Occidental Chemical Corporation Ingleside Plant - Executive Summary

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Occidental Chemical Corporation (OxyChem), a wholly owned subsidiary of Occidental Petroleum Corporation (OPC), is a leading producer of electrochemicals, proprietary products, plastics, and resins.  Occidental Chemical Corporation's Ingleside Plant is an integral part of the OxyChem committment to the industrial chemicals market.  The Ingleside Plant, located on Highway 361 near Corpus Christi, Texas, produces important commodity chemicals such as chlorine, caustic soda, ethylene dichloride (EDC), and vinyl chloride monomer (VCM).  The VCM Plant  is a joint venture between OxyMar and OxyVinyls entities. The OxyMar portion of the VCM Plant is a joint venture between Occidental Chemical and Japan's Marubeni Corporation.  The OxyVinyls portion is a joint venture between Occidental Chemical and Geon Corporation. The Ingleside Plant  is strategically located on 1,071 acres along the Texas Coastal Bend with excellent dock. pipeline, and rail facilities.  The facility emplo 
ys 256 OxyChem and 150 permanent contract employees. 
The Ingleside Chlor-Alkali plant began operating in 1977 as a DuPont facility.  OxyChem acquired the facility in 1987 and refurbished it to restart production in 1988.  In 1989, a $40 million EDC plant was added to the facility.  A $300 million OxyMar VCM plant was started up in 1990 and expanded ($150 million) in 1997.   In July 1998, the Chlorine Plant was expanded at a cost of $50 million.   Currently, a $150 million Co-Generation power plant is under construction onsite and scheduled to be operational in 1999.  The CoGeneration plant is a joint venture with Conoco Global Power, Inc. 
1.  Accidental Release Prevention and Emergency Response Policies at the Stationary Source  (' 68.155(a)): 
OxyChem is committed to operating the Ingleside 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 and regulations, industry standards and b 
est practices.  As part of this commitment, OxyChem 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 Ingleside 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 requirements of OSHA 1910.119.  This document is intended to satisfy the RMP plan requirement of the RMP rule and to provide the public with a description of the risk management program at the Ingleside Plant. 
The RMP at the Ingleside Plant consists of the following three elements: 
7 A hazard assessment program to help understand (a) the potential off-site consequences of hypothetical accidental releases and (b) accidents that have occurred during the last five ye 
ars associated with the use of substances regulated by the RMP rule (regulated substances) 
7 A prevention program to help maintain and safely operate the processes containing more than a threshold quantity of a 
regulated substance (covered processes) 
7 An emergency response program to help respond to accidental releases of regulated substances from covered processes 
Information further describing these elements is provided in this RMP Plan. 
Although the risk management program at the Ingleside Plant helps provide assurance that the facility is maintained and operated in a safe manner, it is only one component of the safety and environmental program at the Ingleside Plant.  In fact, the Ingleside Plant has a comprehensive safety and environmental program in place, establishing many levels of safeguards against releases of hazardous substances as well as injuries and damage from such releases. 
OxyChem's policy on the use of hazardous substances:  Before using a hazardous substance at the 
Ingleside Plant, less hazardous alternatives are always considered.  When a hazardous substance is used at the Ingleside Plant, OxyChem reviews the potential for an accidental release of this substance which could adversely affect plant workers, the public and the environment, and takes steps to prevent any such effects.  This is accomplished through the facility's Management of Change (MOC), also referred to as the Technical/Engineering Assistance Request (TEAR) program, and Process Hazard Review (PHR) procedures which are followed for all new installations or modifications of existing processes. 
OxyChem strives to prevent accidental releases of the hazardous substances used at the facility:  OxyChem implements reasonable controls to prevent foreseeable releases of hazardous substances. When a hazardous substance is used or produced at the Ingleside Plant, the equipment is carefully designed, installed, operated and maintained to reduce the likelihood of an accidental release.  Indus 
try and government standards are closely adhered to in the design, construction and operation of the equipment. 
OxyChem also uses the Corporate Fire, Safety and Environmental (FS&E) Guidelines when designing new or modifying existing processes.  Each project is thoroughly reviewed before approval. In addition, OxyChem requires the documentation of standard operating procedures and training of affected employees with regard to these procedures as part of the MOC procedure. OxyChem's 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. 
OxyChem's goal is to minimize impacts from an accidental release.  In the event of an accidental release, the Ingleside 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.  OxyChem utilizes emergency response plans as required by government re 
gulation.  The Ingleside Plant maintains an active 16 member HAZMAT Team on each shift to respond to on-site events.  These first reponders are trained to respond to emergencies such as chemical releases, fires, explosions, etc.  The HAZMAT Team is also backed up by the Refinery Terminal Fire Company (RTFC) located in Corpus Christi.  The facility also maintains an active Chemical Emergency Response Team (CERT) which is on call 24 hours a day to 
respond to an off-site chemical emergencies.  Both of these teams are trained and equipped to respond to chemical emergencies involving Ingleside's products, raw materials, and intermediates.  OxyChem also has established a Special Situations Center in the Dallas corporate office to assistant in all emergencies. In addition, OxyChem works with the local fire department and with the local emergency planning committee (LEPC) of San Patricio County to help prevent injuries and/or environmental damage if an event does occur. 
Ingleside Plant's emerg 
ency response plan has been developed to meet the emergency planning, response and notification requirements of the Federal, OSHA, and EPA regulations. 
This plan outlines the responsibilities and actions required to control an emergency that limits itself to within the Ingleside Plant.  If the emergency extends beyond the plant boundaries and affects the surrounding communities, the Emergency Management Plan is initiated by a call to 911 and a statement of the type of emergency.  A Special Situations Plan (SSP) has also been developed to assist the surrounding communities in the event a major chemical emergency from the Ingleside Plant would affect them. 
OxyChem is an active participant in the community:  OxyChem is an active participant in plant and community programs which promote education, safety, and environmental awareness.  The facility has implemented a Voluntary Protection Program (VPP) in which employee participation at all levels is required in designing, implementing and ma 
intaining safety programs.  Safety is a primary concern in our facility and is demonstrated by our selection by OSHA in September 1991 as a STAR facility in the Voluntary Protection Program (VPP).  The Ingleside Plant STAR has been recertified twice with the most recent being granted in August 1998. 
OxyChem is an industry leader in the implementation of the Chemical Manufacturer's Association sponsored Responsible Care(r) Initiative. As part of OxyChem's Responsible Care(r) efforts, the Ingleside Plant has voluntarily been involved in a Community Advisory Panel (CAP) since 1991. 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 periodically 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 well as other community involvement, the  
plant stays abreast of community concerns and works to address them. 
In order to effectively implement these policies, OxyChem has established a management system headed by the respective Safety and Environmental Departments to oversee safety and environmental related activities. 
2.  The Stationary Source and Regulated Substances Handled (' 68.155(b) ): 
The Ingleside Plant handles nine regulated substance that are covered by the RMP rule, as shown in the following list of RMP-covered Program Level 3 processes at the plant. 
These nine regulated substances are handled as either products, intermediates, or raw materials. 
Regulated Substance     Process               Largest 
Vessel Quantity*, lb.     RMP Threshold, lb.* 
Chlorine                         Cl2 Processing/Storage 655,000                        2,500 
Vinyl Chloride                 VCM Storage 
12,500,000                       10,000 
Ammonia (anhydrous)   WWT and NOx Reduction 
40,000                       10,000 
            VCM Refrigeration 
90,000                       10,000 
Ethylene                          EDC/VCM Production 
14,000                       10,000 
Hydrogen Chloride          By-Product of Incineration 
42,000                         5,000 
Chloroform                      By-Product of VCM 
267,000                       20,000 
Ethyl Chloride                  By-Product of VCM 
10,000                       10,000 
*    - Process and threshold quantity is the quantity of "pure" 
chemical, not of the solution 
Chlorine is one of the major products manufactured and handled at this facility.  Chlorine is produced in an electrolytic process using brine to produce chlorine, sodium hydroxide, and hydrogen.  Liquid chlorine is also brought into the facility via railcar.  The liquid chlorine is used to produce Ethylene Dicloride (EDC) and ultimately Vinyl Chloride Monomer (VCM).  Based upon information gathered from the Material Safety Data Sheet (MSDS), the specific haza 
rds of chlorine are a severe irritant to the eyes, skin, lungs, and respiratory tract, potentially explosive when reacted with organic products, and can cause chemical pneumonia and even death in high concentrations. 
Vinyl Chloride Monomer (VCM) is also a major product manufactured at the Ingleside facility.  VCM is produced in the OxyMar facility by cracking EDC in high temperature furnaces.  The product VCM is stored in storage tanks for eventual transfer to ships or railcars.  Based upon information gathered from the Material  Safety Data Sheets (MSDS), the specific hazards of VCM are an irritant to the eyes, skin, and respiratory tract, an extremely flammable gas under pressure, and a known human carcinogen. 
Anhydrous Ammonia is used as a processing aid in the facility.  It is used to reduce nitrogen oxide (NOx) formation in EDC Cracking Furnaces and Boilers and is also used as a nutrient for microbes in wastewater treatment. Based upon information gathered from the Material Safety 
Data Sheets (MSDS), the specific hazards of ammonia are an irritant to the eyes, skin, and respiratory tract and can cause fire and explosion when reacted with strong oxidizers. 
Ethylene is used in the facility as a raw material for the production of Ethylene Dichloride (EDC).  The ethylene is transported into the facility via pipeline and is used in both the Chlor/Alkali EDC process and the OxyMar Direct Chlorination and Oxyhydrochlorination processes.  Based upon information gathered from the Material Safety Data Sheets (MSDS), the specific hazards of ethylene are an extremely 
flammable chemical and also a simple asphyxiant. 
Propylene is used in the facility as a refrigerant in the VCM process.  Propylene is transported into the facility in tanktrucks and is stored in a dedicated 30,000 gallon tank. Based upon information gathered from the Material Safety Data Sheets (MSDS), the specific hazards of propylene include being a narcotic and asphyxiant in high concentrations and may cau 
se burns similar to frosbite. 
Hydrogen Chloride (HCl) is generated in the facility as a byproduct in the high temperature cracking of EDC to VCM and also in the incineration process of chlorinated compounds. Based upon information gathered from the Material Safety 
Data Sheets (MSDS), the specific hazards of hydrogen chloride include skin inflammation and burns from direct contact with hydrogen chloride.  Fumes or gases, evolved from hydrochloric acid, may also cause irritation of the respiratory tract with burning, choking, and coughing. 
Chloroform is generated in the facility as a by-product in the generation process of Vinyl Chloride Monomer (VCM). Chloroform, or Trichloromethane, is a colorless volatile liquid with a pleasant odor and a slightly sweet taste. Based upon information gathered from the Material Safety Data Sheets (MSDS), the specific hazards of chloroform include damage of the central nervous system, liver, and kidneys based on either inhalation or ingestion.  Breathin 
g high levels of chloroform may also cause dizziness, headaches, or irregular heart beat. 
Chloroethane is generated in the facility as a by-product in the generation process of Ethylene Dichloride (EDC). Chloroethane, or Ethyl Chloride, is a clear colorless volatile liquid.  Based upon information gathered from the Material Safety Data Sheets (MSDS), the specific hazards of chloroethane include headache, nausea, gastrointestinal disturbances, and blindness. 
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 Ingleside Plant performed off-site consequence analysis to estimate the potential for an accidental release of a regulated substance to would affect 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 realit 
y, however, OxyChem does not expect a worst-case release scenario to ever occur.  The alternative release scenarios are more realistic scenarios and were developed to help the LEPC improve the community emergency response plan. 
There were two methods that were used to calculate distances to the toxic endpoints.  The EPA's Off-site Consequence Analysis Guidance Reference Tables or Equations as well as the SAFER Trace 8.0 modeling program were utilized to calculate toxic endpoints for the worst case scenario for chlorine and the alternative release scenarios for chlorine, ammonia, hydrochloric acid, and chloroform.  The meteorological data used for the modeling was the EPA default for the worst case and EPA suggested values for the 
alternative release scenarios. The EPA recommended Landview III program was utilized to estimate the number of people living within the toxic endpoint distances of each scenario. USGS maps were utilized to identify the public and environmental receptors locate 
d within this distance. 
The following information summarizes the off-site consequence analyses performed by the Ingleside Plant: 
3.1 Toxic Substances - Chlorine, Ammonia, Hydrogen Chloride (HCl), and Chloroform 
The "worst-case release scenario" for chlorine is the failure of one of the largest chlorine storage tanks which would release 655,000 pounds of liquid chlorine in a 10minute period as mandated by EPA.  It is assumed that the liquid chlorine vaporizes within the 10-minute time period. The worst case release scenario was evaluated using EPA's Off-site Consequence Analysis Guidance Reference Tables/Equations.  Under the EPA default worst weather conditions, the chlorine gas cloud would travel a distance greater than 25 miles before the concentration of chlorine was reduced to below 3 ppm (which is the 'endpoint' Emergency Response Planning Guideline value established in the RMP rule). The Landview III Environmental Mapping Software indicates that 234,000 people live within this di 
stance from the chlorine tank.  Several public receptors as well as environmental receptors are also located within this distance. 
The "alternative release scenario" for chlorine is the failure of a 1-inch unloading hose connected from a liquid chlorine tank car to the chlorine unloading header releasing 921 lbs of chlorine in a 30 second period.  The SAFER Trace 8.0 software was used for this alternative release scenario to determine the off-site consequences.  Assuming a wind speed of 3 meters/sec, a D stability class, and rural topography, the chlorine cloud would travel 3.2 miles before reaching a chlorine concentration of below 3 ppm (which is the endpoint Emergency Response Planning Guideline value established in the RMP rule). The Landview III software indicates that 1100 people live within this distance from the car unloading spot.  Several public receptors as well as environmental receptors are also located within this distance. 
The "alternative release scenario" for ammonia i 
s a high pressure gas release caused by a 3/4 inch severed pipe at the ammonia storage tank located at Boiler #5.  This high pressure gas release lasts for 5 minutes before the Emergency Response Team (ERT) can isolate the leak.  A water fog system is also used to mitigate the ammonia release. 
The event releases a total of 384 pounds of ammonia.  The EPA's Off-site Consequence Analysis Reference Tables/Equations was used to determine the off-site consequences of this scenario.  Using Table 10 to determine a neutrally buoyant plume distance to a toxic endpoint, it is assumed that the wind speed is 3 meters/sec, the stability class is D, and the topography is rural.  Using these assumptions, the buoyant ammonia cloud would travel 0.31 miles before reaching an ammonia concentration of 200 ppm (which is the endpoint Emergency Response Planning Guideline value established in the RMP rule).  The Landview III software indicates that 6 people live within this distance from the ammonia tank.  S 
everal public receptors as well as environmental receptors are also located within this 
The "alternative release scenario" for hydrogen chloride (HCl) is a gasket leak on the discharge of the HCl column reflux pump at the VCM Plant.  This liquid HCl release lasts for 20 minutes before operations and the Emergency Response Team can isolate the leak.  The liquid HCl vaporizes and 4,860 pounds is released to the atmosphere.  The EPA's Offsite Consequence Analysis Reference Tables/Equations was used to determine the off-site consequences of this scenario.  Using Table 14 to determine a dense gas distance to a toxic endpoint, it is assumed that that the wind speed is 3 meters/sec, the stability class is D, and the topography is rural.  Using these assumptions, the dense HCl cloud would travel 1.1 miles before reaching a HCl concentration of 20 ppm (which is the endpoint Emergency Response Planning Guideline value established in the RMP rule).  The Landview III software indicates t 
hat 75 people live within this distance form the HCl column reflux pump. Several public receptors as well as environmental receptors are also located within this distance. 
The "alternative release scenario" for chloroform (trichloromethane) is an overpressurization of the light ends distillation column in the VCM Plant.  The pressure relief valve lifts resulting in a release of chloroform of 1,814 pounds over a two minute period.  The EPA's Off-site Consequence Analysis Reference Tables/Equations was used to determine off-site consequences of this scenario.  Using Table 14 to determine a dense gas distance to a toxic endpoint, it is assumed that the wind speed is 3 meters/sec, the stability class is D, and the topography is rural. 
Using these assumptions, the dense chloroform cloud would travel 0.56 miles before reaching a chloroform concentration of 100 ppm (which is the endpoint Emergency Response Guideline value established in the RMP rule).  The Landview III software indicates that 
20 people live within this distance from the VCM light ends distillation column. Several public receptors as well as environmental receptors are also located within this distance. 
3.2 Program 3 Processes-Flammable Substances (Gases and Volatile Liquids) 
There are five (5) regulated flammable substances in quantities above the threshold quantities at the plant.  The five regulated flammable substances are: vinyl chloride monomer (VCM), methane, ethylene, propylene, and chloroethane (ethyl chloride). 
The "worst case scenario" for vinyl chloride monomer (VCM) involves a VCM storage sphere that contains 12,500,000 pounds of VCM.  The entire quantity of the tank is released and the VCM vapor cloud detonates.  The worst case scenario for this flammable substance was evaluated using Appendix C in EPA's Off-site Consequence Analysis Guidance Reference Tables/Equations.   Under the EPA's equation for determining distance to a 1 psi overpressurization for a vapor cloud explosion, the entire vap 
or cloud was assumed to be within the flammability limits and the cloud was assumed to explode.   For worst case purposes, the  10% yield factor was used which means that 10% of the flammable vapor in the cloud was assumed to participate in the explosion.  Using the criteria listed above and data provided in Tables in Appendix C, Equation C.1 yielded a 1 psi overpressurization 
that extended 1.4 miles from the source.  The Landview III Environmental Mapping software indicates that 1,100 people live within this distance from the VCM storage sphere. Several public receptors as well as environmental receptors are also located within this distance. 
The "alternative release scenario" for vinyl chloride monomer (VCM) is a hose failure at the VCM ship dock due to hydrostatic pressure in the line.  This scenario releases 1,300 pounds of liquid VCM which then vaporizes and explodes.  Appendix C in EPA's Off-site Consequence Analysis Guidance Reference Tables/Equations was again used to determine 
the distance to a 1 psi overpressurization for a vapor cloud explosion.  As was used in the worst case scenario, the vapor cloud was  assumed to be within the flammability limits, the cloud was assumed to explode, and the 10% yield factor was used.  Equation C.1 in Appendix C yielded a 1 psi overpressurization that extended 347 feet from the VCM ship loading dock.  The Landview III Environmental Mapping software indicates that 5 people live within this distance from the VCM ship dock.  At 347 feet from the dock, marine traffic in the La Quinta Channel could also be affected. 
4.  The General Accidental Release Prevention Program and the Specific Prevention Steps (' 68.155(d) ): 
Since 1987, the Ingleside Plant has used a prevention program to help prevent accidental releases of hazardous substances.  Upon purchase of the Chlor/Alkali facility from DuPont in 1987, the Process Change Request (PCR) program was initiated as a management of change program.  Beginning in 1991, the plant revis 
ed this prevention program to comply with the 14 elements of the OSHA Process Safety Management (PSM) prevention program.  In 1996, the EPA RMP rule established two levels of prevention requirements: 
Program 3 is essentially the same as OSHA PSM, except that the program also focuses on protecting the public and the environment outside the plant's fenceline; 
The following sections briefly describe the elements of the Ingleside Plant's Program 3 prevention program that address EPA's RMP rule prevention program requirements.  Each of the sections listed below are documented and maintained in two documents at the plant: 1) The Plant Safety and Health Procedues Manual and 2) The OxyChem Process Reliability Guidelines Manual.  Each of these manuals is updated routinely so that each procedure is readily available for all plant employees. 
4.1 Program 3 Prevention Program 
The Ingleside Plant's Program 3 prevention program consists of the following elements: 
4.1.1  Process Safety Information 
Ingleside 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.  OxyChem ensures that this process safety information is available to 
all employees. 
Material safety data sheets (MSDSs) document the physical properties of the hazardous materials handled at the plant, including 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 
MSDSs for hazardous substances handled in each process are available from the plant's Envi 
ronmental  Department and are also available at the VCM Plant control room.  In addition, key MSDSs are provided to the LEPC for use in helping formulate emergency response plans. 
The engineering design documents include the operating parameters and the design basis and configuration of the equipment in each covered process.  The available information includes: 
7 Operating parameters 
7 Process flow diagrams 
7 Process chemistry 
7 Maximum intended inventories 
7 Safe upper and lower limits for parameters such as temperature, pressure, or flow 
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 
Operating manuals contain the process objectives, process chemistry, overview of the process operations, critical process variables with consequences of deviations, equipment and instruments descrip 
tions, troubleshooting guidelines, start-up and shut down procedures and equipment operating procedures. 
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 Ingleside Plant performs and updates, within every 5 years as required by OSHA, process hazard analyses (PHAs) of the covered process to help identify process hazards and generate recommendations that might improve the safe operation of the process.  A team composed of personnel with engineering and process operating experience and a leader with process hazard analysis experience is assembled to analyze the hazards of the process.  The plant primarily uses the "HAZOP" technique to perform this analysis.  The PHA team prepares a written report describing the results of the analysis, including a list of recommendations. Responsibility to resolve the recommendations is assigned to unit personnel and, when appropriate, changes to en 
hance the 
safety of the process are implemented. 
4.1.3 Operating Procedures 
The Ingleside Plant process engineers, operators (subject matter experts), and supervisors work together to develop and maintain operating procedures to define how tasks related to process operations should be safely performed. The operating procedures (1) are used to train employees and (2) serve as reference guides for appropriate actions to take during both normal operations and process upsets. Operating procedures include: 
7 Steps for safely conducting activities 
7 Applicable process safety information, such as safe operating limits and consequences of process 
7 Safety and health considerations, such as chemical hazards, personal protective equipment requirements and actions to take if exposure to a hazardous substance occurs 
Plant personnel develop and maintain operating procedures that cover all phases of operations, including initial startup, normal operations, normal shutdown, emergency shutd 
own, startup following a turnaround or emergency shutdown and temporary operations.  The operating procedures are used both to help in operating the plant's processes and as a training guide. 
4.1.4 Training 
The Ingleside 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.  Oral reviews and written tests are used to verify that an employee understands the training material before the employee can resume work in the process. The operators are consulted annually at safety meetings to evaluate the effectiveness and frequency of the training. Recommendations from the operators are reviewed and changes to the training program are implemented as appropriate. Training documentation is tracked by the T 
raining Coordinator using a Training Records Information Management (TRIM) system.  The TRIM system is capable of producing several reports including exception reports that the coordinator can use to re-schedule employees who missed scheduled training sessions. 
4.1.5 Mechanical Integrity 
The Ingleside 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 in-plant inspection and testing program to help identify equipment deterioration before the equipment fails and (2) a quality assurance 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: 
* Specifications for inspection and testing of process equipment 
* Specifications for replacement parts and equipment 
* Procedures for inspecting, testing and maintaining process 
* Listing of Ingleside's highly hazardous chemicals 
* Training of maintenance personnel 
* Documentation of maintenance activities 
* Quality Assurance activities 
4.1.6 Management of Change (Technical/Engineering Assistance Request (TEAR) program) 
The Ingleside Plant management of change (TEAR) program evaluates and approves all proposed changes to chemicals, equipment and procedures for a covered process to help ensure that the change does not negatively affect safe operations.  Process changes that are determined to be a replacement in kind (e.g., replacing a valve with an identical valve) are allowed without completing a full management of change program. All other changes must be confirmed through the full management of change program to help ensure that inadvertent consequences of process changes are prevented, safety consequences of changes are addressed, affected process safety information and procedures are updated, and affected employees are notified of the changes. 

.1.7 Pre-startup Review 
The Ingleside Plant performs a safety review through our TEAR procedures of a new or modified process before the process is placed into service to help ensure that the process has been prepared to operate safely.  This review confirms that: 
7 Construction and equipment are in accordance with design specifications 
7 Adequate safety, environmental, operating, maintenance and emergency procedures are in place 
7 Employee training has been completed 
7 For a covered process, a PHA has been performed if the process is new or management of change requirements have been completed if an existing process has been modified 
The TEAR pre-start up safety review check list will be completed during the MOC walk through for new processes, major modifications, and/or start up of existing processes that have been shut down for more than 6 months. 
4.1.8 Compliance Audit 
The Ingleside Plant audits covered processes every 3 years to be certain that the prevention program is effectivel 
y addressing the safety issues of operations at the plant. 
The plant assembles an audit team that includes personnel knowledgeable in the RMP rule and in the process, and this team evaluates whether the prevention program satisfies the requirements of the RMP rule and whether the prevention program is sufficient to help ensure safe operation of the process.  The results of the audit are documented, recommendations are resolved and appropriate enhancements to the prevention program are implemented. 
Both Occidental Petroleum Corporation and Occidental Chemical Corporation perform audits of the facility programs, processes, and documentation at regular intervals. The facility is required to address all action items within 6 months of notification. 
4.1.9 Incident Investigation 
The Ingleside Plant investigates incidents, including near misses, that could reasonably have resulted in a serious injury to personnel, serious injury to the public, or a 
catastrophic release of a regulated substanc 
e so that similar incidents can be prevented in the future.  The plant trains employees to identify and report any incident requiring investigation.  An investigation team is assembled, and the investigation is initiated within 48 hours of the incident.  The results of the investigation are documented, recommendations are resolved, and appropriate process enhancements are implemented.  Recommendations and preventative actions are then tracked to final closure by the Safety and Environmental departments. 
4.1.10 Employee Participation 
The Ingleside Plant developed a written employee participation program for all covered processes to help ensure that the safety concerns of the plant's workers are addressed.  The plant encourages active participation of personnel in the prevention program activities of all processes at the plant.  Employees are consulted on, and informed about, all aspects of the RMP rule prevention program, including PHAs, TEARs, and operating procedures. The Safety Envir 
onmental Awareness Team (SEAT) is also an important aspect of the employee participation program.  The SEAT is comprised of a cross section of employees throughout the plant including permanent contractors.  All groups in the plant are represented including management, operations, maintenance, technical, environmental, safety, etc.  The SEAT has 27 members and is co-chaired by an Operations Technician and the plant's Safety Manager.  All safety or environmental concerns are open for discussion by the SEAT committee.  All changes dealing with safety programs and procedures are also reviewed by SEAT. 
There are several other safety and environmental programs which are also maintained by employee participation.  These programs include job observations, housekeeping inspections, safety meetings, process hazard reviews, incident investigations, hazard communication, and emergency response teams. 
4.1.11 Hot Work Permits 
The Ingleside Plant established a hot work permit program to control spar 
k or flame- producing activities that could result in fires or explosions in covered processes at the plant.  The plant reviewed OSHA's fire prevention and protection requirements in 29 CFR 1910.252(a) and created a Hot Work Permit  to comply with these requirements.  The trained operator in the area where the hot work will take place is responsible for filling out the Hot Work Permit and informing the the hot work crew of the hazards of the job. 
4.1.12 Contractors 
The Ingleside Plant established a 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 hires contractors who can safely perform the desired job tasks. The plant explains to the contract supervisors the hazards of the process on which they and their employees will work, the plant's safe work practices, and the plant's emergency response procedures.  The plant requires that the contractor super 
visors train each of their employees who will work at the plant before that worker begins work at the plant site. The plant periodically reviews contractors' training documents and conducts audits of the contractor's work performance to help ensure that safe practices are followed. 
5   Five-year Accident History (' 68.155(e) ): 
A  180-pound chlorine release occurred on March 1, 1997. This release was the result of a low anolyte level in a diaphragm cell in the chlorine cell lines which caused the overpressurization of the chlorine header.  There were no off-site injuries and no environmental impact.  The property damage caused by the overpressurization was approximarely $400,000.  As a result of the incident, the Ingleside Plant revised chlorine cell line maintenance procedures, training for chlorine cell line operators, and chlorine cell line operating procedures.  There were no other releases of  
regulated substances in the past five years which had an offsite impact. 
6.  The emerge 
ncy response program (' 68.155(f) ). 
The Ingleside Plant has established a written emergency response plan and maintains an emergency response team (ERT) trained in these emergency response procedures.  All plant personnel are trained in evacuation procedures and in-plant drills are conducted periodically. The drills are used to test the response time of the Emergency Response Team,  to test the plant employee accountability program, and to activate the plant's Emergency Command Center (ECC).  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 Eme 
rgency Response Plan 
7 EPA 40 CFR 355.40 - Emergency Planning and Release Notifications 
7 EPA 40 CFR 112 - Spill Prevention, Control and Countermeasures Plan 
7 EPA 40 CFR 68 - Risk Management Programs for Chemical Accidental Release Prevention 
The Ingleside Plant has a Chemical Emergency Response Program Team (CERP) available 24 hours per day to respond to in plant chemical emergencies. The plant's CERP team serves as the Chlorine Institute's CHLOREP (Chlorine Emergency Plan) Sector 26  Response Team for South Texas and responds to chlorine emergencies within this region. The team maintains a  mobile chemical emergency command center equipped with the necessary equipment to respond to chlorine emergencies.  The CERP Team is also equipped to respond to any OxyChem VCM chemical emergency, on or off-site. 
The Ingleside Plant uses a SAFER Real Time modeling program to assess release impacts if any and to aid in the determination of response activity. The Ingleside Plant also has a communit 
y alert network (CAN) system available through the San Patricio Local Emergency Planning Committee (LEPC) to notify the public of a potential or actual hazardous situation. The CAN is a  new telephonic public notification system which alerts neighboring residents of events such as evacuations and sheltering in place.  In addition, the 
Ingleside Plant has developed a Special Situations Plan (SSP) which is a program designed for responding to emergencies that may have impacts beyond the immediate plant and is a supplement to the Emergency Response Plan.  The Special Situation Plan links the local response to the OxyChem Corporate Emergency Response Center located in Dallas, Texas which can then provide assistance as needed. The intent of the SSP is to aid the community after an event in order to return their quality of life back to normal as quickly as possible. 
The facility is a member of the San Patricio County Local Emergency Planning Committee (LEPC), whose membership includes: 
7 Occ 
idental Chemical 
7 DuPont 
7 Reynolds Metals 
7 San Patricio County Emergency Planning Agency 
7 San Patricio County Officials (County Judge, County Commissioners, etc.) 
7 Texas Department of Public Safety 
7 San Patricio County Sheriff's Department 
7 San Patricio County City Officials (Mayors, Councilmen, School Principals, etc.) 
The San Patricio County LEPC meets every two months and conducts annual training exercises of the emergency response plan. 
7.  Planned Changes to Improve Safety (' 68.155(g) ). 
The Ingleside Plant constantly tries to improve the safety of the processes through annual reviews of our plant procedures, near misses and incident investigation programs, and a program soliciting safety and environmental suggestions from the plant employees.  The key element of Ingleside's safety and environmental programs is prevention. Ingleside will continue to improve all its processes in order to prevent significant events from occurring in the future. 
8.  Certification Statement 
the best of the undersigned's knowledge, information, and belief formed after reasonable inquiry, the information submitted is true, accurate, and complete. 
Original on Cover Letter 
Robert W. Moore ----------------------------------------------------------------------------------------------------Signature 
Print Name 
Plant Manager 
June 18, 1999 ----------------------------------------------------------------------------------------------------- 
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