Georgia Gulf Lake Charles, LLC - Executive Summary |
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Environmental Protection Agency Risk Management Plan 11255 Louisiana Executive Summary 10-May-2000 Georgia Gulf Lake Charles, LLC 1600 VCM Plant Road Westlake, LA 70669 4013 LDEQ Agency Interest Number Georgia Gulf Lake Charles, LLC Risk Management Plan Executive Summary Georgia Gulf Lake Charles, LLC is committed to the safety of the workforce and the public. This commitment is demonstrated by the resources invested in accident prevention, training of highly qualified personnel, and considering safety in the design, installation, operation and maintenance of our facility process. Our policy is to implement reasonable controls to prevent chemical releases. However, if a release does occur, our personnel are trained and equipped to quickly respond to, control/contain, and mitigate the release. Georgia Gulf Lake Charles, LLC is committed to Responsible Care?, a voluntary initiative for the safe management of chemicals. Georgia Gulf Lake Charles, LLC follows the Responsible Care?, C ode of Management Practice, which is integral to the development and implementation of our Environmental and Health and Safety policies. Georgia Gulf Lake Charles, LLC has developed and implemented Community Awareness and Emergency Response Procedures to assist in emergency preparedness and foster community right to know. This is further demonstrated by Georgia Gulf Lake Charles, LLC's involvement in outside agencies and willingness to provide an open line of communication with the community. Georgia Gulf Lake Charles, LLC is located in Westlake, Louisiana. The facility came into existence on November 13, 1999 as part of the Vinyls acquisition by Georgia Gulf Corporation and Affiliates from CONDEA Vista Company. Georgia Gulf Lake Charles, LLC is a producer of Vinyl Chloride Monomer (VCM). There are two primary process technologies utilized in the production, one being direct chlorination and the other oxy-chlorination. Regulated chemicals such as vinyl chloride monomer, hydrochlo ric acid, and propylene are used in the production process. Other regulated chemicals used in our process, which are in quantities below the threshold quantity include chlorine, ethylene, and sulfur dioxide. The worse case scenario (WCS) associated with a toxic substance handled at the Georgia Gulf Lake Charles, LLC involves a catastrophic failure of the hydrogen chloride storage vessel resulting in a release of 721,000 pounds of anhydrous hydrogen chloride. Although we have numerous controls to prevent such a release and to manage the consequences, no credit for administrative controls or passive mitigation measures was taken into account when evaluating this scenario. Look-up tables published by USEPA were used to determine the maximum distance to the toxic endpoint. Based on these Look-up tables, maximum distance to the scenario endpoint of .03 mg/L (approximately 20 ppm) for the worse case scenario is 25 miles. The alternative case scenario (ARS) for hydrogen chloride is the release of hydrogen chloride vapor over a 15-minute period from a one-inch hole in a process line that contains hydrogen chloride. The 15-minute release duration is the maximum time necessary to block off and transfer to storage the hydrogen chloride contained in the process line thus stopping the release. No other mitigation measures other than to empty the process line were taken into account when evaluating this scenario. A dense phase dispersion model "PHAST" developed by Det Norse Veritas (DNV) was used to determine the maximum distance to the toxic endpoint of 0.03 mg/L (approximately 20 ppm) to be 1.02 miles. The WCS (worse case scenario) associated with the release of a flammable substance involves the release of largest inventory, in a single vessel of vinyl chloride monomer (VCM). No credit was taken for active mitigation measures when evaluating this scenario. The WCS assumes that the full capacity inventory (9,600,00 pounds) vaporizes and ignites, resulting in a vapor clo ud explosion (VCE) which would result in a maximum distance to the 1-psi overpressure endpoint of 1.27 miles. The ARS for flammable substances at Georgia Gulf Lake Charles, LLC assumes a failure of one vinyl chloride liquid loading hose while loading a railcar resulting in a release of approximately 8,333 pounds of vinyl chloride. The scenario assumes a VCE that would result in a maximum distance to the 1-psi overpressure endpoint for this ARS scenario of 0.04 miles. Process Safety Information Georgia Gulf Lake Charles, LLC maintains a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters, specific chemical inventories and equipment design basis/configuration information. Specific departments within the facility are assigned responsibility for maintaining up-to-date process safety information. Employees are provided training on how to locate the information from various computer terminals located throughout the plant. Chemical specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDS). This information is supplemented by documents that address known corrosion concerns and known hazards associated with inadvertent mixing of specific chemicals. Georgia Gulf Lake Charles, LLC has documented safety-related limits for specific process parameters. The facility ensures that the process is maintained within these limits using process controls, monitoring instruments, protective instrument systems, and highly trained personnel. Georgia Gulf Lake Charles, LLC maintains an electronic database accessible by both employees and contractor supervision, which provides information about the design and construction of process equipment. This information combined with written procedures and trained personnel, provides a basis for establishi ng inspection and maintenance activities as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not comprised. Process Hazard Analysis Georgia Gulf Lake Charles, LLC has a comprehensive program to help ensure the 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 facility primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. HAZOP 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 and maintenance experience as well as engineering expertise. The 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 made available to those individuals associated with the process unit for comments and forwarded to local and corporate management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest rank receive immediate attention. All approved mitigation options being implemented in response to PHA findings are tracked through completion. The final resolution of each finding is documented and retained. Operating Procedures Operators, supervisors, and plant engineers work together to develop and maintain operating procedures. These procedures define how tasks related to process operations are safely performed. At Georgia Gulf Lake Charles, LLC, operating procedures: (1) are used to train employees and (2) serve as refe rence guides for appropriate actions to take during both normal operations and process upsets. Operating procedures include: - Steps for safely conducting activities - Applicable process safety information, such as safe operating limits, - Safety and health considerations, such as chemical hazards, personnel protective equipment required, and steps to take if exposed to a particular chemical. Plant personnel develop and maintain operating procedures that cover all phases of operations, including initial startup, normal operation, normal shutdown, emergency shutdown, startup following a turnaround or emergency shutdown, and temporary operations. Training Georgia Gulf Lake Charles, LLC trains its workers to safely and effectively perform their assigned tasks. The training program includes both initial and refresher training. All new operators receive six weeks of comprehensive training before being assigned to the operating unit. This training includes training on specific types o f equipment, such as pumps and compressors, general overview of the process, properties and hazard substances in the process, detailed review of plant procedures, such as, safe work practices and emergency response. Written tests are used to verify that employees understand the training material before a new employee can report to a process unit. Once the new employee reports to the unit, detailed training with respect to the process and specific procedures is given to the employee. Once the new hire has demonstrated, through written tests and demonstration of learned skills, mastery of process specific operating procedures, the employee is allowed to begin work. Refresher training 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. Written tests are used to verify that employees understand the training before an employee can resume work in the process. The operators have been consulted in safety meetings and through questionnaires regarding effectiveness and frequency of training. Recommendations are reviewed and changes to the training program are implemented as appropriate. Management of Change The Management of Change program for Georgia Gulf Lake Charles, LLC evaluates and approves all proposed changes to chemicals, equipment, and procedures for covered processes to help ensure that a change does not negatively affect safe operations. All changes that are deemed to be a true process change must be confirmed through a full management of change program to help ensure process safety information and procedures are updated, and affected employees are notified and trained where applicable of the change. Pre-Startup Safety Review (PSSRs) Georgia Gulf Lake Charles, LLC conducts a safety review of a new or modified process before the process is placed in service. The purpose of the PSSR is to ensure the safety feature s, procedures, personnel and equipment are appropriately prepared for startup prior to placing the equipment in service. The review provides an 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 Georgia Gulf Lake Charles, LLC has well established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, emergency shutdown systems, and rotating equipment 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. 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. Written procedures help ensure that work is performed in consistent manner and provides 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. If a deficiency is identified, the equipment will be repaired in a timely manner. All outstanding deficiencies are tracked until such time a final solution has been implemented and documented. Another integral part of the mechanical integrity program is quality assurance. Georgia Gulf Lake Charles, LLC incorporates quality assurance into equipment purchase and repairs. This h elps ensure that new equipment is suitable for intended use and that proper materials and spare parts are used when repairs are made. Safe Work Practices Georgia Gulf Lake Charles, LLC has an extensive safe work program in place to ensure worker safety. Examples of the program include (1) control of the entry/presence/exit of support personnel, (2) lockout/tagout procedures to ensure isolation of energy sources for equipment undergoing maintenance, (3) procedures for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedures to conduct heat/spark producing activities, and (5) a permit and procedures to ensure that adequate precautions are in place before entry into a confined space. These procedures, along with training of affected personnel, help in defining a system to ensure that operations and maintenance activities are performed safely. Incident Investigation Georgia Gulf Lake Charles, LLC investigates all incidents that coul d reasonably have resulted in a serious injury to personnel, the public, or the environment so similar incidents can be prevented. Employees are trained to identify and report any incident requiring investigation. The initial investigation process is initiated within 48 hours of the incident. Depending on the incident, an investigation team may be formed. Results of the investigation are documented and tracked through completion. Employee Participation Georgia Gulf Lake Charles, LLC maintains a written employee participation program to help ensure that safety and environmental concerns of the plant workers are addressed. The plant encourages active participation of personnel in safety, health, and environmental activities at the plant. Employees are consulted and/or informed about all aspects of the RMP prevention program including PHA's (Process Hazard Analysis) and operating procedures. Compliance Audits Georgia Gulf Lake Charles, LLC audits the covered processes to ensure that the prevention programs are effectively addressing safety, health, and environmental issues. The facility assembles an audit team that includes personnel knowledgeable in the processes. This team evaluates the RMP/PSM prevention programs to ensure they satisfy the requirements of the RMP/PSM rules and whether the prevention programs are sufficient to ensure safe operation of the facility. The results of the audit are documented, recommendations are resolved, and appropriate enhancements made to the operations of Georgia Gulf Lake Charles, LLC. Contractors Georgia Gulf Lake Charles, LLC has established a program to help ensure that contractor activities are performed in a safe manner. This program reviews the safety record of the contractors to ensure the plant only hires contractors who can safely perform the desired task. The facility communicates to the contractor supervisor the hazards of the process on which they and their employees will work, the plants safe work practices, and the plants emergency response procedures. The plant requires that the contractor supervisors train each of their employees on hazards and procedures specific to the site. The plant periodically reviews contractors training documents and work performances to help ensure that safe practices are followed. Five Year Accident History The facility has experienced five events in the 5-year period beginning January 1, 1995 through the current date. Of these events, three have resulted in an off-site impact and two have not had an off-site impact, but resulted in minor on-site injuries. The events are as follows: ? January 24,1995-Accidental release of hydrogen chloride, vinyl chloride monomer, and ethylene dichloride. No injuries, exposure to toxic chemicals or property damage either offsite or within the boundaries of the plant occurred as a result of the release. As a precaution approximately 1000 people were sheltered in place. ? March 10, 1995 - Accidental release of hydrogen chlorid e, vinyl chloride monomer, and ethylene dichloride. One person on-site was treated and released and on-site damage was minimal. No injuries, exposures to toxic chemicals, property damage or environmental damage occurred off-site as a result of this release. As a precaution, approximately 5000 people were sheltered in place as a result of this release. ? August 10,1996 - Accidental release of hydrogen chloride and chlorine. Three employees were treated for exposure to hydrogen chloride and chlorine before returning to work. No exposure to toxic chemicals, injuries, property damage or environmental damage occurred off-site as a result of the release. Because the release was easily contained, no one was sheltered in place. ? June 5, 1997 - Accidental release of hydrogen chloride. No injuries, exposure to toxic chemical, or property damage either off-site or within the boundaries of the plant occurred as a result of this release. As a precaution, 1000 people were sheltered in place. ? December 12, 1999 - Accidental release of hydrogen chloride, vinyl chloride monomer and ethylene dichloride. There were two minor injuries as a result of the release with no off-site injuries or property damage. Emergency Response Program Georgia Gulf Lake Charles, LLC's emergency response program has been developed to meet the emergency planning, response, and notification requirements of the following regulations: - OSHA 29 CFR 1910.38 (a) - Employee Emergency Action Plans - OSHA 29 CFR 1910.120 (q)-Hazardous Waste Operations and Emergency Response (HAZWOPER) - OSHA 29 CFR 1910.110 (n) Process Safety Management of Highly Hazardous Chemicals - OSHA 29 CFR 1910 Subpart L-Fire Protection - LADEQ LAC 33:I 3901- Notification Regulations for Unauthorized Discharge - LDPS Title 33, Part V, Subpart 2, Ch.1011-Release Reporting - EPA 40 CFR Part 302.6- Notification Requirements - EPA 40 CFR Part 355.40-Emergency Planning and Release Notification - EPA 40 CFR Part 68- Risk Management Pro grams for Chemical Accidental Release Program - EPA 40 CFR Part 355.30- Facility Coordinator and Emergency Response Plan - EPA 40 CFR Part 112- Spill prevention, Control and Countermeasures - Plan - EPCRA 302- List of Extremely Hazardous Substances The emergency response strategy for the facility is to prevent and/or control emergency situations via the use of engineering, design, and fixed protection systems. The plant has an Emergency Response Team that is available 24 hours per day, and trained to respond and take actions to contain, control, and mitigate any release that might occur. The team has access to on-site emergency equipment that is appropriate for situations that could possibly occur at the facility. Emergency Response Team drills are conducted to assess the emergency response effort at the facility and make modifications where appropriate. In addition to the considerable on-site resources, Georgia Gulf Lake Charles, LLC is a member of Calcasieu Mutual Aid. This membersh ip allows the facility to draw on the emergency response resources of other industries in the immediate area. The following is a partial listing of the equipment that is available for emergency response through Mutual Aid or On-site: - Firepumps w/ fixed firewater system - Fire Monitors - Fire Extinguishers - Dry Chemical Truck - Foam Pumper - Water Deluge Systems - Fixed Extinguishing Systems - Spill Response Unit Georgia Gulf Lake Charles, LLC is a participant in the Calcasieu Community Awareness and Emergency Response group and the community planning process cooperating 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 per the requirements of 40 CFR 355. Planned Changes to Improve Safety Georgia Gulf Lake Charles, LLC constantly strives to improve safety and reduce risk through auditing, suggestions from employees, incident investigations, and the use of proper engineering standards and specifications. |