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Westlake Petrochemical LP

Parent Companies:
Weslake Chemical Corporation
EPA Facility ID:
100000146834
Other ID:
LAD985184761
Facility DUNS:
616815254
Parent Company DUNS:
608366308

Location:

Address:
900 Highway 108
Sulphur, LA 70664
County:
CALCASIEU
Lat / Long:
30.183, -93.347 (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 70664 -2449
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:
210
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
0520-00145-V5
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Nov. 17, 2008
Inspecting Agency:
State occupational safety agency
Using Predictive Filing:
No

Processes:

Ethylene Producer Petro 1
RMP ID:
1000061957
CBI claimed:
No
Program Level:
3
NAICS:
Plastics Material and Resin Manufacturing (325211)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ethylene [Ethene]
74-85-1
560,000
No
Ethane
74-84-0
220,000
No
Methane
74-82-8
14,000
No
Propylene [1-Propene]
115-07-1
400,000
No
1,3-Butadiene
106-99-0
14,000
No
Chlorine
7782-50-5
4,000
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
Ethylene Producer Petro 2
RMP ID:
1000061958
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ethane
74-84-0
360,000
No
Ethylene [Ethene]
74-85-1
950,000
No
Propylene [1-Propene]
115-07-1
670,000
No
Methane
74-82-8
47,000
No
1,3-Butadiene
106-99-0
24,000
No
Propane
74-98-6
52,000
No
Chlorine
7782-50-5
4,000
No
Ammonia (anhydrous)
7664-41-7
20,500
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
Polyethylene Manufacturer
RMP ID:
1000061959
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
1-Butene
106-98-9
14,000
No
Pentane
109-66-0
320,000
No
Ethylene [Ethene]
74-85-1
24,000
No
Chlorine
7782-50-5
3,600
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Styrene Manufacturer
RMP ID:
1000061960
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Chlorine
7782-50-5
4,000
No
Ethylene [Ethene]
74-85-1
20,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Co-Products Storage
RMP ID:
1000061961
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Bulk Stations and Terminals (42471)
Chemical name
CAS#
Quantity (lbs.)
CBI
1-Butene
106-98-9
500,000
No
1,3-Butadiene
106-99-0
4,200,000
No
Propylene [1-Propene]
115-07-1
7,600,000
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 70664
Foreign Address:

Phone:
(337) 583-6428

Latest RMP Submission:

Date:
March 30, 2015
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000049404

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 Manufacturer)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas liquified by pressure
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 Ethylene Producer Petro 2)
CBI claimed:
No
Percent weight:
99.9
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 Polyethylene Manufacturer)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's OCA Guidance Reference Tables or Equations
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:
  • Deluge systems
not considered:
  • Sprinkler 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 Co-Products Storage)
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 Ethylene Producer Petro 1)
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
  • Water curtain
  • Excess flow valve

6. Five-year accident history

July 3, 2014 at 19:15
ID:
1000038141
NAICS:
Petrochemical Manufacturing (32511)
Duration:
48 hours and 12 minutes
Chemicals involved:
  • Ethylene [Ethene]
Release events:
Gas release
Weather conditions at time of event
Wind speed:
17.0 miles/h NW
Temperature:
80.00 ℉
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:
0
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$250000
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Equipment failure
Off-site responders notified:
Notified Only
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • New process controls
Oct. 3, 2009 at 09:10
ID:
1000038137
NAICS:
Petrochemical Manufacturing (32511)
Duration:
1 hours
Chemicals involved:
  • Ethane
Release events:
Fire
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:
$242000
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Equipment failure
Off-site responders notified:
No, not notified
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Revised maintenance
  • Revised operating procedures
Feb. 21, 2008 at 03:45
ID:
1000038138
NAICS:
Petrochemical Manufacturing (32511)
Duration:
25 minutes
Chemicals involved:
  • Ethylene [Ethene]
Release events:
Fire
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:
$240000
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Equipment failure
Off-site responders notified:
No, not notified
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Revised maintenance
  • Revised operating procedures

7. Prevention: Program level 3

Ethylene Producer Petro 1, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000051481
Safety Review Date
Feb. 28, 2013, since latest RMP submission
PHA Update Date
Feb. 28, 2013, since latest RMP submission
PHA Techniques
  • What if
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Contamination
  • Equipment failure
  • Cooling loss
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Inhibitor Addition
  • Rupture Disks
Mitigation Systems
  • Dikes
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • Process Parameters
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
April 15, 2014, since latest RMP submission
Training Review Date
April 15, 2014, since latest RMP submission
Maintenance Review Date
April 15, 2014, since latest RMP submission
Maintenance Inspection Date
Feb. 15, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Feb. 24, 2015
Management of Change Review Date
Feb. 15, 2015
Pre-startup Review Date
Feb. 15, 2015
Compliance Audit Date
March 15, 2013
Compliance Audit Change Completion Date
March 31, 2014
Incident Investigation Date
March 1, 2009
Incident Invest. Change Completion Date
April 15, 2009
Participation Plan Review Date
April 15, 2014
Hot Work Review Date
April 15, 2014
Contractor Safety Review Date
April 15, 2014, since latest RMP submission
Contractor Safety Eval. Date
Dec. 15, 2014, since latest RMP submission
Ethylene Producer Petro 2, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000051495
Safety Review Date
Feb. 28, 2013, since latest RMP submission
PHA Update Date
Feb. 28, 2013, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Contamination
  • Equipment failure
  • Cooling loss
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Scrubbers
  • Flares
  • Interlocks
  • Rupture Disks
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • Increased Inventory
  • Process Parameters
  • Process Detection
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
April 15, 2014, since latest RMP submission
Training Review Date
April 15, 2014, since latest RMP submission
Maintenance Review Date
April 15, 2014, since latest RMP submission
Maintenance Inspection Date
Jan. 15, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Feb. 15, 2015
Management of Change Review Date
April 15, 2014
Pre-startup Review Date
Feb. 15, 2015
Compliance Audit Date
March 15, 2013
Compliance Audit Change Completion Date
March 15, 2014
Incident Investigation Date
July 6, 2014
Incident Invest. Change Completion Date
Dec. 31, 2014
Participation Plan Review Date
April 15, 2014
Hot Work Review Date
April 15, 2014
Contractor Safety Review Date
April 15, 2014, since latest RMP submission
Contractor Safety Eval. Date
Dec. 15, 2014, since latest RMP submission
Polyethylene Manufacturer, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000051493
Safety Review Date
Feb. 28, 2013, since latest RMP submission
PHA Update Date
Feb. 28, 2013, since latest RMP submission
PHA Techniques
  • What if
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Equipment failure
  • Cooling loss
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Inhibitor Addition
  • Rupture Disks
Mitigation Systems
  • Dikes
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
April 15, 2014, since latest RMP submission
Training Review Date
April 15, 2014, since latest RMP submission
Maintenance Review Date
April 15, 2014, since latest RMP submission
Maintenance Inspection Date
Feb. 15, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Feb. 15, 2015
Management of Change Review Date
April 15, 2014
Pre-startup Review Date
Feb. 15, 2015
Compliance Audit Date
March 15, 2013
Compliance Audit Change Completion Date
March 15, 2014
Incident Investigation Date
March 1, 2009
Incident Invest. Change Completion Date
April 15, 2009
Participation Plan Review Date
April 15, 2014
Hot Work Review Date
April 15, 2014
Contractor Safety Review Date
April 15, 2014, since latest RMP submission
Contractor Safety Eval. Date
Dec. 15, 2014, since latest RMP submission
Styrene Manufacturer, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000051494
Safety Review Date
Oct. 17, 2013, since latest RMP submission
PHA Update Date
Oct. 17, 2013, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Contamination
  • Equipment failure
  • Cooling loss
  • Hurricanes
Process Controls
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Grounding Equipment
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • Perimeter Monitors
Changes since PHA
  • Process Controls
  • Process Detection
  • Mitigation Systems
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Observation
Procedure Review Date
April 15, 2014, since latest RMP submission
Training Review Date
April 15, 2014, since latest RMP submission
Maintenance Review Date
April 15, 2014, since latest RMP submission
Maintenance Inspection Date
Feb. 15, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Feb. 21, 2015
Management of Change Review Date
April 15, 2014
Pre-startup Review Date
Feb. 21, 2015
Compliance Audit Date
March 15, 2013
Compliance Audit Change Completion Date
March 15, 2014
Incident Investigation Date
July 1, 2009
Incident Invest. Change Completion Date
July 15, 2009
Participation Plan Review Date
April 15, 2014
Hot Work Review Date
April 15, 2014
Contractor Safety Review Date
April 15, 2014, since latest RMP submission
Contractor Safety Eval. Date
Dec. 15, 2014, since latest RMP submission
Co-Products Storage, Petroleum Bulk Stations and Terminals (42471)
Prevention Program ID:
1000051485
Safety Review Date
June 11, 2014, since latest RMP submission
PHA Update Date
June 11, 2014, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Overfilling
  • Contamination
  • Equipment failure
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Backup Pump
  • Excess Flow Device
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
April 15, 2014, since latest RMP submission
Training Review Date
April 15, 2014, since latest RMP submission
Maintenance Review Date
April 15, 2014, since latest RMP submission
Maintenance Inspection Date
Jan. 15, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Feb. 1, 2015
Management of Change Review Date
April 15, 2014
Pre-startup Review Date
Feb. 1, 2015
Compliance Audit Date
March 15, 2013
Compliance Audit Change Completion Date
March 31, 2014
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
April 15, 2014
Hot Work Review Date
April 15, 2014
Contractor Safety Review Date
April 15, 2014, since latest RMP submission
Contractor Safety Eval. Date
Dec. 15, 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:
June 15, 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 985 184 761 LDEQ Facility ID Number
AI 6164
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 Petrochemical plant 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 Petrochemical site is located in an industrial complex in Sulphur Louisiana. It operates several individual operating units. All facilities are on a contiguous site.

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 prevention 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 r
eceive 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-specific 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 supplem
ented 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 mitigation 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 ris
k 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 through 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 succe
ssfully 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 contractors 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 ar
e 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 undergoing maintenance, (3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e. hot work) and (5) 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.

B.11. MANAGEMENT OF CHANGE

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

B.12. INCIDENT INVESTIGATION

The site promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire or explosion, a toxic gas release, major property damage, an environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent recurrence of the incident or similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to site management for resolution. Corrective actions taken in response to the investigation team?s findings and recommendations are tracked until they are complete. 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 for at least five years so that the reports can be reviewed during future PHAs and PHA revalidations.

B.13. COMPLIANCE AUDITS

To help ensure that the accident prevention program is functioning properly, a comprehensive audit is periodically conducted to determine whether the procedures and practices required by the accident prevention programs are being implemented properly. Compliance
audits are conducted at least every three years. The audit team develops findings that are forwarded to site management for resolution. Corrective actions taken in response to the audit team?s findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained.

B.14. CHEMICAL-SPECIFIC PREVENTION STEPS

The processes at Westlake have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all Program 3 RMP covered processes at the site. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failure or human errors.

In addition to the accident prevention program activities, the site has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (or mitigate) a release. The following types of safety features are used in various processes:

Release Detection
-Hydrocarbon detectors with alarms
-Sophisticated computer control systems

Release Containment/Control
-Process relief valves that discharge to a flare to capture and incinerate episodic releases
-Valves to permit isolation of the process (manual or automated)
-Automated shutdown systems for specific process parameters (e.g. high pressure, high temperature, high level)
-Curbing or diking around applicable tanks to contain liquid releases
-Redundant equipment and instrumentation (e.g. uninterruptible power supply for process control system, backup firewater pump, etc.)
-Flanges, gaskets, and fittings that meet or exceed design code requirements
-Appropriate corrosion allowances in piping and equipment
-Fail-safe positions for control valves on loss of power sources

Release Mitigation
-Fire suppression and extinguishing systems
-Deluge system for specific equipment
-Foam application systems for specific equip
ment to limit the vapors given off from spills
-Trained emergency response personnel
-Personal protective equipment (e.g. protective clothing, respirators, etc.)
-Blast-resistant buildings to help protect control systems and personnel so they can bring a process to a safe condition after an emergency

C. EMERGENCY RESPONSE PROGRAM INFORMATION

Westlake maintains a written emergency response program which is in place to protect worker 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 evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies, and post incident cleanup requirements. In addition, the site 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 updated when necessary based on modifications made to the processes or other facilities. Affected personnel are informed of changes and trained appropriately.

The overall emergency response program for the site is coordinated with the Southwest LA Mutual Aid Association. This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The site has around the clock communications capability with appropriate Mutual Aid officials and emergency response organizations (e.g. fire department). This capability provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In ad
dition to periodic Association meetings, the site conducts periodic emergency drills that may involve the Mutual Aid Association and emergency response organizations, and the site provides regular refresher training to our emergency responders regarding hazards of regulated substances at the site.

D. PLANNED CHANGES

As an OSHA Star site, Westlake Polymers is in a mode of continuous improvement. Changes are ongoing to ensure reliable control of the process. Sources of enhancements to the process include audits, PHAs, incident investigation, and safety suggestions from employees and contractors.