United States
Environmental Protection
Agency
Office of Solid Waste
and Emergency Response
(5104)
EPA 550-F-99-003
February 1999
www.epa.gov/ceppo
vvEPA
PREVENT YEAR 2000 CHEMICAL
EMERGENCIES
The Environmental Protection Agency (EPA) is issuing this Alert as part of its ongoing effort
to protect human health and the environment by preventing chemical accidents. Alerts are
issued when EPA becomes aware of a significant hazard. It is important that facilities. State
Emergency Response Commissions (SERCsl, Local Emergency Planning Committees (LEPCs),
emergency responders and others review this information and take appropriate steps to mini-
mize risk. The Alert is targeted at the chemical process industry to increase awareness of the
potential for chemical safety problems due to upcoming date changes.
THE
Tt is 11:59 p.m. on December 31, 1999.
The Year 2000 problem (also known as
the "millennium bug'") could disrupt
your chemical process and storage opera-
tions. Is your facility prepared? Here are
some examples of what could happen.
4 A safety system, designed to detect
emissions of deadly hydrogen sulfide
gas. shut down during a Y2K test on an
oil rig in the North Sea.
* At a smelter in New Zealand, all the
process controls stopped working at mid-
night on December 31, 1996, because
programmers had failed to take into
account that 1996 was a leap year. The
loss of process control damaged equip-
ment valued approximately at $600.000.
4- A utility company in Hawaii ran tests on
its system to see if it would be affected by
the Y2K bug. Hie entire system shut
down.
At any size company, the Y2K issue could
threaten worker and community safety and
health. It could cause complete shutdowns
of machinery or safety-related systems or
could generate erroneous information (e.g..
wrong temperature) which could lead an
operator to take unsafe or improper steps.
For chemical process industries, the Y2K
problem could increase the potential for
process shutdowns and accidental chemi-
cal releases.
This alert raises awareness about the Y2K
problem and offers a strategy to address the
problem. However, given that the Year
2000 is approaching soon, facilities should
dedicate increasingly more efforts on
developing contingency plans to prepare
for unanticipated events like those above.
Contingency planning is especially impor-
tant for facilities that have not started or
have made little progress in assessing and
remediating the Y2K problem.
In addition to administrative and manage-
ment systems, (payroll, financial records,
inventory), the Y2K problem could affect
three parts of your facility - your software,
your control/process equipment, and criti-
cal services provided to you by others such
as utilities and feedstock suppliers.
YOUR SOFTWARE
The Y2K dilemma is the result of a stan-
dard practice used in software program-
ming. To save memory space and keep
costs down, computer programs and
microchips were traditionally designed to
recognize only the last two digits of a year.
This means that when the year 2000 rolls
around, computers may not be able to dis-
tinguish whether 00 means 1900 or 2000.
This could cause computer programs to
crash and systems to shut down. For
example, if you rely on computer systems
to notify you to schedule maintenance or
retire equipment, the system may not prop-
erly notify' you because the computer can-
not recognize dates after December 31,
1999. See the "Dates to Watch" box for a
few other dates that might cause problems.
Chemical Emergency Preparedness and Prevention Office
Printed on recycled paper
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Februarv 1999
YOUR CONTROL/PROCESS
EQUIPMENT
Even if your operations do not directly use comput-
ers, some of your control machinery, process equip-
ment, automation equipment (e.g., valves, pumps),
and emergency protection equipment (e.g., fire and
gas detectors), may be embedded with computer
chips that are date-sensitive. If these chips misun-
derstand the date change, the equipment could fail
or malfunction, causing process upsets that lead to
accidents. For example, an automatic valve with an
embedded chip could fail in such a way that the
valve turns off the feedstock supply. Because Y2K
problems can affect so many devices, cascading
failures are possible.
YOUR
The Y2K problem can affect manufacturing, elec-
tric utilities and energy suppliers, water utilities,
telecommunications, transportation, and other sec-
tors that are critical to your facility operations.
Disruption of these services can become your prob-
lem. For example, a water supply utility could shut
down, causing loss of critical cooling water to
chemical reactor systems. Most plants also have
suppliers that produce raw and in-process materials
that are vital to running their processes. Many-
plants have customers who accept products through
"just-in-time" delivery schedules. Failure to
receive these materials could result in safety haz-
ards at your plant.
The Y2K concern is real, and the solution may
not be easy. However, the effort now to
identify and fix the problem will reduce the
risk of more costly impacts of business disruptions,
safety failures, and accidental chemical releases.
While many large companies in the chemical indus-
try already have started addressing the Y2K prob-
lem, many small businesses are just beginning to
realize the impact that the Y2K problem may have
on their operations.
/
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February 1999
Y2K compliant (see section on •'Information
Resources" for some vendor web sites).
2. Remedy problem. If critical equipment can be
affected by the Y2K problem, you have several
options including repairing, modifying, or replacing
the equipment. Where mission-critical systems
cannot be assessed, remediated, and corrected, you
could consider operating the system in a manual
over-ride mode. Staff would need training on new
equipment or refresher training on procedures for
manual operation. Additional staff may be needed
when automated processes are switched to manual.
3. Test systems. Your systems and equipment should
be tested to make sure the Y2K malfunction is reme-
died. Do not forget to test dates other than January 1,
2000 (see the "Dates to Watch" box). Before you test,
alert local emergency officials and make sure your
employees and community are prepared for any possi-
ble failures that may have an adverse effect on health
and safety7 or the environment. (See EPA's new
enforcement policy on Y2K testing in section "It s Your
Duty'").
4. Develop and implement contingency plans.
Contingency plans are essential in your strategy to
address the Y2K problem. Even if you believe your
system is Y2K compliant, you should develop a
Y2K contingency plan to prepare for unanticipated
problems. Your contingency plan should not depend
on backup equipment and systems that could also
fail because of the Y2K complication (e.g.. backup
generator, automatic shutdown system). Also, you
may need to address staffing and training for meet-
ing Y2K contingency plans and to handle disrup-
tions to transportation infrastructure and telecom-
munications. Facilities should not overlook the pos-
sibility that non-Y2K compliant computers and
chips in telecommunications and radio may prevent
police, fire, and mutual aid assistance from arriving
promptly or at all. Inform local officials concerned
with emergency situations when testing equipment,
and involve employees in planning for testing and in
responding to unexpected system changes. As part
of your contingency planning you could:
4- Work with and share solutions and lessons
learned with your partners, suppliers, neighbor
facilities, associations, and customers to ensure
that they, too. are addressing the Y2K issue.
EXAMPLES OF EQUIPMENT TO CHECK
/ Controllers
/ Alarms
/ Lighting
/ Robots
/ Air monitoring/leak detection devices
/ Hazard communication databases
/ Underground storage tank monitors
/ Security systems
/ Generators
/ Lab instruments
/ Environmental control systems
/ Controllers for refrigeration, valves,
pumps, sensors and analyzers
/ Programmable control systems
/ Safety shutdown systems
/ Fire detection systems
/ Explosion suppression systems
/ Elevators
/ Conveyors
/ Vehicles
* Work with your SERC, LEPC, and other off-site
emergency management support to review
emergency response procedures and ensure that
the procedures and resources available cover
possible Y2K consequences.
4- Make sure employees are trained and prepared
to shut down the process manually, if necessary.
•* Consider scheduling downtime and mainte-
nance over the end of 1999 and beginning of
2000. During shutdowns, systems can be iso-
lated and Y2K tested. However, before you
schedule downtime, recognize that startups and
shutdowns have their own risks which must be
balanced against the potential risks from Y2K
problems. Also, if you are a large power user.
notify- your utility if you plan to have a shut-
down. Utilities could have operating problems
if power demands unexpectedly drop, particu-
larly if many facilities shut down.
•* Have a full staff available for a number of hours
just before and after critical date changes for
unanticipated emergencies.
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Prevent Year 2000 Chemical Emergencies
February 1999
+ Consider conducting an exercise using a Y2K
scenario to improve emergency response capa-
bilities. One community, Lubbock, Texas.
already has successfully conducted such an
exercise and learned a number of important les-
sons, including the need to prevent emergency
communications failure.
Remember, in terms of contingency planning, facil-
ities should take advantage of the one positive piece
of information that the Y2K problem offers us: the
ability to know when it will occur.
Under the General Duty Clause of the Clean
Air Act (CAA section 112(r)(l)), owners and
operators of facilities with hazardous sub-
stances have a general duty to prevent and mitigate
accidental releases, including those caused by Y2K
failures. Also, under EPA's Risk Management
Program (RMP) Rules (CAA section 112(r)(7)), acci-
dental release scenarios related to Y2K problems
(e.g., loss of utilities, interruption of raw material
deliveries, failure of monitoring devices) would be
reasonable alternative scenarios to consider. The
public may view any Y2K-related operating prob-
lems that occur in January 2000 as a test of the qual-
ity and reliability of your RMP. In addition, EPA has
initiated an enforcement policy designed to encour-
age prompt testing of computer-related equipment to
ensure that environmental compliance is not impaired
by the Y2K computer bug. Under this policy, EPA
intends to waive 1.00% of the civil penalties and rec-
ommend against criminal prosecution for environ-
mental violations caused by tests designed to identify
and eliminate the Y2K-related malfunctions. This
policy is limited and subject to certain conditions.
(See complete policy on EPA's Year 2000 web site
listed in "Information Resources.^)
The Occupational Safety and Health Act (OSHA)
has a similar General Duty Clause (section 5(a)(l))
for protection of employees from hazardous situa-
tions involving the use of highly hazardous sub-
stances. Also, OSHA's Process Safety Management
(PSM) Standard is intended to prevent or minimize
injury to employees from accidents (including
those caused by Y2K problems) involving highly-
hazardous chemicals.
Below are some resources that will help you to
get started to address the Y2K problem at
your facility. Future updates of this resource
list can be found at the EPA CEPPO Website below.
Environmental Protection Agency (EPA)
Provides information on EPA's efforts to address the Year
2000 problem. This includes EPA's Y2K enforcement policy,
and under the heading "Environmental Y2K Sectors." the
Office of Water guidance for wastewater systems (including a
checklist of basic systems) and the Office of Solid Waste
flyer on waste management and the Y2K problem.
http://www.epa.gov/year2000/
EPA's Office of Solid Waste and Emergency Response Y2K
information.
http://clu-in.com/y2k.htm
EPA's Chemical Emergency Preparedness and Prevention
Office (CEPPO) has this Y2K alert and updates.
http://www.epa.gov/ceppo
Occupational Safety and Health Administration (OSHA)
The OSIIA web site has a bulletin on Y2K.
http://www.osha.gov/Y2knews.pdf
Chemical Safety and Hazard Investigation Board (CSB)
The CSB has sponsored a conference and report on the Y2K
problem and the potential for accidental chemical releases.
Relevant Year 2000 sites can be found on the CSB Web site by-
clicking on Chem Links and then searching on "'Year 2000."
http://www.cliernsafety.gov
U.S. Small, Business Administration (SBA)
This web site offers information specific to helping small
businesses address the Y2K problem. It provides a list of
questions to help identity date-sensitive equipment. SBA also
has an extensive list of links to major corporations that post
their Y2K status online.
http://www.sba.gov/y2k/
Hotline: 1-800-U-ASK-SBA (1-800-827-5722)
General Accounting Office
Guide: "Year 2000 Computing Crisis: Business Continuity
and Contingency Planning" has general principles for use by
businesses as well as government agencies.
http://www.gao.gov/special.pubs/bcpgidde.pdf
National Institute of Occupational Safety & Health (NIOSH)
NTOSH has Y2K case studies, a web forum, vendor list, and
an equipment manufacturer director}'.
http://www.cdc.gov/niosh/y2k/y2k-hmpg.html
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Prevent Year 2000 Chemical Emergencies
February 1999
Health & Safety Executive (UK)
The British Health and Safety Executive web site offers sev-
eral reports on the Y2K problem. Of particular interest to the
chemical industry is "Health and Safety and the Year 2000
Problem - Guidance on Year 2000 Issues As They Affect
Safety-Related Control Systems'" and "Contingency Planning
for a Safe Year 2000."
http:7Avww.open. gov.uk/hse/dst/2000indx.htm
National Fire Data Center
A basic system check that can help you determine if your
organization's computer system is Y2K compliant is available
on this website.
http://www.usfa.ferna.gOV/y2k/y 2kcom.htm
Electronic Systems Center of the Air Force Materiel
Command (site maintained by Mitre Corporation)
The site provides information on Y2K certification, compli-
ance, solutions, testing and evaluations, contingency plans,
cost estimation, tools and services.
http://www.niitre.org/teclinology/y2k
National Institute of Standards and Technology
The site has links to free software tests, self-help tools and
product compliance status databases for use in Y2K assess-
ment, testing, contingency planning and remediation.
Information is provided for smaller manufacturers through the
Manufacturing Extension Partnership, a nationwide network
of centers providing technical and business assistance to
smaller manufacturers. Small manufacturing firms can call 1 -
800-MEP-4MFG.
http://www.nist.gov/y2k
President's Council on Year 2000 Conversion-Product
Compliance Information
The site has a list of computer manufacturers' Y2K sites.
http:/Avww.y2k.gov/java/product_compliance.html
Mary Kay O'Connor Process Safety Center
The site has links to compliance status of some manufactur-
ers' control systems. Click on Y2K information.
http://process-safety.tamu.edu/y2k/y2k.htm
Chemical Manufacturers Association (CMA) Survey
CMA has developed a standard survey form for the use of its
members. This survey package is designed to help companies
assess Y2K efforts of critical suppliers and customers and
minimize the risk of service interruption. The survey (posted
on 12/14/98) can be found in the "What's New'" section of the
CMA website.
http: //www. cmahq. com
Case Study of One Chemical Manufacturer's Approach to
Y2K Problem
http://www.dell.coin/smallbiz/y2k/studies.litniSnierisol
American Petroleum Institute
The site provides industry activities, company status reports,
Y2K database, and technical links.
http: //www. api. org/ecity A/2k/index. html
Year 2000
The site has a list of Ycar2000 vendors and consultants.
http://www.year2000.com
National Bulletin Board for Year 2000
Provides tools for analysis, conversion, and testing for Y2K
problems.
http: //it2 000 .com/so lution s/index. html
Y2K Freeware and Shareware
http://www.apliis.usda.gov/y2k/wares.html
Year 2000 Embedded Systems Vendors, Associations, and
Manufacturers
http://ourworld. CompuServe. com/homepages/roleigh_martin/y
2k_com.htm
Some PC Test Results far Y2K Problems
http:/Avww.hqisec. anny.mil/y2kweb/y2kresults.html
http://www.nirn.com.au/year2000/ye02001.limi
FOR MORE INFORMATION.
CONTACT THE EMERGENCY PLANNING AND COMMUNITY
RIGHT-TO-KNOW HOTLINE
800 424-9346 OR (703) 412-9810
TDD (800) 553-7672
MONDAY-FRIDAY. 9 AM TO 6 PM, EASTERN TIME
•»*«»
TO OBTAIN COPIES OF THIS PUBLICATION, CONTACT NATIONAL
SERVICE CENTER FOR ENVIRONMENTAL PUBLICATIONS
(NSCEP) PHONE: 800-490-9198 FAX: 513-489-8695
http://www.epa.gov/ncepihoni
VISIT THE CEPPO HOME PAGE ON THE WORLD WIDE WEB AT:
http:/Avww.epa.gov/ceppo
NOTICE
The statements In this document are Intended solely as guidance. This document does not substitute for EPA's or other agency regula-
tions, nor Is It a regulation itself. Site-specific application of the guidance may vary depending on process activities, and may not apply to
a given situation. EPA may revoke, modify, or suspend this guidance In the future, as appropriate.
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Prevent Year 2000 Chemical Emergencies February 1999
United State Environmental
Protection Agency
(5104)
Washington, DC 20460
Official Business
Penalty for Private Use
$300
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