Equistar Chemicals, LP - Lake Charles Plant - Executive Summary |
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LDEQ Facility ID Number: 17547 Equistar Chemicals, LP (Equistar), a limited partnership formed by Lyondell Petrochemical, Millennium Chemical, and Occidental Petroleum Corporation, operates an ethylene and propylene manufacturing facility, the Lake Charles plant, in Sulphur, Louisiana. The facility is located at 4300 Hwy 108 South. The ethylene facility, or stationary source, consists of one process plant and support facilities. Equistar employs approximately 112 full time employees at the plant site. 1) Accidental release prevention and emergency response policies at the stationary source (' 68.155a): Equistar is committed to operating the plant in a manner that is safe for its workers, the public and the environment. As part of this commitment, Equistar has established a system to help ensure safe operation of the processes at the Lake Charles Plant. One component of this system is a risk management program (RMP) that helps manage the risks at the plant and that complies with th e requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR part 68, Accidental Release Prevention Requirement Risk Management Programs (the RMP rule) and the OSHA 1910.119. This document is intended to satisfy the RMP Plan requirement of the RMP rule and to provide the public with a description of the risk management program at the Plant. The risk management program at the Lake Charles Plant consists of the following three elements: 7 A hazard assessment to help understand (a) the potential off-site consequences of hypothetical accidental releases and (b) accidents that have occurred during the last five years associated with the use of substances regulated by the RMP rule (regulated substances) 7 A prevention program to help maintain and safely operate the processes containing more than a threshold quantity of a regulated substance (covered processes) 7 An emergency response program to help respond to accidental releases of regulated substances from covere d processes Information further describing these elements is provided in this RMP Plan. Although the risk management program at the Lake Charles Plant helps provide assurance that the facility is maintained and operated in a safe manner, it is only one component of the safety program at the Plant. In fact, the Plant has a comprehensive safety program in place, establishing many levels of safeguards against a release of a hazardous substance as well as injuries and damage from a release of a hazardous substance. Equistar's policy on the use of hazardous substances: Before using a hazardous substance, less hazardous alternatives are considered. When a hazardous substance is used, Equistar considers the potential for this substance which could adversely affect the plant workers, the public and the environment through the management of change and the process hazard analysis processes and takes steps to prevent any such effects. Equistar strives to prevent accidental releases of the ha zardous substances used at the facility: Equistar implements reasonable controls to prevent foreseeable releases of hazardous substances. When a hazardous substance is used, the equipment is carefully designed, built, operated and maintained to reduce the likelihood of an accidental release. Industry and government standards are closely adhered to in the design, construction and operation of the equipment. Equistar uses Fire, Safety and Environmental (FS&E) Guidelines when designing new or modifying existing processes. Each project is thoroughly reviewed before approval. In addition, Equistar requires the documentation of standard operating procedures and the training of affected employees with regard to these procedures as part of the management of change process. Equistar's mechanical integrity program provides an ongoing process to verify the mechanical integrity of the equipment, piping and instruments to prevent the release of hazardous substances. Equistar's goal is to minimi ze impact from an accidental release: In the event of an accidental release, the Lake Charles Plant controls and contains the release in a manner that will be safe for workers and will prevent impact to the public and the environment. Equistar provides response training to its personnel, designates an emergency response coordinator to oversee response activities, conducts regular drills to review response activities, and coordinates response efforts with area industry and the local emergency response agencies. Equistar trains its workers to respond to an accidental release, reducing the consequences of a release if it occurs. In addition, Equistar works with the area industry, the local fire department and the local emergency planning committee (LEPC) to help prevent injuries and/or environmental damage if a release does occur. Response activities have been discussed with the Local Emergency Planning Committee and Southwest Louisiana Mutual Aid Association. Equistar is an active par ticipant in the community: As part of Equistar 's Responsible Care(r) efforts, the Lake Charles Plant has voluntarily been involved in a Community Advisory Panel (CAP) since July, 1992. The purpose of this group is to share information about plant operations with members of the community and to discuss their concerns. The group meets monthly and covers topics of interest to the members including plant safety and environmental performance, emergency response programs, health issues and process safety performance. Through this outreach effort, as well as other community involvement, the plant stays abreast of community concerns and works to address them. The safety program at the Lake Charles Plant consists of a number of elements, only some of that are required by the RMP rule. This RMP Plan is primarily intended to describe those parts of the safety program at the Lake Charles Plant that are required by the RMP rule. The Lake Charles Plant is an active member in the OSHA Voluntary Participation Program (VPP) and has been designated an OSHA Star site, the highest ranking for a plants safety program. The Lake Charles Plant was the first certified OSHA Star site in southwest Louisiana (9/93). It was the first facility to be recertified an OSHA Star site in southwest Louisiana (11/96). The Lake Charles Plant was the first site to be certified, without any contingencies, out of the OSHA Baton Rouge office. The Lake Charles plant actively participates in and is committed to the Chemical Manufacturers Association's Responsible Care(r) initiative. Over the past five years the Lake Charles Plant has received the following safety and environmental awards: Environmental Awards: 7 Louisiana Governor's Environmental Leadership Recognition Award '97 Safety Awards: National Petroleum Refinery Association 7 1994 Award for Meritorious Safety Performance - Incident Rate 0.0% 7 1994 Gold Award - 100% reduction in recordable incident rate 7 1994 Award for Safety Ach ievement - 6 years without lost workday 7 1994 Award for Safety Achievement - 2,010,000 manhours without lost workday 7 1995 Gold Award - 100% reduction in recordable incident rate 7 1995 Award for Safety Achievement - 7 years without lost workday 7 1996 Award for Meritorious Safety Performance - Incident Rate 0.8% 7 1996 Award for Safety Achievement - 8 years without lost workday 7 1997 Award for Meritorious Safety Performance - Incident Rate 0.7% 7 1997 Award for Safety Achievement - 9 years without lost workday . 1998 Gold Award - 100% reduction in recordable incident rate . 1998 Award for Meritorious Safety Performance - Incident Rate 0.0 % . 1998 Award for Safety Achievement - 3,126,530 employee hrs without lost workday . 1998 Award for Safety Achievement - 10 years without lost workday Chemical Manufactures Association 7 Certificate Of Honor "No Lost Workdays" 1992 - 1998 Louisiana Chemical Association . S.A.F.E. (Serious About Fostering Excellence) Program Awards in t he categories of Employee Safety, Contractor Safety-Level 2, Contractor Safety-Level 3, Environmental, and Community Involvement Equistar is committed to the safety of workers, the public and the preservation of the environment through the prevention of accidental releases of hazardous substances. Equistar implements reasonable controls to prevent foreseeable releases of hazardous substances. These controls include programs to train personnel, to help ensure safety in the design, installation, operation, maintenance of processes and to evaluate the hazards at the Lake Charles plant. The Lake Charles plant participates in auditing processes like the OSHA VPP to measure and enhance its prevention program. It is our policy to adhere to all applicable federal, state and local rules and regulations, industry standards and best practices. To effectively implement these policies, Equistar has established a management system headed by the Health, Environmental and Safety (HES) Departmen ts to oversee safety and environmental-related activities. 2) The stationary source and the regulated substances handled (' 68.155 b): Equistar's Lake Charles Plant is located on a 300-acre site and began operations in 1969 under Cities Service. OxyChem purchased the site from Cities Service, which had shut the facility down two years prior, then modernized and started up the ethylene plant in 1986. In May of 1998, the plant was leased to Equistar from Occidental Petroleum upon joining the Equistar partnership. The Lake Charles Plant's key products are ethylene and propylene with by-products of hydrogen, crude butadiene and pyrolysis gasoline. The feedstocks used are ethane and propane. The stationary source consists of one ethylene process area and support facilities. All feedstocks and products arrive or leave the facility by pipeline. Pyrolysis gasoline is transported by pipeline to the Texas Petrochemicals Corporation's dock where it is loaded into barges for transportat ion. The Lake Charles Plant handles several regulated substances in sufficient quantity to be covered by the RMP rule and falls under the Level 3 Program at the plant. Currently, Equistar does not have any RMP listed toxic material above the threshold quantity. Regulated Substance Process Quantity *, lb. RMP Threshold, lb. Ethylene 490,000 10,000 Propylene 25,000,000 10,000 1,3 Butadiene * 710,000 10,000 Butene * 320,000 10,000 Butane * 45,000 10,000 Isobutane * 11,000 10,000 2-Pentene (E) ** 200,000 10,000 2-Methyl-1-butene ** 130,000 10,000 1,3 Pentadiene ** 170,000 10,000 Methane 29,000 10,000 Ethane 110,000 10,000 Propane 550,000 10,000 *The quantity given is the component's amount in the mixture Crude Butadiene, not the mixture total. **The quantity given is the component's amount in the flammable mixture Pyrolysis Gasoline, not the mixture total. The following are the five products and by-products produced at Equistar's Lake Charles Plant which fall under the RMP guidelines. Two of the five are mixtures, not pure chemicals, so the RMP listed components and their respective percentage have been provided: Ethylene is a listed flammable under RMP which is produced and sold to others to make plastic bags, synthetic fabrics, antifreeze, safety glass, paints, aspirin, a raw material for all plastics. 490,000 lbs is the maximum amount in the process at any given time. Propylene is a listed flammable under RMP which is used to make carpet, synthetic fibers, automobile parts, nylon products, synthetic fabrics, raw m aterial for all plastics, pharmaceuticals, luggage, toys, disposable diapers. 25,000,000 lbs is the maximum amount in the process at any given time. Crude Butadiene contains some listed flammables under RMP and is produced and sold to others to further refine and then used to make tires, carpet, seat belts, fishing line, rubber goods, footwear. 1,100,000 is the maximum amount in the process at any given time and it contains the following listed components under the RMP rule: 7 1,3 Butadiene 64.6% 7 Butene 29.3% 7 Butane 4.1% 7 Isobutane 1.0% Pyrolysis Gasoline contains some listed flammables under RMP and is produced and sold to others to further refine and then used to make computer cases, telephones, piping, food packaging, housewares. 6,700,000 lbs is the maximum amount in the process at any given time and it contains the following listed components under the RMP rule: 7 2-Pentene (E) 3.0% 7 2-Methyl-1-butene 2.0% 7 1,3 Pentadiene 2.5% Methan e is a listed flammable under RMP, which is produced and imported by pipeline to use as a fuel on equipment in the operating unit. 29,000 lbs is the maximum in the process at any given time. The following are two additional RMP listed materials that are used, but not produced, at Equistar's Lake Charles Plant: Ethane is a listed flammable under RMP which, as a raw material entering the Plant by pipeline, is used to produce the above mentioned products. There is no physical storage of ethane on site. 110,000 lbs is the maximum amount in the process at any given time. Propane is a listed flammable under RMP which, as a raw material entering the Plant by pipeline, is used to produce the above mentioned products. There is some emergency storage of propane to utilize as a raw material. 550,000 lbs is the maximum in the process at any given time. 3) The worst-case release scenarios and the alternate release scenarios, including administrative controls and mitigation measures to li mit the distances for each reported scenario (' 68.155c): The Lake Charles Plant performed off-site consequence analysis to estimate the potential for accidental release of a regulated substance to affect the public or the environment. The RMP rule requires the off-site consequence analysis to evaluate a "worst-case release scenario " (WCS) and an "alternative release scenario" (ARS) for each toxic and one for all flammables. In reality, however, Equistar does not expect a worst-case release scenario to ever occur. The alternative release scenarios are developed to help the LEPC improve the community emergency response plan. EPA Look-Up Tables were used for evaluating the distance to 1 psi overpressure for the flammable WCS. To model the alternative releases, the TRACE modeling program was used. Equistar's Lake Charles plant uses an onsite SAFER Real Time system for emergency response determination. TRACE, which is a model based on the same dispersion principles as SAFER, is the model of choice for the consequence analysis. The meteorological data used for the WCS modeling was the EPA default data, and weather conditions used for the ACS were those typical for the Lake Charles area obtained from review of past weather history. The EPA-recommended Landview program was utilized to estimate the number of people living within this distance from the location of the storage tank. United States Geological Survey (USGS) maps were utilized to identify the public and environmental receptors located within this distance. The following information summarizes the off-site consequence analysis performed by the Lake Charles Plant: 3.1 Toxic Substances - Not Applicable 3.2 Program 3 Processes-Flammable Substances The Lake Charles Plant has one flammable worst case scenario. The flammable worst case scenario involves the vaporization of the maximum allowable inventory, taking into account administrative controls of managing inventory, of the existing pyrolysis gas oline storage tank in accordance with the guidelines specified. No passive mitigation was considered in the worst case determination. The worst case flammable release impacts a distance from the source of the release of 0.7 miles. The U.S. Census indicates that there are no residences within this distance from the tank location. USGS maps indicate that while commercial areas are located within this distance, there are no environmental receptors. The Lake Charles Plant also generated an alternative release scenario for a flammable release. The alternative scenario for a flammable could be release of propylene as a result of a 2 inch pipe shear in the operating facility. This scenario considers reasonable alert and emergency response times and is the result of a review of all possible credible release scenarios. Passive and active mitigation measures were considered in the release evaluation. The flammable release impacts an area 0.2 miles from the release source, which reaches be yond the facility boundary. The U.S. Census data could not be used for this small an impact area. A physical survey indicates that there are no residences within this distance from the release point. USGS maps indicate that no receptors are located within this distance. Only one commercial area is located within this distance. 4) The general accidental release prevention program and chemical specific prevention steps (' 68.155d): The facility complies with the EPA's Accidental Release Prevention Rule (40 CFR part 68) and OSHA's Process Safety Management Rule (29 CFR 1910.119). As a participant in the OSHA Voluntary Participation Program, the facility has had an initial audit and a recertification audit both conducted by OSHA to maintain the program status since 1993. Since 1993, OSHA has listed the Lake Charles Plant as an OSHA star facility, the highest ranking for a plant's safety program. Program 3 is essentially the same as OSHA PSM, except that the program also focuses on protecting the public and the environment outside the plant's fenceline. The Lake Charles Plant's Program 3 prevention program consists of the following 12 elements: A) Process Safety Information The Lake Charles Plant maintains a variety of technical documents that are used to help ensure safe operation of the plant processes. These documents address (1) physical properties of hazardous substances handled at the plant, (2) operating parameters of the equipment used at the plant and (3) design basis and configuration of the equipment at the plant. Equistar ensures that this process safety information is available to all employees, the LEPC, the local fire department, the area hospital and the county sheriff's office. Material safety data sheets (MSDSs) document the physical properties of the hazardous materials handled at the plant, including regulated substances in covered processes. The information available for each hazardous substance typically includes: 7 Toxicity informatio n and permissible exposure limits 7 Physical data (e.g., boiling point, melting point, flash point) 7 Reactivity and corrosively data 7 Thermal and chemical stability data 7 Hazards of mixing substances in the process MSDSs for hazardous substances handled in the process are throughout the facility, so that the employees have ready reference to this information. In addition, key MSDSs are provided to the LEPC and the Fire Department for use in helping formulate emergency response plans. The engineering design documents include the operating parameters and the design basis and configuration of the equipment in the covered process. The available information includes: 7 Operating parameters 7 Block flow or simplified process flow diagrams 7 Process chemistry 7 Maximum intended inventories 7 Safe upper and lower limits for parameters such as temperature, pressure, or flow 7 Consequences of deviations from established operating limits 7 Design basis and configuration of equipment 7 Piping and instrumentation diagrams, including materials of construction 7 Electrical classification 7 Safety systems 7 Applicable design codes and standards 7 Design basis for relief and ventilation systems When important information was not available, from the design documents, it was developed through special projects or, in the case of operating parameters, during process hazard analyses of the process. Many of the operating parameters are included in the operating procedures to help with the safe operation of the process. These documents are used to (1) train employees, (2) perform process hazards analyses and (3) help maintain the equipment. B) Process Hazard Analysis The Lake Charles Plant performs and periodically updates process hazard analyses (PHAs) of the covered process to help identify process hazards and generate recommendations that might improve the safe operation of the process. A team composed of personnel with engineering and process operating experience and a leader with process hazard analysis experience is assembled to analyze the hazards of the process. The plant primarily uses the HAZOP and "what-if checklist" techniques to perform this analysis. The PHA team prepares a written report describing the results of the analysis, including a list of recommendations. Responsibility to resolve the recommendations is assigned to unit personnel and, as appropriate, changes to enhance the safety of the process are implemented. C) Operating Procedures Lake Charles Plant engineers, operators and supervisors work together to develop and maintain operating procedures to define how tasks related to process operations should be safely performed. The operating procedures (1) are used to train employees and (2) serve as reference guides for appropriate actions to take during both normal operations and process upsets. Operating procedures include: 7 Steps for safely conducting activities 7 Applicable process safety information, such as safe oper ating limits and consequences of process deviations 7 Safety and health considerations, such as chemical hazards, personal protective equipment requirements and actions to take if exposure to a hazardous substance occurs Plant personnel develop and maintain operating procedures that cover all phases of operations, including initial startup, normal operations, normal shutdown, emergency shutdown, startup following a turnaround or emergency shutdown, and temporary operations. D) Training The Lake Charles Plant trains its workers to safely and effectively perform their assigned tasks. The training program includes both initial and refresher training that covers (1) a general overview of the process, (2) the properties and hazards of the substances in the process and (3) a detailed review of the process operating procedures and safe work practices. Oral reviews and written tests are used to verify that an employee understands the training material before the employee can resume work i n the process. The operators are consulted annually at safety meetings to evaluate the effectiveness and frequency of the training. Recommendations from the operators are reviewed and changes to the training program are implemented as appropriate. E) Mechanical Integrity The Lake Charles Plant maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger workers, the public or the environment. The mechanical integrity program includes (1) an inspection and testing program to help identify equipment deterioration and damage before the equipment fails, and (2) a quality assurance program to help ensure that new and replacement equipment meets the design standards required for service in the plant's processes. The mechanical integrity program includes: 7 Specifications for inspection and testing of process equipment 7 Specifications for replacement parts and equipment 7 Procedures for inspecting, testing, and maintaining process eq uipment 7 Procedures for safe work practices such as Lock, Tag and Try; Hot Work; Confined Space Entry; and Line Breaking 7 Training of maintenance personnel 7 Documentation of maintenance activities F) Management of Change The Lake Charles Plant management of change program evaluates and approves all proposed changes to chemicals, equipment and procedures for a covered process to help ensure that the change does not negatively affect safe operations. Process changes that are determined to be a replacement-in-kind (e.g., replacing a valve with an identical valve) are allowed without completing a full management of change program. All other changes must be confirmed through the full management of change program to help ensure that inadvertent consequences of process changes are prevented, safety consequences of changes are addressed, affected process safety information and procedures are updated, and affected employees are notified of the changes. G) Pre-Startup Review The Lake Charles Plant performs a safety review of a new or modified process before the process is placed into service to help ensure that the process has been prepared to operate safely. This review confirms that: 7 Construction and equipment are in accordance with design specifications 7 Adequate safety, operating, maintenance and emergency procedures are in place 7 Employee training has been completed 7 For a covered process, that management of change requirements have been completed. A pre-startup review checklist is completed to document the review and to ensure that appropriate issues have been addressed. H) Compliance Audit The Lake Charles Plant audits the covered process to be certain that the prevention program is effectively addressing the safety issues of operating the plant. The plant assembles an audit team that includes personnel knowledgeable in the RMP rule and in the process, and this team evaluates whether the prevention program satisfies the requirements of the RMP rule and whether the prevention program is sufficient to help ensure safe operation of the process. The results of the audit are documented, recommendations are resolved, and appropriate enhancements to the prevention program are implemented. I) Incident Investigation The Lake Charles Plant investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public, or the environment so similar incidents can be prevented in the future. The plant trains employees to identify and report any incident requiring investigation. An investigation team is assembled, and the investigation is initiated within 48 hours of the incident. The results of the investigation are documented, recommendations are resolved and appropriate process enhancements are implemented. J) Employee Participation The Lake Charles Plant developed a written employee participation program for the covered process to help ensure that the safety concerns of the plant's workers are addr essed. The plant encourages active participation of personnel in the prevention program activities at the plant. Employees are consulted on, and informed about, all aspects of the RMP rule prevention program, including PHAs and operating procedures. K) Hot Work Permits The Lake Charles Plant established a hot work permit program to control spark or flame- producing activities that could result in fires or explosions in covered processes at the plant. The plant reviewed OSHA's fire prevention and protection requirements in 29 CFR 1910.252(a) and created a Hot Work Permit Form to comply with these requirements. Personnel who are to perform hot work are required to fill out the Hot Work Permit Form. The Shift Supervisor reviews the completed form before work can begin. Training in the use of the Hot Work Permit Form is included in the plant's safe work practices orientation. L) Contractors The Lake Charles Plant established a program to help ensure that contractor activities at the plant are performed in a safe manner. The program reviews the safety record of all contractors to help ensure that the plant only hires contractors who can safely perform the desired job tasks. The plant explains to the contract supervisors the hazards of the process on which they and their employees will work, the plant's safe work practices, and the plant's emergency response procedures. The plant requires that the contractor supervisors' train each of their employees who will work at the plant before that worker can begin work at the plant site. The plant periodically reviews contractors' training documents and work performance to help ensure that safe practices are followed. 5) The five-year accident history (' 68.155e): The facility experienced an accidental release of propylene and methane on July 6, 1994 when a leak developed on a piece of operating equipment. The release did not find an ignition source and was subsequently isolated. The release resulted in the repl acement of the existing equipment, but did not result in any other additional on-site or off-site impact. No off-site response or assistance was required. Revisions were made to the operating procedures, mitigation systems, emergency response plan, and the equipment design as a result of the incident. 6) The emergency response program (' 68.155f): The Equistar Lake Charles Plant emergency response plan has been developed to meet the emergency planning, response and notification requirements of the following regulations: 7 OSHA 29 CFR 1910.38 (a) - Employee Emergency Action Plans 7 OSHA 29 CFR 1910.119 (n) - Process Safety Management Of Highly Hazardous Chemicals 7 OSHA 29 CFR 1910.120 (p) and (q) - Hazardous Waste Operations and Emergency Response (HAZWOPER) 7 OSHA 29 CFR 1910, Subpart L - Fire Protection 7 LADEQ LAC 33.1'3901 - Notification Regulations for Unauthorized Discharges 7 LDPS Title 33, Part V, Subpart 2. Ch. 101'10111 - Release Reporting 7 EPA 40 CFR Part 302.6 - No tification Requirements 7 EPA 40 CFR Part 355.30 - Facility Coordinator and Emergency Response Plan 7 EPA 40 CFR Part 355.40 - Emergency Planning and Release Notifications 7 EPA 40 CFR Part 112 - Spill Prevention, Control and Countermeasures Plan 7 EPA 40 CFR Part 68 - Risk Management Programs for Chemical Accidental Release Prevention 7 EPCRA section 302 - List Of Extremely Hazardous Substances The emergency response strategy for the Lake Charles Plant is to prevent and/or control emergency situations via the use of engineering, design and fixed fire protection systems. Fixed fire protection systems are designed to National Petroleum Refiners Association (NPRA) guidelines. The plant has an Emergency Response Team on each shift, available 24 hours per day, to respond and initiate response actions to contain, control and if possible mitigate the release. The team has access to on site emergency equipment, which are appropriate for the anticipated emergency situations and capabiliti es of Equistar personnel. The following is a listing of some of the equipment, which is available for emergency response: 7 2500 gallon per minute / 70 foot Aerial Pumper Truck 7 HAZMAT / OPA 90 Response Trailer 7 Rescue / Medical Response Vehicle 7 21,000 gallon per minute Firewater System 7 Mobile Incident Command Trailer Quarterly drills are conducted to assess and evaluate the emergency response effort at the Lake Charles Plant. If assistance is required during an emergency response, the Southwest Louisiana Mutual Aid Association would be activated and requested to provide additional resources as necessary. The Lake Charles Plant uses a SAFER Real Time modeling system to assess release impacts if any and to aid in the determination of response activity. The Lake Charles Plant has a community alert (CAL) system available through the Office of Emergency Preparedness to notify the public of a potential or actual hazardous situation. In addition, the Lake Charles Plant has dev eloped a Special Situations Plan which is a program designed for responding to emergencies that may have impacts beyond the immediate plant and is a supplement to the Emergency Response Plan. The Special Situations Plan links the local response also to the Equistar Corporate Emergency Response Center located in Houston to assist as needed. The Lake Charles Plant is an active participant in the community planning process with the Calcasieu Parish Local Emergency Planning Committee. A copy of the plant's Emergency Response Plan has been forwarded to the Office of Emergency Preparedness as per the requirements of 40 CFR 355. The Lake Charles Plant is an active member of the Community-Industry Hazardous Materials Advisory Council. The Lake Charles Plant is an active participant in and is committed to the Chemical Manufacturers Association's Responsible Care(r) initiative conducting annual assessments of the Plant's compliance effort. 7) Planned changes to improve safety (' 68.155g ): The Lake Charles Plant constantly strives to improve the safety of the processes at the facility through the auditing process, the suggestion process, and the incident investigation process. |