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Sasol Chemicals USA LLC

Parent Companies:
EPA Facility ID:
100000099886
Other ID:
LAR000041087
Facility DUNS:
102663713

Location:

Address:
2201 Old Spanish Trail
Westlake, LA 70669
County:
CALCASIEU
Lat / Long:
30.251, -93.281 (Get map)
Method:
Interpolation - Photo
Description:
Center of Facility
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Sasol Chemicals USA LLC
Phone:
(337) 494-5450
Address:
2201 Old Spanish Trail
Westlake, LA 70669 -0727
Foreign Address:

Person responsible for RMP implementation:

Name:
Richard Brink
Title:
Senior Manager SHE

Emergency contact:

Name:
Scott Tyler
Title:
Safety and Security Manager
Phone:
(337) 310-8409
24-hour phone:
(337) 494-5450
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(337) 494-5072
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Calcasieu Parish LEPC
Full-Time Equivalent Employees:
718
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
3271
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
March 26, 2015
Inspecting Agency:
Louisiana Department of Environmental Quality
Using Predictive Filing:
No

Processes:

Linear Alkyl Benzene Unit
RMP ID:
1000068645
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid]
7664-39-3
396,260
No
Chlorine
7782-50-5
4,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Ethoxylation Unit
RMP ID:
1000068646
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ethylene oxide [Oxirane]
75-21-8
6,284,740
No
Public OCA Chemical
0
No
Ethylene Unit
RMP ID:
1000068647
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
1,3-Butadiene
106-99-0
601,253
No
Propylene [1-Propene]
115-07-1
799,056
No
Ethane
74-84-0
251,497
No
Butene
25167-67-3
120,100
No
Ethylene [Ethene]
74-85-1
271,086
No
Butane
106-97-8
81,229
No
Methane
74-82-8
11,958
No
Propane
74-98-6
52,761
No
Chlorine
7782-50-5
20,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Normal Paraffin Extract
RMP ID:
1000068648
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Pentane
109-66-0
1,019,961
No
Public OCA Chemical
0
No
Alcohol Unit
RMP ID:
1000068649
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ethylene [Ethene]
74-85-1
21,386
No
Pentane
109-66-0
59,153
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
CoMonomers
RMP ID:
1000068650
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Propylene [1-Propene]
115-07-1
140,368
No
Ethylene [Ethene]
74-85-1
260,690
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
Jan. 22, 2016
Type:
Resubmission
Reason:
Voluntary update (not described by any of the above reasons)
Registered:
Yes
RMP ID:
1000054857

Deregistration:

Date:
Effective Date:
Reason:
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 Linear Alkyl Benzene Unit)
CBI claimed:
No
Percent weight:
99.5
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:
  • 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 Linear Alkyl Benzene Unit)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas
Model used:
PHAST Dispersion Modeling
Wind speed (meters per sec):
3.80
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Drains
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Sumps
Active mitigation
considered:
  • Sprinkler systems
  • Water curtain
  • Emergency shutdown
not considered:
  • Deluge systems
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
Public OCA Chemical (in Linear Alkyl Benzene Unit)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas
Model used:
EPA Reference Table 24
Wind speed (meters per sec):
3.80
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Berms
not considered:
  • Dikes
  • Enclosures
  • Drains
  • Sumps
Active mitigation
considered:
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in Ethoxylation Unit)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Liquid
Model used:
PHAST Dispersion Modeling
Wind speed (meters per sec):
3.80
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Deluge systems
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
Public OCA Chemical (in Ethylene Unit)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas
Model used:
EPA Reference Table 24
Wind speed (meters per sec):
3.80
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Drains
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Sumps
Active mitigation
considered:
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown

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 Ethylene Unit)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
Passive mitigation
considered:
  • None
not considered:
  • Blast walls
Public OCA Chemical (in Normal Paraffin Extract)
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 Normal Paraffin Extract)
CBI claimed:
No
Model used:
DNV PHAST Dispersion Modeling
Passive mitigation
considered:
  • Dikes
not considered:
  • 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

Linear Alkyl Benzene Unit, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000057313
Safety Review Date
Jan. 7, 2016, since latest RMP submission
PHA Update Date
April 24, 2015, since latest RMP submission
PHA Techniques
  • What if/Checklist
Hazards Identified
  • Toxic release
  • Fire
  • Overpressurization
  • Corrosion
  • Equipment failure
  • Cooling loss
  • Tornado
  • 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
  • Rupture Disks
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Blast Walls
  • Deluge System
  • Water Curtain
  • Neutralization
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Process Parameters
  • Perimeter Monitoring
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Observation
Procedure Review Date
Jan. 4, 2016, since latest RMP submission
Training Review Date
June 1, 2015, since latest RMP submission
Maintenance Review Date
Jan. 5, 2016, since latest RMP submission
Maintenance Inspection Date
Dec. 9, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Jan. 15, 2016
Management of Change Review Date
Oct. 29, 2015
Pre-startup Review Date
Jan. 5, 2016
Compliance Audit Date
April 15, 2013
Compliance Audit Change Completion Date
April 15, 2015
Incident Investigation Date
Feb. 19, 2014
Incident Invest. Change Completion Date
June 30, 2014
Participation Plan Review Date
April 9, 2014
Hot Work Review Date
June 5, 2015
Contractor Safety Review Date
July 16, 2015, since latest RMP submission
Contractor Safety Eval. Date
Oct. 29, 2015, since latest RMP submission
Ethoxylation Unit, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000057312
Safety Review Date
Jan. 7, 2016, since latest RMP submission
PHA Update Date
Feb. 12, 2015, since latest RMP submission
PHA Techniques
  • What if/Checklist
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Fire Walls
  • Blast Walls
  • Deluge System
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Process Controls
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 5, 2016, since latest RMP submission
Training Review Date
June 1, 2015, since latest RMP submission
Maintenance Review Date
Jan. 5, 2016, since latest RMP submission
Maintenance Inspection Date
Jan. 6, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Jan. 15, 2016
Management of Change Review Date
Oct. 29, 2015
Pre-startup Review Date
Nov. 13, 2015
Compliance Audit Date
April 15, 2013
Compliance Audit Change Completion Date
April 15, 2015
Incident Investigation Date
March 17, 2015
Incident Invest. Change Completion Date
June 15, 2015
Participation Plan Review Date
April 9, 2014
Hot Work Review Date
June 5, 2015
Contractor Safety Review Date
July 16, 2015, since latest RMP submission
Contractor Safety Eval. Date
Oct. 29, 2015, since latest RMP submission
Ethylene Unit, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000057314
Safety Review Date
Jan. 7, 2016, since latest RMP submission
PHA Update Date
Aug. 26, 2015, since latest RMP submission
PHA Techniques
  • What if/Checklist
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Tornado
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
  • Rupture Disks
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Fire Walls
  • Blast Walls
  • Deluge System
  • Water Curtain
  • Neutralization
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Process Parameters
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
Jan. 5, 2016, since latest RMP submission
Training Review Date
June 1, 2015, since latest RMP submission
Maintenance Review Date
Jan. 5, 2016, since latest RMP submission
Maintenance Inspection Date
Dec. 17, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Jan. 15, 2016
Management of Change Review Date
Oct. 28, 2015
Pre-startup Review Date
Jan. 7, 2016
Compliance Audit Date
April 15, 2013
Compliance Audit Change Completion Date
April 15, 2015
Incident Investigation Date
Feb. 13, 2015
Incident Invest. Change Completion Date
Aug. 13, 2015
Participation Plan Review Date
April 9, 2014
Hot Work Review Date
June 5, 2015
Contractor Safety Review Date
July 16, 2015, since latest RMP submission
Contractor Safety Eval. Date
Oct. 29, 2015, since latest RMP submission
Normal Paraffin Extract, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000057315
Safety Review Date
Jan. 7, 2016, since latest RMP submission
PHA Update Date
Dec. 4, 2012, since latest RMP submission
PHA Techniques
  • What if/Checklist
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Tornado
  • 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
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Process Parameters
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
Dec. 28, 2015, since latest RMP submission
Training Review Date
June 1, 2015, since latest RMP submission
Maintenance Review Date
Jan. 5, 2016, since latest RMP submission
Maintenance Inspection Date
Dec. 31, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Jan. 15, 2016
Management of Change Review Date
Oct. 28, 2015
Pre-startup Review Date
Sept. 24, 2015
Compliance Audit Date
April 15, 2013
Compliance Audit Change Completion Date
April 15, 2015
Incident Investigation Date
Feb. 12, 2010
Incident Invest. Change Completion Date
Aug. 15, 2012
Participation Plan Review Date
April 9, 2014
Hot Work Review Date
June 5, 2015
Contractor Safety Review Date
July 16, 2015, since latest RMP submission
Contractor Safety Eval. Date
Oct. 29, 2015, since latest RMP submission
Alcohol Unit, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000057316
Safety Review Date
Jan. 7, 2016, since latest RMP submission
PHA Update Date
Oct. 1, 2014, since latest RMP submission
PHA Techniques
  • What if/Checklist
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Fire Walls
  • Blast Walls
  • Deluge System
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Process Parameters
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Dec. 10, 2015, since latest RMP submission
Training Review Date
June 1, 2015, since latest RMP submission
Maintenance Review Date
Jan. 5, 2016, since latest RMP submission
Maintenance Inspection Date
Jan. 7, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Jan. 15, 2016
Management of Change Review Date
Oct. 28, 2015
Pre-startup Review Date
Jan. 8, 2016
Compliance Audit Date
April 15, 2013
Compliance Audit Change Completion Date
April 15, 2015
Incident Investigation Date
Dec. 18, 2014
Incident Invest. Change Completion Date
Oct. 30, 2015
Participation Plan Review Date
April 9, 2014
Hot Work Review Date
June 15, 2015
Contractor Safety Review Date
Jan. 16, 2015, since latest RMP submission
Contractor Safety Eval. Date
Oct. 29, 2015, since latest RMP submission
CoMonomers, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000057317
Safety Review Date
Jan. 7, 2016, since latest RMP submission
PHA Update Date
March 28, 2014, since latest RMP submission
PHA Techniques
  • What if/Checklist
Hazards Identified
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Interlocks
  • Alarms
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
Mitigation Systems
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 6, 2016, since latest RMP submission
Training Review Date
June 1, 2015, since latest RMP submission
Maintenance Review Date
Jan. 5, 2016, since latest RMP submission
Maintenance Inspection Date
Dec. 29, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Jan. 15, 2016
Management of Change Review Date
Oct. 28, 2015
Pre-startup Review Date
Jan. 8, 2016
Compliance Audit Date
April 15, 2013
Compliance Audit Change Completion Date
April 15, 2015
Incident Investigation Date
May 16, 2015
Incident Invest. Change Completion Date
July 31, 2015
Participation Plan Review Date
April 9, 2014
Hot Work Review Date
June 5, 2015
Contractor Safety Review Date
July 16, 2015, since latest RMP submission
Contractor Safety Eval. Date
Oct. 29, 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:
Oct. 16, 2015
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

3271 LDEQ Facility ID Number

Sasol Chemicals USA, LLC. Lake Charles Chemical Complex

Risk Management Plan

Executive Summary



Sasol's Lake Charles Chemical Complex (LCCC) has a long-standing commitment to worker and public safety. 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 processes. Our policy is to implement reasonable controls to prevent chemical releases. However, if a release does occur, our trained personnel will respond to control, contain, and mitigate the release.



Sasol's Lake Charles Chemical Complex (LCCC) located in Westlake, Louisiana uses natural gas and by-products from refinery operations to produce specialty chemicals for detergents and cosmetics. The chemical complex uses or produces several regulated flammables such as ethylene, propane, butane, propylene, ethane, butane, hydrogen, methane, and pentane. Chemicals maintained on site at the LCCC listed on the EPA's list of toxic chemicals and are above EPA's threshold quantity are Chlorine, Ethylene Oxide and Hydrogen Fluoride. Other regulated chemicals used in our process, which are stored below the threshold quantity, are Sulphur Dioxide and Ammonia.



Process Safety Information



The LCCC (Lake Charles Chemical Complex) 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 chemical complex 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 chemical complex.



Chemical specific information, including exposure
hazards and emergency response/exposure considerations, is provided in material safety data sheets (MSDS). This information is supplemented by documents that address known corrosion concerns and known hazards associated within inadvertent mixing of specific chemicals. For the different process areas, the chemical complex has documented safety related limits for specific process parameters (e.g. temperature, pressure, composition, etc.). The chemical complex ensures that the processes are maintained within the limits using process controls, monitoring instruments, protective instrument systems, and highly trained personnel.





The chemical complex also maintains an electronic database, that is accessible by both employees and contractor supervision, which provides information about the design pressure and temperature ratings, electrical classification, etc. This information in combination with written procedures and trained personnel provides a basis for establishing inspection and maintenance activities as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised.



Process Hazard Analysis



The Lake Charles Chemical Complex (LCCC) has a comprehensive program to help ensure the hazards associated with the various processes are identified and controlled. Within this program, each process is systemically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.



The LCCC primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations and the What-if/Checklist method for Process Hazard Analysis revalidations. 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 measure
s when the team believes such measures are necessary.



The PHA team findings are made available to people associated with the process unit for comments and forwarded to 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 until they are complete. 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 the Lake Charles Chemical Complex (LCCC), 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:

? 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



The Lake Charles Chemical Complex (LCCC) trains its workers to safely and effectively perform their assigned tasks. The training program includes both initial and refresher training.



All new employees assigned as operators receive comprehensive training before being assigned to a specific operating unit. This training includes training on specific types of equipment, s
uch as pumps and compressors, general overview of the process, properties and hazard substances in the process, and detailed review of complex procedures, such as, safe work practices and of emergency response. Oral reviews and written tests are used to verify that employees understand the training material before a new employee can report to a process unit. Once a new employee reports to a particular process unit, he receives detailed training with respect to process specific procedures and for specific tasks, before he is allowed to begin work in a specific operating unit.



Refresher training covers (1) a general overview of the process, (2) the properties and hazards of the substances in the process and, (3) a review of the process operating procedures and safe work practices. Oral review and 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 (MOCA)



The Management of Change program for the LCCC 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. 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 a full management of change program to help ensure process safety information and procedures are updated, and affected employees are notified of the change.



Pre-Startup Safety Review (PSSR)



The Lake Charles Chemical Complex (LCCC) 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 features, procedures, personnel and equipment are appropriately prepared for startup prior to placing the equipment in service. The review provides one additional check to make sure construction of new processes and significant modifications to existing processes are, in accordance with the design specifications and that all supporting systems is 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

The Lake Charles Chemical Complex (LCCC) has well established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, emergency shutdown systems, and rotating equipment (pumps and compressors) in a safe operating condition. The basic aspects of this program include (1) conducting training, (2) developing written procedures, (3) performing inspections and test, (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 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 (e.g. adequate wall thickness for pressure vessels). 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 docum
ented.





Another integral part of the mechanical integrity program is quality assurance. The LCCC incorporates quality assurance into equipment purchase and repairs. This helps 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



The Lake Charles Chemical Complex (LCCC) has a long standing 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 spark producing activities (i.e. hot work), 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, form a system to help ensure that operations and maintenance activities are performed safely.



Incident Investigation



The Lake Charles Chemical Complex (LCCC) 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. The LCCC trains employees to identify and report any incident requiring investigation. The investigation 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 appropriate changes are made.





Employee Participation



The Lake Charles Chemical Complex (LCCC) 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 infor
med about all aspects of the RMP prevention program including PHA's (Process Hazard Analysis) and operating procedures.



Compliance Audits



The Lake Charles Chemical Complex (LCCC) audits the covered processes to be certain that the prevention program is effectively addressing safety, health, and environmental issues. The complex assembles an audit team that includes personnel knowledgeable in the processes. This team evaluates whether the prevention program satisfies the requirements of the RMP rule and whether the prevention program is sufficient to ensure safe operation of the complex. The results of the audit are documented, recommendations are resolved, and appropriate enhancements made to the operations of the LCCC.



Contractors



The Lake Charles Chemical Complex (LCCC) 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 safety perform the desired task. The complex 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 complex site.





Five Year Accident History



The facility has experienced zero events in the period of June 1994 to present, which had offsite impacts. In addition, there was one event that did not result in any offsite consequences but did result in one minor onsite injury. The one event is as follows:

? October 24, 1999, less than 1 pound of Ethylene Oxide was released during a normal operating procedure.

Injury to a unit operator due to exposure to the chemical occurred as a result of the release.



Emergency Response Program



The Lake Charles Chemical Complex (LCCC) 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 1910.119(n)-Process Safety Management of Highly Hazardous Chemicals

? OSHA 29 CFR 1910 Subpart L-Fire Protection

? LADEQ LAC 33.1? 3901- Notification Regulations for Unauthorized Discharge

? LDPS Title 33, Part V, Subpart 2, Ch.101? 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 Programs 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 Lake Charles Chemical Complex (LCCC) 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 which is appropriate for situations that could possibly occur at the LCCC. In addition to the considerable on-site resources, the LCCC is a member of Calcasieu Mutual Aid. This membership allows the LCCC (if needed) to draw on the emergency response resources of other industries in the immediate area. The following is a partial listing of equipment which is available for emergency response:



? Firepumps w/fixed firewater system

? Fire Monitors

? Fire Extinguishers

? Dry Chemical Truck

? Foam Pumper

? Water Deluge Systems

? Fixed Extinguishing Systems

? Spill Response Unit

? Emergency Response Team



Drills are conducted to
assess the emergency response effort at the LCCC.



Sasol Chemicals USA, LLC Lake Charles Facility is a participant in 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 in 40 CFR 355.



Planned Changes to Improve Safety



The Lake Charles Chemical Complex (LCCC) constantly strives to improve safety and reduce risk through auditing, suggestions from employees, incident investigations, and the use of proper engineering standards and specifications.



Title V Operating Permits

? Ethoxylation Unit-2325

? Linear Alkyl Benzene Unit-2894

? Ethylene Unit-2743

? Steam Unit-2901

? ASU Unit-2895

? Normal Paraffin Extract Unit-2896

? Alcohol Unit-2865

? Alumina Unit-2565

? CoMonomer (ECHO) Unit-3088



The reasons for the resubmittal are because of a company name change and updating the maximum intended inventories for certain chemicals after a planned review of the current processes.