considered unlikely, but is more effective to use as a planning case for response. This scenario was chosen due to an incident at another ethylene plant (not in the Westlake Group of companies). There are no toxic materials at threshold quantities requiring an ARS analysis. FIVE YEAR ACCIDENT HISTORY Westlake Petrochemicals 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. March 1998 - Flash fire occurred in a Process Gas Dryer. Four contr act personnel working in and around the vessel were injured. There were no offsite impacts and no significant property damage. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS The following is a summary of the general accident prevention program in place at the Westlake Petrochemicals site. Because processes at the site are regulated 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. And because our site is an OSHA Star worksite, (denoting the highest safety designation a plant can receive from OSHA), our programs are frequently reviewed by OSHA to ensure continuous improvements. Employee Participation The Westlake Petrochemicals site encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical docu ments 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 employee 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. 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 through a computerized document management system. These documents address chemical properties and associated hazards, limits for key pro cess 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 readily 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 Mockingbird 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. For specific process areas, the plant has documented safety-related limits for specific process parameters (e.g., temperature, level, composition, pressure ) in data books. The plant ensures that the process is maintained within these 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 temperature 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. Process Hazard Analysis Westlake Petrochemicals 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 ar e 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 analysis 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. Operating Procedures The site maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5 ) normal shutdown, and (6) initial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. These procedures are periodically 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 process. In addition, the units maintain a data book that provides guidance on how to respond to upper or lower limit exceedences for specific process or equipment parameters. This information, along with written operating procedures, is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks. 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 bas ic 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. Contractors Westlake Petrochemicals 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. Pre-Startup Safety Reviews (PSSRs) The site conducts a PSSR for any new facility or facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that safety feat ures, 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 properly implemented. Mechanical Integrity Westlake Petrochemicals 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 def iciencies, and (5) applying quality assurance measures. In combination, these activities forma 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. Inspections 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 o peration 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. Safe Work Practices Westlake Petrochemicals has long-standing safe work practices in place to help ensure worker and process safety. Examples of these 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 proc edures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change Westlake Petrochemicals 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. Changes 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. 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 response 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. 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 documented, and the two most recent audit reports are retained. CHEMICAL-SPECIFIC PREVENTION STEPS The processes at Westlake Petrochemicals have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all Program 2 and 3 EPA RMP covered processes at the site. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failure and (2) 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 7 Sophisticated computer control system Release Containment/Control 7 Process relief valves that discharge to a flare to capture and incinerate episodic releases 7 Valves to permit isolation 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 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 Trained emergency response personnel 7 Personal protective equipment (e.g., protective clothing, respirators, etc.) 7 Blast-resistant buildings to help protect control systems and personnel EMERGENCY RESPONSE PROGRAM INFORMATION Westlake Petrochemicals 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 proce dures 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 updated 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 incid ent, 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 quarterly refresher training to our emergency responders regarding hazards of regulated substances at the site. PLANNED CHANGES TO IMPROVE SAFETY As an OSHA Star Site, Westlake Petrochemicals is in a mode of continuous improvement. Changes are ongoing to ensure reliable control of the process. Sources of enhancements to the processes include audits, PHAs, incident investigation, and Safety Suggestions from employees and contractors. |