Oxy Vinyls, LP - LaPorte VCM Plant - Executive Summary
Oxy Vinyls' LaPorte VCM Plant manufactures vinyl chloride monomer (VCM) from chlorine and ethylene. Oxy Vinyls, LP is a joint venture between Occidental Chemical Corporation (a subsidiary of Occidental Petroleum Corporation) and The Geon Company. The facility is located near the Houston Ship Channel at 2400 Miller Cut-Off Road. It was originally constructed in 1973 and currently employs 180 full-time employees. |
1. Accidental Release Prevention and Emergency Response Policies at the Stationary Source (' 68.155(a)):
Oxy Vinyls is committed to operating the LaPorte VCM Plant in a manner that is safe for its workers, the public and the environment. It is our policy to adhere to all applicable Federal, State and local rules/regulations, industry standards and best practices. As part of this commitment, Oxy Vinyls has established a system to help ensure safe operation of the processes at this facility, which includes the prevention of accidental releases of hazardous substances. One
component of this system is a risk management program (RMP) that helps manage the risks at the LaPorte VCM Plant and complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR Part 68, Accidental Release Prevention Requirement: Risk Management Programs (the RMP rule), and OSHA 1910.119. This document is intended to satisfy the RMP requirement of the RMP rule and to provide the public with a description of the risk management program for the LaPorte VCM Plant.
The RMP at the LaPorte VCM Plant consists of the following three elements:
7 A hazard assessment to help understand (a) the potential off-site consequences of hypothetical accidental releases and (b) accidents that have occurred during the last five years associated with the use of substances regulated by the RMP rule;
7 A prevention program to help maintain and safely operate the covered processes containing, or with the potential of involving, more than a threshold quantity of a regulate
7 An emergency response program to respond to any accidental releases of regulated substances from covered processes.
Information further describing these elements is provided in this RMP plan.
Oxy Vinyls' policy on the use of hazardous substances: Before using a hazardous substance at the LaPorte VCM Plant, less hazardous alternatives are always considered. When a hazardous substance is used, the plant personnel review the potential for an accidental release of this substance (which could adversely affect plant workers, the public or the environment) and take steps to prevent any such effects. This is accomplished through the facility's Management of Change (MOC) and Process Hazard Analysis (PHA) procedures, which are followed for all new installations or modifications of existing processes.
Oxy Vinyls strives to prevent accidental releases of the hazardous substances used at the facility: Oxy Vinyls implements reasonable controls to prevent foreseeable releases of
hazardous substances. When a hazardous substance is used at the LaPorte VCM Plant, the equipment is carefully designed, installed, operated and maintained to reduce the likelihood of an accidental release. Industry and government standards are closely adhered to in the design, construction and operation of the equipment. Corporate Fire, Safety and Environmental (FS&E) Guidelines are also used when designing new or modifying existing processes. Each project is thoroughly reviewed before approval. In addition, Oxy Vinyls requires the documentation of standard operating procedures and training of affected employees with regard to these procedures as part of the MOC procedure. Oxy Vinyls' mechanical integrity program provides an ongoing process to verify the mechanical integrity of the equipment, piping and instruments to prevent the release of hazardous substances.
Oxy Vinyls' goal is to minimize impacts from an accidental release: In the event of an accidental release, the LaPorte
VCM Plant controls and contains the release in a manner that will be safe for workers and will prevent impact to the public and the environment. Oxy Vinyls utilizes emergency response plans as required by government regulation. Oxy Vinyls trains its workers to respond to an accidental release, reducing the consequences of a release if it occurs. Oxy Vinyls also has established a Special Situations Center in the Dallas corporate office and the Houston area to assist workers, their families and the public during and after all emergencies. In addition, the LaPorte VCM Plant actively works with CIMA (Channel Industries Mutual Aid), the LaPorte and Deer Park Local Emergency Planning Committees (LEPC's), and other local emergency service providers to help prevent and/or address public exposure or environmental damage in case a release does occur. The LaPorte VCM Plant, in conjunction with the East Harris County Manufacturers Association (EHCMA), has assisted the LaPorte LEPC in installat
ion of the city wide emergency broadcast system and developed/implemented a RMP public communications plan. The LaPorte VCM Plant promotes the use of the Community Awareness & Emergency Response (CAER) Phone Hotline to inform the citizens of any unusual plant event and actively works with the LaPorte Citizens' Advisory Panel.
The LaPorte VCM Plant's emergency response plan has been developed to meet the emergency planning, response and notification requirements of the Federal, OSHA, and EPA regulations, as well as Oxy Vinyls' guidelines. This plan outlines the responsibilities and actions required for control of an emergency within the boundaries of the LaPorte VCM Plant. If the emergency extends beyond or potentially extends beyond the plant boundaries, the Special Situations Plan is initiated and the response is coordinated with CIMA, the LaPorte LEPC, Oxy Vinyls Corporate, and other necessary groups.
Oxy Vinyls is an active participant in the community: Oxy Vinyls is an active
participant in employee and community programs, which promote education, safety and environmental awareness. The facility involves employees in designing, implementing and maintaining safety programs. Safety is a primary concern in the facility and is demonstrated by the selection of the plant in 1997 as an OSHA Star Site under OSHA's Voluntary Protection Program (VPP).
Oxy Vinyls is an industry leader in the implementation Responsible Care. (Chemical Manufacturer's Association) initiative. As part of the Responsible Care. efforts, the LaPorte VCM Plant assisted in formation of the LaPorte Citizen's Advisory Panel. The purpose of this group is to share information about plant operations with members of the community and to discuss their concerns. The group meets monthly and covers topics of interest, to the members, including plant safety and environmental performance, emergency response programs, health issues and process safety performance. Through this outreach effort, as wel
l as other community involvement, the plant stays informed of community concerns and works to address them.
A Plant Manager's Safety Council, with representation from all departments including the permanent contractor, meets at least monthly to promote dialog between employees and management, to oversee and promote plant safety, and participates in safety audits.
2. The Stationary Source and Regulated Substances Handled (' 68.155(b)):
The LaPorte VCM Plant handles five substances that are covered by the RMP rule, which are Vinyl Chloride (largest vessel inventory of 7,000,000 pounds), Hydrogen Chloride (largest vessel inventory of 450,000 pounds), Chlorine (largest vessel inventory of 180,000 pounds), Propylene (largest vessel inventory of 86,000 pounds) and Ammonia (largest vessel inventory of 15,540 pounds). The LaPorte vinyl chloride manufacturing process is considered a Program 3 process.
Ethylene, Chlorine and Hydrochloric Acid are the primary feedstocks for the LaPorte VCM P
lant. These materials are primarily delivered to the plant by pipeline. Ethylene and chlorine are reacted to form ethylene dichloride (EDC). The EDC is purified and fed to a cracking furnace where it is processed to form vinyl chloride monomer (VCM). A hydrochloric acid (HCl) by-product, along with supplemental HCl from outside sources, is reacted to form more EDC. The vinyl chloride monomer is then purified and stored in storage tanks prior to shipment by pipeline or railcar to other sites (Oxy Vinyls or others).
Propylene is used as a refrigerant similar to Freon to cool and condense gases and liquids in the purification process.
Anhydrous Ammonia is used as a nutritional feed supplement for the microorganisms that help purify the plant's waste water.
3. The Worst-Case Release Scenario(s) and the Alternate Release Scenario(s), Including Administrative Controls and Mitigation Measures to Limit the Distances for Each Reported Scenario (' 68.155(c)):
The LaPorte VCM Plant pe
rformed off-site consequence analysis to estimate the potential for the accidental release of a regulated substance that might effect the public or the environment. The RMP rule requires the off-site consequence analysis to evaluate a "worst-case release scenario " and an "alternative release scenario." In reality, however, Oxy Vinyls does not expect a worst-case release scenario to ever occur. The alternative release scenarios are developed to help the LEPC improve the community emergency response plan.
The EPA Look-Up Tables were used for evaluating the distance to the endpoint for the worst-case release scenarios and the alternate release scenarios. Various sources (Landview, USGS maps, and DeLorme Street Atlas USA) were used to estimate the number of people living within the endpoint distances, as well as the public and environmental receptors, of the scenarios.
The following information summarizes the off-site consequence analysis performed by the LaPorte VCM Plant:
oxic Substances -
Hydrogen Chloride - The "worst-case release scenario" for anhydrous hydrochloric acid (HCl) is the catastrophic failure of the HCl storage tank with no mitigation, which could release 450,000 pounds of HCl over a 10-minute period. The gas cloud could travel a distance of 25.0 miles before the concentration diminishes below the toxic endpoint of 0.30 mg/L. This could affect a 1,800,000 residential population. It could also affect public receptors and environmental receptors, including a state park and wildlife sanctuary.
An "alternate release scenario" involves a > inch hole in a pipeline (with emergency shutdown isolation), which could release 7,400 pounds of HCl. This could result in a toxic endpoint distance of 1.5 miles. No residential population would be affected. Public receptors include only area industrial facilities; and an environmental receptor could include a state park.
Chlorine - The "worst-case release scenario" for chlorine is not as great a
s for hydrogen chloride; therefore, a description of this scenario is not included in the plan. An "alternate release scenario" involves the failure of a chlorine unloading hose (with emergency shutdown isolation), which could release 10,560 pounds of Chlorine. This could result in a toxic endpoint distance of 0.4 miles (below 0.0087 mg/L concentration or 3 parts per million). No residential population would be affected. The only public receptors could be adjacent industrial facilities and no environmental receptors.
Ammonia - The "worst-case release scenario" for anhydrous ammonia is not as great as for hydrogen chloride; therefore, a description of this scenario is not included in the plan. An "alternate release scenario" involves the failure of a = inch ammonia line (with emergency shutdown isolation), which could release 9,400 pounds of ammonia. This could result in a toxic endpoint distance of 0.2 miles. No residential population would be affected. No public or environmen
tal receptors would be affected.
3.2 Flammable Substances
Vinyl Chloride - The "worst-case release scenario" for vinyl chloride is the catastrophic failure of a storage sphere with no mitigation, which could release 7,000,000 pounds of vinyl chloride in a 10-minute period. It is assumed that the vinyl chloride vaporizes within the 10-minute time period to form a vapor cloud. The worst case release scenario then assumes a vapor cloud explosion. The distance to a 1-psi (pound per square inch) overpressure could then be 1.15 miles. No residential population would be affected. Public receptors include only area industrial facilities; and an environmental receptor could include a state park.
An "alternate release scenario" involves a 2-inch pipeline rupture (with emergency shutdown isolation) over 20-minutes, which could release 62,840 pounds of vinyl chloride. This could result in an endpoint distance of 0.21 miles. No residential population would be affected. Public receptors in
clude only adjacent industrial facilities; and no environmental receptor would be affected.
Propylene - The "worst-case release scenario" for propylene is not as great as for vinyl chloride; therefore, a description of this scenario is not included in the plan. The "alternate release scenario" for propylene would not be as great as for vinyl chloride; therefore, a description of this scenario is not included in the plan.
4. The General Accidental Release Prevention Program and the Specific Prevention Steps (' 68.155(d)):
The LaPorte VCM Plant developed a prevention program to further prevent accidental releases of hazardous substances in accordance with the Codes and associated Management Practices of Responsible Care. in 1990. Beginning in 1992, the plant revised these prevention programs to comply with the 14 elements of the OSHA Process Safety Management (PSM) program. RMP's Program 3, applicable for flammable and toxic substances at this site, is basically the same as OSHA PS
M, except that the program also focuses on protecting the public and the environment outside the plant's boundaries. The following sections briefly describe the elements of the LaPorte VCM Plant's RMP Program 3 prevention plan that address EPA's RMP requirements.
4.1 Program 3 Prevention Program
The LaPorte VCM Plant's Program 3 prevention program consists of the following 12 elements:
4.1.1 Process Safety Information
The LaPorte VCM Plant maintains technical documents, which are used to help ensure safe operation of the plant processes. These documents address (1) physical properties of hazardous substances handled at the plant, (2) operating parameters of the equipment used at the plant and (3) design basis and configuration of the equipment at the plant. Oxy Vinyls ensures that this process safety information is up-to-date and available to all employees.
Material Safety Data Sheets (MSDS's) document the physical properties of the hazardous materials handled at the plant, inclu
ding regulated substances in covered processes. The information available for each hazardous substance typically includes:
7 Toxicity information and permissible exposure limits;
7 Physical data (e.g., boiling point, melting point, flash point);
7 Reactivity and corrosivity data;
7 Thermal and chemical stability data;
7 Hazards of mixing substances in the process.
MSDS's are available from the plant's Safety Department and Industrial Hygienist. Copies of the MSDS's are also maintained in the process area control rooms, maintenance areas, and other key areas so that the employees have ready reference to this information. Key MSDS's are provided to CIMA and the LEPC for use in emergency response plans and, as needed, to any other responders.
Information pertaining to the technology of the process is included in the "LaPorte VCM Plant Process Overview" documents in the Operating Manuals. This available information includes:
7 Technology of the VCM Process with general operating par
7 Block flow diagram and simplified process flow diagram;
7 Process chemistry;
7 Maximum intended inventories;
7 General safe upper and lower limits for parameters such as temperature, pressure, or flow.
Additional process safety information identified and kept up to date includes:
7 Design basis and configuration of equipment;
7 Piping and instrumentation diagrams, including materials of construction;
7 Electrical classification;
7 Safety systems;
7 Applicable design codes and standards;
7 Design basis for relief and ventilation systems;
7 Ventilation system design;
7 Material and energy balances.
These documents are used to (1) train employees, (2) perform process hazards analyses and (3) help maintain the equipment.
4.1.2 Process Hazard Analysis
The LaPorte VCM Plant performs process hazard analyses (PHA's) of the covered processes to help identify process hazards and generate recommendations that might improve the safe operation of the process. All RMP covered processe
s were initially reviewed using the HAZOP methodology by April of 1997; and all covered processes are re-validated at least every five years using the HAZOP and/or What If methodology.
A PHA team is typically composed of a leader with applicable PHA training and experience, a scribe, area representative (knowledgeable supervisor), area engineer, area operating technician, engineering representative, maintenance representative, and other representatives (as applicable). A PHA report is written describing the results of the analysis. Findings and recommendations are risk ranked; addressment is tracked through the plant's "Action Items" tracking system.
4.1.3 Operating Procedures
The LaPorte VCM Plant has a "Procedure for Procedures" in place. Procedure Specialist, who are experienced operational technicians trained in writing procedures, develop / modify the procedures. They then go through a technical review by process engineering; then, a review by other operational technicians;
a review by safety and environmental professionals; and finally, a field review / verification. Procedures address the following:
7 Steps for safe operations during all phases of operations, including initial startup, normal operations, applicable temporary operations, emergency shutdown procedures for identified scenarios, emergency operations, normal shutdown, and normal startup after turnarounds and emergency shutdowns;
7 Safe upper and lower operating limits with consequence of deviation and actions to correct or avoid deviations, and critical equipment information;
7 Safety and health considerations identifying the hazards of the process chemicals, preventative controls, personal protective equipment requirements, exposure measures, and chemical quality / controls;
7 Critical safety systems descriptions and functions.
Operating procedures are readily available in the operating areas; and they are maintained and reviewed annually and as part of related changes during the Manageme
nt Of Change procedure. Safe work practices and procedures (Lock, Tag & Try; Line Breaking; Confined Space Entry; Hot Work Permit) are in place throughout the plant to ensure the control of hazards during all activities by employees and contractors.
The LaPorte VCM Plant trains its workers to safely, and effectively, perform their assigned tasks. The training program includes both initial and refresher training that covers (1) a general overview of the process, (2) the properties and hazards of the substances in the process and (3) a detailed review of the process operating procedures and safe work practices for applicable personnel. Oral reviews and written tests are used to verify that an employee understands the training material before the employee can start work in the process. Employees involved in operating the process prior to May 26, 1992 were evaluated and certified in writing as having the required knowledge, skills, and abilities to safely carry out the du
ties and responsibilities as specified in the operating procedures. Operating personnel attend monthly refresher training meetings and receive necessary training on all changes, per the Management Of Change procedure, prior to their exposure to the change.
The operators are consulted regularly regarding effectiveness and frequency of the training during reviews and refresher training. Recommendations from the operators are reviewed and changes to the training program are implemented as appropriate. Training is documented using the "TRIM" software package; and training files are maintained by the Training Department.
4.1.5 Mechanical Integrity
The LaPorte VCM Plant maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger workers, the public or the environment. The mechanical integrity program includes (1) an inspection and testing program to help identify equipment deterioration before the equipment fails and (2) a quality assur
ance program to help ensure that new and replacement equipment meets the design standards required for service in the plant's processes. The mechanical integrity program includes identification of applicable equipment, which could significantly and adversely affect the safety, health and environmental integrity of the process; maintenance procedures for specific critical work; training regarding specific job tasks and process overview/hazards; inspection and testing program, by a third party and per good engineering practices, to ensure system reliability; and maintained inspection and testing documentation with deficiency reporting and correction.
The Management Of Change procedure addresses mechanical integrity issues for any change to the process, equipment, or other process safety information.
4.1.6 Management of Change
The LaPorte VCM Plant's Management Of Change (MOC) procedure sets requirements for reviews and approvals of all proposed changes to chemicals, equipment and proc
edures for a covered process to help ensure that the change does not negatively affect safe operations. The MOC procedure ensures that the affected employees are notified of the changes, training is provided, and that process safety information and procedures are updated. Plant personnel receive training on how to identify potential changes and the types of changes that are covered by the procedure.
4.1.7 Pre-startup Review
The LaPorte VCM Plant performs a Pre-Startup Safety Review (PSSR) as part of the MOC procedure for any process change before the process is placed into service. This PSSR ensures that:
7 Process safety information is updated;
7 A PHA is completed to insure the safety, health & environmental integrity of the process;
7 Adequate safety, operating, maintenance and emergency procedures are in place;
7 Affected employees are trained prior to introduction to the change;
7 Human factors reviewed during a process walk-through;
7 Construction and equipment are in accorda
nce with design specifications during a process walk-through;
7 Critical PHA and PSSR items are addressed prior to startup.
Startup can not begin until the MOC and PSSR are completed, a walk-through inspection is completed, and the area manager has approved startup. An MOC and PSSR are completed for all new processes, major modifications and/or start up of existing processes that have been shut down for extended periods.
4.1.8 Compliance Audit
The LaPorte VCM Plant audits covered processes every year to be certain that the prevention programs are effectively addressing the safety issues of the process. Every year, the corporate office performs a detailed audit. In 1997, OSHA performed an audit for the Voluntary Protection Program (VPP) and the OSHA Star recognition. The plant and corporate use detailed protocols (regulatory and best practices) to audit all safety aspects, including process safety management practices. It ensures that the plant has programs in place to meet the re
quirements and verifies employee participation/knowledge. Responsibilities for recommendations are assigned and tracked through completion.
4.1.9 Incident Investigation
The LaPorte VCM Plant has an "Incident Reporting and Investigation Procedure" in place. Employees are trained to identify and to report any incident which resulted in, or could have resulted in, any on-site or offsite injury / impact. The supervisor is responsible for ensuring that an initial investigation is completed no later than the end of the shift and for submitting copies of the Incident Report Form to the Safety Department, Area Superintendent and area Department Manager.
For any incident involving the potential or actual catastrophic release of a highly hazardous chemical, a formal incident review is performed with the supervisor and employees involved. Recommendations or corrective actions are documented, along with all of the required data; responsibilities are assigned; and addressment is tracked in the
"Action Items" tracking system. Information on all incidents is shared with all employees. More serious incidents are reviewed with affected employees during special sessions when applicable.
Oxy Vinyls has a formal program including training for incident investigations and the report generation. The Safety Department retains incident investigation reports for the last five years.
4.1.10 Employee Participation
The LaPorte VCM Plant has a written employee participation program to help ensure that the safety concerns of the plant's workers are addressed. The program is detailed in the Employee Participation section of the Process Safety Management manual. A system is in place where any employee (Oxy Vinyls or contractor) can submit anonymous questions, comments, or suggestions for any aspect of the Process Safety Management and Risk Management Program. The plant encourages active participation of personnel in the prevention program activities of all processes at the plant. Emp
loyees are involved in development and / or revision of all Safety procedures, operating procedures, and maintenance procedures. They participate in, and are informed about, all aspects of the Process Safety Management and RMP rule prevention program, including PHA's, MOC's and other aspects. A Plant Manager's Safety Council, with representation from all departments (including contractors), meets monthly to discuss Safety and develop Safety awareness programs.
4.1.11 Hot Work Permits
The LaPorte VCM Plant has a Hot Work Permit Procedure in place to control spark or flame-producing activities that could result in fires or explosions in all process areas of the plant. Personnel who must perform hot work are required to fill out the Hot Work Permit and get operational approval prior to start of work. The permit is dated and issued for a specified time. It also identifies the type of hot work, safety equipment required, nature and location of the work, and requires area monitoring.
Hot Work Permit Procedure training is included in the plant's safe work practices orientation and refresher training.
The LaPorte VCM Plant has an established program to help ensure that contractor activities at the plant are performed in a safe manner. The program reviews the safety record of all contractors to help ensure that the plant only uses contractors who can safely perform the desired job tasks. The plant ensures contractors observe all safe work practices and are aware of the hazards of the process and the plant's emergency response procedures.
5. Five-year Accident History (' 68.155(e)):
There have been two incidents, during the last five years, at the LaPorte VCM Plant, which met the EPA Risk Management Program reporting requirements:
7 1/9/97 - Minor release of 6 pounds of chlorine from a ruptured pipe elbow caused minor inhalation injury (recordable) to an employee; however, there were no offsite consequences;
7 1/6/96 - Rupture disk
from vent header knockout pot blew, releasing 86 pounds of HCl, causing minor inhalation injury (recordable) to a contractor; however, there were no offsite consequences.
6. The emergency response program (' 68.155(f)).
The LaPorte VCM Plant has established a written emergency response plan and maintains an emergency response team trained in emergency response procedures. The written emergency response plan complies with the following federal and state contingency plan regulations:
7 OSHA 29 CFR 1910.38(a) - Employee Emergency Action Plans;
7 OSHA 29 CFR 1910.119 (n) - Process Safety Management of Highly Hazardous Chemicals;
7 OSHA 29 CFR 1910.120(p) and (q) - Hazardous Waste Operations and Emergency Response (HAZWOPER);
7 OSHA 29 CFR 1910, Subpart L - Fire Protection;
7 EPA 40 CFR 302.6 - Notification Requirements;
7 EPA 40 CFR 355.30 - Facility Coordinator and Emergency Response Plan;
7 EPA 40 CFR 355.40 - Emergency Planning and Release Notifications;
7 EPA 40 CFR 112 - Spill Pre
vention, Control and Countermeasures Plan;
7 EPA 40 CFR 68 - Risk Management Programs for Chemical Accidental Release Prevention.
The LaPorte VCM Plant is a member and actively participates in the Channel Industries Mutual Aid (CIMA) organization. CIMA is an organization of Houston Channel industries established to coordinate and assist member companies with industry emergencies.
The LaPorte VCM Plant uses a computerized modeling system to assess release impact and to aid in the determination of response activities. The LaPorte VCM Plant actively works with the LaPorte Local Emergency Planning Committee (LEPC) and supports the LaPorte Emergency Warning System and the CARE telephone hotline.
In addition, the LaPorte VCM Plant has developed a Special Situations Plan which is a
program designed for responding to emergencies that may have impacts beyond the boundaries of the plant and is a supplement to the Emergency Response Plan. The Special Situation Plan links the local response to the Corporate Emergency Response Center (in Dallas, Texas), which can provide additional assistance.
The facility is a member of the East Harris Chemical Manufacturers Association (EHCMA). EHCMA is an organization of more than 120 chemical manufacturers, refineries and related facilities in the Houston Ship Channel/Galveston Bay area. This group and its seven outreach areas, including the LaPorte Outreach Area, communicate regularly with the local citizen's advisory panels or councils regarding community/industry issues. The LaPorte VCM Plant, as part of the EHCMA organization, has actively presented information concerning the RMP program and specific plant information, including the worst-case release and alternate release scenarios, to the community. Additionally, the L
aPorte VCM Plant actively participates and communicates with the City of LaPorte; the LaPorte LEPC and the neighboring Deer Park LEPC; the LaPorte Independent School District through Partners in Education; and other local organizations.
7. Planned Changes to Improve Safety (' 68.155(g)).
The LaPorte VCM Plant constantly tries to improve the safety of the processes through reviews of our plant procedures, near misses and incident investigation programs, and programs soliciting safety and environmental suggestions from the plant employees.
8. Certification (' 68.185).
To the best of the undersigned's knowledge, information, and belief formed after reasonable inquiry, the information submitted is true, accurate, and complete.
Signed by Chris Burrell *, Plant Manager, on June 17, 1999.
* The Certification with original signature is included with this RMP submittal.