This advisory recommends ways Local Emergency Planning Committees (LEPCs) and chemical facilities can reduce
risks posed by the presence of hydrogen fluoride (HF) in their communities.  Hydrogen fluoride, a strong inorganic
acid, is produced and used as a gas or liquid without water (i.e., in anhydrous form), or in a water (aqueous)
solution. The anhydrous form is potentially more hazardous than hydrogen fluoride in dilute water solutions,
because anhydrous hydrogen fluoride has greater potential for fuming and forming vapor clouds.  If anhydrous
hydrogen fluoride is accidentally released, it may react with water vapor to form a white vapor cloud.  Under certain
conditions, such a cloud has the  potential to travel considerable distances close to the ground and pose a threat to
people in its path.  EPA stresses that although mishandling of HF can cause harm,  there is no cause for undue
alarm about its presence in the community  when it is properly and safely managed.

Inhalation of hydrogen fluoride vapor, either in anhydrous form or from water solutions, can cause' irritation if the
exposure is mild (i.e., low concentration in  air for a short time), or severe damage to the respiratory system or death
in the case of exposure to high concentrations.  Contact with the liquid or vapor can severely burn skin, eyes, and
other tissue.  Burns from hydrogen fluoride are particularly dangerous and require immediate and special treatment
by trained medical personnel.

The largest use of hydrogen fluoride is in the manufacture of fluorine-containing chemicals, particularly
chlorofluorocarbons (CFCs). Hydrogen fluoride may be used in some petroleum refinery operations, aluminum
production, nuclear applications, glass etching and polishing, and metal treating and cleaning.
   Although major incidents involving hydrogen fluoride have been rare, one example was an accident at a Texas
   petroleum refinery. A construction accident at an alkylation unit resulted in the release of 30,000  to 50,000
   pounds of hydrogen fluoride and isobutane.  The vapors migrated to an adjacent residential area.  Eighty-five
   square blocks and approximately 4,000 residents were evacuated.  There were no fatalities.  More than 1,000
   residents went to three neighboring hospitals. Although about 100 were admitted, most of those reporting to
   hospitals were treated on an outpatient basis. In some cases, there were reports of skin irritation and irritation
   to the eyes, nose, throat, and lungs. Some vegetation in the  path of the cloud was also damaged.
Federal Requirements:

Hydrogen fluoride's acute toxicity prompted EPA to
list it as an extremely hazardous substance (EHS),
with a threshold planning quantity (TPQ) of 100
pounds, under Section 302 of the Emergency Planning
and Community Right-to-Know Act (commonly
known as SARA Title III).  OSHA's Process Safety
Management Standard, published February 24,  1992,
requires facilities with anhydrous hydrogen fluoride in
quantities at or above the threshold of 1,000 pounds
to implement process safety management to protect
employees by preventing or minimizing the
consequences of chemical accidents. In addition,
OSHA regulations require that facility employees who
could potentially be exposed to hydrogen fluoride in
any form be trained to handle  and use it safely and to
recognize and deal with the potential hazards posed
by this chemical.  EPA regulations required under the
Clean Air Act soon will require facilities with HF
above a threshold quantity to prepare risk
management plans; these plans will be provided to
LEPCs and the state.
Page 1
   Chemical Emergency Preparedness and Prevention Advisory

-------
RECOMMENDED STEPS FOR LEPCS

Section 302 of SARA Title III requires LEPCs to
develop comprehensive emergency plans to address
facilities where hydrogen fluoride as well as other
EHSs arc present in excess of their threshold
planning quantities (100 pounds for hydrogen
fluoride).  Because an accidental release of hydrogen
fluoride can pose a significant health and safety
hazard, EPA suggests that LEPCs take the following
steps:

Hazards Analysis/Hazard Identification:

•  Know which facilities produce or use hydrogen
   fluoride. These facilities include:

   -   Chemical manufacturers (e.g.,
      chlorofluorocarbons, fluorine, organic and
      inorganic fluorine compounds, linear
      alkylbenzenes);

   -   Petroleum refinery alkylation units;

   -   Aluminum producers;

   -   Pharmaceutical companies; and

   -   Uranium processors.

•  Facilities that produce or use water solutions of
   hydrogen fluoride, which may be less hazardous
   than pure hydrogen  fluoride, particularly if the
   solutions are dilute, include:

   -   Chemical manufacturers (e.g., some
      inorganic fluorine compounds);

   -   Stainless steel producers;

   -   Manufacturers of metal products;

   -   Electronic equipment manufacturers;

   -   Transportation equipment manufacturers;

   -   Aerospace industry; and

   -   Glass manufacturers.

•  Know routes and methods of HF transportation in
   the area.

Note: There are many other names for hydrogen
fluoride.  Hydrogen fluoride without water may be
called anhydrous hydrogen fluoride; HF; AHF;  HF-A;
hydrofluoric acid; hydrofluoric acid, anhydrous; or
anhydrofluoric acid. Water solutions of hydrogen
fluoride may be called hydrofluoric acid; hydrofluoric
acid, aqueous; hydrofluoric acid solution; aqueous HF;
HF 70% (or other concentration); hydrofluoric acid
70% (or other concentration); or fluorhydric acid.

HF Characteristics:

•  Be aware of the characteristics that make hydrogen
   fluoride hazardous, including:

   -  It is highly toxic;

   -  Depending on temperature and
      concentration, it may be highly corrosive
      to many substances (e.g., dilute HF
      attacks most common metals);

   -  It can become airborne if released above
      its boiling point of 67° F; and

   -  Anhydrous hydrogen fluoride may form a
      vapor cloud containing aerosol if released
      under certain conditions.  Depending on
      the conditions, the cloud may travel
      considerable distances while remaining
      close to the ground.

Vulnerability Analysis:

•  Example exposure guidelines  include:

   -  IDLH (30 ppm  for 30 minutes) and

   -  ERPG-3 (50 ppm for 1 hour).

•  When modeling potential releases of hydrogen
   fluoride, take into account its important
   properties, such as possible behavior as a
   dense gas (heavier than air), aerosol formation
   (HF vapor and droplets), and reaction with water
   vapor. In addition to including the chemistry of
   HF in vulnerability analysis, it is important to
   include other factors such as release rate,
   release quantity, meteorological conditions,  and
   area topography.

•  Note that the physical and chemical behavior of
   hydrogen fluoride is complex upon  release and
   models not designed to address this behavior
   may provide inaccurate estimates of dispersion
   and  downwind concentrations.

•  Identify vulnerable populations in potentially high
   concentration areas.
Page 2
   Chemical Emergency Preparedness and Prevention Advisory

-------
Emergency Planning/Testing the Plan:
•  Review methods facilities use to detect and
   respond to releases.

•  Engage in a dialogue with facilities regarding
   methods for preventing accidental releases of
   hydrogen fluoride and systems in place to reduce
   the off-site risk if release should occur.  On-site
   means of reducing off-site risks may include
   emergency transfer systems, water spray mitigation
   systems, remotely-operated isolation valves, HF
   detectors,  and HF inventory reduction.  Be aware
   that the effectiveness of these methods may be site
   specific. For example, reducing inventories could
   possibly lead to an increase in transportation-
   related risk.

•  Regularly  exercise and review Title III plans to
   ensure that facilities handling large quantities of
   hydrogen fluoride are covered, and that emergency
   response issues concerning possible releases of
   hydrogen fluoride have been addressed.  Consider
   whether plans should  include protection in place
   and/or evacuation in case of a hydrogen fluoride
   release.

•  Determine if the local emergency response plan is
   consistent with the facility's response  plan.

•  Ensure that local hospitals and physicians are
   properly trained and prepared to treat victims of
   hydrogen fluoride exposure;  in  particular, ensure
   that they are aware of the special hazards of
   hydrogen fluoride exposure and are equipped to
   treat such exposure.

Right-to-Know/Risk Communication:

•  Inform the community of the potential hazards of
   HF, as well as emergency response methods for
   treating victims of hydrogen fluoride exposure.
•  Send a copy of this advisory to all fire
   departments, medical facilities, and hydrogen
   fluoride facilities in your LEPC jurisdiction, calling
   their attention to the recommended steps for
   facilities in the section below.

RECOMMENDED STEPS FOR FACILITIES

In cooperation with LEPCs and local response
officials, facilities should  take the following steps:

Handling and Storage:

•  Protect HF-containing vessels and piping from
   impact by vehicles, machinery, or falling objects.
   Heavy  objects  should not be lifted over equipment
   containing hydrogen fluoride if it is  possible to
   avoid doing so. If not possible, potentially  affected
   equipment should be emptied prior  to the lift.

•  Ensure that all containers, piping, valves, and
   fittings contacting hydrogen fluoride are
   constructed of hydrogen fluoride-resistant
   materials.  These materials may include special
   alloys (such as Monel), specially-treated metals,
   corrosion-resistant substances such as Teflon, and
   Hastelloy-B. Carbon steel is generally used for
   anhydrous hydrogen fluoride.  Hydrogen fluoride is
   incompatible with glass, concrete, and other silica-
   based materials.  Even dilute solutions of hydrogen
   fluoride should not be stored in glass containers.

•  In industrial use, anhydrous HF may contain some
   water.  Improper control of moisture may result in
   accelerated corrosion.

«  Carry out regular inspections of equipment used
   for hydrogen fluoride  (including transfer hoses) for
   thickness  and cracks, fractures, or defects due to
   corrosion or mechanical stress.  Include welds in
   the inspection.

e  Refer to Department  of Transportation (DOT)
   regulations for shipping, packaging, marking, and
   labeling requirements.

Employee Safety:

o  Ensure that adequate training is provided to all
   facility employees concerning the safe handling,
   storage, and use of hydrogen fluoride.
Page 3
   Chemical Emergency Preparedness and Prevention Advisory

-------
•  Ensure that adequate training is provided to all
   employees concerning the need to wear personal
   protective clothing and equipment that is
   appropriate to the task for both emergency and
   non-emergency situations.

•  Ensure that adequate training is provided to all
   employees concerning emergency and notification
   procedures in the event of an accident.

*  Ensure that the proper protective equipment is
   easily accessible in case hydrogen fluoride is
   released. Train employees in the proper use of the
   equipment. Inspect and test the equipment
   regularly.

*  Have trained medical and/or emergency response
   personnel and  adequate supplies  (including first
   aid supplies) on site, or quickly available, to
   provide proper first aid in case of exposure.

Hazard Awareness:

•  Avoid  unintended contact between hydrogen
   fluoride and other chemicals. Hydrogen fluoride
   may  react with other substances (e.g., alkalies,
   some oxides, sulfides, and cyanides), sometimes
   violently, and sometimes  producing toxic gases.

Risk Minimization:

•  Use good design and engineering practices for
   locating equipment containing hydrogen fluoride
   to minimize damage from possible equipment
   ruptures, explosions, or fires.
•  Control access to hydrogen fluoride areas to avoid
   entry by untrained personnel.

•  Ensure that no containers are leaking or broken,
   and conduct regular maintenance checks of all
   equipment and containers coming in contact with
   hydrogen fluoride, particularly checking for
   evidence of corrosion.

•  Design hydrogen fluoride facilities with systems to
   minimize releases in the event of a leak or
   malfunction (e.g., by providing valves to isolate the
   area of the leak or providing the means to rapidly
   transfer the hydrogen fluoride to a different
   vessel).

•  Have procedures in place for quick, organized
   response in case of a release of hydrogen fluoride.

Emergency Notification:

•  In the event of a release, contact the National
   Response Center [(800) 424-8802], your SERC and
   LEPC, the local fire department, police
   department, and other local emergency responders.

•  When contacting these organizations, provide the
   following information:  chemical name, estimate of
   quantity released, time and duration of the release,
   affected media (e.g., air, surface water,
   groundwater), potential health risks, and the name
   and telephone number of a contact person at the
   facility.
                                      CLEAN AIR ACT AMENDMENTS

   Hydrogen fluoride is specifically mentioned in the accidental release provisions of the Clean Air Act
   Amendments of 1990. This law requires EPA to promulgate an initial list of at least 100 substances that may
   cause death, injury, or serious adverse effects to human health or the environment.  Congress has identified the
   first  15 substances to be included on this list; hydrogen fluoride is among them.  Where regulated substances
   above the threshold quantity are present at a facility, the owner/operator will be  required to prepare a risk
   management plan that includes a hazard assessment, an accidental release prevention program, and a response
   program.  The law requires that EPA publish regulations under the amended Clean Air Act within three years,
   and allows facilities an additional three years to comply.  Facilities will be required to provide copies of the risk
   management plan to the LEPC, as well as  to the state.  Under  the Clean Air Act Amendments of 1990, EPA
   also was directed by Congress to carry out  a study of the potential hazards of hydrogen fluoride to the public
   and to make recommendations for the reduction of such hazards.
                                                             Chemical Emergency Preparedness and Prevention Advisory

-------
  OTHER INFORMATION

  The following is a list of some sources of information about hydrogen fluoride and the Emergency Planning and
  Community Right-to-Know Act.
  • The American Petroleum Institute (API)
    Recommended Practice 751, "Safe Operation of
    Hydrofluoric Acid Alkylation Units."  Call API at
    (202) 682-8375.

  • API background paper, "The Use of Hydrofluoric
    Acid in the Petroleum Refining Alkylation Process."
    Call API at (202) 682-8163.

  • CHEMTREC, a 24-hour emergency hotline that
    provides information and assistance to responders
    during an emergency.  Contact  (800) 424-9300 or
    (202) 483-7616.  (Note: CHEMTREC is for
    emergency use only.}  A call to CHEMTREC will
    also activate the Chemical Manufacturers
    Association's HF Mutual  Aid Group, comprised of
    specially trained teams that respond to emergencies
    involving hydrogen fluoride.

  • Response Information Data Sheets (RIDS) that
    include hydrogen fluoride response information are
    found in CAMEO™, a computer-based planning
    and response management program that is available
    from:

        The National Safety Council
        444 N. Michigan Avenue
         Chicago, IL 60611
         (312) 527-4800 (x6900)
•  Your County or State Health Agency.

•  Your State Emergency Response Commission.

•  Your EPA Regional CEPP Coordinator. EPA
   Regional offices are located in  Boston, New York,
   Philadelphia, Atlanta, Chicago, Dallas, Kansas City,
   Denver, San Francisco, and Seattle.

•  EPA's Emergency Planning and Community Right-
   to-Know Information Hotline at (800) 535-0202, or
   (703) 920-9877 from Monday to Friday, 8:30 a.m. to
   7:30 p.m., Eastern time.

•  Chemical Manufacturers Association, Hydrogen
   Fluoride Panel.  For further information, contact
   Fernando Leiva (202) 887-1100.

•  "Hydrofluoric Acid Anhydrous  - Technical:
   Properties, Uses, Storage and Handling," DuPont
   Chemicals and Pigments. Contact (800) 441-9442.

•  "Recommended  Medical Treatment for
   Hydrofluoric Acid Exposure," Allied-Signal, 1991.
   Contact Allied-Signal Technical Services, (800) 622-
   5002.
PageS
     Chemical Emergency Preparedness and Prevention Advisory

-------
  This advisory is the third of a new series which EPA is publishing to alert LEPCs to hazards posed by
  hazardous substances that have resulted in accidents where death, injury, or evacuations have occurred.  LEPCs
  arc responsible for emergency planning for hazardous materials and for collecting and managing data on
  hazardous chemicals present in their community.

  Please send comments on this Advisory and suggestions for future topics to:

                                    CEPP Advisory
                                    EPA OS-120
                                    401 M Street, SW
                                    Washington, DC 20460

  Additional copies of this advisory and the earlier advisories on swimming pool chemicals and ammonia are
  available from the above address or by calling (800) 535-0202 or (703) 920-9877.
Page 6
Chemical Emergency Preparedness and Prevention Advisory

-------