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Westlake Vinyls Company

Parent Companies:
Westlake Group of Companies
EPA Facility ID:
100000133438
Other ID:
70734BRDNCLOUIS
Facility DUNS:
0
Parent Company DUNS:
608366308

Location:

Address:
36045 Highway 30
Geismar, LA 70734
County:
ASCENSION
Lat / Long:
30.210, -91.014 (Get map)
Method:
Interpolation - Digital map source (TIGER)
Description:
Center of Facility
Horizonal accuracy:
10 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
Westlake Vinyls Company, LP
Phone:
(225) 673-6121
Address:
PO Box 228
Geismar, LA 70734
Foreign Address:

Person responsible for RMP implementation:

Name:
John Scroggins
Title:
Plant Manager

Emergency contact:

Name:
Ronnie Meyers
Title:
HSES Manager
Phone:
(225) 673-0623
24-hour phone:
(225) 747-0400
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(225) 673-6121
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Ascension Parish LEPC
Full-Time Equivalent Employees:
173
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
1248-V7;2874-V3
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
June 17, 2015
Inspecting Agency:
EPA
Using Predictive Filing:
No

Processes:

PVC
RMP ID:
1000046494
CBI claimed:
No
Program Level:
3
NAICS:
Plastics Material and Resin Manufacturing (325211)
Chemical name
CAS#
Quantity (lbs.)
CBI
Vinyl chloride [Ethene, chloro-]
75-01-4
570,000
No
Chlorine
7782-50-5
13,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
VCM-E
RMP ID:
1000046495
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Vinyl chloride [Ethene, chloro-]
75-01-4
11,000,000
No
Hydrogen chloride (anhydrous) [Hydrochloric acid]
7647-01-0
290,000
No
Propylene [1-Propene]
115-07-1
55,000
No
Chlorine
7782-50-5
34,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Chlor-Alkali
RMP ID:
1000046496
CBI claimed:
No
Program Level:
3
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Chemical name
CAS#
Quantity (lbs.)
CBI
Chlorine
7782-50-5
6,900,000
No
Hydrochloric acid (conc 37% or greater)
7647-01-0
600,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Ryan Estevens
Address:
36045 Hwy 30
Geismar, LA 70734
Foreign Address:

Phone:
(225) 673-0656

Latest RMP Submission:

Date:
Aug. 31, 2015
Type:
Resubmission
Reason:
Voluntary update (not described by any of the above reasons)
Registered:
Yes
RMP ID:
1000037903

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 Chlor-Alkali)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
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 VCM-E)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas liquified by refrigeration
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in Chlor-Alkali)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in Chlor-Alkali)
CBI claimed:
No
Percent weight:
37.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
not considered:
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
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 VCM-E)
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 VCM-E)
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
Public OCA Chemical (in VCM-E)
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

Feb. 13, 2017 at 14:45
ID:
1000050373
NAICS:
Petrochemical Manufacturing (32511)
Duration:
1 minutes
Chemicals involved:
  • Chlorine
Release events:
Gas release
Weather conditions at time of event
Wind speed:
2.0 miles/h ESE
Temperature:
70.00 ℉
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:
1
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$0
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
1
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Human Error
Contributing factors:
  • Human error
Off-site responders notified:
No, not notified
Changes introduced as a result of the accident:
  • Revised operating procedures
May 9, 2012 at 14:54
ID:
1000031341
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Duration:
19 minutes
Chemicals involved:
  • Chloroform [Methane, trichloro-]
  • Ethylene [Ethene]
Release events:
Gas release
Weather conditions at time of event
Wind speed:
7.0 miles/h N
Temperature:
82.00 ℉
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:
3
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:
  • By-pass condition
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • New mitigation systems
March 22, 2012 at 08:00
ID:
1000031340
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Duration:
30 minutes
Chemicals involved:
  • Chlorine
  • Vinyl chloride [Ethene, chloro-]
  • Hydrogen chloride (anhydrous) [Hydrochloric acid]
Release events:
Fire
Weather conditions at time of event
Wind speed:
4.0 miles/h ESE
Temperature:
54.00 ℉
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:
$3600000
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$1100000
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Equipment failure
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Revised operating procedures
  • New process controls
  • New mitigation systems

7. Prevention: Program level 3

PVC, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000040463
Safety Review Date
June 8, 2015, since latest RMP submission
PHA Update Date
Aug. 12, 2014, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
March 9, 2015, since latest RMP submission
Training Review Date
May 26, 2015, since latest RMP submission
Maintenance Review Date
Nov. 17, 2014, since latest RMP submission
Maintenance Inspection Date
May 8, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 7, 2015
Management of Change Review Date
April 9, 2015
Pre-startup Review Date
April 7, 2015
Compliance Audit Date
Oct. 11, 2013
Compliance Audit Change Completion Date
April 16, 2015
Incident Investigation Date
April 12, 2015
Incident Invest. Change Completion Date
April 13, 2015
Participation Plan Review Date
Dec. 10, 2013
Hot Work Review Date
Feb. 4, 2015
Contractor Safety Review Date
Dec. 10, 2013, since latest RMP submission
Contractor Safety Eval. Date
June 3, 2015, since latest RMP submission
VCM-E, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000040464
Safety Review Date
June 10, 2015, since latest RMP submission
PHA Update Date
Nov. 13, 2014, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • Dikes
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Feb. 18, 2015, since latest RMP submission
Training Review Date
May 13, 2015, since latest RMP submission
Maintenance Review Date
Nov. 17, 2014, since latest RMP submission
Maintenance Inspection Date
April 6, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
June 9, 2015
Management of Change Review Date
April 9, 2015
Pre-startup Review Date
June 9, 2015
Compliance Audit Date
Oct. 11, 2013
Compliance Audit Change Completion Date
April 16, 2015
Incident Investigation Date
May 27, 2015
Incident Invest. Change Completion Date
Jan. 1, 2016
Participation Plan Review Date
Dec. 10, 2013
Hot Work Review Date
Feb. 4, 2015
Contractor Safety Review Date
Dec. 10, 2013, since latest RMP submission
Contractor Safety Eval. Date
June 3, 2015, since latest RMP submission
Chlor-Alkali, Other Basic Inorganic Chemical Manufacturing (32518)
Prevention Program ID:
1000040465
Safety Review Date
Feb. 2, 2015, since latest RMP submission
PHA Update Date
March 29, 2013, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Floods
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Grounding Equipment
  • Rupture Disks
Mitigation Systems
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
April 24, 2015, since latest RMP submission
Training Review Date
April 22, 2015, since latest RMP submission
Maintenance Review Date
Nov. 17, 2014, since latest RMP submission
Maintenance Inspection Date
May 13, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Oct. 14, 2014
Management of Change Review Date
April 9, 2015
Pre-startup Review Date
Oct. 14, 2014
Compliance Audit Date
Oct. 11, 2013
Compliance Audit Change Completion Date
April 16, 2015
Incident Investigation Date
June 17, 2015
Incident Invest. Change Completion Date
June 17, 2015
Participation Plan Review Date
Dec. 10, 2013
Hot Work Review Date
Feb. 4, 2015
Contractor Safety Review Date
Dec. 10, 2013, since latest RMP submission
Contractor Safety Eval. Date
June 3, 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 31, 2015
Local Response Agency:
Local Response Agency Phone:
(225) 621-8360
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

RISK MANAGEMENT PLAN EXECUTIVE SUMMARY





LDEQ Facility ID Number - 1138



Westlake Vinyls Company, LP (WVC)acquired a chemical manufacturing facility formerly owned and operated by Borden Chemicals and Plastics Operating Limited Partnership (BCP) in Geismar, Louisiana. BCP had operated the facility until April 2002 when all process units were shutdown. De-inventory of all chemicals was completed by September 2002. In December 2002, WVC acquired a portion of the facility from BCP. As required by 40 CFR 68.155, WVC is including with the Risk Management Plan Submission the following Executive Summary.



WVC has conducted EDC production operations since November 2003 and PVC and VCME production operations since December 2004. WVC performed all appropriate equipment testing, HAZOPs, Pre start-up Safety Reviews (PSSR's), and all other startup procedures prior to startup of operations. Chlor-Alkali operations began in the 4th Quarter 2013.



Accidental Release Prevention and Emergency Response Policies



WVC has a commitment to protection of the health and safety of its employees and the general public. It is WVC policy to provide the safest workplace possible for our employees while also minimizing to the fullest extent practical any impact on the neighboring community, which includes striving to eliminate accidental releases. This commitment is demonstrated by the resources invested in accident prevention, such as emphasizing safety in the design, installation, operation, and maintenance of our processes; providing proper training to personnel; having up-to-date operating procedures; and implementing an effective maintenance and mechanical integrity program. Our policy is to implement appropriate controls to minimize the potential for releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the re
lease in order to minimize to the fullest extent any possible impact on the neighboring community.



Stationary Source and Regulated Substances



The WVC facility is located in Sections 3, 49, and 50 of Township 9 South, Range 2 East and Section 11 of Township 10 South, Range 2 East in Ascension Parish. The site is approximately 22 miles southeast of Baton Rouge, Louisiana at the intersection of Louisiana Highways 73 and 30 near the rural town of Geismar, LA. The facility began operation in 1961 under the direction of Borden Chemical, Inc. and was operated continuously until the entire plant was shut down in April 2002. In December 2002, WVC acquired certain assets of the complex. The plants now operated by WVC include vinyl chloride (including ethylene dichloride), polyvinyl chloride, and chlor-alkali (chlorine and caustic). The remaining plants which included urea, urea-formaldehyde concentrate, acetylene, anhydrous ammonia, formaldehyde, industrial gases (carbon monoxide and hydrogen), methanol, and air separation products (oxygen, nitrogen, and argon) are not owned by WVC and are not operated by WVC.



The plant uses or produces the following RMP regulated substances in quantities above the threshold quantities listed in 40 CFR 68.130:



Toxics: chlorine and hydrogen chloride

Flammables: propylene and vinyl chloride



Accidental Release Prevention Program and Chemical Specific Prevention Steps



The following is a summary of the general accident prevention programs in place at WVC's Geismar facility. Because the processes at the plant regulated by the EPA RMP regulation are also subject to the OSHA PSM standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program.



Employee Participation



WVC employees participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling
technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team. Employees are involved in the writing of procedures and development of the training materials that accompany them. Employees have access to all information created as part of the plant accident prevention program. Specific ways that employees are involved in the process safety management program are documented in an employee participation plan that is maintained at the plant and addresses each process safety program element.



Process Safety Information



WVC has a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, specific chemical inventories, and equipment design basis/configuration information. Specific departments within the plant are assigned responsibility for maintaining up-to-date process safety information. Employees have been advised of the location of the process safety information and trained in how to use the information.



Chemical-specific information, including information on exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). 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 (PHA)



WVC has a comprehensive program to ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify potential process safety 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 evaluat
ions. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The analyses are conducted by a team comprised of individuals who have operating, safety, environmental and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures. Suggestions for additional prevention and/or mitigation measures are made when the team finds such measures are necessary.



To ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, WVC will update and revalidate the hazard analysis results at least once every five years for the life of the process. The results and findings from these updates will be documented and forwarded to management for consideration, and the final resolution documented and retained.



Operating Procedures



WVC maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) shutdown, and (4) initial startup of a new process. Temporary and emergency operating procedures are developed for each case prior to commencement of the operation. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. Procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change process. Procedures are reviewed annually.



Training



WVC has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in both safety issues and plant operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After an operator demonstrates (e.g., through tests, skills demonstration) adequate k
nowledge to perform the duties and tasks in a safe manner, the operator can work independently. In addition, all operators will receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training will be conducted at least once every three years. All training is documented for each operator, including, the means used to verify that the operator comprehended the training.



Contractors

WVC routinely employs contractors to work on or near process equipment. Additional contractor work force is present during periods of increased maintenance or construction activities. Contractors are provided both plant-wide and unit-specific training. In addition, craftsmen must complete the eight-hour safety-training program for industrial workers provided by industry through the local safety council. The training is maintained through annual refresher training.



In addition to the safety training, procedures are in place to ensure that contractors perform their work in a safe manner; have the appropriate knowledge and skills; are aware of the hazards in their workplace; understand what they should do in the event of an emergency; understand and follow site safety rules; and inform plant personnel of any hazards that they find. Each contractor employee is provided with a process overview and information about safety and health hazards, emergency response plan requirements, and safe work practices prior to beginning work. WVC evaluates contractor safety programs and performance during the contractor selection process. Plant personnel monitor contractor performance to ensure that contractors are fulfilling their safety obligations.





Pre-Startup Safety Reviews (PSSRs)



WVC conducts a Pre-Startup Safety Review (PSSR) for any new facility or major facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that necessary
training, safety features, procedures, and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one 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



WVC has established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems 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 equipment.



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 to help ensure that they can perform their job in a safe manner. Written procedures help ensure that work is performed in a consistent manner and provide 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 (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service, as appropriate, or management will review the use of the equipment and determine what actions are necessary to ensure the safe o
peration of the equipment until the actions are completed.



Another integral part of the mechanical integrity program is quality assurance. WVC incorporates quality assurance measures (e.g., purchasing specifications and inspection procedures) into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made.



Safe Work Practices



WVC has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include: (1) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (2) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (3) a permit and procedure to control spark-producing activities (i.e., hot work), and (4) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely.



Management of Change



WVC has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, and equipment information, as well as procedures and drawings are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change.



The management of change program is designed to allow anyone at the facility the ability to initiate a MOC. Employees have been trained concerning the v
arious elements that would constitute a change such as parts, procedures, operating conditions, etc. The MOC change form provides an abbreviated version of the pre-startup review. Management of the documents and approval to proceed are controlled at the department level.





Incident Investigation



WVC promptly investigates all process safety related incidents. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to plant management. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. When necessary, short-term interim measures are taken until the permanent fix is implemented. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained on file for at least five years to supplement the hazard analysis records for the affected areas, and are reviewed during PHAs and PHA revalidations. WVC implemented a non-conformance report database and an employee improvement program in November 2003.



Compliance Audits



To help ensure that the process safety program is functioning properly, WVC periodically undergoes an audit to determine whether the procedures and practices required are being implemented. Compliance audits are conducted at least every three years. The WVC Corporate HSE office conducted a PSM compliance audit in February 2011. Both hourly and management personnel participate in the audits. The audit team develops findings that are forwarded to the plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are re
solved. The final resolution of each finding is documented. Additionally, OSHA is in the process of conducting an NEP auidt which started on 3/23/12 and is on-going at the time of this update.



CHEMICAL-SPECIFIC PREVENTION STEPS



The processes at WVC have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all EPA RMP-covered processes at the facility. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and/or human errors. In addition to the accident prevention program activities, WVC has safety features to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used where appropriate:



Release Detection



--Hydrocarbon detectors with alarms



Release Containment/Control



--Process relief valves that discharge to a flare to capture and incinerate episodic releases

--Scrubber to neutralize chemical releases

--Valves to permit isolation of the process (manual or automated)

--Automated shutdown systems for specific process parameters (e.g., high level, high temperature)

--Vessel to permit partial removal of the process inventory in the event of a release (e.g., dump tank)

--Curbing or diking to contain liquid releases

--Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump)

--Atmospheric relief devices



Release Mitigation



--Fire suppression and extinguishing systems

--Deluge systems for specific equipment

--Trained emergency response personnel

--Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus)



Five-year Accident History



There have been two accidents which meet the criteria established under RMP that have occurred at WVC's Geismar facility during the
past five years. WVC investigates every incident that meets RMP criteria very carefully to determine ways to minimize the potential for similar incidents from occurring in the future. While our goal is to eliminate the occurrence of such events, WVC recognizes that they may occur and therefore we also work to ensure proper response to minimize and mitigate any potential impact on our employees and the neighboring community.



Emergency Response Program



WVC's Geismar facility maintains a written emergency response program to protect workers and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including proper first-aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post-incident cleanup and decontamination requirements. In addition, the plant has procedures that address maintenance, inspection and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is reviewed annually and updated when necessary based on modifications made to plant processes or other plant facilities. Emergency response program changes are administered such that informing and/or training affected personnel is accomplished prior to implementation of the change.



The overall emergency response program for the Geismar facility is coordinated with the Geismar Area Mutual Aid (GAMA) network which is comprised of local industries and the Ascension Parish Local Emergency Planning Committee (LEPC). This co
ordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The Geismar facility has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response. In addition to periodic GAMA meetings, the Geismar facility conducts periodic emergency drills.





Planned Changes to Improve Safety



WVC will continue to evaluate the systems and programs in place and make necessary improvements and adjustments to ensure a well-functioning, effective process safety/ risk management program.