Occidental Chemical Corporation - Niagara Plant - Executive Summary

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Occidental Chemical Corporation (OxyChem), a wholly owned subsidiary of Occidental Petroleum Corporation (OPC), owns and operates a chlor-alkali  and specialty chemicals manufacturing facility in Niagara Falls, New York.  This facility is known as the Niagara Falls Plant and is located in the city of Niagara Falls on Buffalo Avenue.  The Chlor-Alkali facility consists of a plant which manufactures chlorine, caustic, hydrogen and also has facilities to store,  load and ship chlorine.  The Specialty Chemical areas main emphasis is the chlorination and fluorination of toluene.  Other operations include production of nitrile compounds, flame retardants, and muriatic acid. The Niagara Plant facility was originally constructed in 1906 and currently employs 650 full-time employees. 
1.  Accidental Release Prevention and Emergency Response Policies at the Stationary Source  (' 68.155(a)): 
OxyChem is committed to operating the Niagara Falls plant in a manner that is s 
afe for its workers, the public and the environment.  It is our policy to adhere to all applicable Federal, State and local rules and regulations, industry standards and best practices.  As part of this commitment, OxyChem has established a system to help ensure safe operation of the processes at this facility  which includes the prevention of accidental releases of hazardous substances.  One component of this system is a risk management program (RMP) that helps manage the risks at the Niagara Falls 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's PSM regulation 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 Niagara Falls Plant. 
The RMP at the Niagara Falls 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 processes) 
* 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 Niagara Falls Plant helps provide assurance that the facility is maintained and operated in a safe manner, it is only one component of the safety and environmental program at the Niagara Falls Plant.  In fact, the Niagara Falls Plant has a comprehensive safety and environmental program in place, establishing many levels of saf 
eguards against release of a hazardous substance as well as injuries and damage from such a release. 
Facility's policy on the use of hazardous substances:  Before using a hazardous substance at the Niagara Falls Plant, less hazardous alternatives are always considered.  When a hazardous substance is used at the Niagara Falls Plant, it is reviewed to understand the potential for an accidental release of this substance which could adversely affect plant workers, the public and the environment, and then steps are taken to prevent any such effects.  This is accomplished through the facility's Management of Change (MOC) and Process Hazard Review (PHR) procedures which are followed for all new installations or modifications to existing processes. 
The Facility strives to prevent accidental releases of  hazardous substances used:  The Niagara Falls Plant implements reasonable controls to prevent foreseeable releases of hazardous substances. When a hazardous substance is used at the Niagara F 
alls 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.  The facility also uses the Corporate Fire, Safety and Environmental (FS&E) Guidelines when designing new or making significant modifications to 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's mechanical integrity program provides an ongoing process to verify the mechanical integrity of the equipment, piping and instruments to prevent the release of hazardous substances. 
The Facility's goal is to minimize impacts from an accidental release:  In the event of an accidental release, the Niagara Falls Plant controls and  
contains the release in a manner that will be safe for workers and will minimize the impact to the public and the environment. The Niagara Falls Plant utilizes emergency response plans as required by government regulations and maintains an active Emergency Response Team which is on call 24 hours a day to respond to an accidental chemical release.  OxyChem also has established a Special Situations Center at the corporate headquarters in Dallas, Texas to assist in all emergency situations. In addition, The Niagara Falls Plant works with the local fire department and with the local emergency planning committee (LEPC) to help prevent injuries and/or environmental damage if a release does occur.   
Niagara Falls Plant's emergency response plan has been developed to meet the emergency planning, response and notification requirements of the Federal, OSHA, and EPA regulations.  This plan outlines the responsibilities and actions required to control an emergency that limits itself to within the 
Niagara Falls Plant.  If the emergency extends beyond the plant boundaries and affects the surrounding communities, the Niagara Falls Community Awareness & Emergency Response (CAER) Plan is initiated by a call to 911 and a statement of the type of emergency. 
The Facility is an active participant in the community:  The Niagara Plant is an active participant in plant and community programs which promote education, safety and environmental awareness.  Safety is a primary concern in our facility and is demonstrated by our selection by OSHA in June, 1996 as an OSHA Star facility under  OSHA's Voluntary Protection Program (VPP), in which employee participation at all levels is required in designing, implementing and maintaining safety programs.  
The Niagara Falls Plant is an industry leader in the implementation of the Chemical Manufacturer's Association sponsored Responsible Care(r) Initiative. As part of OxyChem's Responsible Care(r) efforts, the Niagara Falls plant has voluntarily been 
involved in a Community Advisory Panel (CAP) since 1991. The purpose of this group is to share information about  plant operations with members of the community and to discuss their concerns.  The group meets periodically and covers topics of interest to the members including plant safety and environmental performance, emergency response programs, health issues and process safety performance.  Through this outreach effort, as well as other community involvement, the plant stays abreast of community concerns and works to address them. 
In order to effectively implement these policies, OxyChem 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 Niagara Falls Plant handles four regulated substances that are covered by the RMP rule, as shown in the following list of RMP-covered Program Level 3 processes at th 
e plant. 
Regulated Substance 
Largest  Vessel Inventory, lb. 
RMP Threshold, lb.* 
Storage Tanks 
Hydrofluoric Acid 
Rail Car 
Sulfur Trioxide 
Storage tank 
Sulfur Dioxide 
Rail Car 
*  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, liquefy, store and ship chlorine, related alkaline co-products, hydrogen gas and chlorine based specialty products. The daily production of the liquid chlorine is collected in three (3) 600-ton storage tanks and two (2) 150-ton vaporizer feed tanks.   The 600-ton chlorine tanks are operated in batch mode and are filled to only 85% of capacity as a safeguard.  The chlorine from these tanks is shipped to wholesale customers via, 55-ton and 90-ton rail cars.  The two 150-ton chlorine vaporizer feed tanks operate in continuo 
us mode  and the chlorine is used internally as a raw material for the manufacture of other Niagara Falls Plant specialty products.  As a safeguard, the two vaporizer feed tanks are also filled to only 85% of capacity.  The facility complies with the Department of Transportation (DOT) regulations in the loading and shipment of the Chlorine product.  The facility also uses best practices and Chlorine Institute recommended practices in its operations.  One ton containers of liquid chlorine are utilized within the facility for cooling water system treatment. 
     Hydrofluoric Acid (HF) is a major raw material used to produce fluorinated specialty chemical intermediates.  Among these are several grades of Oxsol solvents which meet stringent air quality standards.  Hydrofluoric acid is supplied via 90 ton rail cars.  The rail cars are positioned inside a fully enclosed refrigerated building which maintains the HF in a liquid state.  Liquid HF is then vaporized at a controlled rate as it e 
nters the process.  A dedicated vent and scrubber system exists for the HF handling area.   
Sulfur Trioxide (SO3) is purchased in solution dissolved in sulfuric acid and is commonly referred to as Oleum.  Oleum is a raw material used as a Sulfonating agent in a multi-step process to produce an organic chemical intermediate. The Oleum is received via 25 ton tank trucks.  The trucks are off loaded to a dedicated storage tank which feeds the process equipment.  The storage system has a fume scrubber to contain any SO3 vapors during the off loading process. 
Sulfur Dioxide (SO2) is a major raw material used to produce products for the photography and rubber manufacturing industries.  SO2 is received in 90-ton rail cars, which are connected to the process.  The sites where the 90-ton rail cars are used have dedicated control systems for the safe handling of this material.  There are safeguards installed to prevent over pressurizing the line, and automatic shutoff vales in place that clos 
e to isolate the tank car should line pressure loss be detected. 
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 Niagara Falls Plant 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."  In reality, however, OxyChem does not expect a worst-case release scenario to ever occur.  The alternative release scenarios are developed to help the LEPC improve the community emergency response plan.   
     EPA Look-Up Tables were used for evaluating the distance to the toxic endpoint for the worst-case scenario.  The TRACE model was used for alternative release scenarios to determine t 
he possible off-site consequences.  the meteorological data used for the modeling was the EPA default for the worst case and EPA suggested values for the alternative release scenario. The EPA recommended Landview program was utilized to estimate the number of people living within the affected distance from the location of each scenario.   It should be noted that the Canadian population is not included in these values.  USGS maps were utilized to identify the public and environmental receptors located within the affected distance. 
The following information summarizes the off-site consequence analysis performed by the Niagara Falls Plant: 
3.1.a  Toxic Substances - Chlorine 
The "worst-case release scenario" for chlorine is the total failure of one of the three chlorine storage tanks which would release 600 tons of liquid chlorine in a 10-minute period as mandated by EPA.  It is assumed that the liquid chlorine vaporizes within the 10-minute time period.  The worst case release scenario 
was evaluated following EPA's Look-Up Tables identified in the Offsite Consequence Analysis Guidance Document.  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 1,100,000 people live within this distance from this storage vessel.  There are both public and environmental receptors within this distance. 
The "alternative case release scenario" for chlorine is the failure of a 1.5-inch loading hose connected from the liquid chlorine tank car loading header to a rail car releasing 528 pounds of chlorine in a 10 second period.  The Toxic Release Analysis for Chemical Emission (TRACE) model, which is based on our Systematic Approach For Emergency Response (SAFER ) modeling system, was used for alternative release scenarios to determi 
ne the off-site consequences.  Assuming a wind  
speed of 3 meters/sec, a (D) stability class and urban topography, the chlorine cloud would travel 1.5 miles before reaching a chlorine concentration of below 3 PPM (which is the endpoint Emergency Response Planning Guideline value established in the RMP rule).  The U.S. Census indicates that 8000 people live within this distance from the car loading spot.  There are both public and environmental receptors within this distance. 
3.1.b  Toxic Substances - Hydrogen Fluoride 
The "worst-case release scenario" for hydrofluoric acid:  The worst case scenario reported for Chlorine yielded the largest off-site consequences thus the worst case scenario for Hydrofluoric acid is not included. 
The "alternative case release scenario" for hydrofluoric acid is the failure of a three inch vapor line from the hydrogen fluoride vaporizer to the LPF reactors.  In this scenario  an automatic block valve fails to close in the line resulting in a release of 
406 pounds over a 90 second period.  The TRACE model was used for alternative release scenarios to determine the off-site consequences.  Assuming a wind speed of 3 meters/sec, a D stability class and urban topography, the hydrogen fluoride cloud would travel 1.7 miles before reaching a hydrogen fluoride concentration below 20 PPM (which is the endpoint Emergency Response Planning Guideline value established in the RMP rule).  The U.S. Census indicates that 10,000 people live within this distance from the car unloading spot.  There are both public and environmental receptors within this distance. 
3.1.c  Toxic Substances - Sulfur Trioxide  
The "worst-case release scenario" for Sulfur Trioxide: The worst case scenario reported for Chlorine yielded the largest off-site consequences thus the worst case scenario for Sulfur Trioxide is not included. 
The "alternative case release scenario" for Sulfur Trioxide is the failure of a 2 inch loading hose connected from a tank trailer to the stor 
age tank releasing 9400 pounds of Oleum (6100 pounds of Sulfur Trioxide) in a 10 minute period.  The TRACE model was used for alternative release scenarios to determine the off-site consequences.  Assuming a wind speed of 3 meters/sec, a D stability class and urban topography, the sulfur trioxide cloud would travel 1.5 miles before reaching a sulfur trioxide concentration of below 3 PPM (which is the endpoint Emergency Response Planning Guideline value established in the RMP rule).  The U.S. Census indicates that 7500 people live within this distance from the car unloading spot.   There are both public and environmental receptors within this distance. 
3.1.d  Toxic Substances - Sulfur Dioxide 
The "worst-case release scenario" for sulfur dioxide:  The worst case scenario reported for Chlorine yielded the largest off-site consequences thus the worst case scenario for Sulfur dioxide is not included. 
The "alternative case release scenario" for sulfur dioxide is a severed unloading  
hose at the tank car unloading spot, with associated failure of the automatic shutoff valve on the downstream side of the hose.  A pressure switch detects the loss of pressure associated with the severed hose, and interlocks shut off the nitrogen pressurizing the car and also shuts the liquid SO2 valve at the tank car side of the hose.  The pipeline to the process would empty, as would the SO2 vaporizer contents.  A total release of approximately 594 pounds would occur.    The TRACE model was used for alternative release scenarios to determine the off-site consequences.  Assuming a wind speed of 3 meters/sec, a D stability class and urban topography, the sulfur dioxide cloud would travel 1.0 mile before reaching a concentration below 3 PPM (which is the endpoint Emergency Response Planning Guideline value established in the RMP rule).  The U.S. Census indicates that 2100 people live within this distance from the release location.  There are both public and environmental receptors withi 
n this distance. 
3.2 Program 3 Processes-Flammable Substances 
There are no regulated flammable substances in quantities above the threshold quantities at the plant.   
4.  The General Accidental Release Prevention Program and the Specific Prevention Steps (' 68.155(d)): 
Since 1990, the Niagara Falls Plant has used a prevention program to help prevent accidental releases of hazardous substances in complying with  Extremely Hazardous Substance Regulations.  Beginning in 1994, the plant revised this prevention program for the chlorine manufacturing and storage processes to comply with the 14 elements of the OSHA Process Safety Management (PSM) prevention program.  In 1996, the EPA RMP rule established two levels of prevention requirements: 
This Program  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; 
The following sections briefly describe the elements of  EPA's RMP rule prevention  
program requirements. 
4.1 Niagara Plant Prevention Program 
The Niagara  Plant's  Prevention Program consists of the following 12 elements: 
4.1.1  Process Safety Information  
The Niagara Falls 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.  The Facility ensures that this process safety information is 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: 
* Toxicity information and permissible exposure limits  
* Physical data (e.g., boiling point, melting point, flash point)  
* Reacti 
vity and corrosivity data  
* Thermal and chemical stability data  
* Hazards of mixing substances in the process 
MSDS's for hazardous substances handled in each process are available from the plant's Safety Department.  Copies of the MSDS's for the hazardous substances within each operating area of the plant are maintained at the main gate computer station so that the operators have ready reference to this information.  In addition, key MSDS's are provided to the LEPC  for use in helping formulate emergency response plans. 
The engineering design documents include the operating parameters and the design basis and configuration of the equipment in each covered process.  The available information includes: 
* Operating parameters 
* Process flow diagrams 
* Process chemistry 
* Maximum intended inventories 
* Safe upper and lower limits for parameters such as temperature, pressure, or flow 
* Design basis and configuration of equipment 
* Piping and instrumentation diagrams, including material 
s of construction 
* Electrical classification 
* Safety systems 
* Applicable design codes and standards 
* Design basis for relief and ventilation systems 
Operating manuals contain the process objectives, process chemistry, overview of the process operations, critical process variables with consequences of deviations, equipment and instruments descriptions, troubleshooting guidelines, start-up and shut down procedures and equipment operating procedures.  
These documents are used to (1) train employees, (2) perform process hazards analyses and (3) help maintain the equipment. 
4.1.2 Process Hazard Analysis 
The Niagara Falls Plant performs and updates, within every 5 years as required by OSHA rule, process hazard analyses (PHA's) 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 or maintenance experience and a leader with proces 
s 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 the safety of the process are implemented. 
4.1.3 Operating Procedures 
Niagara Falls 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 o 
f process deviations 
* 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 turnaround or emergency shutdown and temporary operations.  The operating procedures are used both to help in operating the plant's processes and as a training guide. 
4.1.4 Training 
The Niagara Falls Plant trains its workers to safely and effectively perform their assigned tasks.  The operations training program includes both initial and refresher training that covers (1) a general overview of the process,  
(2) the properties and hazards of the substances in the process and (3) a detailed review of the process operating procedures and safe work practices.  Oral reviews and/or written tests are used to  
verify that an employee understands the training material before the employee can resume work in the process.  The Niagara Falls Plant Training Steering Committee, in conjunction with Area Advisory Committees, establishes procedures to facilitate two-way communication in the development and implementation of the training process.  Operators  participate in the Area Advisory Committee which reviews, identifies, and develops plans to address training needs in accordance with plant policy and OSHA compliance guidelines.  Additionally, operators, evaluate the effectiveness of the area training process. The maintenance training program consists of New York State Department Of Labor (DOL)  apprenticeship training, plant Safety Regulations (SR's) equipment specific training (where needed), detailed and advanced craft skill specific training and process specific safety (maintenance level II ) training. 
4.1.5 Mechanical Integrity 
The Niagara Falls Plant maintains the mechanical integrity of pr 
ocess 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 centers around the following: 
* 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 
4.1.6 Management of Change 
The Niagara Falls Plant management of change program ensures an evaluation and approval process for al 
l proposed changes to chemicals, equipment and procedures for a covered process to help ensure that the change does not negatively affect safe operations.  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 and trained if necessary. 
4.1.7 Pre-startup Review 
The Niagara Falls 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 p 
erformed 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 or as deemed necessary by the MOC administrators. 
4.1.8 Compliance Audit 
The Niagara Falls 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 and PSM rules and in the process, and this team evaluates whether the prevention program satisfies the requirements of the RMP rule and whether the prevention program is sufficient to help ensure safe operation of the process.  The results of the audit are documented, recommendations are resolved and 
appropriate enhancements to the prevention program are implemented. 
Both Occidental Petroleum Corporation and Occidental Chemical Corporation perform audits of the facility programs, process and documentation at regular intervals.  The facility is required to address all action items generated from these audits in a timely fashion. 
4.1.9 Incident Investigation 
The Niagara Falls 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 and/or safety enhancements are implemented. 
The Facility has a formal program including training for inciden 
t investigations and the report generation. 
4.1.10 Employee Participation 
The Niagara Falls 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 PHA's, OMC's and operating procedures. 
4.1.11 Hot Work Permits 
The Niagara Falls 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 obtain a Hot Work Permit from their shift supe 
rvisor.  Training in the use of the Hot Work Permit is included in the plant's safe work practices orientation. 
4.1.12 Contractors 
The Niagara Falls 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 supervisor's 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 on each job to help ensure that safe practices are followed. 
5.    Five-year Accident History  
(' 68.155(e)): 
     It is Niagara Falls Plant policy to investigate even minor incidents of chemical release in order to learn how to make system improvements.  There have been incidents of this nature investigated in the past 5 years related to the applicable RMP chemicals, which were not reportable under environmental regulations.  However, there have been no incidents resulting in community impact requiring evacuation, shelter in place, or response assistance from agencies or groups outside the Niagara plant except for standby alert or training drills.   
6.   The emergency response program (' 68.155(f)). 
The Niagara Falls 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 Emerge 
ncy 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 (HazWOPER) 
* 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 265 - RCRA Sub part D 
* EPA 40 CFR 68 - Risk Management Programs for Chemical Accidental Release Prevention. 
The Niagara Falls Plant has a Chemical Emergency Response Program Team (CERP) available 24 hours per day to respond to in plant chemical emergencies or off site transportation incidents involving hazardous materials.  The plant's CERP team serves as the Region 9 CHLOREP Regional Response Team for the northern Indiana and northeastern Illinois and backup team for Region 4 
(New York) to respond to chlorine emergencies. The team maintains a  mobile chemical emergency command center equipped with the necessary equipment to respond to chlorine emergencies. 
The Niagara Falls Plant uses a SAFER Real Time modeling program to assess release impacts if any and to aid in the determination of response activity. The Niagara Falls Plant has access to the Niagara County Community Alert Network (CAN) that is capable of making simultaneous phone calls to residents in various sectors of the county to provide information during an emergency event.  In addition to Plant Emergency Procedures, the Niagara Falls Plant has developed a Special Situations Plan  which is designed for addressing situations that may have an impact on the community.  The Special Situation Plan links the local response to the OxyChem Corporate Emergency Response Center located in Dallas, Texas.  Corporate resources and assistance can be provided as needed. 
The Niagara Falls Plant tests their emer 
gency preparedness by conducting emergency drills on a regular basis.  The facility has been a regular participant in drills sponsored by the local Emergency Planning Committee that has involved emergency response agencies from Niagara County, Erie County and Canada.  Additionally, the facility conducts plant drills in conjunction with local responders such as the Niagara Falls Fire Department. 
The Niagara Falls Plant is also an active member of the Niagara County Local Emergency Planning Committee (LEPC).  Membership on the LEPC includes representatives of government agencies, response organizations and local industry. This group is responsible for assuring that coordinated emergency response strategies exist to effectively handle emergency situations within Niagara County. 
7.  Planned Changes to Improve Safety (' 68.155(g)). 
The Niagara Falls Plant maintains an on going program attempting to improve the safety of processes by means of reviews of our plant procedures, near misses 
and incident investigation programs, and solicitation of safety and environmental suggestions from the plant employees.  
8.    Certification. 
To the best of the undersigned's knowledge, information, and belief formed after reasonable inquiry, the information submitted is true, accurate, and complete. 

Thomas F. Feeney 
Print Name 
Plant Manager                       

June 18, 1999 
*  Original signature is included in the attached cover letter.     
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