Westalake PVC Coorporation - Executive Summary |
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WESTLAKE PVC CORPORATION RISK MANAGEMENT PLAN EXECUTIVE SUMMARY The Westlake PVC Corporation at Calvert City, Kentucky is a program 3 facility under the EPAs Risk Management Plan. The facility contains one covered process with the handling of vinyl chloride. The Westlake PVC Plant Manager has the overall responsibility for the facility. The Westlake PVC Environmental Supervisor reports to the Plant Manager and has overall responsibility for compliance with all aspects of the plants Risk Management Plan. The Westlake PVC Plant at Calvert City manufactures polyvinyl chloride for use in the plastic industry. The largest quantity feedstock, vinyl chloride, is used in the production of polyvinyl chloride resin. In 1998, the site produced over 600 million pounds of PVC resin and shipped to various customers in the United States and Canada. The Westlake PVC Corporation is committed to continuous improvement in all aspects of safety and environmental performance. As a site that is under the OSHA Process Safety Management (PSM) regulation, the Calvert City Plant is committed to preventing chemical emergencies. Prevention of chemical emergencies starts with specifying that all equipment, piping, vessels, tanks, etc., meet all applicable design codes and specifications. Documentation of these codes and specifications form the basis of our process information including flow diagrams, piping and instrument diagrams, process descriptions, etc. Supplementing this information are trained employees working with operating instructions, startup/shutdown instructions and consequences of deviation to keep our processes operating in safe limits that minimize any adverse impact on the employees, the environment and/or the surrounding community. Under PSM, employees are involved in all aspects of Plant operations and the Safety / Environmental programs. Employees are regularly trained, certified and subject to random substance abuse checks to insure the safety of the Plant . Our safety process contains many other elements including Management of Change, hot work procedures and regular process hazards analysis using the hazard and operability (HAZOP) methodology. All contractors at the facility are subject to the same rules and procedures as Westlake employees as well as the Contractor Safety Program. A comprehensive Mechanical Integrity Program includes routine checks of all process equipment, tanks, vessels and piping. Auditing of these programs is done at the production unit, Plant and Corporate levels. Key to the Plants prevention programs are the layers of protection provided in the process. At the lowest levels, trained operators working with current operating procedures and process safety information keep the processes operating safely and in compliance. Control systems and instrumentation provide the tools to maintain the process within these limits and provide the information and control to keep the process in control. Instrumentation al arms, process trips and interlocks alert the plant operators to deviations and provide early warning to process upsets. In the event an upset leads to an uncontrolled condition, process safety devices including pressure relief valves, rupture discs, automatic shutdown and critical interlocks will be activated. Most all of the process areas are covered by fire sprinklers, sensors, monitor nozzles and dry or CO2 chemical extinguishers. Backing up the safety systems are trained emergency responders. Each shift is lead by a Shift Supervisor who, in an emergency, assumes the duties as on-scene Commander. Westlake PVC is a member of the Calvert Industrial Mutual Aid Program (CIMAP) and can count on pooled resources from surrounding plants. The Calvert City Fire Department is also a responding party to emergencies if needed. As a member of LEPC, Westlake stages drills with all emergency responders. DES, LEPC and the Calvert City Fire Department members tour the facility to familiariz e themselves with the plant, hazardous materials, equipment, layout and personnel. The Westlake PVC Plant has one flammable liquid (Vinyl Chloride Monomer) on site. This is the chemical that will be covered in the flammable scenarios. The Vinyl Chloride bullet tank has a maximum capacity of 440,000 pounds. Passive mitigation includes a 4 foot earthen berm that will contain the entire contents of the tank. Under the worst case scenario, 440,000 pounds of Vinyl Chloride would be contained in the diked area in the event of a total tank failure. The distance to a 1.0 psi overpressure endpoint using the EPA look up tables would exceed the plant boundary. The alternative case scenario is a derailment of a railcar which damages the Vinyl Chloride Pipeline. The distance to a 1.0 psi overpressure endpoint using the EPA look up tables would exceed the plant boundary. There have been no releases of Vinyl Chloride at the Westlake PVC Facility in the past five years that have had an advers e impact on the community nor have there been any incidents at the Facility that met the EPA Risk Management Program (RMP) reporting requirements with respect to injuries involving a release of vinyl chloride. |