Oxy Vinyls, LP - Executive Summary

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Oxy Vinyls, LP Pedricktown PVC Plant manufactures polyvinyl chloride (PVC) resin from polymerization of vinyl chloride.  Oxy Vinyls, LP ("OxyVinyls") is a joint venture between Occidental Chemical Corporation and Geon Company.  The facility is located in Pedricktown, NJ (Salem County) at the intersection of U.S. Route 130 and Porcupine Road. Part of a facility constructed by the BFGoodrich Company in the late 1960's, it became part of the Geon Company in 1993 prior to the creation of the joint venture in May of 1999.  It currently employs 42 full-time employees.  Activities or historical events described in the following summary, if dated before May, 1999, occurred when the facility was part of either BFGoodrich or Geon. 
1.  Accidental Release Prevention and Emergency Response Policies at the Stationary Source  (' 68.155(a)): 
OxyVinyls is committed to operating the Pedricktown 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, OxyVinyls 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 Pedricktown 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 at the Pedricktown PVC Plant. 
The RMP at the Pedricktown PVC Plant consists of the following three elements: 
7 A hazard assessment to help understand (a) the potential off-site consequ 
ences of hypothetical accidental releases and (b) accidents that have occurred during the last five years associated with the use of substances regulated by the RMP rule; 
7 A prevention program to help maintain and safely operate the covered processes containing, or with the potential of involving, more than a threshold quantity of a 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 Pedricktown 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 Pedricktown PVC Plant.  In fact, the Pedricktown 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 injuries and damage  
from such a release. 
OxyVinyls' policy on the use of hazardous substances:  Before using a hazardous substance at the Pedricktown PVC Plant, less hazardous alternatives are always considered. When a hazardous substance is used at the Pedricktown PVC Plant, the plant personnel review the potential for an accidental release of this substance (which could adversely affect plant workers, the public and the environment) and takes steps to prevent any such effects.  This is accomplished through the facility's Management of Change (MOC) and Process Hazard Assessment (PHA) procedures, which 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:  OxyVinyls implements reasonable controls to prevent foreseeable releases of hazardous substances.  When a hazardous substance is used at the Pedricktown PVC Plant, the equipment is carefully designed, installed, operated and main 
tained 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' 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, OxyVinyls requires the documentation of standard operating procedures and training of affected employees with regard to these procedures as part of the MOC procedure.  OxyVinyls' 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 an accidental release:  In the event of an accidental release, the Pedricktown 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. O 
xyVinyls utilizes emergency response plans as required by government regulation. OxyVinyls trains its workers to respond to an accidental release, reducing the consequences of a release if it occurs.  OxyVinyls also has established a Special Situations Center in the Dallas corporate office to support the Pedricktown PVC Plant in assisting workers, their families and the public during and after all emergencies.  In addition, the Pedricktown facility has been an active member of the Salem County Hazardous Materials Advisory Council, one of the key reasons that this county was the first in the United States to have an approved Emergency Response plan in full compliance with the EPA's Emergency Planning and Community Right To Know Act (EPCRA).  The plant continues to work closely with the emergency response community, the public and other concerned industrial facilities to better prepare for emergencies that may impact our area. The Pedricktown Plant is a major contributor in time, experti 
se and other resources in the training and equipping of local volunteer emergency response personnel. 
The Pedricktown PVC Plant's emergency response plan has been developed to meet the emergency planning, response and notification requirements of the Federal, OSHA, and EPA regulations, as well as OxyVinyls' guidelines. This plan outlines the responsibilities and actions required for control of an emergency within the boundaries of the Pedricktown PVC Plant.  If the emergency extends beyond or potentially extends beyond the plant boundaries, the Pedricktown PVC Plant's emergency plan has been developed to notify, assist and fully cooperate with local, state and federal emergency response units.   The OxyVinyls plant contributes knowledgeable and trained staff toward the industrial complex's emergency response team, which also contains members from BFGoodrich and Geon. 
OxyVinyls is an active participant in the community:  OxyVinyls is an active participant in employee and community pro 
grams, which promote education, safety and environmental awareness.  The facility involves employees in designing, implementing and maintaining safety programs.  Safety is a primary concern in our facility.  
OxyVinyls is an industry leader in the implementation of the Chemical Manufacturer's Association sponsored Responsible Care. initiative. As part of the Responsible Care. efforts, the Pedricktown PVC Plant assisted in formation of the Salem County Hazardous Materials Advisory Council in 1987 and has been actively involved in this organization since its inception.  By involving the efforts of governmental representatives, volunteer emergency response units, hazardous material transporters, industrial facilities, medical care facilities and the state police emergency response experts, the HMAC anticipates the nature and scope of emergencies which might occur, plans for an effective and coordinated response and puts these plans into practice. Through this outreach effort, as well as o 
ther community involvement, the plant stays informed of community concerns and works to address them.   
2.  The Stationary Source and Regulated Substances Handled (' 68.155(b)): 
The Pedricktown PVC Plant handles one regulated flammable substance (vinyl chloride) and one regulated toxic substance (anhydrous ammonia) that are covered by the RMP rule; The process in which these materials are handled is a Program Level 3 process. 
Vinyl Chloride is the primary feedstock for the Pedricktown PVC Plant, both for the OxyVinyls operations and the Geon Company operation. The primary purpose of the OxyVinyls facility is to manufacture, store and ship PVC resin.  Vinyl chloride is delivered by railcar, to two large storage spheres, from other OxyVinyls sites located in Deer Park, TX or LaPorte, TX. The vinyl chloride 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 (PV 
C) resin in a water slurry solution.  After drying, the PVC resin is then transferred and stored in silos until loaded into railcars, hopper trucks or bags for shipment to customers. 
The facility and railcars 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 Pedricktown PVC Plant performed off-site consequence analysis to estimate the potential for the accidental release of a regulated substance that might effect the public or the environment.  The RMP rule requires the off-site consequence analysis to evaluate a "worst-case release scenario " and an "alternative release scenario." for both vinyl chloride and anyhdrous ammonia.   In reality, however, OxyVinyls does not expect a worst-case release scenario to ever occur.  The alternative release scenarios are develop 
ed 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 and alternate release scenarios.  Various sources, including USGS maps, street atlases and actual field surveying was used to estimate the number of people living within this 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 Pedricktown PVC Plant: 
3.1 Program 3 Processes -Toxic Substances 
The "worst case scenario" for anhydrous ammonia is the failure of the high pressure receiver in the refrigeration area, which was assumed to release all 10080 pounds (1540 gallons) within a 10 minute period, with simultaneous failure of all safety systems, as mandated by EPA. The distance to the toxic endpoint of 0.14 mg/L is 1.8 miles. 
It is important to note that 0.14 mg/L is the concentration of ammonia that 
EPA believes someone could be exposed to for one hour without experiencing or developing "irreversible or serious health effects or symptoms which could impair an individual's ability to take protective action". 
The Pedricktown PVC Plant is located in a rural section of Salem County, and it has been estimated that, in addition to the persons working in the industrial complex of BFGoodrich, Geon, OxyVinyls and Pedricktown Cogeneration Limited Partnership facilities, there are approximately 2,900 residents who live within the 1.80 miles of this very unlikely release. OxyVinyls is sharing all RMP information with these industrial sites and their employees, the same as if they were residential receptors. 
The "alternative release scenario" for ammonia is a failure of a pipeline in the refrigeration system that would cause the release of 1900 pounds of ammonia over a 10 minute period.  Passive and active safety systems, including dikes and berms, water spray and alarm systems are expected 
to reduce the impact zone of this to a radius of 0.3 miles.  There are no residential dwellings within this distance of the release point. 
3.2 Program 3 Processes - Flammable Substances 
The "worst-case release scenario" for vinyl chloride is the failure of one of the storage spheres, which was assumed to release all 3,200,000 pounds of vinyl chloride in a 10-minute period with simulatneous failure of all safety systems, 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 Pedricktown PVC Plant is located in a rural section of Salem County, and it has been estimated that, in addition to the persons working in the industrial complex of BFGoodrich, Geon, OxyVinyls and the Pedricktown Cogeneration Lim 
ited Partnership facility, there are approximately 1,075 residents who live within the 0.86 miles of this very unlikely release. OxyVinyls is sharing all RMP information with these sites and their employees, the same as if they were residential receptors. 
The "alternative case release scenario" for vinyl chloride is the failure of a hose connection between a railcar and an unloading station. The amount released is 1,500 pounds (190 gallons) over 10 minutes.  The result is a vapor cloud fire.  The distance from the source to its endpoint is less than 317 feet, based upon EPA guidelines.  Active safety systems could further reduce area within this endpoint. There are no residential dwellings within this distance of the release point.  
4.  The General Accidental Release Prevention Program and the Specific Prevention Steps (' 68.155(d)): 
The Pedricktown 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 CareR in the late 1980's.  Beginning in 1989, the facility revised and upgraded these prevention programs to comply with the New Jersey Toxic Catastrophe Prevention Act, which applied to ammonia.  The facility voluntarily extended these prevention-based management systems to vinyl chloride in the early 1990's. Beginning in 1994, the plant further fine-tuned these prevention programs to comply with the 14 elements of the OSHA Process Safety Management (PSM) program.  RMP's Program 3, applicable for both vinyl chloride and ammonia at this site, is essentially 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 Pedricktown PVC Plant's RMP Program 3 prevention plan that address EPA's RMP requirements. 
4.1 Program 3 Prevention Program 
The Pedricktown PVC Plant's Program 3 prevention program consists  
of the following 12 elements: 
4.1.1 Process Safety Information 
The Pedricktown 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.  OxyVinyls 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 mixing substances in t 
he process. 
MSDS are available from the plant's H,E&S Manager. 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 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 "Pedricktown 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 configuration of equipment; 
7 Piping and instrumentation diagrams, 
including materials of construction; 
7 Electrical classification; 
7 Safety systems; 
7 Applicable design codes and standards; 
7 Design basis for relief and ventilation systems; 
7 Ventilation system design; 
7 Material and energy balances. 
These documents are used to (1) train employees, (2) perform process hazards analyses and (3) help maintain the equipment. 
4.1.2 Process Hazard Analysis 
The Pedricktown PVC Plant performs process hazard analyses (PHA's) of the covered processes to help identify process hazards and generate recommendations that might improve the safe operation of the process.  All RMP covered processes were initially reviewed using the HAZOP methodology by 1993, and all covered processes are re-validated at least every five years using the HAZOP methodology. 
A PHA team is typically composed of a leader with applicable PHA training and experience, a scribe, area representative (knowledgeable supervisor), area engineer, area operating technician, maintenance represent 
ative, and other representatives (as applicable).  A PHA report is written describing the results of the analysis.  Findings and recommendations are risk ranked; responsibilities are tracked through the plant's tracking software system. 
4.1.3 Operating Procedures 
The Pedricktown PVC Plant has a Training Coordinator, who has 25 years experience as an operator, and is trained in writing, development and modification of operating procedures.  The procedures 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 (Lockout/Tagout; Line Breaking; Equipment Isolation; 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 Pedricktown 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 ov 
erview of the process, (2) the properties and hazards of the substances in the process and (3) a detailed review of the process operating procedures and safe work practices for applicable personnel. Oral reviews and written tests are used to verify that an employee understands the training material before the employee can start work in the process. Employees involved in operating the process 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 and are re-certified every 3 years. 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 p 
rogram are implemented as appropriate.  Training is documented using the "TRIM" software package; and training files are maintained by the Training Coordinator. 
4.1.5 Mechanical Integrity 
The Pedricktown 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 an 
d 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 Pedricktown PVC Plant's Management Of Change (MOC) procedure sets requirements for reviews and approvals of all proposed changes to equipment and procedures for a covered process to help ensure that the change does not negatively affect safe operations.  All new chemicals, or chemicals used in new applications, are subject to review by the New Chemical Review Committee (NCRC).  The MOC and NCRC procedures ensure that the affected employees are notified of the changes, training is provided, and that process safety information and procedures are updated.  Plant personnel receive training on how to identify potenti 
al changes and the types of changes that are covered by the MOC procedure. 
4.1.7 Pre-startup Review 
The Pedricktown 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, majo 
r modifications and/or start up of existing processes that have been shut down for more than six months. 
4.1.8 Compliance Audit 
The Pedricktown PVC Plant audits covered processes every year to be certain that the prevention programs are effectively addressing the safety issues of process. Approximately every three years, the Corporate office performs a detailed "Coordinated Safety Audit".  On an annual basis, the facility performs a self-audit to review the compliance status under the New Jersey Toxic Catastrophe Prevention Act regulations, which encompass the Risk Management Program elements. The plant and corporate audits 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.   
4.1.9 Incident Investigation 
The Pedricktown PVC Plant has an "Experience Value Incident Reporting and Investiga 
tion 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 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 by the H,E&S Manager.  Information on all incidents is shared with all employees.  More serious incidents are reviewed with affected employees during special sessions when applicable. 
OxyVinyls has a formal program including training for incident investigations and the report generation.   
The H,E&S Manager retains incident investigation reports for the last five years.  
4.1.10 Employee Participation 
The Pedricktown 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 (OxyVinyls or contractor) can address 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 procedures, operating procedures, and maintenance procedures.  They participate in, and are informed about, all aspects of the Process Safety Management and RMP rule prevention program, including PHA's, MOC's and other aspects.  
4.1.11 Hot Work  
The Pedricktown 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 orientation and refresher training. 
4.1.12 Contractors 
The Pedricktown 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 saf 
e 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 facility that met the EPA Risk Management Program reporting requirements with respect to injuries or offsite environmental effects involving a release of vinyl chloride or ammonia.  
6. The emergency response program (' 68.155(f)). 
The Pedricktown PVC Plant has established a written emergency response plan and maintains an emergency response team trained in emergency response procedures.  The team is comprised of employees from BFGoodrich, Geon and OxyVinyls. The written emergency response plan complies with the following federal and state contingency plan regulations: 
7 OSHA 29 CFR 1910.38(a) - Employee Emergency Action Plans; 
7 OSHA 29 CFR 1910.119 (n) - Process Safety Management of Highly Hazardous Chemicals; 
7 OSHA 29 CFR 1910.120(p) and (q) -  Hazardous Waste Operations and Emergency  
Response (HAZWOPER); 
7 OSHA 29 CFR 1910, Subpart L - Fire Protection; 
7 EPA 40 CFR 302.6 - Notification Requirements; 
7 EPA 40 CFR 355.30 - Facility Coordinator and Emergency Response Plan; 
7 EPA 40 CFR 355.40 - Emergency Planning and Release Notifications; 
7 EPA 40 CFR 112 - Spill Prevention, Control and Countermeasures Plan; 
7 EPA 40 CFR 68 - Risk Management Programs for Chemical Accidental Release Prevention. 
The Pedricktown PVC Plant is a member and actively participates in the Salem County Hazardous Material Advisory Council and the Tri-State Mutual Aid organizations.  These groups have been established to coordinate and assist member companies with industry emergencies. The Pedricktown PVC Plant also actively works with the Oldmans Township Local Emergency Planning Committee (LEPC). 
In addition, the Pedricktown 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, which can provide additional assistance. 
The Pedricktown PVC Plant, as part of a group of concerned local industries, presented detailed information regarding their Risk Management Program activities to the press and the members of the general public in a series of well-publicized outreach efforts, the most recent occuring on May 1, 1999. The plant has actively presented information concerning the RMP program and specific facility information, including the worst-case release and alternate release scenarios, to the community.   
7.   Planned Changes to Improve Safety (' 68.155(g)). 
The Pedricktown PVC Plant constantly tries to improve 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 Karenanne R. O'Brien *, Plant Manager, on June 18, 1999. 
*  The Certification with original signature is included with this RMP submittal.
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