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Equistar Chemicals, LP - Lake Charles Polymers

Parent Companies:
LyondellBasell Industries
EPA Facility ID:
100000051196
Other ID:
LAD008080541
Facility DUNS:
8080541
Parent Company DUNS:
107214587

Location:

Address:
4101 Highway 108
Westlake, LA 70669
County:
CALCASIEU
Lat / Long:
30.194, -93.321 (Get map)
Method:
Interpolation - Digital map source (TIGER)
Description:
Center of Facility
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
Equistar Chemicals, LP
Phone:
(337) 882-1651
Address:
P.O. Box 1687
Lake Charles, LA 70602
Foreign Address:

Person responsible for RMP implementation:

Name:
Shawn Cullen
Title:
Site Manager

Emergency contact:

Name:
Christopher Sappington
Title:
HSE Manager
Phone:
(337) 439-7349
24-hour phone:
(817) 832-4087
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(337) 882-1651
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Calcasieu Parish LEPC
Full-Time Equivalent Employees:
185
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
0520-00006-V7
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Jan. 27, 2015
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Polypropylene
RMP ID:
1000063417
CBI claimed:
No
Program Level:
3
NAICS:
Plastics Material and Resin Manufacturing (325211)
Chemical name
CAS#
Quantity (lbs.)
CBI
Propylene [1-Propene]
115-07-1
1,100,000
No
Ethylene [Ethene]
74-85-1
26,000
No
1-Butene
106-98-9
1,900,000
No
Propane
74-98-6
860,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Joe Bush with Equistar
Address:
4101 Hwy 108
Westlake, LA 70669
Foreign Address:

Phone:
(337) 430-6741

Latest RMP Submission:

Date:
Oct. 27, 2015
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000050408

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

None

3. Toxics: Alternative release

None

4. Flammables: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Polypropylene)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Blast walls

5. Flammables: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Polypropylene)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Excess flow valve

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

Polypropylene, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000052684
Safety Review Date
April 1, 2015, since latest RMP submission
PHA Update Date
May 15, 2015, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Fire Walls
  • Deluge System
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Process Parameters
  • Process Controls
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
July 22, 2016, since latest RMP submission
Training Review Date
Feb. 18, 2015, since latest RMP submission
Maintenance Review Date
March 31, 2015, since latest RMP submission
Maintenance Inspection Date
April 8, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Oct. 19, 2015
Management of Change Review Date
Nov. 20, 2014
Pre-startup Review Date
Aug. 14, 2015
Compliance Audit Date
Jan. 27, 2015
Compliance Audit Change Completion Date
June 1, 2016
Incident Investigation Date
Oct. 12, 2015
Incident Invest. Change Completion Date
Dec. 31, 2015
Participation Plan Review Date
Oct. 28, 2012
Hot Work Review Date
April 9, 2015
Contractor Safety Review Date
Feb. 17, 2015, since latest RMP submission
Contractor Safety Eval. Date
March 16, 2015, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
May 20, 2015
Local Response Agency:
Local Response Agency Phone:
(337) 437-3500
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

Executive Summary

Equistar Chemicals LP - Lake Charles Polymers - Risk Management Plan

LDEQ Facility - Agency Interest # 1253



LATEST UPDATE WAS DONE IN OCTOBER 2015 AS A 5-YEAR UPDATE.





1. Accidental Release Prevention and Emergency Response Policies:



In accordance with our corporate Health, Safety, and Environmental Policy, we strive to conduct our business in a manner that protects the environment and provides for the safety and health of employees, contractors, customers and the public. This includes:

? Conducting our business with a goal of zero injuries and incidents

? Providing a safe, healthy and secure work environment for employees and contractors

? Maintaining a risk-based management system that is designed to ensure compliance with applicable legal and other requirements and promoting continual performance improvement

? Providing stewardship of our processes and products, practice pollution prevention and optimizing resource use across all stages of the product life cycle

? Communicating openly with all stakeholders on relevant health, safety and environmental issues



The facility's overall approach to chemical safety can be summed up by "Goal Zero"; zero injuries, zero releases and zero quality defects. Senior management has made it clear that working safely is a "first and forever" expectation and all employees are held to the highest level of performance with regards to both process and occupational safety and environmental performance. Through tools such as the Rules of Performance and Check Signals and Operational Excellence initiatives, the site is committed to achieving "Goal Zero" performance.



2. Facility and Regulated Substances Handled:



Equistar uses the patented Spheripol & Catalloy technologies to manufacture polypropylene plastic resins. These processes include interconnected storage vessels and pipelines containing Propylene, Ethylene, Propane, and Butene.



3. General Accidental Release Prevention Program and
Chemical-Specific Prevention Steps:



The site has implemented and maintains management systems compliant with the release prevention requirements set out under 40 CFR 68 and the OSHA Process Safety Management (PSM) Standard, 29 CFR 1910.119. The site was designed and built according to strict engineering standards using Equistar's world-wide experience and long history with polyolefin technology process design.



The following sections briefly describe the elements of the release prevention program:



Process Safety Information

Equistar maintains a record of written safety information that describes the chemical hazards, operating parameters, and equipment designs associated with the process.



Process Hazards Analysis

Equistar conducts studies to ensure the hazards associated with the process are identified and controlled efficiently. Process Hazards Analysis, PHA, methodology is used to carry out these analyses using a team of qualified personnel with expertise in engineering, maintenance and process operations. PHA's are revalidated at least every 5 years and findings are addressed in a timely manner.



Operating Procedures

Equistar maintains written operating procedures that address various modes of operation such as start-up, shutdown, normal operation, temporary operation, emergency shutdown, emergency operation and start-up after a turnaround. Operating procedures are validated annually and made accessible electronically to operations personnel.



Training

Equistar's training program ensures that employees that operate the process are competent, trained in their assigned tasks and familiar with the appropriate operating procedures. New employees receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently. Written tests and field observation are used to verify understanding of the training. Additional training is provided regularly and operators are recertified at leas
t as frequently as required by regulation. The training program is reviewed periodically for possible improvements.



Mechanical Integrity

Equistar performs documented maintenance verifications to ensure process equipment is functioning properly. These inspections include piping, pressure vessels, tanks, relief and vent systems, emergency shutdown systems, controls and pumps to name but a few. Maintenance is performed by qualified personnel who receive specialized training on specific pieces of equipment. Deficiencies found during inspections are addressed in a timely manner.



Management of Change

The Management of Change process controls changes to process chemicals, equipment, technology, personnel and procedures. Changes are reviewed by a multidisciplinary team of competent personnel prior to implementation to determine if there is any impact on safety, health or the environment and the process includes notification or training of affected personnel.



Pre-Start-up Safety Reviews, PSSR

PSSR's of new processes or modifications to existing processes confirm that construction, equipment, operating and maintenance procedures, and training or communication of the change are suitable for safe start-up prior to putting equipment into operation.



Compliance audits

A team of company subject matter experts audits site management systems at least every 3 years to ensure that the provisions set out under the PSM and RMP regulations are being implemented. Any findings are addressed in a timely manner.



Incident Investigation

Equistar investigates any incident that results in or could reasonably be expected to result in an employee injury or a catastrophic release of a hazardous material. The investigation identifies the immediate and underlying causes and generates corrective actions to prevent recurrence. The multidisciplinary investigation team issues a report that is retained for 5 years.



Employee Participation

Equistar believes that process safety
and accident prevention is a team effort. Employees are strongly encouraged to express their views concerning accident prevention and to recommend improvements. Employees have access to all information created under the PSM and RMP rules including PHA's, and they participate in investigation teams, safety teams, and other related projects.



Contractors

Contractors are hired to complete specialized maintenance and construction projects. Prior to selecting a contractor, Equistar conducts a thorough evaluation of the contractor's safety performance. Equistar has a strict policy of informing all contract personnel of known and potential hazards related to the contractor's work and the site's processes. Contractors are informed of the procedures for emergency response should the accidental release of a hazardous material occur.



4. Five Year Accident History:



There have been no incidents at the site in the past 5 years that have resulted in deaths, injuries or significant property damage on site, or that have resulted in known offsite deaths, injuries, evacuations, sheltering in place, property damage or environmental damage.



5. Emergency Response Program:



The Lake Charles site maintains a written Emergency Response Plan to minimize the effects of any accidental release of hazardous material or other situations such as medical emergencies, hurricanes or bomb threats. The plan addresses adequate first aid and medical treatment; evacuation; notification of local emergency response agencies and the public; and the post incident decontamination of affected areas. The Emergency Response Plan has been coordinated with the Local Emergency Planning Committee, LEPC, and the Southwest Louisiana Mutual Aid organization and is updated regularly based on the analysis of actual emergencies or scheduled drills. A well-trained Emergency Response Team led by an Incident Commander is always present on site. Emergency response equipment and systems are tested and s
erviced regularly to ensure proper functioning. Emergency response drills with prepared incident scenarios are conducted regularly and analyzed for possible improvements.



6. Planned Changes to Improve Safety:



The corporate "Goal Zero" philosophy drives Equistar to continuously look for new ways to improve safety at the facility. The site has planned improvements to the fire water system and site process control systems.