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Westlake Polymers Corp, Poly 1 & 2

Parent Companies:
Weslake Chemical Corporation
EPA Facility ID:
100000144471
Other ID:
LAD0981522048
Facility DUNS:
150409100
Parent Company DUNS:
150403764

Location:

Address:
3525 Cities Service Highway
Sulphur, LA 70663
County:
CALCASIEU
Lat / Long:
30.200, -93.327 (Get map)
Method:
GPS - Unspecified
Description:
Plant Entrance (General)
Horizonal accuracy:
50.9 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
Westlake Chemical Corporation
Phone:
(337) 583-2200
Address:
900 Hwy 108
Sulphur, LA 70665
Foreign Address:

Person responsible for RMP implementation:

Name:
Wayne Ahrens
Title:
Plant Manager
Email:

Emergency contact:

Name:
Wayne P. Smith
Title:
HS&E Manager
Phone:
(337) 583-6927
24-hour phone:
(337) 263-0684
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(337) 583-3116
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Calcasieu Parish LEPC
Full-Time Equivalent Employees:
185
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
0052-00127-V4
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Nov. 17, 2008
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Polyethylene HP
RMP ID:
1000059708
CBI claimed:
No
Program Level:
3
NAICS:
Plastics Material and Resin Manufacturing (325211)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ethylene [Ethene]
74-85-1
59,000
No
Vinyl acetate monomer [Acetic acid ethenyl ester]
108-05-4
320,000
No
Isobutane [Propane, 2-methyl]
75-28-5
100,000
No
Propylene [1-Propene]
115-07-1
110,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Howard Wasserman
Address:
3525 Cities Service Hwy
Sulphur, LA 70663
Foreign Address:

Phone:
(337) 583-6428

Latest RMP Submission:

Date:
Dec. 8, 2014
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000047840

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 Polyethylene HP)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
4160.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • Dikes
not considered:
  • 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 Polyethylene HP)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
6.70
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
not considered:
  • Enclosures
  • Berms
  • Drains
  • 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 Polyethylene HP)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
Passive mitigation
considered:
  • Administrative Control that keeps level below 90%
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 Polyethylene HP)
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

Jan. 17, 2014 at 08:50
ID:
1000036826
NAICS:
Plastics Material and Resin Manufacturing (325211)
Duration:
1 hours
Chemicals involved:
  • Vinyl acetate monomer [Acetic acid ethenyl ester]
Release events:
Fire
Weather conditions at time of event
Wind speed:
None
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:
0
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$100000
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Human Error
Contributing factors:
  • Human error
  • Improper procedure
Off-site responders notified:
Notified Only
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Revised maintenance
  • Revised training
  • Revised operating procedures
Sept. 14, 2012 at 20:15
ID:
1000036825
NAICS:
Plastics Material and Resin Manufacturing (325211)
Duration:
15 minutes
Chemicals involved:
  • Ethylene [Ethene]
Release events:
Gas release
Explosion
Weather conditions at time of event
Wind speed:
3.0 miles/h S
Temperature:
79.00 ℉
Atmospheric stability:
D
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:
2
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$5000
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Human Error
Contributing factors:
  • Improper procedure
  • Maintenance activity/inactivity
Off-site responders notified:
Notified Only
Changes introduced as a result of the accident:
  • Revised training
  • Revised operating procedures
April 15, 2008 at 09:02
ID:
1000036823
NAICS:
Plastics Material and Resin Manufacturing (325211)
Duration:
1 minutes
Chemicals involved:
  • Ethylene [Ethene]
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:
0
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$45000
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:
  • Maintenance activity/inactivity
Off-site responders notified:
No, not notified
Changes introduced as a result of the accident:
  • Revised maintenance
Oct. 12, 2007 at 07:19
ID:
1000036822
NAICS:
Plastics Material and Resin Manufacturing (325211)
Duration:
1 minutes
Chemicals involved:
  • Ethylene [Ethene]
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:
0
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$60000
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:
  • Upset condition
  • Decompostion reaction
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

Polyethylene HP, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000049752
Safety Review Date
April 25, 2013, since latest RMP submission
PHA Update Date
April 25, 2013, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • None
Procedure Review Date
Jan. 18, 2014, since latest RMP submission
Training Review Date
Jan. 18, 2014, since latest RMP submission
Maintenance Review Date
Jan. 18, 2014, since latest RMP submission
Maintenance Inspection Date
Sept. 29, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Oct. 13, 2014
Management of Change Review Date
Oct. 18, 2014
Pre-startup Review Date
Oct. 13, 2014
Compliance Audit Date
May 1, 2013
Compliance Audit Change Completion Date
Dec. 31, 2015
Incident Investigation Date
April 15, 2008
Incident Invest. Change Completion Date
Dec. 31, 2008
Participation Plan Review Date
Jan. 14, 2014
Hot Work Review Date
Dec. 1, 2013
Contractor Safety Review Date
Sept. 18, 2014, since latest RMP submission
Contractor Safety Eval. Date
Nov. 1, 2014, since latest RMP submission
Polyethylene HP, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000049753
Safety Review Date
March 28, 2013, since latest RMP submission
PHA Update Date
March 28, 2013, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Dikes
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
  • Process Detection
Training Type
  • Classrom
  • On the Job
Competency Testing
  • None
Procedure Review Date
Jan. 14, 2014, since latest RMP submission
Training Review Date
Jan. 18, 2014, since latest RMP submission
Maintenance Review Date
April 18, 2014, since latest RMP submission
Maintenance Inspection Date
Oct. 18, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Oct. 13, 2014
Management of Change Review Date
Jan. 18, 2014
Pre-startup Review Date
Oct. 13, 2014
Compliance Audit Date
May 1, 2013
Compliance Audit Change Completion Date
May 1, 2015
Incident Investigation Date
Aug. 5, 2008
Incident Invest. Change Completion Date
Dec. 31, 2009
Participation Plan Review Date
Jan. 18, 2014
Hot Work Review Date
Jan. 18, 2014
Contractor Safety Review Date
April 18, 2014, since latest RMP submission
Contractor Safety Eval. Date
Nov. 1, 2014, since latest RMP submission
Polyethylene HP, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000049754
Safety Review Date
April 10, 2012, since latest RMP submission
PHA Update Date
April 10, 2012, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Blast Walls
  • Enclosure
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Parameters
  • Process Controls
Training Type
  • Classrom
Competency Testing
  • None
Procedure Review Date
Jan. 14, 2014, since latest RMP submission
Training Review Date
April 18, 2014, since latest RMP submission
Maintenance Review Date
April 18, 2014, since latest RMP submission
Maintenance Inspection Date
Nov. 23, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Nov. 13, 2014
Management of Change Review Date
April 18, 2014
Pre-startup Review Date
Nov. 13, 2014
Compliance Audit Date
May 1, 2013
Compliance Audit Change Completion Date
May 1, 2015
Incident Investigation Date
Sept. 14, 2012
Incident Invest. Change Completion Date
Sept. 30, 2012
Participation Plan Review Date
Jan. 18, 2014
Hot Work Review Date
Jan. 18, 2014
Contractor Safety Review Date
April 18, 2014, since latest RMP submission
Contractor Safety Eval. Date
Nov. 1, 2014, since latest RMP submission
Polyethylene HP, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000049755
Safety Review Date
May 26, 2012, since latest RMP submission
PHA Update Date
May 26, 2012, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Quench System
  • Purge System
Mitigation Systems
  • Blast Walls
  • Enclosure
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • None
Procedure Review Date
Jan. 14, 2014, since latest RMP submission
Training Review Date
April 18, 2014, since latest RMP submission
Maintenance Review Date
April 18, 2014, since latest RMP submission
Maintenance Inspection Date
Oct. 15, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Sept. 19, 2014
Management of Change Review Date
April 18, 2014
Pre-startup Review Date
Sept. 19, 2014
Compliance Audit Date
May 1, 2013
Compliance Audit Change Completion Date
Dec. 31, 2015
Incident Investigation Date
Sept. 16, 2012
Incident Invest. Change Completion Date
Oct. 31, 2012
Participation Plan Review Date
April 18, 2014
Hot Work Review Date
April 18, 2014
Contractor Safety Review Date
April 18, 2014, since latest RMP submission
Contractor Safety Eval. Date
Nov. 1, 2014, since latest RMP submission
Polyethylene HP, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000049756
Safety Review Date
April 19, 2013, since latest RMP submission
PHA Update Date
April 19, 2013, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Contamination
  • Equipment failure
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Power
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Blast Walls
  • Enclosure
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • None
Procedure Review Date
April 18, 2014, since latest RMP submission
Training Review Date
April 18, 2014, since latest RMP submission
Maintenance Review Date
April 18, 2014, since latest RMP submission
Maintenance Inspection Date
Sept. 22, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Oct. 13, 2014
Management of Change Review Date
April 18, 2014
Pre-startup Review Date
Oct. 13, 2014
Compliance Audit Date
May 1, 2013
Compliance Audit Change Completion Date
Dec. 31, 2015
Incident Investigation Date
Jan. 17, 2014
Incident Invest. Change Completion Date
Feb. 28, 2014
Participation Plan Review Date
April 18, 2014
Hot Work Review Date
April 18, 2014
Contractor Safety Review Date
April 18, 2014, since latest RMP submission
Contractor Safety Eval. Date
Nov. 1, 2014, 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:
Aug. 1, 2014
Local Response Agency:
Local Response Agency Phone:
(337) 721-3800
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

LAD 981 522 048 LDEQ Facility ID Number



Westlake Polymers, Sulphur, LA

Risk Management Plan

Executive Summary



This summary to the RMP plan provides the following information:

A. Accidental release prevention and emergency response policies

B. Description of the stationary source and regulated substances

C. General accident release prevention program and chemical-specific prevention steps (Management Systems for Process Safety/Risk Management)

D. Planned changes



ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES



The Westlake Polymers in Sulphur LA has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained personnel will respond to, control and contain the release.



A. DESCRIPTION OF THE FACILITY



The Westlake Polymers site is located in an industrial complex in Sulphur Louisiana. It operates 5 low-density polyethylene units using minor variants of one process. The polyethylene product is sold to other companies who make a wide variety of finished products, from plastic film and bags, to the clear plastic shaker-caps on hot sauce bottles. The first units were built in 1965 and the last major change, a restart of an existing unit, occurred in 1993.



B. MANAGEMENT SYSTEMS FOR PROCESS SAFETY/RISK MANAGEMENT



B.1. SCOPE



The following is a summary of the general accident prevention programs in place at the Westlake Chemical Corporation. Because the processes at the site that are covered by the EPA RMP regulation are 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 prev
ention program. Westlake believes the requirements of the two regulations are so similar, or so complimentary, that only one management system is required to comply with all of them. And because our site is an OSHA Star worksite, (denoting the highest safety designation a plant can receive from OSHA), our programs are frequently reviewed by OSHA to ensure continuous improvements.



B.2. EMPLOYEE PARTICIPATION



Westlake encourages employees to 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 have access to all information created as part of the site accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that is maintained at the site and addresses each program element. In addition, the site has onsite committees dedicated to safety that include members from various areas of the plant, including operations, maintenance, engineering and plant management.



B.3. PROCESS SAFETY INFORMATION



The Westlake sites keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents are available to all personnel onsite in paper form or through our computerized document management system. 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 plant are assigned responsibility for maintaining up-to-date process safety information. A list of reference documents and their location is readily available as part of the written employee participation plan to help employees locate any necessary process safety information.



Chemical-spe
cific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDS) that are available to employees through the computerized document management system and in the central MSDS file. This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with inadvertent mixing of chemicals. The plant ensures that the process is maintained within safe limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g. automated shutdown systems).



The site also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, electrical rating of equipment, etc. This information, in combination with written procedures and trained personnel, provides a basis for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised.



B.4. PROCESS HAZARD ANALYSIS



Westlake has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.



The site primarily uses the hazard and operability (HAZOP) analysis technique along with checklists to perform these evaluations. The combination of HAZOP and checklist analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The analyses are conducted using a team of people who have operating, maintenance and engineering expertise as well as knowledge of the analysis technique being used. This team identifies and evaluates hazards of the process as well as accident prevention and mitigat
ion measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary.



The PHA team findings are forwarded to local management for resolution. Implementation of mitigation options in response to PHA findings is based on relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options being implemented in response to PHA findings are tracked until they are completed. The final resolution of each finding is documented and retained.



To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the site periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every five years and will be conducted at this frequency until the process is no longer operating. Once again, the team findings are forwarded to management for consideration, and the findings along with the final resolution is documented and retained.



B.5. OPERATING PROCEDURES



The site maintains written procedures that address various modes of process operations, such as unit startup, normal operations, temporary operations, normal shutdown, and emergency shutdown. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. These procedures provide guidance on how to respond to upper or lower limit exceedences for specific process or equipment parameters. All this information is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks. These procedures are regularly reviewed and certified as current and accurate. The procedures are maintained current and accurate by revising them as necessary to reflect changes made thr
ough management of change and ISO (quality) processes.



B.6. TRAINING



To complement the written procedures for process operations, the site has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in plant operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate (through tests and skills demonstrations) that they have adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every three years. All of this training is documented for each operator, including the means used to verify that the operator understood the training.



B.7. CONTRACTORS



Westlake uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the site has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform site personnel of any hazards that they find during their work. This is accomplished by providing contractors with a process overview, information about safety and health hazards, emergency response plan requirements, and safe work practices prior to their beginning work. In addition, the site evaluates contractor safety and performance during the selection of a contractor. Site personnel periodically monitor contractor performance to ensure that co
ntractors are fulfilling their safety obligations.



B.8. PRE-STARTUP SAFETY REVIEW (PSSRs)



The site conducts PSSRs for new facilities or facility modifications that require a change in the process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel and the 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 as a quality assurance function by requiring verification that accident prevention program requirements are properly implemented.



B.9. MECHANICAL INTEGRITY



Westlake has well-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 the 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 (if possible) or a team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment.



Another integral part of the mechanical integrity program is quality assurance. The site incorporates quality assurance measures into equipment purchases and repairs. This action helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made.



The Mechanical Integrity (MI) program is the responsibility of the Maintenance and Reliability Managers. Details are contained in the Mechanical Integrity Program procedures developed by Maintenance and Reliability.



The following items are covered by the MI procedures:

-Periodic inspection of all pressure vessels and tanks

-Periodic inspection of process piping

-Periodic inspection and testing of all Relief Devices including ?safety? relief valves, rupture disks, and ?emergency? tank vent hatches. This program also includes the flame and detonation arrestors onsite.

-Periodic testing of critical rotating equipment

-Periodic testing of safety critical systems such as emergency shutdowns and controls



Westlake Engineering Department conducts Quality Assurance reviews on new construction projects per their project procedures.



B.10. SAFE WORK PRACTICES



Westlake has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include (1) control of entry/presence/exit of support personnel in the units, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment und