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WESTLAKE CHEMICAL CORPORATION

LAKE CHARLES DOCUMENT: 4301-06-335

SAFETY & HEALTH REVISION DATE: 1/17/2018

DOCUMENT NAME: EXCAVATION & TRENCHING PAGE: 1 of 11

1 Purpose

1.1 To establish minimum guidelines for excavation, drilling and trenching on

Westlake Corporation, Lake Charles property. The focus of this procedure is to

maximize employee safety, assure environmental stewardship and preserve

Westlake property. See DOT PIPELINE Procedure 2035-DP-1702 for lines

outside of the Plant.

2 Scope

2.1 This procedure applies to Westlake employees and Contractors involved in

excavation, drilling and trenching at the Westlake, Lake Charles Facility. The

Competent Person must issue an Excavation Permit (see Exhibit 1) before work is

initiated.

Note: This procedure only covers excavations that are 15 feet deep or less. For

excavations deeper than 15 feet, or any drilling operations, contact the

Environmental Department for approval.

Note: All excavations in the following areas must be pre-approved by the

Environmental Department (See Attachment A - Excavation and

Trenching Map (Areas of Concern) – Westlake Drawing # 43A-20015.1):

Barge Slip Isolated Canal

Sabine River Water Pond Coon Island Loop

WESTLAKE Canal Bayou Verdine

Membrane Derivatives South Terminal

North Dock

Electrical Transformers in Plant A

Note: In some of the above referenced areas, WESTLAKE HSWA Permit

prohibits leaving excavated deep soil (3-15’ below grade) at the surface (0-3’).

Note: The HSWA Permit requires that industrial water supply wells installed at the

facility in the 500-Foot Sand of the Chicot Aquifer within the Technical

Impracticability (TI) Zone to have properly sealed boreholes (WESTLAKE,

2007.01). Therefore, the design and installation of any water supply wells within

the TI Zone at the Lake Charles facility requires the review and approval by

appropriate Westlake personnel (Environmental Department) and the Louisiana

Department of Environmental Quality (LDEQ). The HSWA Permit also prohibits

the installation of potable water supply wells at the Lake Charles facility in the

70/80-Foot Water-Bearing Unit (WBU) or the 200-Foot Sand of the Chicot

Aquifer within the TI Zone.





3 Responsibilities

3.1 Only Westlake designated personnel who have been trained as a Competent

Person will be authorized to initiate and oversee excavation work conducted on

Westlake Lake Charles property. They will operate in an administrative function

unless Westlake personnel are required to enter the excavation. They will be the

Competent Person for Westlake personnel only. Contractors must furnish their

own Competent Person for all excavations where their employees enter an

excavation.

3.2 Contractors are required to provide a trained Competent Person for excavations. If

multiple companies are required to enter the excavation, each company will

furnish a Competent Person to monitor their respective personnel.

4 Procedure

4.1 Area Owner Representative

4.1.1 If requested by the Competent Person, Unit Supervision will provide

information necessary to identify all underground utilities and piping

located in the proximity of the excavation.

4.1.2 After all known utilities and piping are identified, the unit supervisor, or

their designee, may give authorization for the excavation work. This is

contingent upon any other unit activities that may interfere with the safety

of the personnel in the excavation.

4.2 Competent Person

4.2.1 Determine prior to issuing the excavation permit the location of all

underground lines in the area. Solicit the assistance of the Unit Supervisor

as necessary.

4.2.2 For excavations outside the plant perimeter, or inside the plant perimeter

where another company’s pipeline crosses near the area, a notification to

LA One Call, formerly known as DOTTIE (811 or 1-800-272-3020) must

be made 48 hours prior to digging. Emergency situations do not require

the 48-hour wait but LA One Call must be notified. Note: “Near” is

defined by Westlake to be within 100 feet.-.- (See Attachment B – LA

One Call Map – Non-Westlake Pipelines Within Plant - WESTLAKE

Drawing # 32A-20181.1)

4.2.3 Ensure that when approaching the estimated location of underground piping

or utilities the exact location of the installation shall be determined by safe

and acceptable means.





4.2.4 Ensure that employees are notified of all underground piping and utilities

and appropriate safeguards are taken.

4.2.5 Determine the appropriate type of protective system to be used (Shoring,

Shielding or Sloping system) for the excavation.

4.2.6 Inspect the area prior to the start of the work and as needed throughout the

shift. Inspections shall include the adjacent areas, and integrity of

protective systems.

4.2.7 Prior to allowing re-entry into the excavation, the job site must be re-

inspected following a rainstorm or a plant evacuation.

4.2.8 Analyze a soil sample of the excavated material to determine its future use

or disposal method. (See Environmental Waste - Procedure For Soil

Management 35-WST-PRO-001)

4.2.9 Determine if the area to be excavated is in one of the following area: South

Terminal, Derivatives, North Dock area, Membrane, Sabine River Water

Pond, Barge Slip, Coon Island Loop, Bayou Verdine, Plant A transformer

areas, Isolated Canal, or WESTLAKE Canal. If so, contact the

environmental department prior to excavating for special instructions, and

follow the provisions of Section 5.9.

4.2.10 Ensure that the atmosphere is tested for Lower Explosive Limits (LEL),

oxygen deficiencies (less than 19.5%), and where a hazardous atmosphere

exists or could reasonably be expected to exist before employees enter.

4.2.11 Determine the level of personal protective equipment (PPE), required for

the job.

4.2.12 Determine if the excavation is a Confined Space. If so, assure that all

requirements are met in accordance with the Safety Procedure #8,

Confined Space Entry.

5 General

5.1 All surface encumbrances that create a hazard to employees shall be removed or

supported, as necessary. All exposed utilities or piping (as a result of the

excavation work) must be braced and supported.

5.2 A stairway, ladder, ramp or other safe means of egress shall be located in trench

excavations that are 4 feet or more in depth and placed no farther than 50 feet

apart to limit - lateral travel to 25 feet or less. A sloped personnel entry ramp or

stairway should be used where it is practical to install. This eliminates the need to

use a ladder for entry or exit provided it is within the 25 ft. lateral travel distance.





5.3 No employee shall be permitted underneath or adjacent to load handling or

digging equipment.

5.4 Employees shall not work in excavations where there is accumulated water, or in

excavations where water is accumulating, unless adequate precautions have been

taken to protect the employee against hazards posed by water accumulation.

5.5 Excavated materials or other materials or equipment will be placed no closer than

2 feet from the edge of excavation.

5.6 All excavations will have barricades, guard rails, hand rails, warning lights, etc, as

needed for protection of personnel, vehicles or equipment working or passing

adjacent to the excavation site. See Safety Procedure #22, Plant Barricades 4301-

06-343.

5.7 If heavy equipment is to be operated near the edge of the excavation site, the sides

of the excavation will be braced to prevent collapse.

5.8 Employees entering bell-bottom pier holes, or other similar deep and confined

footing excavation, shall wear a harness with a lifeline securely attached to it. The

lifeline shall be individually attached while in the excavation and separate from

any line used to handle material.

5.8.1 Excavated soil will be tested and handled in accordance with the

Procedure For Soil Management 35-WST-PRO-001.

5.9 If an excavation is in a designated area of potential contamination Addtional

requirements include:

5.9.1 Air monitoring to identify hazards within the excavation and spoils pile.

5.9.2 Wearing personal protective equipment selected based on air monitoring

and knowledge of potential contaminants,

5.9.3 Training - Contractor (40 hour HAZWOPER trained), Westlake - training

in ppe, respiratory protection and Hazcom.)

5.9.4 Decontamination methods

5.10 A bucket watch will be used when digging around utilities or other obstructions

and safe line identification techniques used in identifying lines.





6 Shoring

6.1 All soils in the plant will be classified as Class C soils unless the Westlake

Competent Person can demonstrate a higher classification of soil by using both

visual and manual means.

6.2 Any excavation requiring shoring materials will use a manufactured trench

shoring system or a system that has been engineered, tested and certified to meet

OSHA requirements and is rated for the full depth of the trench. Engineered

system data must be kept by the supervisor of the job.

6.3 Shoring systems will be installed in accordance with manufacturers’ guidelines.

6.4 Only qualified personnel will be allowed to construct shoring systems.

6.5 Shoring system will be hydraulic and constructed of a high tensile strength

aluminum or equivalent materials to withhold the side loads.

6.6 If a manufactured, approved, “Shoring system” is not used, the configuration of

the slope will meet the requirements for class C soil unless a higher soil

classification is determined by the Westlake Competent Person.

7 Definitions

7.1 Aluminum Hydraulic Shoring means a pre-engineered shoring system

comprised of aluminum hydraulic cylinders (crossbraces) used in conjunction

with vertical rails (uprights) or horizontal rails (walers). Such system is designed,

specifically to support the sidewalls of an excavation and prevent cave-ins.

7.2 Bell-bottom pier hole means a type of shaft or footing excavation, the bottom of

which is made larger than the cross section above to form a belled shape.

7.3 Benching (Benching system) means a method of protecting employees from

cave-ins by excavating the sides of an excavation to form one or a series of

horizontal levels or steps, usually with vertical or near-vertical surfaces between

levels.

7.4 Cave-in means the separation of a mass of soil or rock material from the side of

an excavation, or the loss of soil from under a trench shield, shoring or other

support system, and its sudden movement into the excavation, either by falling or

sliding, in sufficient quantity so that it could entrap, bury, or otherwise injure and

immobilize a person.





7.5 Competent Person means one who is capable of identifying existing and

predictable hazards in the surroundings, or working conditions which are

unsanitary, hazardous, or dangerous to employees, and who has authorization to

take prompt corrective measures to eliminate them. Must present valid Competent

Person Training Certificate.

7.6 Cross braces mean the horizontal members of a shoring system installed

perpendicular to the sides of the excavation, the ends of which bear against either

uprights or wales.

7.7 Excavation means any man-made cut, cavity, trench, or depression in an earth

surface, formed by earth removal.

7.8 Faces or sides means the vertical or inclined earth surfaces formed as a result of

excavation work.

7.9 Failure means the breakage, displacement, or permanent deformation of a

structural member or connection so as to reduce its structural integrity and its

supportive capabilities.

7.10 Hazardous atmosphere means an atmosphere which by reason of being

explosive, flammable, poisonous, corrosive, oxidizing, irritating, oxygen

deficient, toxic, or otherwise harmful, may cause death, illness, or injury.

7.11 Kickout means the accidental release or failure of a cross brace.

7.12 Protective system means a method of protecting employees from cave-ins, from

material that could fall or roll from an excavation face or into an excavation, or

from the collapse of adjacent structures. Protective systems include support

systems, sloping and benching systems, shield systems, and other systems that

provide the necessary protection.

7.13 Ramp means an inclined walking or working surface that is used to gain access to

one point from another, and is constructed from earth or from structural materials

such as steel or wood.

7.14 Sheeting means the members of a shoring system that retain the earth in position

and in turn are supported by other members of the shoring system.

7.15 Shield (Shield system) means a structure that is able to withstand the forces

imposed on it by a cave-in and thereby protect employees within the structure.

Shields can be permanent structures or can be designed to be portable and moved

along as work progresses. Additionally, shields can be either premanufactured or

job-built in accordance with §1926.652 (c)(3) or (c)(4). Shields used in trenches

are usually referred to as "trench boxes" or "trench shields."





7.16 Shoring (Shoring system) means a structure such as a metal, hydraulic,

mechanical or timber shoring system that supports the sides of an excavation and

which is designed to prevent cave-ins.

7.17 Sides. See "Faces."

7.18 Sloping (Sloping system) means a method of protecting employees from cave-ins

by excavating to form sides of an excavation that are inclined away from the

excavation so as to prevent cave-ins. The angle of incline required to prevent a

cave-in varies with differences in such factors as the soil type, environmental

conditions of exposure, and application of surcharge loads.

7.19 Structural ramp means a ramp built of steel or wood, usually used for vehicle

access. Ramps made of soil or rock are not considered structural ramps.

7.20 Support system means a structure such as underpinning, bracing, or shoring,

which provides support to an adjacent structure, underground installation, or the

sides of an excavation.

7.21 Trench (Trench excavation) means a narrow excavation (in relation to its

length) made below the surface of the ground. In general, the depth is greater than

the width, but the width of a trench (measured at the bottom) is not greater than

15 feet (4.6m). If forms or other structures are installed or constructed in an

excavation so as to reduce the dimension measured from the forms or structure to

the side of the excavation to 15 feet (4.6m) or less (measured at the bottom of the

excavation), the excavation is also considered to be a trench.

7.22 Trench box. See "Shield."

7.23 Trench shield. See "Shield."

7.24 Uprights means the vertical members of a trench shoring system placed in

contact with the earth and usually positioned so that individual members do not

contact each other. Uprights placed so that individual members are closely

spaced, in contact with or interconnected to each other, are often called

"sheeting."

7.25 Wales means horizontal members of a shoring system placed parallel to the

excavation face whose sides bear against the vertical members of the shoring

system or earth.





8 References

29 CFR 1910.120 – Hazardous Waste Operations and Emergency Response

29 CFR 1926 650 Subpart P – Excavations

49 CFR Part 192, 193, 195

9 Attachments

Exhibit 1- WESTLAKE Excavation Permit

Attachment A - Excavation and Trenching Map - Areas of Concern – 43A-20015.1

Attachment B - LA One Call Map – Non-Westlake Pipelines Within Plant – 32A-20181.1





DATE: LOCATION:

PURPOSE OF EXCAVATION:

Axiall DRAWING AVAILABLE YES NO N/A Circle one.

If yes, include drawing number

ANY OTHER Axiall UNDERGROUND LINES/ UTILITIES IN THE AREA

If yes, list lines and approximate depth YES NO N/A Circle one.

WAS LA ONE CALL NOTIFIED 48 HRS. IN ADVANCE? (Section 4.2.2) YES N/A Circle one.

See - LA One Call Map - Non-Axiall Pipelines Within Plant - 32A-20181.1)

In-Plant lines that belong to others within 100 ft.? YES NO N/A Circle one.

SHORING OR SLOPING AS REQUIRED BY PROCEDURE? YES NO N/A Circle one.

(Describe construction or system or specify slope grade)

IS AREA TO BE EXCAVATED IN A DESIGNATED AREA OF POTENTIAL CONTAMINATION?

See- Excavation and Trenching Map - 43A-20012.1 YES NO Circle one

If yes, meet with environmental department and complete the following:

1. What are the potential contaminates and PEL?

2. What instrument will be used to monitor concentration and is calibration current?

TYPE: Current Calibration: YES / NO

TYPE: Current Calibration: YES / NO

3. What type of PPE is appropriate for the contaminant and concentration by task?

4. What are the decontamination methods and location?

ADDITIONAL COMMENTS:

RECEIVED BY CONTRACTING SUPERVISOR

AXIALL, Lake Charles Excavation Permit

LINE/DEPTH LINE/DEPTH

APPROVAL BY COMPETANT PERSONS

AXIALL CONTRACTOR





Attachment A - Excavation and Trenching Map - Areas of Concern – 43A-20015.1





Attachment B – LA One Call Map – Non-WESTLAKE Pipelines within Plant – 32A-20181.1

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