Occidental Chemical Taft Plant - Executive Summary |
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3176 LDEQ Facility ID Number EXECUTIVE SUMMARY 3176 LDEQ Facility ID Number Occidental Chemical Corporation (OxyChem), a wholly owned subsidiary of Occidental Petroleum Corporation (OPC), owns and operates a Chlor-Alkali manufacturing facility in Hahnville, Louisiana. This plant, the Taft plant, is bordered on the south by Louisiana Highway 3127, on the east by Louisiana Highway 3142, to the north by Louisiana Highway 18, and on the west by other industrial facilities. Overall, the Taft plant has about 347 full-time employees, including contractors. 1. Accidental Release Prevention and Emergency Response Policies at the Stationary Source ( 68.155(b)): OxyChem is committed to operating the Taft plant in a manner that is safe for its workers, the public, and the environment. It is Taft plant policy to adhere to all applicable federal, state, and local rules and regulations, industry standards, and best practices. In order to effectively implement these policies, OxyChem establish ed a management system headed by the Health, Environmental and Safety (HES) Departments to oversee safety and environmental activities. 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 Taft plant and that 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). One of the requirements of the RMP rule is to submit a risk management plan (RMP Plan) describing the risk management program at the Taft plant. 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 Taft plant. The risk management program at the Taft plant consists of the following three elements: - 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 (regulated substances). - A prevention program to help maintain and safely operate the processes containing more than a threshold quantity of a regulated substance (covered process). - 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. OxyChem limits the use of hazardous substances: Before using a hazardous substance at the Taft plant, less hazardous alternatives are considered. When a hazardous substance is used at the Taft plant, OxyChem considers the potential for this substance to adversely affect plant workers, the public, and the environm ent and takes 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 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 at the Taft 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. 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 t raining of affected employees with regard to these procedures as part of the MOC procedure. OxyChem has a mechanical integrity program providing 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 Taft 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 trains its workers to respond to an accidental release, reducing the consequences of a release if it occurs. This training includes response training for its personnel, designating an emergency response coordinator to oversee response activities, conducting regular drills to review response activities, and coordinating response efforts with area industry and the local emergency response agencies. OxyChem works with the local fire department and with the local emergency planning committee (LEPC) and Department of Emergency Preparedness (DEP) to help prevent injuries and/or environmental damage if a release does occur. In addition, OxyChem has established a Special Situations Center at our corporate offices in Dallas, Texas to assistant in all emergencies. OxyChem utilizes emergency response plans as required by government regulation. The Taft plant's emergency response plan has been developed to meet the emergency planning, response and notification requirements of the Federal, OSHA, Louisiana, and EPA regulations. This plan outlines the responsibilities and actions required to control an emergency that limits itself to within the Taft plant. Response activities have been coordinated with the LEPC and the St. Charles Parish Department of Emergency Preparedness at the Hahnville courthouse, if the emergency were to extend beyond the plant boundaries and affect the surrounding communities. OxyChem is an active particip ant in the community: As part of OxyChem's Responsible Care efforts, the Taft 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 bimonthly and covers topics of interest 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. The Taft plant received the CMA Responsible Care Employee Health and Safety Code Sustained Excellence Award in 1998. 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 i n designing, implementing and maintaining safety programs. Safety is a primary concern in our facility and is demonstrated by our selection by OSHA in 1994 and recertification in 1997 as an OSHA Star facility under the VPP. The Taft plant supports education by participating in the River Parishes Chemical Industry Council and the Partners-in-Education Program with J.B. Martin Middle School. The River Parishes Chemical Industry Council is affiliated with the Louisiana Chemical Association and encourages education excellence through scholastic competition in essay writing, chemical testing, science fair competition, and industrial technology competition. Cash awards and scholarships are given to students based on their achievements. As part of our Partners-in-Education Program OxyChem provides tutors, lab equipment, computer equipment, plant tours, science and social studies fair judges, and assistance with student and teacher appreciation week each year. The Taft plant annually spo nsors one delegate each to Boys State and Girls State. These programs allow students to learn about government operations. Taft plant personnel also participate in the St. Charles Parish Business Association to encourage discussions of business growth and opportunity in the Parish. Other community involvement includes the United Way of St. Charles, River Parishes Industrial Relations, the St. Charles Mutual Aid Organization, and the St. Charles Business Expo. Over the past five years the Taft Plant has received the following safety and environmental awards: Environmental Awards: - Recipient of OxyChem 1997 Environmental Excellence Award for outstanding environmental performance. - Recipient of 1997 OxyChem Environmental Merit Award for three consecutive years of meritorious achievement. - Recipient of OxyChem 1996 Environmental Merit Award for outstanding environmental performance. - Recognized as an Environmental Leadership Facility for commitment to the principles of the Lo uisiana Environmental Leadership Pollution Prevention. Safety Awards: - Recipient of OxyChem President's Gold Star Award for achieving 4 years without a recordable accident in April 1999. - Recipient of OxyChem President's Gold Star Award for achieving 2,000,000 man-hours without a recordable accident in September 1998. - Recipient of OxyChem President's Gold Star Award for achieving 3 years without a recordable accident in April 1998. - Recipient of OxyChem President's Silver Star Award for achieving 1,500,000 man-hours without a recordable accident in October 1997. - Award of merit from the National Safety Council for operating 2,306,236 hours without occupational injury or illness involving days away from work March 20, 1994-December 31, 1997. - Recipient of OxyChem President's Bronze Star Award for achieving 1,000,000 man-hours without a recordable accident in September 1996. - Recipient of Chlorine Institutes Chairman's Award for outstanding safety performance in 1996 OxyChem is committed to the safety of workers, the public, and the preservation of the environment through the prevention of accidental releases of hazardous substances. OxyChem implements reasonable controls to prevent foreseeable releases of hazardous substances. These controls include programs to train personnel, to help ensure safety in the design, installation, operation, and maintenance of processes, and to evaluate the hazards at the Taft plant. The Taft plant participates in auditing processes like OSHA VPP to measure and enhance its prevention program. 2. The Stationary Source and Regulated Substances Handled ( 68.155(b)): The Taft plant consists of two Chlor-Alkali plants which manufacture chlorine, caustic and hydrogen. There is also a sulfur monochloride manufacturing unit at Taft. The Taft complex has facilities to store, load, and ship the chlorine and the other materials. One Chlor-Alkali plant was constructed in 1966, the other plant in 1973. The Taft plant handles only one regulated substance that is covered by the RMP rule: chlorine. It is an RMP covered Program Level 3 process. Regulated Substance Process Largest Vessel Inventory, lbs. RMP Threshold, lb.* Chlorine Storage Tanks 1,392,000 2,500 * - Process and threshold quantity is the quantity of "pure" chemical, not of the solution Chlorine is one of the major products made at this facility. The primary purpose of this facility is to manufacture, store and ship chlorine, caustic, and hydrogen gas. The daily production of the liquid chlorine is collected in five 600-ton or three 400-ton chlorine storage tanks. The chlorine from these tanks is shipped by pipelines and railcars to customers. The facility complies with the Department of Transportation (DOT) regulations in the loading and shipment of the chlorine product. The facility also uses best practi ces and Chlorine Institute recommended practices in its operations. The chlorine is used in a number of household products, and is also purchased by other industries as a raw material. OxyChem is committed to meeting the needs of its customers and continuously improving the quality of its products resulting in increased customer satisfaction. In June 1993, the Taft plant became ISO 9002 registered. 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 Taft plant has performed off-site consequence analysis to estimate the potential for accidental release of a regulated substance to 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" for each toxic in a process over the threshold quantity. In reality, however, OxyChem does not expect the worst-case release scenario to occur. The alternative release scenarios are developed to help the Local Emergency Planning Committee, LEPC, and the Department of Emergency Preparedness, DEP, improve the community emergency response plan. EPA Comp was used for evaluating the distance to the toxic endpoint for the worst-case and alternate case scenarios. The meteorological data used for the modeling was the EPA default. The EPA recommended Landview program was utilized to estimate the number of people living within this distance from the location of the storage tank. United States Geological Survey (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 Taft plant: 3.1 Toxic Substances - Chlorine The "worst-case release scenario" for chlorine is the failure of one of the largest chlorine storage tanks which would re lease 1,392,000 pounds of liquid chlorine in a 10-minute period as required by EPA. It is assumed that all of the liquid chlorine vaporizes within the 10-minute time period. Although the facility limits the inventory level in the tank to 90%, it was not used in the scenario. The worst case release scenario was evaluated following EPA's Comp software. 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 U.S. Census indicates that 847,183 people live within this distance from tank; several public receptors are also located within this distance, including residences, schools, hospitals, prisons, recreational and industrial areas. Environmental receptors located within this distance include Indian Mounds near Grand Point. In addition, Salvador and Manchac Sta te Wildlife Management Areas are included within this distance. The "alternative case release scenario" is a 1/4 inch hole in a tank outlet pipe in the #2 Chlor-Alkali plant which results in a release of 8,400 pounds of chlorine over a 120 minute duration. The alternate case release scenario was evaluated following EPA's Comp software. Under the EPA default worst weather conditions, the chlorine gas cloud would travel 0.2 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). There are no residences within a 0.2 mile radius of the alternate case scenario. The only public receptors are commercial and industrial areas. There are no environmental receptors. Perimeter monitors around the facility will notify plant personnel of a possible leak in the piping. 3.2 Program 3 Processes-Flammable Substances There are no regulated flammable substances in quantities above the thr eshold quantities at the plant. 4. The General Accidental Release Prevention Program and the Specific Prevention Steps ( 68.155(d)): The Taft plant has always had prevention and maintenance programs in place to help prevent accidental releases of hazardous substances. Beginning in May 1992, the plant revised and integrated these programs for the chlorine manufacturing and storage processes to comply with the 14 elements of the OSHA Process Safety Management (PSM) prevention program (29 CFR part 1910.119). The facility is currently in compliance with the PSM program. The Taft plant complies with the EPA's Accidental Release Prevention Rule (40 CFR part 68) which was promulgated in 1996. As a participant in the OSHA Voluntary Participation Program (VPP), the facility has had an initial audit and a recertification audit both conducted by OSHA to maintain program status since 1994. Since 1994 the Taft plant has been listed as an OSHA Star facility, the highest ranking by OSHA for a plant's safety program. 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 fence line. It is the EPA's intention that facilities develop one prevention program to protect both worker safety, the public, and the environment. The following sections briefly describe the elements of the Taft plant's Program 3 prevention program that address EPA's RMP rule prevention program requirements. The Taft plant's Program 3 prevention program consists of the following 12 elements: 4.1 Process Safety Information The Taft plant maintains a variety of 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 safe ty information is available to all employees, the LEPC, the DEP, the local fire department, the St. Charles Parish hospital, and the police. Material safety data sheets (MSDS) 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: - Toxicity information and permissible exposure limits - Physical data (e.g., boiling point, melting point, flash point) - Reactivity and corrosivity data - Thermal and chemical stability data - Hazards of mixing substances in the process MSDSs for hazardous substances handled in each process are available from the plant's Safety Department or the Site Coordinator. In addition, key MSDS are provided to the LEPC and DEP 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 c overed process. The available information includes: - Operating parameters - Block flow or simplified process flow diagrams - Process chemistry - Maximum intended inventories - Safe upper and lower limits for parameters such as temperature, pressure, or flow - Consequences of deviations from established operating limits - Design basis and configuration of equipment - Piping and instrumentation diagrams, including materials of construction - Electrical classification - Safety systems - Applicable design codes and standards - Design basis for relief and ventilation systems When important information is not available from the design documents, it was developed through special projects, or, in the case of operating parameters, during process hazard analysis of the process. Operating manuals contain the process objectives, process chemistry, overview of the process operations, critical process variables with consequences of deviations, equipment and instruments descriptions, troubleshooti ng 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. 4.2 Process Hazard Analysis The Taft plant performs and updates, within every 5 years as required by OSHA and the EPA rule, process hazard analyses (PHA) 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 enhance t he safety of the process are implemented. 4.3 Operating Procedures The Taft plant process engineers, operators 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: - Steps for safely conducting activities, - Applicable process safety information, such as safe operating limits and consequences of process deviations, and - 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 shutdown, startup following a tu rnaround 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. 4.4 Training The Taft plant trains its workers to safely and effectively perform their assigned tasks. The training program includes both initial and refresher training within every three years 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 were consulted to determine the frequency of refresher training.. 4.5 Mechanical Integrity The Taft plant maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger workers, the public or the environment. The mec hanical integrity program includes (1) an inspection and testing program to help identify equipment deterioration and damage 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. Some of the program high lights include: - Specifications for inspection and testing of process equipment - Specifications for replacement parts and equipment - Procedures for inspecting, testing and maintaining process equipment - Procedures for safe work practices such as Lock, Tag and Try; Hot Work; Confined Space Entry; and Line Breaking - Training of maintenance personnel - Documentation of maintenance activities 4.6 Management of Change The Taft plant management of change 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. 4.7 Pre-Startup Review The Taft plant performs a safety review through our MOC 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: - Construction and equipment are in accordance with design specifications - Adequate safety, operating, maintenance and emergency procedures are in place - Employee training has been completed - For a covered process, a PHA has been performe d if the process is new or management of change requirements have been completed if an existing process has been modified The management of change 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 to ensure that appropriate issues have been addressed. 4.8 Compliance Audit The Taft plant audits covered processes every 3 years to be certain that the prevention program is effectively 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 enhanc ements to the prevention program are implemented. Both Occidental Petroleum Corporation and Occidental Chemical Corporation perform audits of the facility programs, process and documentation at regular intervals. Action plans are completed in a timely fashion. 4.9 Incident Investigation The Taft plant investigates incidents, including near misses, that could reasonably have resulted in a serious injury to personnel, the public or 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 within 48 hours of the incident. The results of the investigation are documented, recommendations are resolved and appropriate process enhancements are implemented. OxyChem has a formal program including training for incident investigations and the report generation. 4.10 Employee Participation The Taft 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, MOCs and operating procedures. 4.11 Hot Work Permits The Taft plant established a hot work permit program to control spark 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 Form to comply with these requirements. Personnel who are to perform hot work are required to fill out the Hot Work Permit Form. The area operator reviews the completed form before work can begin unless the work is in a designated flammable area. Operations coord inator reviews the completed permit form before work is began in designated flammable areas. Training in the use of the Hot Work Permit Form is included in the plant's safe work practices orientation. 4.12 Contractors The Taft 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 supervisors 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 tha t safe practices are followed. 5. Five-year Accident History ( 68.155(e)): The Taft plant has had no accidents which meet the criteria outlined in 40 CFR 68.155(e). OxyChem maintains records for all accidental chemical releases and environmental incidents which occur at the Taft plant. OxyChem conducts formal investigations to identify and correct the root causes of each event. 6. The Emergency Response Program ( 68.155(f)). The Taft plant has established a written emergency response plan and maintains an emergency response team trained in these emergency response procedures. All plant personnel are trained in evacuation procedures. The written emergency response plan complies with the following federal and state contingency plan regulations: - OSHA 29 CFR 1910.38(a) - Employee Emergency Action Plans - OSHA 29 CFR 1910.119 (n) - Process Safety Management of Highly Hazardous Chemicals - OSHA 29 CFR 1910.120(p) and (q) - Hazardous Waste Operations and Emergency Response (HA ZWOPER) - OSHA 29 CFR 1910, Subpart L - Fire Protection - EPA 40 CFR 302.6 - Notification Requirements - EPA 40 CFR 355.30 - Facility Coordinator and Emergency Response Plan - EPA 40 CFR 355.40 - Emergency Planning and Release Notifications - EPA 40 CFR 112 - Spill Prevention, Control and Countermeasures Plan - EPA 40 CFR 68 - Risk Management Programs for Chemical Accidental Release Prevention - EPCRA Section 302 - List of Extremely Hazardous Substances - LDEQ LAC 33:I.3901 - Notification Regulations for Unauthorized Discharges - LDEQ LAC 33:V Subpart 2 Chapter 101.10111 - Release Reporting The Taft plant has a Chemical Emergency Response Plan (CERP) team available 24 hours per day to respond to in-plant chemical emergencies. The team maintains a mobile chemical emergency command center equipped with the necessary equipment to respond to chlorine emergencies. The Emergency Response Plan is communicated to all plant personnel and contractors annually, and employee emergency responder s receive additional training annually based on job responsibilities. There is a full-time plant nurse at the Taft plant, and a plant physician who provides on-site physicals and services one day per week and 24-hour on call coverage for emergencies. The St. Charles Hospital is available 24 hours per day for emergencies. The Hospital has been contracted to provide ambulance services for the Taft plant. The Taft plant uses a SAFER Real Time modeling program to assess release impacts if any and to aid in the determination of response activity. The Taft plant has a community alert system available through the Department of Emergency Preparedness at the St. Charles Parish Courthouse in Hahnville, Louisiana to notify the public of a potential or actual hazardous situation. In addition, the Taft plant has developed a Special Situations Plan which is a program designed for responding to emergencies that may have impacts beyond the immediate plant and is a supplement to the Emergency Resp onse 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 Taft plant is an active participant in the community planning process with the St. Charles Parish Local Emergency Planning Committee. A copy of the Taft plant's Emergency Response Plan has been forwarded to the Department of Emergency Preparedness as per the requirements of 40 CFR part 355. The Taft plant is an active participant in and is committed to the Chemical Manufacturer's Association's Responsible Care initiative conducting annual assessments of the plant's compliance effort. The Taft plant was involved in a community-wide effort to develop RMP programs with other industries in St. Charles parish, and is available to provide technical support to small businesses in need of assistance to develop and RMP program. The Special Situation Plan has been developed that defines the roles and resp onsibilities of employees that are involved in an emergency but are not directly involved in the on-scene response. The Special Situation Plan has four specialized teams that have been trained to work with the public for recovery purposes, to coordinate activities with the press, assist family members of employees, and serve as telephone operators. Communication of relevant and useful emergency response planning information is shared with the DEP and LEPC. Also, the Taft plant works with other facilities in the area to share emergency response information. Currently, the local community response plan is well developed and integrated into the Taft plant plan. Information and experiences are also communicated through the Community Advisory Panel. Facility tours are given at the Taft plant for outside emergency responders to promote emergency preparedness and to provide current knowledge of facility operations. 7. Planned Changes to Improve Safety ( 68.155(g)). The Taft plant co nstantly strives to improve the safety of the processes through annual reviews of our plant procedures, near misses and incident investigation programs, auditing programs, and a program soliciting safety and environmental suggestions from the plant employees. 8.0 Certification Statement for Program Level 2 & 3 Processes: To the best of the undersigned's knowledge, information, and belief formed after reasonable inquiry, the information submitted is true, accurate, and complete. Ron Loving* Ron Loving Signature Print Name Plant Manger 5/25/99 Title Date * - Original signature is on attached certification statement. Page 10 of 10 06/14/99 |