Oxy Vinyls, LP - Pasadena PVC Plant - Executive Summary

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Oxy Vinyls' Pasadena PVC Plant manufactures polyvinyl chloride (PVC) resin from polymerization of vinyl chloride.  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 on the Houston Ship Channel at 4403 Pasadena Freeway.  It was originally constructed in 1960, has been expanded on four separate occasions, and currently employs 167 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 Pasadena PVC 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 preven 
tion of accidental releases of hazardous substances.  One component of this system is a risk management program (RMP) that helps manage the risks at the Pasadena PVC 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 Pasadena PVC Plant. 
The RMP at the Pasadena PVC 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 potentia 
l of involving, more than a threshold quantity of a regulated substance; 
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. 
Although the risk management program at the Pasadena PVC Plant helps ensure that the facility is maintained and operated in a safe manner, it is only one component of the safety and environmental program at the Pasadena PVC Plant.  In fact, the Pasadena PVC Plant has a comprehensive safety and environmental program in place, establishing many levels of safeguards against release of a hazardous substance, as well as safeguards to prevent injuries and damage from such a release. 
Oxy Vinyls' policy on the use of hazardous substances:  Before using a hazardous substance at the Pasadena PVC Plant, less hazardous alternatives are always considered. When a hazardous substance is used, the plant personnel review the potential fo 
r 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 Review (PHR) 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 Pasadena PVC 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 Pasadena PVC 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 at the Pasa 
dena PVC Plant to assist workers, their families and the public during and after all emergencies.  In addition, the Pasadena PVC Plant actively works with CIMA (Channel Industries Mutual Aid), the Pasadena and Deer Park Local Emergency Planning Committees (LEPC's), and other local emergency service providers to help prevent and/or address injuries or environmental damage in case a release does occur.  The Pasadena PVC Plant, in conjunction with the East Harris County Manufacturers Association (EHCMA), has assisted the Pasadena LEPC in installation of the city wide emergency broadcast system and developed/implemented a RMP public communications plan.  The Pasadena PVC 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 Pasadena Citizens' Advisory Council (PCAC). 
The Pasadena PVC Plant's emergency response plan has been developed to meet the emergency planning, re 
sponse 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 Pasadena PVC Plant.  If the emergency extends beyond or potentially extends beyond the plant boundaries, the Pasadena PVC Plant's Special Situations Plan is initiated and the response is coordinated with CIMA, the Pasadena 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 plant's selection in 1991 as the first OSHA Star Site on the Houston Ship Channel under OSHA's Voluntary Protection Program (VPP); an 
d OSHA Star re-certification was completed in 1994 and 1998. 
Oxy Vinyls is an industry leader in the implementation of the Responsible Care. (Chemical Manufacturer's Association or CMA) initiative. As part of the Responsible Care. efforts, the Pasadena PVC Plant assisted in formation of the Pasadena Community Advisory Council (PCAC) and has been involved with the PCAC 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 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 well as other community involvement, the plant stays informed of community concerns and works to address them.  Members of the PCAC participated in the CMA's Management Systems Verification, including the Pasadena PVC Plant, in mid-1997; and they 
have also participated in some safety audits. 
A Plant Safety Committee, 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 Pasadena PVC Plant handles one regulated (flammable) substance (vinyl chloride) that is covered by the RMP rule; it is a Program Level 3 process. 
Vinyl Chloride is the primary feedstock for the Pasadena PVC Plant.  The primary purpose of this facility is to manufacture, store and ship PVC resin.  Vinyl chloride is primarily delivered by pipeline, to two large storage spheres, from other Oxy Vinyls sites located in Deer Park, TX or LaPorte, TX.  However, at times and based on pipeline source limitations, vinyl chloride is delivered by railcars from other sources and unloaded into the same spheres.  The vinyl chlorid 
e is transferred from the spheres to charge tanks via pipeline; where it is then introduced into reactors.  In the reactor, vinyl chloride is polymerized to make polyvinyl chloride (PVC) resin in a water slurry solution.  After drying, the PVC resin is then transferred and stored in silos until loaded into railcars for shipment to customers. 
The facility and pipelines comply with the Department of Transportation (DOT) regulations.  
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 Pasadena PVC Plant performed off-site consequence analysis to estimate the potential for the accidental release of a regulated substance that might 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 reality, however, Oxy Vin 
yls 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 scenario and the alternate release scenario.  Various sources (Landview, USGS maps, and DeLorme Street Atlas USA) and actual field surveying 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 Pasadena PVC Plant: 
3.1 Toxic Substances -  
There are no regulated toxic substances in quantities above the threshold quantities at the plant. 
3.2 Program 3 Processes - Flammable Substances 
The "worst-case release scenario" for vinyl chloride is the catastrophic failure of one of the storage spheres, which would release 3,000,000 p 
ounds of vinyl chloride in a 10-minute period and all safety systems fail, as mandated by EPA.  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 would then be 0.86 mile per EPA's Offsite Consequence Analysis Guidance Document. 
The Pasadena PVC Plant is located over a mile north of any residential areas and on the Houston Ship Channel, which is primarily populated by plants of other companies.  Therefore, the official residential population within the 1 psi overpressure endpoint for the worst-case release scenario is zero.  However, there are four plants (owned and operated by Aristech, Enron, Georgia Gulf, and Houston Ammonia Terminal) within the endpoint.  Oxy Vinyls is sharing all RMP information with these sites and their employees, the same as if they were residential receptors.   The only enviro 
nmental receptor within the endpoint is the Houston Ship Channel. 
The "alternate release scenario" is the failure of a 2-inch railcar unloading hose or a 2" equivalent hole in any loading / unloading line.  This release could be detected and isolated by active and passive safety systems in ten minutes or less and would result in a maximum release of 25,000 pounds of vinyl chloride over that ten minute period. For this scenario, the distance to a 1 psi overpressure would then be 0.056 mile (or 295 feet) for a vapor cloud explosion, per EPA's Offsite Consequence Analysis Guidance Document. 
The residential population within the 1 psi overpressure endpoint for this alternate release scenario is zero.  In fact, it would barely get offsite, but could possibly affect an adjacent warehouse/office building at a plant site (Aristech) just north of the Pasadena PVC Plant.  Oxy Vinyls is also sharing this scenario information with the same four plants as mentioned for the worst-case release scen 
ario.  There are no environmental receptors within the endpoint of the alternate release scenario. 
4.  The General Accidental Release Prevention Program and the Specific Prevention Steps (' 68.155(d)): 
The Pasadena PVC 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 vinyl chloride at this site, is basically the same as OSHA PSM, 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 Pasadena PVC Plant's RMP Program 3 prevention plan that address EPA's RMP requirements. 
4.1 Program 3 Prevention Program 
The Pasadena PVC Plant's Program 3 preventi 
on program consists of the following 12 elements: 
4.1.1 Process Safety Information 
The Pasadena PVC 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, 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 mixi 
ng 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 "Pasadena PVC Plant Process Technology" document in the Process Safety Management Manual.  This available information includes: 
7 Technology of the PVC Process with general operating parameters; 
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 configurati 
on 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 Pasadena PVC Plant performs process hazard analyses (PHA's or PHR'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 processes were initially reviewed using the HAZOP methodology by January of 1996; 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 (know 
ledgeable 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 Compliance and Critical Action Tracking System. 
4.1.3 Operating Procedures 
The Pasadena PVC Plant has a "Procedure for Procedures" in place.  Subject Matter Experts (SME's), 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; 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 Management 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. 
4.1.4 Training 
The Pasadena PVC 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, written tests, demonstrations and observations 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 duties 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 Pasadena PVC 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 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 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 Pasadena PVC Plant's Management Of Change (MOC) procedure sets requirements for reviews and approvals of all proposed changes to chemicals, equipment and procedures 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 trai 
ning on how to identify potential changes and the types of changes that are covered by the procedure. 
4.1.7 Pre-startup Review 
The Pasadena PVC 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 accordance 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 an extended time. 
4.1.8 Compliance Audit 
The Pasadena PVC Plant audits covered processes every year to be certain that the prevention programs are effectively addressing the safety issues of the process. Approximately every three years, the Corporate office performs a detailed "Coordinated Safety Audit".  In 1991, 1994 and 1998, OSHA performed an audit for the Voluntary Protection Program (VPP) and the OSHA Star recognition.  The Plant Safety Committee, in conjunction with the Safety Department, conducts the coordinated safety audit on the years that the corporate office does not audit.  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 requirements and verifies employee participation/ knowledge. Responsibilities for 
recommendations are assigned and tracked through completion. 
4.1.9 Incident Investigation 
The Pasadena PVC Plant has an "Incident Reporting and Investigation Standard" 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 management staff 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 Compliance & Critical Action Items system.  Information on all incidents is s 
hared 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 Pasadena PVC 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 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.  Employees are involved in development and / or revision of all Safety procedure 
s, 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 Safety Committee, with representation from all departments (including contractors), meets monthly to discuss Safety and develop Safety awareness programs.  
4.1.11 Hot Work Permits 
The Pasadena PVC 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 o 
rientation and refresher training. 
4.1.12 Contractors 
The Pasadena PVC 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 no incidents, at the Pasadena PVC Plant, involving a release of vinyl chloride that meet the EPA Risk Management Program reporting requirements.  
6. The emergency response program (' 68.155(f)). 
The Pasadena PVC 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 a 
nd 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 Prevention, Control and Countermeasures Plan; 
7 EPA 40 CFR 68 - Risk Management Programs for Chemical Accidental Release Prevention. 
The Pasadena PVC 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 Pasadena PVC Plant has employees that participate on the Hou 
ston Chemical Emergency Response Program Team (CERP), available 24 hours per day to respond to plant chemical emergencies. The team maintains a mobile chemical emergency command center equipped with the necessary equipment to respond to any chemical emergencies. 
The Pasadena PVC Plant uses a SAFER system to assess release impact and to aid in the determination of response activities.  The Pasadena PVC Plant actively works with the Pasadena Local Emergency Planning Committee (LEPC) and supports the Pasadena Emergency Warning System and the CARE telephone hotline. 
In addition, the Pasadena PVC 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 t 
he 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 Pasadena Outreach Area, communicate regularly with the local citizen's advisory panels or councils regarding community/industry issues.  The Pasadena PVC 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 Pasadena PVC Plant actively participates and communicates with the City of Pasadena; the Pasadena LEPC and the neighboring Deer Park LEPC; the Pasadena Independent School District through Partners in Education; and other local organizations. 
7.   Planned Changes to Improve Safety (' 68.155(g)). 
The Pasadena PVC Plant constantly tries to imp 
rove the safety of the processes through annual 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 Byron McWhirter *, Plant Manager, on June 17, 1999. 
*  The Certification with original signature is included with this RMP submittal.
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