Oxy Vinyls, LP - Battleground Chlor-Alkali Plant - Executive Summary

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The Battleground Chlor-Alkali Plant is a chlorine & caustic manufacturing facility owned by Oxy Vinyls, LP.  Oxy Vinyls, LP, referred to as "OxyVinyls", is a joint venture between Occidental Chemical Corporation (a subsidiary of Occidental Petroleum Corporation) and The Geon Company. This facility is located in LaPorte, Texas at Battleground Road & Highway 134.  The Battleground Plant, part of the Houston Operations, manufactures and ships chlorine, caustic soda, and hydrogen and also temporarily stores railcars of vinyl chloride for shipment to external customers.  The facility was originally constructed in 1974 and employs approximately 150 full-time employees. 
1.  Accidental Release Prevention and Emergency Response Policies at the Stationary Source  (' 68.155(a)) 
OxyVinyls is committed to operating the Battleground 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 regula 
tions, industry standards and best practices.  As part of this commitment, OxyVinyls has established a system to help ensure safe operation of the processes at this facility that includes the prevention of accidental releases of hazardous substances.  One component of this system is a risk management program (RMP) that provides the basis for managing risks at the Battleground Plant.  The RMP 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), 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 Battleground Plant. 
The Risk Management Program at the Battleground Plant consists of the following three elements: 
7 A hazard assessment to (a) help the facility and community understand the potential off-site consequences of hypothet 
ical accidental releases and to (b) provide information to the public regarding accidents that have occurred during the last five years 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 Battleground 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 Battleground Plant.  In fact, the Battleground Plant has a comprehensive safety and environmental program in place, establishing many levels of safeguards against release of a hazardous substance as well as i 
njuries and damage from such a release. 
OxyVinyls' policy on the use of hazardous substances: Before using a hazardous substance at the Battleground Plant, less hazardous alternatives are always considered.  When a hazardous substance is to be used at the Battleground Plant, the plant personnel review the potential for an accidental release of this substance that 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) and Process Hazard Analysis (PHA) procedures that are followed for all new installations or modifications of existing processes. 
OxyVinyls strives to prevent accidental releases of the hazardous substances used at the facility by implementing reasonable controls to prevent foreseeable releases of hazardous substances. When a hazardous substance is used at the Battleground Plant, the equipment is carefully designed, installed, operated and ma 
intained 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.  OxyVinyls 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, the facility requires the documentation of standard operating procedures and training of affected employees with regard to these procedures as part of the MOC procedure.  The facility 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. 
OxyVinyls' goal is to minimize impacts from accidental releases should they occur.  In the event of an accidental release, the Battleground Plant controls and contains the release in a manner that will be safe for workers and will minimize the impact to 
the public and environment. The facility maintains an active Emergency Response Team that is on call at all times to respond to accidental releases of any of the hazardous chemicals handled by OxyVinyls facilities.  OxyVinyls also has established a Special Situations Center in the Dallas corporate office and at the facility to assistant workers, their families, and the public during and after all emergencies. In addition, OxyVinyls has a leadership role in Channel Industries Mutual Aid (CIMA).  This is a state chartered non-profit mutual-aid cooperative combining the fire fighting, rescue, hazardous material handling and emergency medical capabilities to its members in the Houston Ship Channel area.  Participating in this organization ensures emergency response capabilities far greater than an individual plant can provide.  Along with the CIMA organization, the plant takes an active role in the local emergency planning committee for LaPorte.  The facility promotes the use of the CAER  
Phone Hotline number to inform citizens of any unusual plant event and actively works with the LaPorte Citizen's Advisory Council. 
An OxyVinyls 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 OxyVinyls' corporate guidelines.  This plan outlines the responsibilities and actions required for control an emergency within the boundaries of the Battleground Plant.  If the emergency extends beyond or could potentially extend beyond the plant boundaries, the LaPorte Local Emergency Planning Committee (LEPC) is notified and a statement of the type of emergency and any community protection factors are recommended. 
The facility employees are active participants in the community.  As part of OxyVinyls Responsible Care. efforts, the Battleground Plant had a leadership role in establishing the Citizen's Advisory Council to La Porte Industry in 1990.  The purpose of this group is  
to share information about plant operations with members of the community and to discuss their concerns.  Through this outreach effort, as well as other community involvement, the plant stays abreast of community concerns and works to address them. 
The facility has implemented a Voluntary Protection Program (VPP) in which employee participation at all levels is required in designing, implementing and maintaining safety programs.  Safety is a primary concern in our facility and is demonstrated by our selection by OSHA in Sept.1997 as an OSHA Star facility under OSHA's Voluntary Protection Program (VPP). 
To effectively implement these policies, OxyVinyls has established a management system headed by the Health, Environmental and Safety (HES) Departments to oversee safety and environmental-related activities.  
2.  The Stationary Source and Regulated Substances Handled (' 68.155(b)) 
The Battleground Plant handles three substances that are covered by the RMP rule: 
Regulated Substance   
          Largest Vessel Inventory            RMP Threshold Quantity 
Anhydrous Ammonia                          63,000 lbs.                            10,000 lbs. 
Chlorine                                        1,300,000 lbs.                              2,500 lbs. 
Vinyl Chloride                                   180,000 lbs.                            10,000 lbs. 
Anhydrous ammonia is used as a purifying material for caustic and is reclaimed within the process.  Chlorine is one of the major products made at this facility.  The daily production of the liquid chlorine is collected in seven (7) 650-ton chlorine storage tanks.  Chlorine from these tanks can be shipped to area customers via pipeline and from 55-ton and 90-ton rail cars.  A 250-ton tank and a 650-ton storage tank are operated in an empty and under a vacuum condition at all times to allow chlorine to be emptied from one of the seven storage tanks or pipelines in the event of an emergency condition.  The facility complies wi 
th the Department of Transportation (DOT) regulations in the loading and shipment of the Chlorine product.  Chlorine Institute-recommended practices are followed in the design, operation, and maintenance of this facility.  Vinyl chloride railcars are temporarily stored at the facility's rail yard.  As the railcars are disconnected from the motive force, they are subject to the RMP rule. 
The process units containing ammonia and chlorine are inter-connected by piping and, therefore, are considered one process.  The Marshalling Yard area containing chlorine and vinyl chloride railcars are co-located with the chlorine process unit.  Therefore, this area is also considered part of the same Battleground Chlor-Alkali process.  Based on the RMP criteria for process program levels, this is considered a Program 3 process. 
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 Report 
ed Scenario (' 68.155(c)) 
The facility performed off-site consequence analyses of accidental releases of regulated substances to estimate the potential affects to 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".  OxyVinyls does not expect a worst-case release scenario to ever occur given the multiple levels of protection in place to prevent such a scenario.  The alternative release scenarios that have been developed are based on more likely potential accidental releases.  These have been shared with the LEPC to assist them in improving the community emergency response plan.   
Distances to toxic and flammable endpoints were calculated based on the EPA RMP Offsite Consequence Analysis Guidance. The meteorological data used for the modeling was the EPA default for the worst case scenario and EPA suggested values for the alternative release scenario. The Landview. III 
program was utilized to estimate the number of persons living within this distance from the location of the potential release point.  USGS maps were utilized to identify the public and environmental receptors located within this distance. 
The following information summarizes the off-site consequence analysis performed by the Battleground Plant: 
3.1  Toxic Substances - Ammonia 
The "worst-case scenario" for ammonia would not be as great as for chlorine; therefore, a description of this scenario is not included in the plan.  An alternate release scenario that was selected for ammonia involves a process-upset condition that causes pressure build-up in a vessel, resulting in the pressure relief device opening to the atmosphere.  It is estimated that 4,000 lbs. of gaseous ammonia would be released over a 5-minute period. Under the EPA alternate release weather conditions, the ammonia gas cloud would travel a distance of 0.2 miles before the concentration of ammonia diminished below the t 
oxic endpoint concentration of 0.14 mg/L (200 ppm).  Active mitigation accounted for in the analysis includes multiple process alarms to alert operators of an upset condition.  U.S. Census data indicates that no residences would be affected by this release.  No public receptors or environmental receptors would be affected under this scenario. 
3.2  Toxic Substances - Chlorine 
The "worst-case scenario" involving a toxic substance at this facility would be a catastrophic failure of one of the chlorine storage tanks.  This scenario assumes 1.3 million pounds of liquid chlorine would be released and evaporated within a 10-minute period.  Under the EPA default worst weather conditions, the chlorine gas cloud would travel a distance greater than 25 miles before the concentration of chlorine diminished below the toxic endpoint concentration of 0.0087 mg/L (3 ppm).  No credit is taken for passive or active mitigation in the analysis.  U.S. Census data indicates that approximately 1.8 million  
persons live within this distance from the storage tank.  Essentially all public-type receptors are located within this distance.  Environmental receptors within this distance include a state park and wildlife sanctuary. 
An "alternative case scenario" that was selected for chlorine involves failure of a 1-1/2 inch loading hose connected from the liquid chlorine tank car loading header to a rail car.  It is estimated that this would release about 1,000 lbs. of liquid and gaseous chlorine over a 1-minute period.  Active mitigation accounted for in the analysis includes monitoring sensors to activate emergency shut-off valves.  Under the EPA alternate release weather conditions, the chlorine gas cloud would travel a distance of 0.5 miles before the concentration of chlorine diminished below the toxic endpoint concentration of 0.0087 mg/L (3 ppm).  U.S. Census data indicates that no residences would be affected by this release.  A public receptor within the distance to the toxic endpoint  
is an industrial area.  An environmental receptor within this distance is a state park. 
3.3  Flammable Substances - Vinyl Chloride  
The worst case scenario involving a flammable substance at the facility would be a catastrophic failure of a vinyl chloride railcar.  This flammable substance release scenario assumes that the entire contents of the tank (180,000 lbs.) is released and vaporizes to form a vapor cloud that subsequently ignites.  In this scenario, an endpoint of 1-psi over normal atmospheric pressure would extend to a distance of 0.34 miles.  U.S. Census data indicates that no residences would be affected by this release.  There are no public receptors within the endpoint distance.  An environmental receptor within this distance is a state park. 
The alternate release scenario for vinyl chloride that was selected involves a 4-inch hole in a railcar.  This would be expected to release the entire tank contents over a six-minute period before the vapor cloud ignited.  No credi 
t is taken for active or passive mitigation in the analysis. In this scenario, an endpoint of 1-psi over normal atmospheric pressure would extend to a distance of 0.15 miles.  More realistic criteria used in this scenario results in a shorter endpoint distance than for the worst case scenario even though the quantity released is the same for both scenarios.  U.S. Census data indicates that no residences would be affected by this release.  There are no public receptors nor are there any environmental receptors within this distance from the release point. 
4.  The General Accidental Release Prevention Program and the Specific Prevention Steps (' 68.155(d)) 
The Battleground Plant developed and implemented a prevention program in accordance with CMA's Responsible Care. Process Safety Code in 1990.  The facility later revised their prevention program to comply with the prevention program requirements of OSHA's Process Safety Management standard in 1992.  Under the EPA RMP criteria for esta 
blishing a prevention program, a Program 3 prevention program is required for the Chlor-Alkali process.  The Program 3 prevention program is essentially the same as OSHA PSM, except that the program also focuses on protecting the public and the environment beyond the plant's boundaries. The following sections briefly describe the 12 elements of the Battleground Plant's Program 3 prevention program that address EPA's RMP rule prevention program requirements. 
4.1  Process Safety Information  
The Battleground Plant maintains technical documents that 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.  The facility ensures that this process safety information is up-to-date and available to all employees.  Information pertaining to hazardous chemicals in the  
process is documented in the facility Material Safety Data Sheets (MSDSs) files.  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 
Information pertaining to the technology and equipment in the process is documented in Design manuals, Process Description Manuals, process flow diagrams, engineering drawings, and equipment files.  These documents are used to (1) train employees, (2) perform process hazards analyses and (3) help maintain the equipment. 
The available information includes: 
7 Applicable design codes and standards 
7 Design basis and configuration of equipment 
7 Design basis for relief and ventilation systems 
7 Piping and instrumentation diagrams, including materials of construction 
7 Process chemistry 
7 Operatin 
g parameters 
7 Maximum intended inventories 
7 Safe upper and lower limits for parameters such as temperature, pressure, or flow 
7 Configuration of equipment 
7 Electrical classification 
7 Safety systems 
4.2  Process Hazard Analysis 
The Battleground Plant performs and updates process hazard analyses (PHAs) of the covered process to help identify potential process hazards and generate recommendations that might improve the safe operation of the process.  These process hazard analyses are revalidated at least every five years.   
PHA teams for employee involvement conduct process Hazard Analyses.  These teams are comprised of personnel with engineering, process operating experience, and specialized knowledge.  A leader with applicable PHA training facilitates the hazard analyses.  The PHA team prepares a written report describing the results of the analysis, including a list of recommendations to address potential hazards.  Hazards that are identified are risk-ranked to ensure that highes 
t priority is given to those having the highest consequence and likelihood of occurrence.  The recommendations are assigned to unit personnel and tracked to completion using the facility Action Tracking System. 
4.3  Operating Procedures 
Operating procedures have been developed for each process area.  These are maintained by area Subject Matter Coordinators (SMCs) through a document control system.  Operating procedures are reviewed annually by operators and process engineers and certified as being correct.  The procedures include steps for safe operation during all phases of operation, including initial startup, normal startup, normal operations, normal shutdown, emergency shutdown, startup following a turnaround or emergency shutdown, and temporary operations, as applicable.  Within the operating procedures are: 
7 Steps for safely conducting work activities  
7 Applicable process safety information, such as safe operating limits and consequences of process deviations 
7 Safety and heal 
th considerations, such as chemical hazards, personal protective equipment requirements and actions to take if exposure to a hazardous substance occurs 
4.4  Training 
The Battleground Plant has implemented an effective training program to administer training activities.  The training program includes both initial and refresher training that covers (1) a general overview of the process, (2) safety, health, and environmental topics, (3) process-specific training on the properties and hazards of the substances in the process and (4) job-specific requirements.  This training is provided in both a classroom and on-the-job setting.  A combination of oral reviews and written tests are used to verify that an employee understands the training material.  The training program includes a training management plan that defines administration of the program and annual goals.  In addition, a training matrix has been prepared that defines the specific training courses required of each job function.  An 
electronic training management system, "TRIM", is utilized to ensure that employees receive the necessary training as defined by the training matrix. 
4.5  Mechanical Integrity 
The Battleground Plant maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger workers, the public, or the environment.  Inspectors that have been qualified to API, AWS, and ASNT standards are utilized for performing inspections and tests of mechanical equipment.  Qualified instrument and electrical technicians are utilized for inspections and tests of instrumentation and electrical equipment.  The mechanical integrity program includes - 
(1) an administrative procedure that defines the inspection and testing program 
(2) equipment inspection procedures that defines methods of inspection, acceptance criteria, and inspector qualifications 
(3) specific non-destructive inspection procedures 
(4) a quality assurance program to help ensure that new and replacement  
equipment meets the design standards required for service in the plant's processes 
4.6  Management of Change 
The Battleground Plant Management of Change procedure defines the requirements for review and approval of all proposed changes to chemicals, equipment, and procedures for processes to ensure that safety, health and environmental affects of changes are considered.  The Management of Change system ensures that the affected employees are notified of the changes, training is provided, and that process safety information and procedures are updated accordingly.  Plant personnel receive training on how to identify potential changes and the types of changes that are covered by the Management of Change procedure. 
4.7  Pre-startup Review 
The Battleground Plant performs a Pre-startup Safety Review (PSSR) for all changes to the process before they are put into service to help ensure that the process is safe to operate, procedures are in place, and affected personnel are adequately trained 
to operate or maintain the process.  Startup of the applicable process or equipment cannot commence until issues identified by the Pre-startup Review have been addressed and authorization is given by area supervision.  Specific items that the PSSR confirms are: 
7 Construction and equipment are in accordance with design specifications 
7 Adequate safety, operating, maintenance, and emergency procedures are in place 
7 Affected employees are trained before they can be affected by the change 
7 Construction and equipment are in accordance with design specifications during a process walk-through 
7 A PHA has been performed as specified by the Management of Change procedure 
4.8  Compliance Audit 
The Battleground Plant audits covered processes every 3 years to be certain that the prevention programs are effectively implemented at the plant.  Audit teams conduct internal audits of the prevention program.  These include persons who are knowledgeable in the process and who have been trained in th 
e auditing process.  The audit teams evaluate whether the prevention program satisfies the requirements of the RMP rule and whether the prevention program is effectively implemented.  The results of audits are documented, recommendations are assigned to individuals to be resolved, and appropriate enhancements to the prevention program are implemented.  The Dallas corporate office performs audits of the facility programs, process and documentation at regular intervals.  The facility requires that all action items be addressed in a timely fashion. 
4.9  Incident Investigation 
The Battleground Plant investigates incidents, including near misses, that could reasonably have resulted in a serious injury to personnel, the public, or could have caused damage to the environment 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 w 
ithin 48 hours of the incident.  The results of the investigation are documented, recommendations are assigned to persons to be resolved, and appropriate process or system enhancements are implemented. 
The facility has a formal program in place for reporting incidents, conducting incident investigations, report generation, and tracking of actions resulting from incidents.  Incident causal analysis training is required for all individuals who may need to conduct incident investigations. 
4.10  Employee Participation 
The Battleground Plant developed a written employee participation program for the facility to help ensure that the safety concerns of the plant's workers are addressed.  The facility encourages active participation of personnel in prevention program activities at the plant.  Some examples in which employees participate include development of prevention programs and documentation, process hazard analysis, development of operating procedures, development of alternate release  
scenarios, and incident investigations.  Employees are consulted on and informed about all aspects of the RMP rule prevention program. 
4.11  Hot Work Permits 
The Battleground Plant established a hot work permit program to control spark or flame-producing activities that could result in fires or explosions in all processes at the plant.  The plant reviewed OSHA's fire prevention and protection requirements in 29 CFR 1910.252(a) and developed a Hot Work Permit procedure to comply with these requirements.  Personnel who are to perform hot work are required to receive a Hot Work Permit.  Qualified individuals who issue hot work permits receive specialized training in the procedure and activities related to hot work.  Refresher training on hot work is required every three years. 
4.12  Contractors 
OxyVinyls Houston Operations has established a Contractor Quality Program to help ensure that contractors who perform work in the plant are competent and responsible.  OxyVinyls requires that co 
ntractors undergo a qualification process before being allowed to work at the facility.  Contractors are required to submit information regarding their safety, health, and environmental programs and performance.  This information is evaluated to ensure that the plant only hires contractors who can perform the desired job tasks in a safe and environmentally sound manner.  All contractor employees are required to take a Basic Safety and HAZCOM course offered by the area contractors' safety council, followed by a plant orientation and test on the plant's safe work practices and emergency alarm system.  Area-specific orientations are given to contractor employees to ensure that they understand the hazards of the process on which they will work and the area emergency response procedures.  Depending on the type of work to be performed, contract perennial may be required to have additional training.  The plant conducts frequent evaluations of contractor performance.  All contractors must be r 
e-qualified annually to continue working in the facility.  
5.  Five-year Accident History (' 68.155(e)) 
There have been two accidents at the Battleground facility over the past five years that meet the EPA RMP accident criteria with respect to injuries involving releases of chlorine.  The first accident occurred when a process upset allowed 37 pounds of chlorine to be released.  An employee in the area was treated for chlorine inhalation.  The second incident also involved chlorine inhalation when 1 pound of chlorine was accidentally released.  In both cases, the injured workers returned to work with no more than one day of restricted work activity.  Neither accident had an adverse impact on the community or environment. 
6.  The Emergency Response Program (' 68.155(f)) 
OxyVinyls Houston Operations has established a written emergency response plan and maintains an emergency response team trained in the Emergency Response procedures.  All plant personnel are trained in the plant alar 
m system, sheltering-in-place, and evacuation 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  
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 
OxyVinyls Houston Operations has an Emergency Response Team (ERT) that is available around-the-clock to respond to in-plant chemical emergencies. The plant's offsite transportation response team is called the  
Houston Strike Team.  This team serves as the Region 25 CHLOREP Regional Response Team for central and east Texas and responds to chlorine emergencies within this region. The team maintains a mobile hazardous materials vehicle with the necessary equipment to respond to chlorine emergencies. 
OxyVinyls Houston Operations uses the SAFER. Real Time modeling program to assess potential off-site impacts in the event of a chemical spill or release to aid in the determination of response activity. The Emergency Operations Center has access to the LaPorte community alert (CAL) system that is available to notify the public of a potential or actual hazardous situation. In addition, the facility has developed a Special Situations Plan that is a supplement to the Emergency Response Plan and is designed for responding to emergencies that may have impacts beyond the immediate plant.  The Special Situation Plan links the local response to the Corporate Emergency Response Center located in Dallas, Tex 
as that can then provide assistance as needed. 
OxyVinyls Houston Operations is a member of the LaPorte LEPC, whose membership includes: 
7 City of LaPorte 
7 LaPorte Fire Department 
7 LaPorte Police Department 
7 Harris County Office of Emergency Management 
7 Industrial representatives from the LaPorte industrial area. 
The LaPorte LEPC meets every month and conducts annual training exercises of the emergency response plan. The company's emergency response plan has been communicated to CIMA, the LaPorte Fire Department, and the LaPorte LEPC. 
7.  Planned Changes to Improve Safety (' 68.155(g)) 
The Battleground Plant constantly tries to improve the safety of the processes through annual reviews of our plant procedures, near misses and incident investigation programs, process hazard analysis, and a program for 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 Earl Wooten*, Chlor-Alkali Plant Manager, on June 16, 1999. 
*  The Certification with original signature is included with this RMP submittal.
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