Document B5Q7w8pzNZjdQ47VaEKDnmDE8

fT.-U P'"* * INTEROFFICE MEMORANDUM DATE: August 29, 1996 TO: Herm Waltemate FROM: Bill Lesko/Safety RE: EPA Clean Air Act - RMP Rule OSHA 1910.119 PSM-Audit Status CC: Tim Manning Jim Lewis David Hinson John Gressler Ed Beeler Norm, We received your memo dated 8/16/96 concerning the EPA RMP rule and OSHA 1910.119 self-audit status. Regarding the EPA RMP rule, we have been following the progress of the legislation and intend to fully comply. We believe our worst case flammable scenario involves vinyl chloride, while our worst case toxic scenario will most probably be Anhydrous HCL (chlorine will probably make most probable toxic scenario). I will act as the facility's qualified person with overall responsibility for the development of the risk management program elements. However, l will work closely with David Hinson and Kathy Cameron to ensure all applicable environmental regulations and TNRCC requirements are met. In addition, the LaPorte Plant is involved with efforts by the Texas Chemical Council (TCC) and East Harris County Manufacturer's Association (EHCMA) to develop consistent scenario development and analysis protocols from plant to plant. This will help ensure that two different plants owned by two companies report semilar worst case scenarios and consequences for similar scenarios such as a chlorine rail car rupture. Regarding the PSM audit opportunities, the following table indicates progress in the following items: Number A9401 A9402 A9403 EP9404 PSI9405 Description Graphically illustrate PSM areas Develop a list of PSM chemicals in storage and process Develop a list of PSM materials, location Develop written employee participation procedure Develop index for information system to ensure all required dates Status fhiiiltimMUltir---n posted ^gg^lg^part of plant's Hazcom procedure k NGC 12246 PHA9406 PH9407 PHA9408 PHA9409 PHA9410 PHA9411 OP9412 OP9413 C9414 C9415 PSSR9416 MI9417 MI9418 in a file Revise the plant's PHA schedule and identify rationale for priority PHA's are scheduled according to risk and plant is on target for p completion by deadline PHA's must address facility siting and human factors complete with PHA's each address human factors. Facility siting will be appropriate documentation addressed in a separate HAZOP ^p per API RP 750 ^ Develop system to track recommendations to completion. ^BBjBpnt uses Corrective Acfloffiystem Communicate resolutions to appropriate people that work in the PSM area. Review incident reports involving In progress area to be HAZOP'd. Document a part of individual HAZOP Develop biography profile on each HAZOP team member. Include mm profile as part of individual HAZOP file Include as documentation the specific standard or code being appropriate considered which conducting PHA's Establish a system to certify annually that operating procedures are current and accurate and reflect existing proccess technology Complete revision to plant operating procedures to include consequence of deviation and warns safety system MBEvaluate the system used to verify that truck driver who enter the planty have current safety orientation status Implement a post safety evaluation mmm system (form) for contractors who . work at plant Document pre-start up safety review and file with PHA's a sure job Prepare a written mechanical integrity procedure to comply with with MOC's as IHife1910.119(j) Initiate a formal inspection protocol to assure materials and equipment NGC 12247 MI9419 MOC9420 119421 EPR9422 TS9423 are received as ordered Verify compliance with OSHA's Ongoing. We do have an 1910.111 storage and handling of expanded under insulation p anhydrous ammonia standard. corrosion program and are * Take corrective action to resolve planning to audit the ammonia under insulation external corrosive storage areas in 1996. on piping Fully implement the Management of Change Policy, trace for understranding and document being the same Develop a system to bring to closure all safety-environmental ................. \ j^^BHSlli8art of ISO Corrective Action System incidents that occur in a PSM area. Document this closure action in the PSM file Publish evacuation routes in areas indicating directions to the two plant assembly points ^^^HgfTiarked with flags, c^ffl^^Kand visitors given booklets with maps showing rally points Verify secrecy agreements for contractors who are in sensitive areas of the plant I hope this memo answers any questions you may have. If you need any additional information, please don't hesitate to call. Bill Lesko BL/pb *1