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CIT-CON Oil Corporation

Parent Companies:
EPA Facility ID:
100000137158
Other ID:
70602CTGPTHIGHW
Facility DUNS:
78645629

Location:

Address:
Louisiana Highway 108 -East
Lake Charles, LA 70602
County:
CALCASIEU
Lat / Long:
30.184, -93.343 (Get map)
Method:
Interpolation - Photo
Description:
Plant Entrance (General)
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
CIT-CON Oil Corporation
Phone:
(318) 497-6011
Address:
Louisiana Highway 108 -East
P.O. Box 1562
Lake Charles, LA 70602 -0000
Foreign Address:

Person responsible for RMP implementation:

Name:
Alvin Prebula
Title:
Vice President - CITGO Lake Charle
Email:

Emergency contact:

Name:
CITGO Shift Supervisor
Title:
Shift Supervisor
Phone:
(318) 497-8499
24-hour phone:
(318) 497-8499
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Calcasieu Parish LEPC
Full-Time Equivalent Employees:
193
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Oct. 14, 2003
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Duo Sol
RMP ID:
49188
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Lubricating Oil and Grease Manufacturing (324191)
Chemical name
CAS#
Quantity (lbs.)
CBI
Propane
74-98-6
1,200,000
No
Public OCA Chemical
0
No
MEK 2 - Lube
RMP ID:
49189
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Lubricating Oil and Grease Manufacturing (324191)
Chemical name
CAS#
Quantity (lbs.)
CBI
Propane
74-98-6
220,000
No
Public OCA Chemical
0
No
MEK 1 - Lube
RMP ID:
49190
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Lubricating Oil and Grease Manufacturing (324191)
Chemical name
CAS#
Quantity (lbs.)
CBI
Propane
74-98-6
21,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
June 21, 2004
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
No
RMP ID:
34115

Deregistration:

Date:
Effective Date:
Reason:
Source terminated operations
Other Reason:

2. Toxics: Worst-case

None

3. Toxics: Alternative release

None

4. Flammables: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Duo Sol)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
Passive mitigation
considered:
  • None
not considered:
  • Blast walls

5. Flammables: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Duo Sol)
CBI claimed:
No
Model used:
Safer System Modeling Software
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Excess flow valve

6. Five-year accident history

July 24, 2001 at 06:11
ID:
5517
NAICS:
Petroleum Lubricating Oil and Grease Manufacturing (324191)
Duration:
3 hours and 35 minutes
Chemicals involved:
  • Propane
Release events:
Fire
Weather conditions at time of event
Wind speed:
5.0 miles/h S
Temperature:
94.00 ℉
Atmospheric stability:
B
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
0
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$775000
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
100
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Equipment failure
Off-site responders notified:
No, not notified
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Revised maintenance
  • Revised operating procedures

7. Prevention: Program level 3

Duo Sol, Petroleum Lubricating Oil and Grease Manufacturing (324191)
Prevention Program ID:
28164
Safety Review Date
Oct. 23, 2003, since latest RMP submission
PHA Update Date
Feb. 29, 2000, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Overpressurization
  • Overfilling
  • Contamination
  • Equipment failure
Process Controls
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Alarms
  • Backup Pump
  • Grounding Equipment
Mitigation Systems
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
July 15, 2003, since latest RMP submission
Training Review Date
Aug. 13, 2001, since latest RMP submission
Maintenance Review Date
Sept. 26, 2003, since latest RMP submission
Maintenance Inspection Date
May 25, 2004, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
May 29, 2004
Management of Change Review Date
Oct. 30, 2003
Pre-startup Review Date
None
Compliance Audit Date
Oct. 23, 2003
Compliance Audit Change Completion Date
June 30, 2005
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
March 28, 2003
Hot Work Review Date
April 21, 2004
Contractor Safety Review Date
Jan. 16, 2002, since latest RMP submission
Contractor Safety Eval. Date
May 3, 2004, since latest RMP submission
MEK 2 - Lube, Petroleum Lubricating Oil and Grease Manufacturing (324191)
Prevention Program ID:
28165
Safety Review Date
Oct. 23, 2003, since latest RMP submission
PHA Update Date
Jan. 24, 2000, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Contamination
  • Equipment failure
Process Controls
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Alarms
  • Backup Pump
  • Grounding Equipment
Mitigation Systems
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • Process Controls
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
July 15, 2003, since latest RMP submission
Training Review Date
Feb. 15, 2002, since latest RMP submission
Maintenance Review Date
Sept. 25, 2003, since latest RMP submission
Maintenance Inspection Date
April 10, 2003, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
June 3, 2004
Management of Change Review Date
Oct. 30, 2003
Pre-startup Review Date
None
Compliance Audit Date
Oct. 23, 2003
Compliance Audit Change Completion Date
June 30, 2005
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
March 28, 2003
Hot Work Review Date
April 21, 2004
Contractor Safety Review Date
Jan. 16, 2002, since latest RMP submission
Contractor Safety Eval. Date
May 3, 2004, since latest RMP submission
MEK 1 - Lube, Petroleum Lubricating Oil and Grease Manufacturing (324191)
Prevention Program ID:
28166
Safety Review Date
Oct. 23, 2003, since latest RMP submission
PHA Update Date
Feb. 28, 2001, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Overpressurization
  • Contamination
  • Equipment failure
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Alarms
  • Grounding Equipment
Mitigation Systems
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • Process Detection
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
July 15, 2003, since latest RMP submission
Training Review Date
Feb. 15, 2003, since latest RMP submission
Maintenance Review Date
Sept. 25, 2003, since latest RMP submission
Maintenance Inspection Date
May 27, 2004, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
May 1, 2004
Management of Change Review Date
Oct. 30, 2003
Pre-startup Review Date
None
Compliance Audit Date
Oct. 23, 2003
Compliance Audit Change Completion Date
June 30, 2005
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
March 28, 2003
Hot Work Review Date
April 21, 2004
Contractor Safety Review Date
Jan. 16, 2002, since latest RMP submission
Contractor Safety Eval. Date
May 3, 2004, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
June 3, 2004
Local Response Agency:
Local Response Agency Phone:
(318) 437-3511
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

2964 LADEQ Facility ID Number


1.0 Executive Summary

The CIT-CON Oil Corporation, has a long standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as the training of personnel, investing in "state of the art" process management systems and the application of inherently safer designs in the installation, operations and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our fully equipped and trained personnel will respond to control and contain the release.


2.0 Description of the Stationary Source and Regulated Substances


The CIT-CON Oil Corporation, located in Lake Charles Louisiana, USA, operates a variety of processes which converts partially refined petroleum feedstock to produce various lubricating oils and waxes.


3.0 Hazard Assessment Results

The CIT-CON Oil Corporation has developed a worst case scenario determined from regulated the substances in Program 3 processes. Although CIT-CON Oil Corporation has numerous controls to prevent such a release and to manage the consequences, no credit for administrative controls passive mitigation measures was taken into account in evaluating this scenario.

The alternative case scenario is based on the use of administrative and engineered controls, active mitigation of the leak, and the response of the appropriate emergency personnel / equipment to the alternate case scenario scenes.

The alternative release scenario is selected as being a practical scenario for use in emergency planning and response

Under the Louisiana Department of Environmental Quality Title, the application of a "General Duty Clause" is included within the enforcement of the EPA "Accidental Release Prevention" program. The CIT-CON Oil Corporation explored all other regulated substances as required by the part or rule. The sam
e process vigilance and response capabilities are ready to mitigate any release of these additional regulated substances within or outside the limits of our facility.

4.0 Five Year Accident History

The CIT-CON Oil Corporation has an excellent record of accident prevention over the past 5 years; the frequency being consistently low with efforts to reduce or eliminate all accidental releases from the stationary source. The CIT-CON Oil Corporation has had very few excursions of toxic or flammable releases of regulated substances. The facility investigates incidents carefully to determine ways to prevent similar incidents from occurring.

From June 21, 1999 to June 21, 2004, CIT-CON Oil Corporation has on record 1 accident involving RMP covered processes and meeting the criteria set forth in the EPA regulation. That incident resulted in a fire and damage to equipment in excess of $775,000.

5.0 General Accidental Release Prevention Program Steps


The following is a summary of the general accident prevention program in place at the CIT-CON Oil Corporation. Because processes at the facility are regulated by the EPA RMP regulation are also subject to the OSHA PSM standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program


Employee Participation

The CITGO Petroleum Corporation Lake Charles Manufacturing Complex's Facility encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team. Employees have access to all information created as part of the Facility Accident Prevention Program . Specific ways that employees can be involved in accident prevention program are documented in an Employee Participation Procedure, maintained at the facility and
it addresses each accident program element. In addition, the facility has a number of initiatives under way that address process safety and employee safety issues. These initiatives include forming teams to promote both process safety and personal safety. The teams typically have members from various areas of the plant, including operations, maintenance, engineering, and facility management.



Process Safety Information

The CIT-CON Oil Company keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameter, specific chemical inventories, and equipment design basis / configuration information. Appropriate departments within the facility are assigned responsibility for maintaining portions of process safety information.

Chemical specific information including exposure hazards and emergency response / exposure treatment consideration, is provided in Material Safety Data Sheets (MSDS's). This information is supplemented by documents that specifically addresses known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals.

For specific process areas, the facility has documented safety-related limits for specific process parameters (e.g. temperature, level, composition) in key process parameter documents. The facility ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g. automated shutdown systems).

The facility also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, electrical ratings of equipment, etc. This information, in combination with written procedures and trained personnel provide a basis
for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised.


Process Hazard Analysis

The CIT-CON Oil Corporation has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within the program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.

The CIT-CON Oil Corporation primarily uses the Hazards and Operability (HAZOP) analysis technique to perform these evaluations. Hazop analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. The team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary.

The PHA team findings are forwarded to management for resolution. Implementation of mitigation options in response to a PHA findings is based on a relative risk ranking assigned by the PHA team. The ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. The final resolution of each finding is documented and retained.

To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the CIT-CON Oil Corporation periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted on 5 year intervals and will be conducted at this frequency until the process is no longer o
perating. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration and the final resolution of the findings is documented and retained.

Operating Procedures

The CITGO Petroleum Corporation Lake Charles Manufacturing Complex's Facility maintains written procedures that address various modes of process operation such as (1) initial startup of a new unit, (2) normal operations, (3) temporary operations (4) emergency shutdown, (5) normal shutdown and (6) unit startup. These procedures can be used as reference by experienced operators and provide a basis for consistent training of new operators. These procedures are periodically reviewed and certified as current and accurate. The procedures are maintained current by revising them as necessary to reflect changes made through the management of change process

In addition, the CIT-CON Oil Corporation maintains key process parameter documents which provide guidance on how to respond to upper or lower limit exceedances for specific process or equipment parameters. This information, along with the written operating procedures is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks.


Training

To complement the written procedures for process operations, CIT-CON Oil Corporation has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in the facility operations if they are not already familiar with such operations. After successfully completing this training, a new operator is paired with a senior operator to learn process specific duties and tasks. After operators demonstrate (e.g. through tests, skill demonstration) having adequate knowledge to perform the duties and tasks in a safe and responsible manner on their own, they can work independently. In addition, all ope
rators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher testing is conducted at least every 3 years. All of this training is documented for each operator, including the means used to verify that the operator understood this training

Contractors

To complement the written procedures for process operations, CIT-CON Oil Corporation utilizes contractors to supplement its work force. Because some contractors work on or near process equipment, the facility has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards of their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform facility personnel of any hazards that they find during their work or may introduce in the course of performing their work. This is accomplished by providing contractors with (1) a process overview, (2) information about safety & health hazards, (3) emergency response plan requirements, and (4) safe work practices before beginning their work. In addition, the CIT-CON Oil Corporation evaluates contractor safety programs and performance during the selection of a contractor. Facility personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations.

Pre Startup Review

The CIT-CON Oil Corporation conducts a Pre Startup Safety Review (PSSR) for any new facility or facility modifications that requires a change in the process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel and the equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications
and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented.

Mechanical Integrity

The CIT-CON Oil Corporation has well established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in safe operating condition. The basic aspects of this program include (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality control measures. In combination, these activities from a system that maintains the mechanical integrity of the process equipment.

Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their job task in a safe manner. Written procedures help ensure that work is performed in a consistent manner and provide a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible) or a team and/or department will review the use of the equipment and determine what actions are necessary to ensure the safe operation of that equipment.

Another integral part of the mechanical integrity program is quality assurance. The CITGO Petroleum Corporation's Lake Charles Manufacturing Complex Facility incorporates quality assurance
measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made

Safe Work Practices

The CIT-CON Oil Corporation has long-standing safe work practices in place to help ensure worker and process safety. Examples of this include (1) - control of the entry/presence/exit of support personnel, (2) - a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) - a procedure for safe removal of hazardous materials before process piping or equipment is opened, (4) - a permit and procedure to control spark producing activities (i.e. hot work), and (5) - a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others) along with training of affected personnel, form a process to help ensure that operations and maintenance activities are performed safely.

Management Of Change

The CITGO Petroleum Corporation Lake Charles Manufacturing Complex's Facility has a comprehensive system to manage change to processes. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes to be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change.

Incident Investigation

The CITGO Petroleum Corporation Lake Charles Manufacturing Complex's Facility promptly investigates all incidents that resulted in or r
easonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incidents or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to the facility management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHA's and PHA revalidations

Compliance Audits

To help ensure that the PSM/Accident Prevention Program part or rule is functioning properly, the CIT-CON Oil Corporation in conjunction with the Corporate Safety Group periodically conducts an audit to determine whether the procedure and practices required by the applicable PSM / Accident Prevention part or rule are being implemented. Compliance audits are conducted at least every 3 years. The audit team can consist of a broad base of management and /or hourly personnel from the facility or from other operating units of CIT-CON Oil Corporation and/or contract third parties. The audit team develops findings that are forwarded to facility management for resolution. Corrective actions taken in response to the audit team's findings are tracked until complete. The final resolution of each finding is documented, and the two most recent audit reports are retained.

6.0 Chemical Specific Prevention Steps

The processes at the CIT-CON Oil Corporation have hazards that must be managed to ensure continued safe operation. The accident prev
ention program summarized previously is applied to all of the Program 3 processes EPA RMP-covered processes at the CIT-CON Oil Corporation. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failure and (2) human error.

In addition to the accident prevention program activities, the CIT-CON Oil Corporation has safety features on many of its units to help (1) contain / control a release, (2) quickly detect a release and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in various processes.

Release Detection

? Hydrocarbon Sensors
? Heat Detection heads and sensors


Release Containment / Control

? Process relief valves that discharge to a flare to capture and incinerate episodic releases
? Valves to permit the isolation of the processes (manual and automatic)
? Automated shutdowns for specific process parameters (e.g. high temperature, high level etc..)
? Curbing or diking to contain liquid releases
? Redundant equipment and instrumentation (e.g. uninterruptible power supply for process controllers, backup firewater systems.
? Atmospheric relief devices

Release Mitigation

? Fire Suppression and Extinguishing Systems
? Deluge system for specific equipment
? Trained emergency response Personnel
? Personal Protective Equipment


8.0 Emergency Response Program Information

The CIT-CON Oil Corporation maintains a written emergency response program, which is in place to protect public safety, worker safety and the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency reponse, including proper first aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency re
sponse agencies and the public if a release occurs, and post incident cleanup and decontamination requirements. In addition, the CIT-CON Oil Corporation has procedures that address maintenance, inspection and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties.

The overall emergency response program for the CIT-CON Oil Corporation is coordinated with the Calcasieu Parish, LA Local Emergency Planning Committee (LEPC). The CIT-CON Oil Corporation has around-the-clock communication capability with appropriate LEPC officials and emergency response organizations (e.g., fire departments). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, the CIT-CON Oil Corporation conducts periodic emergency drills that involve the LEPC and emergency response organizations.


7.0 Planned Changes to Improve Safety


The CIT-CON Oil Corporation resolves all findings from PHA's, some of which result in modification to the process. The following types of changes are planned.

? Decrease in process chemical inventories where feasible
? Improve mitigation capacity, both fixed and mobile