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Lyondell Chemical Company

Parent Companies:
Lyondell Chemical Company
EPA Facility ID:
100000083018
Other ID:
70669RCCHM900AI
Facility DUNS:
8080681
Parent Company DUNS:
181843095

Location:

Address:
900A Interstate 10 West
Westlake, LA 70669
County:
CALCASIEU
Lat / Long:
30.236, -93.266 (Get map)
Method:
Interpolation - Photo
Description:
Administrative Building
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Lyondell Chemical Company
Phone:
(337) 491-3000
Address:
900A Interstate 10 West
Westlake, LA 70669
Foreign Address:

Person responsible for RMP implementation:

Name:
Joseph F Marschhauser
Title:
Plant Manager

Emergency contact:

Name:
Patrice Palmer
Title:
HSE Manager
Phone:
(337) 491-3107
24-hour phone:
(337) 491-3000
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(337) 491-3000
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Calcasieu Parish LEPC
Full-Time Equivalent Employees:
291
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
2118-VO
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Sept. 15, 1994
Inspecting Agency:
OSHA
Using Predictive Filing:
No

Processes:

Toluene Diisocyanate
RMP ID:
52498
CBI claimed:
No
Program Level:
3
NAICS:
Cyclic Crude and Intermediate Manufacturing (325192)
Chemical name
CAS#
Quantity (lbs.)
CBI
Phosgene [Carbonic dichloride]
75-44-5
70,000
No
Toluene diisocyanate (unspecified isomer) [Benzene, 1,3-diisocyanatomethyl-]
26471-62-5
8,400,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Phosgene
RMP ID:
52499
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Phosgene [Carbonic dichloride]
75-44-5
6,400
No
Public OCA Chemical
0
No
Toluene Diamine
RMP ID:
52500
CBI claimed:
No
Program Level:
3
NAICS:
Cyclic Crude and Intermediate Manufacturing (325192)
Chemical name
CAS#
Quantity (lbs.)
CBI
Chlorine
7782-50-5
4,000
No
Public OCA Chemical
0
No
Nitric Acid
RMP ID:
52501
CBI claimed:
No
Program Level:
3
NAICS:
Nitrogenous Fertilizer Manufacturing (325311)
Chemical name
CAS#
Quantity (lbs.)
CBI
Chlorine
7782-50-5
4,000
No
Ammonia (anhydrous)
7664-41-7
312,000
No
Butane
106-97-8
52,800
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
June 22, 2004
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
No
RMP ID:
36421

Deregistration:

Date:
Effective Date:
Reason:
Source terminated operations
Other Reason:

2. Toxics: 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 Toluene Diisocyanate)
CBI claimed:
No
Percent weight:
Physical state:
Liquid
Model used:
EPA's OCA Guidance Reference Tables or Equations
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • Dikes
  • Berms
  • Drains
  • Sumps
not considered:
  • Enclosures
Public OCA Chemical (in Phosgene)
CBI claimed:
No
Percent weight:
Physical state:
Gas
Model used:
EPA's OCA Guidance Reference Tables or Equations
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Public OCA Chemical (in Toluene Diamine)
CBI claimed:
No
Percent weight:
Physical state:
Gas
Model used:
EPA's OCA Guidance Reference Tables or Equations
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Public OCA Chemical (in Nitric Acid)
CBI claimed:
No
Percent weight:
Physical state:
Gas
Model used:
EPA's OCA Guidance Reference Tables or Equations
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps

3. Toxics: 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 Toluene Diisocyanate)
CBI claimed:
No
Percent weight:
Physical state:
Liquid
Model used:
EPA's OCA Guidance Reference Tables or Equations
Wind speed (meters per sec):
1.50
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • Dikes
  • Berms
  • Sumps
  • header equalization system
not considered:
  • Enclosures
  • Drains
Active mitigation
considered:
  • Excess flow valve
  • Emergency shutdown
  • header equalization system
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Flares
  • Scrubbers
Public OCA Chemical (in Phosgene)
CBI claimed:
No
Percent weight:
Physical state:
Gas
Model used:
EPA's OCA Guidance Reference Tables or Equations
Wind speed (meters per sec):
1.50
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Excess flow valve
  • Scrubbers
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Flares
Public OCA Chemical (in Toluene Diamine)
CBI claimed:
No
Percent weight:
Physical state:
Gas
Model used:
EPA's OCA Guidance Reference Tables or Equations
Wind speed (meters per sec):
1.50
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
Public OCA Chemical (in Nitric Acid)
CBI claimed:
No
Percent weight:
Physical state:
Gas
Model used:
EPA's OCA Guidance Reference Tables or Equations
Wind speed (meters per sec):
1.50
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • Sumps
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
Active mitigation
considered:
  • Excess flow valve
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Flares
  • Scrubbers

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 Nitric Acid)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
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 Nitric Acid)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
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

July 11, 2003 at 05:15
ID:
5815
NAICS:
Cyclic Crude and Intermediate Manufacturing (325192)
Duration:
27 minutes
Chemicals involved:
  • Phosgene [Carbonic dichloride]
Release events:
Gas release
Weather conditions at time of event
Wind speed:
1.0 miles/h SSE
Temperature:
81.00 ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
0
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$0
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
4700
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Equipment failure
  • Process design failure
Off-site responders notified:
Notified Only
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Revised operating procedures
  • New process controls
Oct. 14, 1999 at 16:10
ID:
5814
NAICS:
Cyclic Crude and Intermediate Manufacturing (325192)
Duration:
14 minutes
Chemicals involved:
  • Phosgene [Carbonic dichloride]
Release events:
Gas release
Weather conditions at time of event
Wind speed:
None meters/second
Temperature:
None ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
Yes
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
1
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$0
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Equipment failure
  • Human error
  • Maintenance activity/inactivity
  • Unsuitable equipment
Off-site responders notified:
No, not notified
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Revised maintenance
  • Revised training
  • Revised operating procedures

7. Prevention: Program level 3

Toluene Diisocyanate, Cyclic Crude and Intermediate Manufacturing (325192)
Prevention Program ID:
30234
Safety Review Date
Jan. 12, 2004, since latest RMP submission
PHA Update Date
Jan. 12, 2004, 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
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
April 21, 2004, since latest RMP submission
Training Review Date
Nov. 1, 2002, since latest RMP submission
Maintenance Review Date
May 18, 2004, since latest RMP submission
Maintenance Inspection Date
May 12, 2004, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
May 18, 2004
Management of Change Review Date
Dec. 19, 2003
Pre-startup Review Date
May 18, 2004
Compliance Audit Date
June 10, 2004
Compliance Audit Change Completion Date
June 30, 2005
Incident Investigation Date
July 11, 2003
Incident Invest. Change Completion Date
Nov. 15, 2004
Participation Plan Review Date
Nov. 22, 2000
Hot Work Review Date
Nov. 8, 2000
Contractor Safety Review Date
June 1, 2004, since latest RMP submission
Contractor Safety Eval. Date
June 4, 2004, since latest RMP submission
Phosgene, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
30235
Safety Review Date
Jan. 12, 2004, since latest RMP submission
PHA Update Date
Jan. 12, 2004, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
April 30, 2004, since latest RMP submission
Training Review Date
Nov. 1, 2002, since latest RMP submission
Maintenance Review Date
May 18, 2004, since latest RMP submission
Maintenance Inspection Date
Feb. 11, 2004, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
March 17, 2004
Management of Change Review Date
Dec. 19, 2003
Pre-startup Review Date
Jan. 27, 2004
Compliance Audit Date
June 10, 2004
Compliance Audit Change Completion Date
June 30, 2005
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Nov. 22, 2000
Hot Work Review Date
Nov. 8, 2000
Contractor Safety Review Date
June 1, 2004, since latest RMP submission
Contractor Safety Eval. Date
June 4, 2004, since latest RMP submission
Toluene Diamine, Cyclic Crude and Intermediate Manufacturing (325192)
Prevention Program ID:
30236
Safety Review Date
Jan. 12, 2004, since latest RMP submission
PHA Update Date
Jan. 12, 2004, 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
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
  • Neutralization
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Parameters
  • Process Controls
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
April 21, 2004, since latest RMP submission
Training Review Date
Nov. 1, 2002, since latest RMP submission
Maintenance Review Date
May 18, 2004, since latest RMP submission
Maintenance Inspection Date
March 11, 2004, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
May 19, 2004
Management of Change Review Date
Dec. 19, 2003
Pre-startup Review Date
April 1, 2004
Compliance Audit Date
June 10, 2004
Compliance Audit Change Completion Date
June 30, 2005
Incident Investigation Date
July 25, 2002
Incident Invest. Change Completion Date
Aug. 13, 2003
Participation Plan Review Date
Nov. 22, 2000
Hot Work Review Date
Nov. 8, 2000
Contractor Safety Review Date
June 1, 2004, since latest RMP submission
Contractor Safety Eval. Date
June 4, 2004, since latest RMP submission
Nitric Acid, Nitrogenous Fertilizer Manufacturing (325311)
Prevention Program ID:
30237
Safety Review Date
Jan. 12, 2004, since latest RMP submission
PHA Update Date
Jan. 12, 2004, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
  • Neutralization
Monitoring Systems
  • None
Changes since PHA
  • Process Parameters
  • Process Controls
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
April 21, 2004, since latest RMP submission
Training Review Date
Nov. 1, 2002, since latest RMP submission
Maintenance Review Date
May 18, 2004, since latest RMP submission
Maintenance Inspection Date
May 17, 2004, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
May 3, 2004
Management of Change Review Date
Dec. 19, 2003
Pre-startup Review Date
April 6, 2004
Compliance Audit Date
June 10, 2004
Compliance Audit Change Completion Date
June 30, 2005
Incident Investigation Date
May 30, 2002
Incident Invest. Change Completion Date
June 15, 2002
Participation Plan Review Date
Nov. 22, 2000
Hot Work Review Date
Nov. 8, 2000
Contractor Safety Review Date
June 1, 2004, since latest RMP submission
Contractor Safety Eval. Date
June 4, 2004, 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 27, 2004
Local Response Agency:
Local Response Agency Phone:
(337) 437-3512
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

2694 LDEQ Facility Identification Number.

State of Louisiana Department of Environmental Quality - Facility ID number: 27051


I. The Accidental Release Prevention and Emergency Response Policies at the Lake Charles Facility

It is the policy of the Lyondell Lake Charles facility to operate in a safe manner, with minimum risk to all workers and visitors and to the surrounding community. While every effort is made to operate the facility safely, it is recognized that accidents can happen. In order to provide for a coordinated, effective, and timely response to emergency incidents, the Lake Charles facility has developed and implemented the Lake Charles Plant Emergency Plan.

The Lake Charles facility has implemented a program to consolidate and streamline the Compliance Audit requirements as defined in OSHA's Process Safety Management Program (29 CFR 1910.119(o) and the Risk Management Program, 40 CFR 68.79 for various regulated on-site process units. The consolidation of Compliance Audit Programs is based on minimizing duplication, redundancy, and inconsistency attributed from overlapping state and federal programs. The Lyondell-Lake Charles facility will demonstrate compliance with the two audit programs on an 'overall most stringent compliance audit program' approach. The 'most stringent overall program' for the regulated process units on-site is defined in the provisions defined in 29 CFR 1910.119(o) - OSHA's Process Safety Management Compliance Audit provisions.


II. Lake Charles Facility and the Regulated Substance Handled

The Lake Charles Plant is a 235-acre site located to the south west of Westlake, and to the west of Lake Charles, Louisiana. The plant is adjacent to Interstate 10, a major east-west interstate highway. The plant has four (4) process units that are regulated under the Risk Management Program as defined in 40 CFR Part 68.

Toluene Diisocyanate (TDI) Complex - The TDI complex consists of units that produce hydrogen and carbon monoxi
de as raw materials for toluene diamine (TDA) and phosgene, the raw materials for TDI. TDI is a major component of flexible urethane foam, which is used in furniture cushioning, bedding, carpet underlay and safety padding. The regulated substances handled in the TDI Complex include:

(1) TDI Process Unit - Stationary Source and Regulated Substances Handled:
Listed Compounds: Phosgene and toluene diisocyanate
Usage: Phosgene is used as a raw material in the TDI process unit. Toluene diisocyanate is the finished product of the TDI process.

(2) Phosgene Process Unit - Stationay Source and Regulated Substances Handled:
Listed Compounds: Phosgene
Usage: Phosgene is a finished product from the Phosgene process unit.

(3) Toluene Diamine Process Unit - Stationary Source and Regulated Substances Handled:
Listed Compound: Chlorine.
Usage: Chlorine is used in water treatment in the Toluene Diamine process unit.

Nitric Acid - The Nitric Acid plant produces a high-quality nitric acid. Nitric acid is used in metal treatment and industrial chemicals.

(4) Nitric Acid Process Unit - Stationary Source and Regulated Substances Handled:
Listed Compounds: Butane, chlorine and ammonia.
Usage: Chlorine is used in water treatment in the Nitric Acid process unit. Ammonia is used as a raw material. Butane is used as a fuel for Nox abatement of waste gasses in the nitric acid process.


III. The General Accidental Release Prevention Program and Chemical Specific Prevention Steps

Efforts to reduce pollution and increase safety at the Lake Charles- Lyondell facility focus on several fronts. Lake Charles facility employees strive to develop technologies that minimize waste, install newer equipment that is more environmentally-sound, treat waste streams that are generated by their manufacturing processes, and develop and enhance their systems for analyzing and addressing risks that help the facility prevent incidents.

Operational Excellence:

Driving Lake Charles facility safety a
nd environmental improvements is Lyondell's Operational Excellence initiative. Established in 1991and adopted at the Lake Charles facility in 1997 after the purchase from Olin, Operational Excellence includes standards that cover specific areas of chemical manufacturing including safety and environmental performance, product quality, manufacturing reliability, and efficiency. Through Operational Excellence, the Lake Charles facility has installed the processes, systems, and technology to identify problems, analyze their causes and define and implement solutions.

Lyondell's Operational Excellence standards complement one another, improve safety and environmental performance, while also leading to gains in efficiency and reliability. For example, by finding ways to reduce or eliminate waste from our manufacturing operations, we're able to improve raw material yields, an attractive bottom-line benefit.

A major emphasis has been improving reliability and the percentage of time our plants are up and running. Besides reducing the chance for safety and environmental problems that occur during process upsets, shutdowns, and startups, improving reliability also reduces production costs. Our goal is a 99 percent reliability rate for our continuous process plants. Toward this end, we've strengthened preventive and predictive maintenance systems and have put in place resources focused on reliability at our manufacturing plants. Rigorous auditing process tracks how well our facility is meeting Operational Excellence's high standards. Audit teams composed of experts from different Lyondell facilities and the corporate auditing group examines performance and documentation to make sure our standards are met.

Process Safety:

Process safety at the Lyondell - Lake Charles facility includes strong inspection and maintenance programs to minimize the risk of a material release or other process upset. Lyondell's ongoing programs minimize the chance of an upset. Lyondell continuousl
y examines the plant's operations for process safety hazards. Understanding these hazards helps ensure they are addressed through equipment design, operating procedures, training, maintenance, and emergency response. Lyondell follows, at a minimum, the rigorous standards set by ASME in designing process vessels and process piping systems to minimize process safety hazards.

The Lake Charles facility has a number of existing engineering controls, systems and operating practices, which, as a whole, provide protection against accidental releases. The following table provides examples of some of the existing controls, systems and practices.

Engineering and Operational Controls:
? Unit gas monitors for phosgene and flammables
? Fenceline gas monitors for phosgene
? Automatic sprinkler systems
? Back-up power generators
? Redundant controllers
? Interlock systems
? Vent scrubbers to treat toxic off-gases
? Remote isolation valves
? Process safety management program
? Double-walled containment vessels for critical equipment use for phosgene
? Seal-less (canned-motor, diaphragm and magnetic drive pumps) and dual mechanical seal for process liquid transfer pumps
? Pipe specifications requiring welded construction
? Point-of-Discharge ventilation and treatment system (ET system) to reduce fugitive emissions from decontamination operations

Administrative Controls:
? Trained and qualified personnel
? Standard operating procedures
? Aggressive inspection program of process equipment
? 24-hour instrument monitoring
? Protective safety process
? Leak detection and repair program
? Vibration and spike energy analysis of critical equipment
? Personnel exposure monitoring badges
? 100% X-ray of welds for critical service use
? Hydrostatic testing of piping systems
? Helium leak tests
? Portable foam for vapor suppression of liquid spill releases
? Within a 24-hour period, plant operators perform periodic inspections

Lake Charles operations undergo a process hazard analysis (PH
A) or equivalent analysis every five years and before any significant process change. The PHA studies all factors that contribute to a plant's safety performance -- from plant design to its employee experience -- identifies potential hazards, and verifies that systems are in place to address the hazards. In addition, risk-screening studies at each of our plants have searched for hazards that have the potential to cause major accidents. Following these studies, a set of safety-critical variables were implemented for each location, covering such factors as reactor temperature, unwanted side reactions, or caustic solution flow to scrubbers which neutralize process toxic off-gases. These variables are continuously monitored to ensure that they are within a safe range.

Contractor Safety:

Lyondell - Lake Charles contractor safety management systems require our contractors to accept the same safety responsibilities and standards that apply to our employees. We have rigorous standards for evaluating their past performance and their safety management systems before they are hired. Once selected, every contractor must go through the appropriate training program for the job. Employees also monitor the contractor's safety performance and conduct unannounced audits to check compliance with safety policies and work procedures. Contractors are also evaluated at the end of a job or on a regular basis for those on-site for longer periods.

Product Stewardship:

Lyondell's product stewardship effort requires commitment from people inside and outside of the Lyondell organization. While ensuring high standards for handling at our manufacturing site, the Lake Charles facility also works closely with our suppliers, manufacturers, transporters, distributors, and customers. We also share ideas with other chemical companies through the Chemical Manufacturers Association's Product Stewardship committees. A successful Product Stewardship effort requires commitment from a wide range of pe
ople at Lyondell, including top management, sales and marketing personnel, logistic people, and safety and health professionals. Our business processes must make it possible for all of these groups to share ideas about potential risks and how to manage them.

Over the past few years we've coordinated a major product stewardship effort for toluene diisocyanate (TDI). Lyondell has undertaken a worldwide campaign to educate customers, distributors, and contracted transportation companies on the safe use of this product.


IV. The Five Year Accident History

The EPA requires that a 5-year history of certain releases be reported. A release must be from a process involving a regulated substance and have caused at least one of the following.

? On-site deaths, injuries, or significant property damage; or
? Known off-site deaths, injuries, property damage, environmental damage, evacuations or sheltering in place.

The incidents listed below meet USEPA's criteria for reporting.

? October 14, 1999 - A gate valve in phosgene service developed a leak as it was manually closed. Less than one pound of phosgene was released and the operator exposed during the operation was treated for the exposure and hospitalized for observation. The use of gate valves in lethal and toxic services was re-evalutated facility-wide.

? July 11, 2003 - During a plant shut down, a pump in phosgene and monochlorobenzene service failed and released nine (9) pounds of phosgene. The release caused the facility's fence-line phosgene monitors to alarm and as a resulted we recommended a precautionary shelter-in-place for the downwind community. There were no injuries or illnesses reported on or off-site. As a result of this incident, the operation of this type of pump in shutdown conditions has been modified.


V. The Emergency Response Program

Community Safety:

Area industries work hard to ensure the safety of their employees, the community and the environment. While Lyondell continues to reduce t
he risk associated with our operations, emergency preparedness and community response are essential to the safety and well being of the community.

We work closely with three community safety groups:

Calcasieu Parish Local Emergency Planning Committee - Local Emergency Planning Committees were created by Congress through SARA Title III, the national Emergency Planning and Community Right-to-know Act. The act was signed into law October 17, 1986, as key legislation to help communities protect public health, safety, and the environment from chemical hazards. To implement this Act, Congress required each state to create a State Emergency Response Commission (SERC). The SERCs were required to divide their states into Emergency Planning Districts and name a Local Emergency Planning Committee (LEPC) for each district.

The Calcasieu Parish Local Emergency Planning Committee was started in 1988. It was made up of mayors, public health officials, government, media representatives, environmentalists, and industry and union representatives. The Calcasieu Parish LEPC is the focal point for community emergency-response planning, evacuation studies, hazardous material transportation studies and public awareness campaigns, and has the responsibility to collect, manage and provide public access to information on hazardous substances within Calcasieu Parish. The Calcasieu Parish LEPC has been recognized for community emergency planning by the U.S. Environmental Protection Agency (EPA) and the Federal Emergency Management Agency.

Community Awareness Emergency Response (CAER) - The CAER organization is a voluntary group of industrial safety representatives and municipal emergency responders. The organization was established in 1985. Through the CAER program, many of the emergency sirens in Calcasieu Parish were purchased. The CAER organization works closely with the Calcasieu Parish LEPC to provide funding for awareness projects, to assist with drills and to suggest ways of improvi
ng the Calcasieu Parish emergency-response plan.

Southwest Louisiana Mutual Aid Association - The Southwest Louisiana Mutual Aid Association is one of the oldest organizations of its type along the Gulf Coast. This organization is made up of emergency responders from area municipalities, volunteer firefighters, law enforcement, medical providers and industrial representatives. The Mutual Aid Association provides equipment and assistance to member facilities during large-scale emergencies.

Emergency Response:

A good emergency response team consists of several components. The first is professional and well-trained people. The Lyondell Lake Charles plant has on of the most elite emergency response teams (ERT) in the area. This team is made up of over 60 volunteers and is staffed 24 hours a day, 365 days a year. Our ERT is extensively trained to respond to any type of incident - fire, HAZMAT, search and rescue, or medical emergencies. This team trains at two of the world's best emergency response training facilities: Texas A&M University and Louisiana State University. Lyondell also augments the site personnel training through the Southwest Louisiana Fire Training Center and on-site training. The ERT operates under a comprehensive emergency response plan, as well as a structured incident command system. We also lend a helping hand by providing emergency response assistance to other organizations in our area under the Mutal Aid Program.

The second component of a good emergency response team is good equipment. Recently, we have purchased one of the largest capacity fire trucks in Southwest Louisiana, a new ambulance, and a new rescue vehicle. These purchases have added to our broad range of equipment and resources to use in the mitigation of emergency events and include: a fire truck, ambulance, diking supplies, deluge sprinkler systems, halon systems, stationary firewater monitors, water hydrants, fire extinguishers, emergency communication network and a haz
ardous material equipment trailer. All of our mobile equipment is available to assist municipal and volunteer fire departments and other companies in our region through the Mutual Aid Program.

Thirdly, a good emergency-response plan requires extensive planning and periodic drills. The Lake Charles facility has a full-time emergency-response coordinator, whose job is to prepare people and equipment for emergency response. Our plan meets all the State and Federal requirements. The facility coordinates the site's plan and drill with State and local agencies while working closely with the Local Emergency Planning Committee, local hospitals and other industries to ensure that the facility is ready to respond to an emergency on our plant site.


VII. Planned Changes to Improve Safety

The Lake Charles facility has an on-going program that continuously strives to develop technologies that minimize waste, install newer equipment that is more environmentally-sound, treat waste streams that are generated by our manufacturing processes, and develop and enhance our systems for analyzing and addressing risks that help the facility prevent incidents.

The Lake Charles Facility has a number of upcoming changes that are intended to improve reliability and safety. Some of the proposed upcoming changes include:

? Critical equipment interlock upgrades;
? Closed-loop sampling systems.