vvEPA United States Air and Energy Engineering Environmental Protection Research Laboratory Agency Research Triangle Park NC 27711 EPA/600/8-87/028 July 1987 Research and Development Prevention Reference Manual: User's Guide Overview for Controlling Accidental Releases of Air Toxics ------- NOTICE This document has been reviewed in accordance with U.S. Environmental Protection Agency policy and approved for publication. Mention of trade names or commercial products does not constitute endorse- ment or recommendation for use. ------- EPA/600/8-87/028 July 1987 PREVENTION REFERENCE MANUAL: USER'S GUIDE OVERVIEW FOR CONTROLLING ACCIDENTAL RELEASES OF AIR TOXICS by: Daniel S. Davis Glenn B. DeWolf Jeffrey D. Quass Radian Corporation Austin. Texas 78766 Contract No. 68-02-3889 Work Assignments 84 and 98 EPA Project Officer T. Kelly Janes Air and Energy Engineering Research Laboratory Research Triangle Park. North Carolina 27711 AIR AND ENERGY ENGINEERING RESEARCH LABORATORY OFFICE OF RESEARCH AND DEVELOPMENT U.S. ENVIRONMENTAL PROTECTION AGENCY RESEARCH TRIANGLE PARK, NC 27711 ------- ABSTRACT Accidental air releases of toxic chemical must be prevented by all reasonable means, and when they do occur, appropriate measures must be taken to reduce their consequences. This User's Guide, which presents an overview of the methods available for identifying, evaluating, and controlling hazards in facilities that use, manufacture, or store acutely toxic chemicals that could be released into the air, is one of a series of manuals dealing with various aspects of toxic chemical releases. Other volumes focus on specific chemicals, on the procedures and technologies for preventing and protecting against accidental releases of toxic chemicals, and on ways to mitigate a release if it occurs. First, a brief history of accidental releases and their control is presented. Hazardous chemicals and their key properties of interest are defined. Hazards in process operations that relate to process design, physical plant design, and to management and maintenance procedures and practices are examined. Formal methods of hazard identification are described and evaluated, and major features of the most common formal methods are compared. The principles of prevention, protection, and mitigation control are discussed, and example control technologies are listed. Finally, an example guide to facility inspections is presented. ACKNOWLEDGEMENTS This manual was prepared under the overall guidance and direction of T. Kelly Janes, Project Officer, with the active participation of Robert P. Hangebrauck, William J. Rhodes, and Jane M. Crum, all of U.S. EPA. In addition, other EPA personnel served as reviewers. Sponsorship and technical support was also provided by Robert Antonpolis of the South Coast Air Quality Management District of Southern California, and Michael Stenberg of the U. S. EPA, Region 9. Radian Corporation principal contributors involved in preparing the manual were Graham E. Harris (Program Manager), Glenn B. DeWolf (Project Director), Daniel S. Davis, Nancy S. Gates, Jeffrey D. Quass, Miriam Stohs, and Sharon L. Wevill. Contributions were also provided by other staff members. Secretarial support was provided by Roberta J. Brouwer and others. Special thanks are given to the many other people, both in government and industry, who served on the Technical Advisory Group and as peer reviewers 11 ------- TABLE OF CONTENTS Section ABSTRACT ii ACKNOWLEDGEMENTS ii FIGURES iv TABLES V 1 INTRODUCTION 1 1.1 General Background ..... 1 1.2 Historical Background and Accidental Events Overview. . . 3 1.3 Purpose of This Manual 11 2 CHEMICAL HAZARDS 24 2.1 Toxic Chemicals 26 2.2 Physical and Chemical Properties 26 3 HAZARDS IN PROCESS OPERATIONS 29 3.1 Background 29 3.2 Process Design Considerations 32 3.3 Physical Plant Design Considerations 35 3.4 Procedures and Practices 38 4 METHODS OF HAZARD IDENTIFICATION AND EVALUATION 42 4.1 Hazard Identification 42 4.1.1 Checklists 48 4.1.2 Safety Reviews 49 4.1.3 Dow and Mond Hazard Indices 49 4.1.4 Preliminary Hazard Analysis 49 4.1.5 "What If" Method 50 4.1.6 Hazard and Operability (HAZOP) Studies 50 4.1.7 Failure Modes, Effects, and Criticality Analysis . 50 4.1.8 Fault Tree Analysis ..... 52 4.1.9 Event Tree Analysis 52 4.1.10 Cause-Consequence Analysis 52 4.2 Methods for Hazard Evaluation 53 5 OVERVIEW OF PRINCIPLES OF CONTROL 56 5.1 Background 56 5.2 Prevention 58 5.2.1 Process Design Considerations 58 5.2.2 Physical Plant Design Considerations 61 5.2.3 Procedures and Practices 68 5.3 Protection 71 5.4 Mitigation 74 5.5 Control Technology Summary 76 6 GUIDE TO FACILITY INSPECTIONS 83 6.1 Background 83 6.2 General Procedure 84 6.3 Specific Procedures 86 iii ------- TABLE OF CONTENTS (Continued) Section Page 7 COSTS OF ACCIDENTAL RELEASE PREVENTION 87 7.1 Costs of Hazard Identification. Evaluation, and Inspection 87 7.2 Costs of Control Technologies 88 7.3 Cost Implications for Policy Planning 93 8 REFERENCES 97 APPENDIX A - LIST OF ACUTELY TOXIC CHEMICALS 99 APPENDIX B - EXAMPLE DETAILED PROCEDURES FOR HAZARD EVALUATION FACILITY INSPECTIONS 109 APPENDIX C - GLOSSARY 159 APPENDIX D - METRIC (SI) CONVERSION FACTORS 164 FIGURES Number Page 1-1 The role of various accidental release control measures in reducing the consequences of an accidental release 4 1-2 In-plant acute hazardous events by location 8 1-3 Causes of loss in the chemical and allied industries from insurance survey 9 1-4 Functional areas of a typical chemical process facility 21 1-5 Example of logic flow for accidental release control plan review . 23 3-1 Major phases of facility life cycles 39 3-2 Types of errors leading to hazards 40 4-1 Relationship between hazard evaluation procedures and hazard evaluation process 54 7-1 Example of a toxic gas storage system 94 IV ------- TABLES Number Page 1-1 Major Toxic Release Incidents Between 1950 and 1980 ....... 5 1-2 Distribution of Event Locations as Reported by Kletz . 10 1-3 Major Organizations Providing Codes and Standards. Recommended Practices. Design Criteria, or Guidelines for Equipment in Chemical and Allied Industry Process Plants .. 12 1-4 Areas Covered by Codes. Standards, and Recommended Practices. Design Criteria, or Guidelines of Designated Organizations .... 14 1-5 Examples of Needs and Approaches for Regulators and Companies Addressed by Prevention Reference Manuals .. 19 2-1 Selected Properties of Some Common Hazardous Chemicals 27 2-2 Chemical Property Data Pertinent to Accidental Release Evaluations 28 3-1 Some Typical Process Hazard Areas and Examples of Corresponding Control Technologies 33 4-1 Summary of Key Features of Hazard Identification and Evaluation Methods 44 4-2 Example Guide Words and Corresponding Deviations for HAZOP Analysis 51 5-1 Examples of Possible Releases and Controls 77 7-1 Estimated Lower Bound Costs for Various Hazard Identification and Evaluation Procedures 89 7-2 Estimated Costs For Typical Inspections 90 7-3 Costs of Some Individual Instrumentation and Control Components For Process System Safety Modifications 91 7-4 Examples of Control Costs for a Toxic Gas Storage System 95 7-5 Specifications Associated with Toxic Storage System ....... 96 ------- SECTION 1 INTRODUCTION 1.1 GENERAL BACKGROUND Increasing concern about the potentially disastrous consequences of accidental releases of toxic chemicals has resulted from the Bhopal, India methyl isocyanate release on December 3, 1984, which killed approximately 2,000 people and injured thousands more. Concern about the safety of process facilities that handle hazardous materials increased further after the accident at the Chernobyl nuclear power plant in the Soviet Union in April of 1986. While headlines of these incidents have created the current awareness of toxic release problems, there have been other, perhaps less dramatic, inci- dents in the past. These previous accidents contributed to the development of the field of loss prevention as a recognized specialty area within the general realm of engineering science. Interest in reducing the probability and consequences of accidental toxic chemical releases that might harm workers within a process facility and people in the surrounding community prompted the preparation of this manual and a planned series of companion manuals. The other manuals in the series will cover: Chemical specific information, Prevention control technologies, and Mitigation control technologies. These manuals compile the technical information that is necessary for develop- ing approaches to preventing and controlling accidental releases. They cover various aspects of release control, including identification of causes; methods of hazard identification and evaluation; and prevention, protection, and mitigation measures. Prevention involves design and operating measures ------- applied to a process to ensure that primary containment is not breached. Protection focuses on the capture or destruction of a toxic chemical involved in an incipient release after primary containment has been breached, but before an uncontrolled release of the toxic chemical to the environment has occurred. Mitigation measures reduce the consequences of a release once it has occurred. The manuals are based on current and historical technical literature and they address fundamental considerations of the design, con- struction, and operation of chemical process facilities where accidental releases of toxic chemicals could occur. Four types of releases are encountered in facilities that use, manufac- ture or store toxic chemicals: Releases from limited process upsets, Process vents, Fugitive emissions, and Accidental, sudden, large releases. Accidental releases are the primary subject of this manual and of other manuals in the series. The User's Guide is a general introduction to the subject of toxic chemical releases and to the broad concepts addressed in more detail in the other manuals. The manual gives a brief history of toxic chemical releases and overview of the accidental release problem. Primary industrial chemicals of concern are identified and the fundamental causes of toxic releases are summarized. Methods commonly used in hazard identification and evaluation are briefly discussed and an overview of the general principles of hazard control are presented. An example of the kind of guide to facility hazard inspections that can be developed from the information in this and other manuals is also presented. ------- The chemical-specific manuals in the series will focus on release hazard issues associated with specific chemicals in their most common industrial uses. The control technologies manual will focus on the fundamentals of process design, equipment design, and procedures and on how changes in these areas can help prevent and reduce the probability and magnitude of accidental releases. The mitigation manual will discuss ways of reducing the conse- quences of accidental releases. The ultimate objective of controlling accidental chemical releases is to reduce adverse consequences to human health and to the general environment. The place of various controls in achieving this objective is illustrated conceptually in Figure 1-1. Each category of controls contributes to the reduction of the consequences of an accidental release. A full accidental release control program will contain some control methods from each of the categories listed in the figure. 1.2 HISTORICAL BACKGROUND AND ACCIDENTAL EVENTS OVERVIEW The Bhopal incident, one of the most dramatic chemical accidents in history, eclipsed the 1976 major toxic discharge in Seveso, Italy, and numer- ous other significant, but less disastrous chemical releases over the years. The historical development of concern about accidental releases tracks the general advance of loss prevention in the process industries. Much of that development has focused on fire and explosion protection. Since physical property losses are largest in these incidents, the magnitude of losses from fire and explosions has dominated industrial insurance issues for years. Accidental toxic releases have not been ignored, however. Lees (1) presents a summary table of major fire, explosion, and toxic release incidents in the chemical industry from the early years of this century through 1979. A listing of toxic releases taken from that table is presented in Table 1-1. ------- RELEASE HAZARDS HAZARD IDENTIFICATION PRE RELEASE PREVENTION ^^^^^^^^^wJ PRE - RELEASE PROTECTION r POST - RELEASE MITIGATION 1 COMMUNITY RESPONSE 1 r ULTIMATE CONSEQUENCES Figure 1-1. The role of various accidental release control measures in reducing the consequences of an accidental release. ------- TABLE 1-1. MAJOR TOXIC RELEASE INCIDENTS BETWEEN 1950 AND 1980 Date 1950 1952 1961 1961 1961 1962 1963 1963 1966 1967 1967 1968 1968 1969 1969 Location Foza Rica, Mexico Wilsum, Germany Billingham, Great Britain La Barre, Lousiana Morganza, Lousiana Cornwall, Ontario Brandtsville, Pennsylvania Philadelphia. Pennsylvania La Spezia, Italy Bankstown, Australia Newton, Alabama East Germany Lievin, France Crete, Nebraska Glendora, Mississippi Chemical Hydrogen sulfide Chlorine Chlorine Chlorine Chlorine Chlorine Chlorine Chlorine Chlorine Chlorine Chlorine Vinyl chloride Ammonia Ammonia Vinyl chloride Deaths 22 7 0 1 0 0 0 0 0 0 0 24 5 ca. 8 0 Injuries 320 Unknown Unknown 114 17 89 Unknown 430+ Unknown 5 Unknown Unknown Unknown 20 Unknown Source: Reference 1 (continued) ------- TABLE 1-1 (Continued) Date 1970 1971 1973 1973 1973 1974 1976 1976 1976 1977 1978 1978 1978 Location Blair, Nebraska Floral, Arkansas Loos, British Columbia McPherson, Kansas Potchef stroom, South Africa Nebraska Baton Rouge, Louisiana Houston, Texas Seveso, Italy Columbia Baltimore, Maryland Chicago. Illinois Youngstown, Florida Chemical Ammonia Ammonia Chlorine Ammonia Ammonia Chlorine Chlorine Ammonia Dioxin (TCDD) Ammonia Sulfur trioxide Hydrogen sulfide Chlorine Deaths 0 0 0 0 18 Unknown Unknown 6 0 30 Unknown Unknown 8 Injuries Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Source: Reference 1. ------- Various other surveys also address accidental releases. A recent publi- cation by the U.S. Environmental Protection Agency (EPA), the Acute Hazardous Events Data Base, examines the causes of toxic chemical accidental release events (2). Along with other statistics, this report presents the locations of toxic release events within a process facility, as shown in Figure 12. The causes of losses in the chemical and allied industries as shown in an insurance survey are presented in Figure 1-3 (3). Table 1-2 summarizes similar information from two other sources (A). Examination of this information shows that it is difficult to absolutely quantify the distribution of accidental release causes; every survey results in a somewhat different distribution of causes. A likely reason for these differences is that every survey uses a different and fairly limited data set. Another possible reason is the difficulty in consistently defining the actual causes of a release. As an example, if a valve were to fail because of corrosion and result in an accidental release, the cause might be classified as valve failure, maintenance failure or design failure, depending on the classification criteria of the specific survey. Even within this complexity, however, some trends can be observed. A comparison of the information shows that faulty pipes and fittings are common causes of accidental releases. The occurrence of such incidents tends to obscure the long and dedicated activity of numerous individuals and organizations who have contributed to the field of loss prevention. Some organizations that have been very active in this area, especially in the last two decades, include the Institute of Chemical Engineers (Britain), the American Institute of Chemical Engineers, the American Petroleum Institute, other organizations and many major corpora- tions, especially in the chemical industry. Two leaders in this field have been Dow, which developed the well-known Dow Index for ranking process facili- ties for fire and explosion potential, and Imperial Chemical Industries, for modifying this index to the Mond Index, which includes toxicity in the rank- ing. Activity in both the public and private sectors in this area is intense. ------- ALL EVENTS DEATH/INJURY EVENTS 00 VALVES/PIPES 19.4* VALVES/PIPES te.er. NUMBER OF EVENTS = 5179 NUMBER OF EVENTS = 304 Figure 1-2. In-plant acute hazardous events by location. Source: Reference 2. ------- 60 % 40* 20% OX INSTRUMENTATION EXCHANGERS GASKETS COMPRESSORS SIGHT GLASSES MECHRNICRL EQUIPMENT FRILURE PROCESS UPSETS HUMRN ERROR RRSON OR SRBOTRGE Figure 1-3. Causes of loss in the chemical and allied industries according to insurance survey. Source: Adapted from Reference 3. ------- TABLE 1-2. DISTRIBUTION OF EVENT LOCATIONS AS REPORTED BY KLETZ Q Percentage Attributable to Each Location Location (Data Source A) (Data Source B) Pipes and fittings 34 61 Vessels 9 - internal reactions 22 - other 21 Relief valves, vents, drains 11 22 Pumps 6 4 Equipment under maintenance 6 4 100 100 Source: Reference 4. Two references were cited by Kletz. Data source A is: One Hundred Largest Losses, Marsh and McLennan, Chicago, Illinois, Sixth Edition, 1985. Data source B is: Davenport, J., Chemical Engineering Progress, September, 1977, p. 54. 10 ------- as each strives to apply the latest knowledge and technology to the prevention and mitigation of accidental toxic chemical releases. A number of public and private organizations have developed codes and standards, recommended practices, design criteria, or guidelines establishing at least minimum standards for equipment and systems potentially involved in accidental releases. Table 1-3 presents a list of some of these organi- zations. Some of the codes and standards developed by these organizations present recommended design criteria for individual pieces of equipment or for entire plant systems. Others present recommended practices for conducting a safe operation. Some of these organizations have published specific hazard evaluation and reduction information. A complete presentation of such infor- mation is beyond the scope of this manual, but the reader may contact in- dividual organizations for additional information. Table 1-4 summarizes general areas addressed by the various organizations. 1.3 PURPOSE OF THIS MANUAL The User's Guide is an introduction to the overall area of accidental chemical releases prevention, protection, and mitigation for government agency personnel, industry managers, technical people, and other persons concerned with reducing the risk of accidental toxic chemical releases. It is intended to assist and inform the reader about where and how to seek additional infor- mation. The manual is also a guide to the more detailed information in the companion set of manuals and to the general technical literature. Government agencies will probably continue to become more involved in this area as awareness specific to accidental releases increases and more regulations are promulgated. Past involvement by industry has been broad. Future participation in the area of accidental release prevention, protection, and mitigation is expected to increase in response both to new regulations and to increased awareness of toxic air release issues on the part of company management, technical staff and the general public. 11 ------- TABLE 1-3. MAJOR ORGANIZATIONS PROVIDING CODES AND STANDARDS, RECOMMENDED PRACTICES, DESIGN CRITERIA, OR GUIDELINES FOR EQUIPMENT IN CHEMICAL AND ALLIED INDUSTRY PROCESS PLANTS Name Abbreviation Technical and Trade Groups Air Conditioning & Refrigeration Institute Air Moving and Conditioning Association American Association of Railroads American Gas Assocation American Petroleum Institute American Water Works Association Chemical Manufacturer's Association (formerly Manufacturing Chemists Association) Chlorine Institute Compressed Gas Association Cooling Tower Institute Manufacturers Standardization Society National Electrical Manufacturers Association Pipe Fabrication Institute Scientific Apparatus Makers Association Society of Plastics Industry Steel Structure Painting Council Tubular Exchanger Manufacturers Association U.S. Government Agencies Bureau of Mines Department of Transportation U.S. Coast Guard Hazardous Materials Regulation Board Federal Aviation Administration Environmental Protection Agency National Bureau of Standards Occupational Safety and Health Administration Testing Standards and Safety Groups American National Standards Institute American Society for Testing and Materials National Fi.re Protection Association Underwriters Laboratories, Inc. National Safety Council ARI AMCA AAR AGA API AWWA CMA (MCA) CI CGA CTI MSS NEMA PFI SAMA SPI SSPC TEMA BM DOT USCG HMRB FAA EPA NBS OSHA ANSI ASTM NFPA UL NSC (Continued) 12 ------- TABLE 1-3 (Continued) Name Abbreviation Insuring Associations American Insurance Association AIA Factory Insurance Association FIA Factory Mutual System FM Oil Insurance Association OIA Professional Societies American Conference of Governmental Industrial Hygienists ACGIH American Industrial Hygiene Association AIHA American Institute of Chemical Engineers AIChE American Society of Mechanical Engineers ASME Amer. Soc. of Htg. Refrig. & Air-Cond. Engs. ASHRAE Illumination Engineers Society IES Institute of Chemical Engineers (Britian) IChE Institute of Electrical and Electronic Engineers IEEE Instrument Society of America ISA Source: Adapted from Reference 6. 13 ------- TABLE 1-4. AREAS COVERED BY CODES, STANDARDS, RECOMMENDED PRACTICES. DESIGN CRITERIA, OR GUIDELINES OF DESIGNATED ORGANIZATIONS (SEE TABLE 1-3 FOR SYMBOLS DEFINITIONS) Accident Case History Air Compressors Air-Fin Coolers Boilers Combustion Equipment and Controls Compressors Cooling Towers Drain and Waste Systems Dust Collection Equipment Dust Hazards Electric Motors Electrical Area Classification Electrical Control and Enclosures Emergency Electrical Systems Fans and Blowers Fire Protection Equipment AGA, AIA, AIChE, API, FIA, FM, NFPA, NSC, OIA, OSHA, USCG AIA, ANSI, FM, USCG ARI, ASHRAE, OIA, USCG ANSI, NFPA, NSC, UL ANSI, FIA, FM. NFPA, NSC, OIA, UL, USCG AIA, ARI, ASHRAE, ASME, FM, OIA, USCG CTI, FM, NFPA, OIA AICHE, AWWA, MCA, USCG FIA, FM, NFPA, USCG ACGIH, AIHA, ANSI, BM, FIA, FM, NFPA, NSC, UL, USCG ANSI. IEEE, MCA, NFPA, UL, USCG AIA, ANSI, API, FIA, FM, MCA, NFPA. NSC. OJA. OSHA, USCG AIA, ANSI, ARI, FIA, FM, IEEE, ISA, MCA, NEMA. NFPA, NSC. OIA, OSHA. UL, USCG AGA. AIA, FM, IEEE, NEMA, NFPA, USCG ACGIH, AIHA, AMCA, ARI, ASME, FM, USCG AIA, ANSI. API, AWWA, BM. CGA, FIA, MCA, NEMA. NFPA, NSC, OIA, OSHA, UL, USCG (Continued) 14 ------- TABLE 1-4 (Continued) Fire Pumps Fired Heaters Gas Engines Gas Turbines Gear Drives Power Transmission Grounding and Static Electrical Inspection and Testing Instrumentation Insulation and Fireproofing Jets and Ejectors Lighting Lubrication Material Handling Materials of Construction Noise and Vibration ANSI, FM, HI. IEEE, NFPA, UL, USCG ANSI. ASME. FIA. FM. NFPA. OIA. UL, USCG FM, NFPA, OIA, USCG AGA. FIA. FM, NFPA, OIA, USCG AGMA, AIA, ANSI. NSC. USX AIA, ANSI. API. FIA, FM, IEEE, NEMA. NFPA. NSC. OIA. OSHA, UL, USCG ABMA. AGMA, AIChE, AMCA, API, ASHRHE, ASTM, AWWA, CGA, CTI, DOT, HEJ, HI, IEEE, MSS, NFPA. NSC. PFI, USCG AIA. ANSI, API, ARI, ASTM. AWWA. CGA, FIA. FM. HMRB, IEEE. ISA, NBS, NFPA. OIA, SAMA, UL, USCG AIA, ANSI. ASHRAE, ASTM, FM, OIA, UL, USCG HEI, USCG ANSI, FM. IEEE. IBS. NEMA. NFPA, NSC, UL, USCG AMCA, ANSI, ASME, NFPA MCA, NFPA. NSC, OSHA AIA, ANSI, ASTM, AWWA, CGA, CI. CTI, FM, HMRB, ISA, MCA, NBS, NFPA, NSC, OIA, TEMA. UL. USCG AGA, AIChE, AIHA, AMCA. ANSI, API. ARI. ASHRAE. ASTM. EPA, ISA, NFPA, NSC, OSHA, UL (Continued) 15 ------- TABLE 1-4 (Continued) Painting and Coating Piping Materials and Systems Plant and Equipment Layout Pneumatic Conveying Power Wiring Pressure Relief Equipment Systems Pressure Vessels Product Storage and Handling Pumps Refrigeration Equipment Safety Equipment Shell and Tube Exchangers Shutdown System Solids Conveyors Stacks and Flares AIChE. ANSI, ASTM. AWWA, HMRB, OSHA. NBS, SSPC, UL AGA, AIA. ANSI, API, ARI, ASHRAE, ASTM, AWWA, CGA. CI. FIA, FM. HMRB, IBS, MSS, NBS, NFPA, NSC, PFI. SPI, UL, USCG AAR, AIA. API, AWWA, CGA, FIA. FM, HMRB, MCA, NFPA. NSC, OIA, USCG ANSI, FIOA, NFPA, USCG ANSI. API, FIA, FM. IEEE. NEMA, NFPA, OIA, OSHA, UL. USCG AIA, API, ASME, CGA. CI. FIA. FM, AIA, API, ASME, CGA, DOT. NFPA, NSC, OSHA, USCG, HMRB, OIA, OSHA, USCG AAR, AIChE, AIA, ANSI, API, CGA, CI, FIA, FM, MCA, NFPA. OIA. OSHA, USCG AIChE, ANSI, AWWA. CI, NFPA, OIA, UL, USCG ANSI, API, ASHRAE, FM, NFPA, UL, USCG ACGIH. AIHA, ANSI, BM, CGA, CI, FM, MCA, NSC, OSHA, UL. USCG AGA, AIChE. API, ASHRAE, ASME, CGA, PFI, USCG AIA. API. FIA, NFPA, OIA, UL, USCG MCA FAA. OIA, USCG (Continued) 16 ------- TABLE 1-4 (Continued) Steam Turbines Storage Tanks Ventilation Venting Requirements AIA. FM, IEEE. OIA, USCG AWWA, CI. NBS. NFPA, OIA, OSHA, UL, USCG ACGIH, AIHA, ANSI, BM, FIA, FM, NFPA, NSC, UL. USCG API, FIA, FM. HMRB, NFPA, USCG Source: Adapted from Reference 6. 17 ------- Table 1-5 illustrates the potential needs of government agency personnel and individual companies if called on to enforce or comply with a regulation specifically geared toward accidental release prevention. These needs include the resources that will be required for such a task. The table summarizes approaches to meeting these needs. The User's Guide and companion manuals will provide one information resource for responding to accidental release regulations established by local authorities. For needs or approaches not specifically covered in the manuals, or for areas where more detail is re- quired than the manuals can provide, the references cited in the manuals can help the reader obtain more detailed information. For both regulators and companies interested in release prevention, an overall concept of a process facility must be developed in terms of the physical and functional areas that would be covered by a complete release prevention evaluation or control plan. Such a concept is shown in Figure 1-4. These aspects of a facility must be addressed at each stage in the total life cycle of the facility.1 The basic stages, design, construction, startup, operation and shutdown, are discussed further in Section 3.4. Chemicals are transported to the facility and pass through a sequence\of transfer, storage, and process operations that produce more chemicals that pass through a similar sequence until they leave the facility. To develop a company hazard control plan or for a regulatory review of such a plan, each step in the sequence must be scrutinized for the following: ' The toxic chemicals used and where. Hazardous processes and operations, and Control measures. Later sections of this manual address each of these considerations by: summarizing the fundamental principles of chemical hazards, process and opera- tional hazards, hazard identification and evaluation, and hazard control. 18 ------- TABLE 1-5. EXAMPLES OP NEEDS AND APPROACHES FOR REGULATORS AND COMPANIES ADDRESSED BY PREVENTION REFERENCE MANUALS Need* Government Approach Meed* Industry Approach Basic Information Types of Facilities vD Types of Processes Hazard Identification Prioritization Identify facilities within the regulators jurisdiction that are subject to safety concerns covered by the accidental release guidelines or regulations. Gather historical background on previous accidental releases at each facility and accidental releases at similar facilities. Obtain intonation about the processes used at each facility. Become aware of the range of accidental release hazards associated with the processes used at each of the facilities covered by the regulation. Develop a criteria for ranking the facilities for accidental release risk. Compare the available resources to the ranking and select which facilities require further investigation and specifically which processes within a facility should be examined for compliance. Identify the range of potential control techniques that could be applied to each process to be examined. Control Measure Verification Document Review Identify which accidental release control techniques are in place at each facility by requesting summary documentation of a control plan. If the documentation provided does not indicate compliance then request additional documentation. Basic Information Types of Processes Hazard Identification Evaluate the requirements of the accidental release safety objectives. guidelines, or regulations in light of the specific processes in use at the facility. Gather historical background on previous accidental releases at similar facilities. Become aware of the range of accidental release hazards associated with the processes used at the facility. Use hazard identification and evaluation methods to evaluate the adequacy of the accidental release prevention measures already in place and to pinpoint areas of deficiency. Control Measure Selection and Evaluation Prioritization Identify the control measures that could be applied to the areas where the present control measures are deficient. Evaluate the resources that are required to perform each level of control. Evaluate the effectiveness of each control method. (Continued) ------- TABLE 1-5 (Continued) Needs Government Approach Needs Industry Approach Facility Inspection If the additional documentation does not indicate compliance then visit the facility and perform a detailed review of control plan documentation. If compliance is not confirmed then inspect those portions of the facility that are of interest. Resources Required/Available Historical literature Newspapers; local news stations. Technical literature Loss prevention journal articles and text books; Accidental Release Prevention Reference Manual (ARPRM) series. Apply measures that will bring the facility into compliance and will provide the most efficient use of resources. Prepared both detailed and summary documentation of control practices. Periodically reinspect the facility; especially important when process changes are made. Resources Required/Available Public records Organizations Regulations Personnel Costs State or local data base. Technical societies and trade organizations; local, state and federal regulatory organizations; consultants. Related regulations that impact accidental release prevention; other regulations that specifically apply to accidental release prevention. Experienced personnel within the regulatory agency. Personnel from other regulatory agencies with experience in accidental release prevention. Outside consultants with experience in accidental release prevention. The costs the agency will incur by performing document and facility reviews at various levels of detail. The facility's cost to perform different varieties of internal hazard evaluation. the cost to implement various control measures, and the cost of assembling a comprehensive control plan. Historical literature Technical literature Public records Organizations Regulations Personnel Costs Newspapers; local news stations. Loss prevention journal articles and text books; Accidental Release Prevention Reference Manual (ARPRM) series. State or local data base. Technical societies and trade organizations; local, state and federal regulatory organizations; consultants. Related regulation that impact accidental release prevention: other regulations that specifically apply to accidental release prevention. Experienced personnel within the plant. Outside consultants with experience in accidental release prevention. The cost to perform different varieties of internal hazard evaluation, the cost to implement various control measures, and the cost of assembling a comprehensive control plan. ------- Transport I Transfer I Storage i Transfer I Processing Transfer 1 Storage I Transfer i Transport Figure 1-4. Functional areas of a typical chemical process facility. 21 ------- Once an accidental release control plan is developed, the review of the control plan by a regulator or the company itself may follow the kind of logic flow shown in Figure 1-5. A regulator will probably go into less detail than a company reviewer, but the logic of analysis will probably be the same. This diagram highlights major decision points in the review process and illustrates the possible iterations that may be involved before a plan can be considered acceptable. Procedures may differ from this in detail in individual circum- stances. The remainder of this manual discusses chemical hazards in Section 2, hazards in process operations in Section 3, methods for hazard identification and evaluation in Section A, an overview of principles of control in Section 5, a guide to facility inspections in Section 6, costs of prevention in Section 7, and references in Section 8. 22 ------- u> Review Drawings, Specifications and Operating Pro- cedures and Com pare lo Proper Practices for Reac- tor Systems Figure 1-5. Example of logic flow for accidental release control plan review, ------- SECTION 2 CHEMICAL HAZARDS A fundamental need from either a regulator's or company's point of view is the identification and ranking of chemical hazards within a process facility. The primary basis for selecting chemicals that pose a significant danger if accidentally released is their acute toxicity, but other properties also enter the selection process. Various lists of hazardous chemicals have been prepared by numerous organizations, including the U.S. Environmental Protection Agency (EPA) and the European Economic Community (EEC). Current hazardous chemicals of primary interest to the U.S. EPA are listed in an EPA publication (5). This list is reproduced in Appendix A of this manual. This section of the manual discusses major considerations for identifying and classifying toxic chemicals and serves as a guide for setting up priority lists of the chemicals themselves. An example ranking system is also illus- trated. 2.1 TOXIC CHEMICALS In the context of accidental releases, hazardous chemicals are materials with acute toxic and other properties that make them an imminent threat to human health and/or the general environment, even after brief exposure. Releases of chemicals that have the potential for long-term health effects and/or environmental damage are also of concern, and while many of the principles discussed in this manual would apply to these, the primary focus is on acute toxic chemicals. 24 ------- The primary methods of expressing toxicity are: Immediately Dangerous to Life and Health (IDLH), defined as the maximum level to which a healthy male worker can be exposed for 30 minutes and escape without suffering irreversible health effects or impairing symptoms. These values have been developed and specified by the National Institute for Occupational Safety and Health (5) . Low Lethal Concentration (LCL ) is the lowest lethal concentration observed in tests on laboratory animals or in accidental human exposure. 50% Lethal Concentration (LC ) is the concentration for which 50% of the test animals died when exposed for a specified period of time. Permissible Exposure Limit (PEL) , defined as the maximum air concentration to which a healthy male worker can be exposed for 8 hours per day, 40 hours per week without adverse effects as determined by the Occupational Safety and Health Association (OSHA) . Short-term Exposure Limit (STEL) is the maximum concen- tration to which workers can be exposed for up to 15 minutes, provided no more than four exposures per day are permitted with at least 60 minutes between exposure periods. The relative acute toxic hazard of different chemicals may be ranked using any one of these criteria. In a recent document, the U.S. EPA suggests using the IDLH as the primary criterion for estimating consequences of 25 ------- accidental releases, with the LC.O and LC as second and third choices, or other criteria if these are not available (5) . The ultimate adverse consequences of a release result from the toxicity of the chemical, but other physical and chemical properties are also important when considering the causes and prevention of releases, and their consequen- ces. 2.2 PHYSICAL AND CHEMICAL PROPERTIES Significant physical and chemical properties include boiling point, vapor pressure, heat of vaporization, density, viscosity, and reactivity. Low boiling points and high vapor pressures increase the quantity of chemical emitted to the air during a release. A low heat of vaporization results in an increased rate of vaporization from spills or liquid releases of volatile toxic chemicals. High vapor or gas densities hinder dispersion and result in low lying clouds which imperil people at ground level. In the case of liquids, viscosity is important because a spilled or leaked low viscosity material will flow and spread more rapidly than a high viscosity material. Other physical properties, also significant in the evaporation and dispersion behavior of liquids, vapors, and gases, include surface tension, diffusivity, and heat capacities. For solids, particle size is important. Reactivity includes properties such as flammability, explosivity, exothermicity, and corrosiveness . Flammability is the ability of a chemical to burn. Explosivity is the ability of a chemical to react rapidly enough with itself or other materials including oxygen in ambient air, to cause an explosion. A common destructive manifestation of reaction with air is a vapor cloud or dust explosions when a material is within its explosive limits. Exothermicity refers more to specific chemical reactions than to the chemicals themselves, but this ability for the reactions to generate significant amounts of heat means that if they get out of control, they can result in thermal runaway, overpressure in 26 ------- containment equipment, and possibly to explosions. Finally, corrosiveness, another aspect of reactivity, can damage equipment and cause equipment failures and chemical releases. A more detailed discussion of the relationship between specific chemical properties and release hazards can be found in the technical literature (1, 6). Vapor pressure, vapor density, and the IDLH are the minimum property data needed to establish that a specific chemical is an acute toxic, air release hazard. Values for some common hazardous chemicals are presented in Table 2-1. TABLE 2-1. SELECTED PROPERTIES OF SOME COMMON HAZARDOUS CHEMICALS Chemical Ammonia Carbon Tetra- chloride Chlorine Chloropicrin Anhydrous Hydrogen Chloride Anhydrous Hydrogen Fluoride Phosgene Sulfur Dioxide Hydrogen Cyanide Boiling Point °F -28.03 170.1 -29.29 233.6 -121.1 67.10 45. 46 13.96 78.26 Vapor (psi) Pressure 68°F 128.9 1.74 92.8 0.35 0.505 15.0 23.5 47.9 12.8 Vapor Density (Air = 1) 32°F 0.597 5.32 2.49 5.70 1.27 1.56 3.40 2.26 0.95 IDLH (ppm) 500 300 25 4 100 20 2 100 50 Sources of data: References 7, 8, 9, 10 and 11. Table 2-2 shows a more complete list of properties as would be required for a complete comparative evaluation of chemicals. Once the chemicals of concern have been identified, the next step in controlling accidental releases is to examine the operations in which these chemicals are used. Hazards in process operations is the subject of the next section of this manual. 27 ------- TABLE 2-2. CHEMICAL PROPERTY DATA PERTINENT TO ACCIDENTAL RELEASE EVALUATIONS Chemical name, synonyms, and Chemical Abstracts Service Registry Number (CAS #) Chemical formula and/or drawing of structure Phase at room temperature Boiling point (normal and/or at pressure) Melting point Liquid density and/or specific gravity at temperature Vapor pressure at temperature(s) (e.g., Antoine equation) Gas density and/or specific gravity at temperature Solubility in water, alcohol, ether, and other reactants/products Liquid viscosity Enthalpy at temperature(s) Specific heat at constant volume Specific heat at constant pressure Critical temperature Critical pressure Critical volume Flash point Limits of flammability and explosivity NEPA 704M Safety Hazard Rating (health, flammability. reactivity, special) Differential thermal analysis CHETAH (Chemical Thermodynamics and Hazards) evaluation (or equivalent) Hazard Properties: Oral Poison Inhalant Poison Contact Poison Lachrymator Contact Irritant Inhalation Irritant Pyrophoric Teratogen Carcinogen Mutagen Releases Vapors Hyroscopic Reaction Properties: Reacts with Air Reacts with Water Reacts with Acids Reacts with Bases Reacts with Alkanes Exothermic Releases Gases Foams Solidifies Violent Reaction Forms Toxic Products Reacts with Metals Polymerizes Autocatalytic Decomposes Light Sensitive Shock Sensitive 28 ------- SECTION 3 HAZARDS IN PROCESS OPERATIONS Once a regulator or company has identified the toxic chemicals manufac- tured, used, or stored at a facility, the process situations that could lead to a release should be identified so that the adequacy of proposed controls (in the case of the regulator), or select appropriate control measures (in the case of the company) can be evaluated. Before identifying process hazards, discussed in Section 4, and their corresponding control measures for specific facilities, discussed in Section 5, an understanding of the kinds of hazards, and available control measures is required. This section of the manual presents an overview of hazards and failure modes of process systems for toxic chemicals as they relate to process design considerations, physical plant design considerations, and operational proce- dures and practices at any stage in the life cycle of a facility. Examples of specific hazards and possible causes are cited for each of these key areas. 3.1 BACKGROUND The preceding sections have presented an overview of accidental releases. The hazard of a release increases with the toxicity and reactivity of the chemicals involved, the process energy content, the inventory, and the com- plexity of the process system. The more toxic a material, the more severe may be the consequences of release. Reactive materials are more dangerous than less reactive materials because physical containment may be more difficult (e.g., corrosion problems), and operational problems may be more severe (e.g., hard to control rapid chemical reaction). Operating pressure and temperature determine process energy content. The higher the energy content, the higher the potential driving force for release and the more difficult it is to design 29 ------- the containment equipment. Large inventories are a greater hazard than small inventories because more material can be released. The more complex a process is, the more physical components there are that can fail, making control more difficult. These broad categories of hazards must be addressed in the safe design, construction, and operation of process systems for toxic chemicals. They can be addressed in the following general categories: Process design considerations; Physical plant design considerations; and Operational procedures and practices. Each of these categories organizes specific hazards, failure modes, and control measures in terms of prevention, protection, and mitigation. Examples of specific hazards and failure modes are discussed in this section. Preven- tion, protection, and mitigation control measures are discussed in Section 5. Basic causes of releases can be summarized as follows: Process or operational failures causing pressure or temperature to exceed limits of the process equipment; Equipment containment failures at normal process condi- tions; Operational or maintenance errors, omissions, or deliber- ate criminal acts (e.g., vandalism) leading to either of the above two conditions, or to direct releases (e.g., inadvertently opening a valve and releasing material); and Imposition of external damaging factors such as fire, explosion, flooding, or mechanical stress, which directly 30 ------- lead to equipment failure. Natural phenomena such as flooding, earthquakes, or wind storms can be contributing factors here. Each of these general causes can have many specific initiating and enabling events or contributing causes, forming a chain leading to the final event which physically results in the release. Prevention and protection measures interdict the event chain at a point before the final release event can occur. Some specific areas of process facilities that should always receive close attention are: Large inventories of toxic materials such as storage areas, and inventories of flammable or explosive materials near large toxic inventories, Exothermic chemical reactors, and inventories of chemicals prone to exothermic reactions with other materials, even if by contamination rather than by design, Any process areas with high energy content; high temper- ature and pressure operations, Any process operations with positive energy input such as distillation, Processes with complex sequencing or unit operations interactions such as recycles, Processes involving toxic chemicals in combination with highly corrosive, flammable, or explosive materials, and 31 ------- Existing process facilities that have recently been modified, are very old, or very new. There are many other specific areas that can be listed, but the above represent areas of high priority. Table 3-1 presents examples of a few typical process hazard areas and possible corresponding control technologies. Other hazard areas and corre- sponding controls could be listed. 3.2 PROCESS DESIGN CONSIDERATIONS Process design considerations encompass technology, procedures and practices associated with the sequence and conditional state of all of the process steps and operations in a chemical process. These considerations include the nature of the chemical materials used in the process and the fundamental manipulated process variables. Process design considerations address the relationships between physical variables and time; in other words, the physical states of the process as a function of time and the means and characteristics of process control. Process design considerations include: Process characteristics and chemistry, Overall process control, Flow control, Pressure control, Temperature control, Quantity control, Mixing effects, Composition control, Energy systems, Detection and alarm systems, and Fire and explosion protection. 32 ------- TABLE 3-1. SOME TYPICAL PROCESS HAZARD AREAS AND EXAMPLES OF CORRESPONDING CONTROL TECHNOLOGIES Hazard Area Large inventories of toxic materials Exothermic chemical reactors Contamination of stored chemicals Distillation processes Example Control Technologies Change process or procedures to reduce need for large inventories. Use substitute. Design storage for higher containment reliability. High reliability cooling systems, including backup cooling. Change process chemistry. High reliability feed process control. (e.g., feed interlocks, ratio control) Emergency relief systems. Emergency dump systems. Emergency quench and inhibition systems. Special backflow protection. Special isolation valves. Equipment/process segregation. High reliability process control. Venting and pressure relief to emergency scrubbers or flares. High reliability heating systems, with emergency shutdown interlocks. Distillation under vacuum. 33 ------- Process failures leading to an accidental release may be related to deficiencies in any of these areas. Such failures would cause the conditional state of the system to exceed the design limits of the equipment or the ability of a human operator to respond quickly or accurately enough to main- tain control for changes that are occurring in the process . For example, the loss of flow control of a reactant to an exothermic chemical reactor could lead to a loss of temperature control, which, in turn, could cause overpres- sure (loss of pressure control). This could lead to a vessel rupture. If events occurred fast enough, a human operator might not be able to detect and respond quickly enough to take corrective action. Some examples of specific hazards associated with each of these consider- ations include: Process characteristics and chemistrypotential explosive mixtures, or highly exothermic reactions; Overall process controla control system which is improp- erly configured for the dynamics of the process, causing sensitivity and difficult-to-control conditions; Flow controlsignificant deviations such as insufficient cooling water rates, excessive reactant feeds, or block- age; Pressure controloverpressure or severe cycling or surges; Temperature controloverheating equipment to the point of materials failure or runaway chemical reactions; Quantity controlincorrect sequence of reactant charge, incorrect reactant ratio, or overfilling a vessel; ------- Mixinginadequate mixing causing poor heat transfer and overheating; Compositioncontamination leading to unexpected reactions or corrosion; Energy systemsloss of critical heating or cooling; Detection and alarm systemsinadequacy or instrument failure; Fire and explosion protectioninadequacy or equipment failure. Details of hazards associated with each of these areas will be discussed in a companion manual on prevention and protection control technologies, in this series. 3.3 PHYSICAL PLANT DESIGN CONSIDERATIONS As stated earlier, a release may result from the conditional state of the process exceeding the physical limits of the equipment, or at normal process conditions when the physical limits of the equipment deteriorate below those required for containment. In either case, equipment will fail. Physical plant design considerations address both situations, as well as the interac- tions of individual equipment failures with failure of the total system. Physical plant design considerations include the following: Codes and standards, Complexity and operability, Reliability, Materials of construction. 35 ------- Vessels (e.g. heat exchanger colunms, tanks, and reac- tors) , Piping and valves, Process machinery, Instrumentation, and Siting and layout. Design must ensure that equipment and components can withstand normal operating conditions for the anticipated life of the facility and can tolerate abnormal conditions within certain bounds. A common cause of failure is the deterioration of equipment over time through various materials failure phenom- ena such as corrosion. Codes and standards provide some basis for ensuring adequate design, but these are primarily minimum standards. In specific cases, design beyond these minimum standards may be important. The complexity and operability of the equipment may also influence how well a process is controlled, and how easily the equipment and its components are maintained. Reliability, the ability of equipment and components to perform their func- tions with few or no failures, depends on adequate design, construction, and maintenance. A fundamental principle of reliability is that the system will be only as reliable as its most unreliable component, which is the basis for backup or redundancy in physical systems. Specific causes of failure have been classified in the technical litera- ture (1). Some common causes of mechanical failure are: Excessive stress, External loading, Overpressure, Overheating, * Mechanical fatigue and shock, Thermal fatigue and shock, Brittle fracture, Creep, and 36 ------- Chemical attack (e.g., corrosion, hydrogen blistering, etc.) Conditions leading to such failure modes range from improper design through improper installation and operation. For example, improper alignment can lead to excessive stress on couplings or shafts of rotating equipment. If properly recognized and evaluated, the prevention of each of these failure modes can be incorporated into initial facility design and construction. The first line of prevention of such failures is in the proper selection and use of construction materials. As can easily be seen, however, some of these conditions are related to operating conditions which can change over time. Recognition of these failure modes is the basis for many of the specific equipment considerations for the categories of vessels, piping and valves, process machinery, and instrumentation. The manual on control technologies will address these considerations in more detail. Siting and layout are also considered to be within the realm of physical plant design considerations. Hazards associated with siting may include both natural and man-made factors. Some natural factors include floods, earth- quakes, and windstorms. Man-made factors include the siting of facilities near other high hazard facilities, or in areas where an adequately educated and trained labor force may not be available. Layout considerations refer to the relationships among equipment and components within a process unit and among process units in an overall facility. Hazards can arise from layout, for example, when highly toxic and flammable materials or incompatible reac- tive materials are stored close together. In summary, physical plant design considerations are concerned with the hardware, as opposed to process design considerations, discussed earlier, which are concerned with the "software" of a process facility. 37 ------- 3.4 PROCEDURES AND PRACTICES The final general hazard area in process operations involves procedures and practices. Hazards in this area arise from human error in decision making, physical actions controlling a process, and in planning, supervising, and other non-physical activities in the design, construction, and operation of process facilities at any stage of a facility's total life cycle. Figure 3-1 illustrates the various phases of a facility life cycle where errors leading to hazards may be introduced. Figure 3-2 illustrates some kinds of errors that may be introduced. The realization of some hazards in this area are indirect; for example, a lax management policy that does not enforce its own safety standards. Others are direct, such as the operator who takes a wrong action at a control panel. One categorization of procedures and practices includes: Management policy, Operator training and practices, Maintenance practices, and Communications. Management policy is important because the successful prevention of accidental releases requires the commitment of the human, financial, and material resources of an organization to do what is necessary for release prevention. One of the most important roles of management, after an appropri- ate safety policy has been established, is to enforce it, keep it up to date, and change it as circumstances change. For example, a preventive maintenance program for high hazard process areas may be well defined and properly written up, but if the program is not audited to see that it really works, then the program may not accomplish its objective. The focus on loss prevention can be so much on specific details that the indirect problem of poor management or supervision in failing to create a proper safety environment is overlooked. Management policy should address special safety procedures for toxic chemicals 38 ------- DESIGN ODCPATIOM SHUT - DOWN to n Figure 3-1. Major phases of facility life cycle. ------- DESIGN ERRORS EQUIPMENT FAILURE INADEQUATE SPECIFICATIONS INADEQUATE SUPERVISION INADEQUATE HAZARD EVALUATION CONSTRUCTION ERRORS - INADEQUATE CONTROL INADEQUATE MAINTENANCE INADEQUATE INSPECTIONS WRONG MATERIALS - IMPROPER PRACTICES INADEQUATE SUPERVISION HUMAN ERROR INADEQUATE QUALIFICATIONS INADEQUATE TRAINING INADEQUATE OPERABILITY INADEQUATE EMERGENCY PROCEDURES Figure 3-2. Types of errors leading to hazards. ------- through all parts of the chemical process life cycle that was shown in Figure 3-1. Operator training and practices have a more direct bearing on release prevention. The skill and knowledge of the operators should be commensurate with the needs of the process, and high hazard processes should, therefore, require a higher standard of operator skill and knowledge than low hazard processes. An often overlooked aspect of operator training is performance auditing. Performance auditing requires a systematic way of obtaining a measurable check on individual operator knowledge is necessary, and especially the operator's knowledge of the possible causes of and means of dealing with unlikely yet potentially serious accidental release events. Emergency re- sponse plan drills should be a regular part of operator training. Maintenance practices are crucial to accidental release prevention. Even if a process facility is originally designed in a way that minimizes the potential for accidental releases, both deliberate and unrecognized changes may occur over time that render a facility unsafe. Proper maintenance is the primary prevention measure that ensures that the original specifications are adhered to and that all special preventive or protective systems are function- al. Finally, the whole human component of accidental release prevention is tied together by effective communications. Information transmitted among the various parts of the organization must be clear, accurate, and timely. Communications procedures for high-hazard facilities should receive high attention and may require different approaches from more routine communica- tions. A more detailed discussion of each of these areas will be found in the manual on control technologies. ------- SECTION 4 METHODS FOR HAZARD IDENTIFICATION AND EVALUATION Hazard identification is the first step in controlling hazards; the evaluation of hazards follows. Hazard identification is qualitative; hazard evaluation is quantitative. Evaluation seeks to determine the relative impor- tance of two different hazards identified and in some cases the relative probability that a specific hazard will be realized. Various formal and systematic methods for both hazard identification and evaluation are used for facilities manufacturing, using, or storing toxic chemicals. This section of the manual presents general descriptions of the various methods of formal hazard identification and identifies key features of each of these methods including: the purpose, best times to use, nature of the results, staff size required, and the relative cost. Also discussed are the various methods of hazard evaluation and the purpose they serve in the various steps of the hazard evaluation process. These methods or variations of them are applicable for use by both regulators and companies. The regulator needs to be familiar with them in order to evaluate their appropriateness, interpret results presented by companies who use the methods, and recommend methods to companies who don't. In some cases a regulator may actually use a technique directly to verify a company's analysis. The company needs to be familiar with the techniques in order to identify, analyze, and control hazards. 4.1 HAZARD IDENTIFICATION The preceding section summarized where hazards can arise in process operations. The first step in hazard control is hazard identification in a specific process or facility. A publication of the American Institute of 42 ------- Chemical Engineers (AIChE) on guidelines for hazard evaluation lists the following methods of formal hazard identification (12): Checklists, Safety Review, Relative Ranking, Preliminary Hazard Analysis, What-If Analysis, Hazard and Operability Studies, Failure Modes, Effects, and Criticality Analysis, Fault Tree Analysis, Event Tree Analysis, Cause Consequence Analysis, and Human Error Analysis. A summary table of key features of these methods is presented in Table 4-1. The Chemical Manufacturer's Association confirmed the use of these methods in a survey of 39 companies (13). "What-If" analyses and Hazard and Operability (HAZOP) studies were named as the top two methods. In general, hazard identification procedures can be divided into four main classes: Expience, Augmented experience, Analytical methods, and Creative methods. The experience method compares a new process or equipment situation with knowledge gained from previous experience with similar processes. This method is an inherent part of the principles of design standards and codes, so that hazard identification consists of identifying where deviations from ------- TABLE 4-1. SUMMARY OF KEY FEATURES OF HAZARD IDENTIFICATION AND EVALUATION METHODS Relative METHOD Checklist Safety Review Ranking (Mond) PURPOSE Identify common hazards Identify hazards Ensure compliance with prescribed procedures Ensure compliance with prescribed procedures Ensure compliance with design intent. Identifies possible changes Determines applicability of new technology to existing hazards Reviews adequacy of safety maintenance Provide relative process ranking by risk WHEN TO USE Design Construction Startup Operation Shutdown Startup Operation (i.e., existing facility) Shutdown Design Operation NATURE OF Qualitative RESULTS STAFF SIZE Small RELATIVE Low COST Qualitative Relative qualitative ranking Small - Moderate Moderate Low - Moderate Moderate (Continued) 44 ------- TABLE 4-1. (Continued) METHOD Preliminary Hazard Analysis What If Analysis HAZOP PURPOSE Identify hazards early in process life cycle prior to final plant design Identify hazards Identify event sequences Identify possible methods of risk reduction Identify hazards Identify operability problems Identify event sequences Identify possible methods of risk reduction WHEN TO USE Early design Process development Pre-startup Operation Late design Operation NATURE OF RESULTS Qualitative Qualitative Qualitative STAFF SIZE Small RELATIVE Low COST Small - Moderate Moderate - Large Moderate Moderate - High (Continued) ------- TABLE 4-1. (Continued) METHOD Failure Modes, Effects and Criticality Analysis Fault Tree Analysis PURPOSE Identify system/equipment failure modes Identify effect of failure on system/plant Rank criticality of each failure mode Determine causes and event sequence leading to a defined event Identify combinations of causes including both equipment failures and human errors WHEN TO USE Design Construction Operation Design Operation NATURE OF RESULTS STAFF SIZE RELATIVE COST Qualitative Quantitative for relative ranking of equipment failures Small Low - Moderate Qualitative Quantitative Small - Large Low - High (Continued) ------- TABLE 4-1. (Continued) METHOD Event Tree Analysis Cause-Consequence Analysis Human Error Analysis PURPOSE Determine consequences sequence of defined initiating event Identify both cause sequences and consequence sequences of events Identify potential human errors Identify effects of human errors Identify cause of human errors WHEN TO USE Design Operation Design Operation Design Construction Operation NATURE OF Qualitative RESULT Quantitative STAFF SIZE Small - Large RELATIVE Low - High COST Qualitative Quantitative Small - Large Low - High Qualitative Small Low 47 ------- established safe procedures exist, based on experience. Basically the exper- ience method relies on comparing a new situation to a known past situation. The augmented experience method relies on various checks on design and operation beyond mere comparison to standards or previous situations. As indicated by the previous list, the "What-If" method appears to be one of the most commonly used. Each step of a process is reviewed to determine what would happen following equipment failures, process upsets, or operating errors. The analytical approach uses either logic diagrams or various types of checklists. Logic diagrams include fault trees, event trees, and cause-consequences diagrams. Logic diagrams clearly define cause-effect relationships and identify combinations of failure that can lead to an unde- sirable event. These methods can be combined with quantitative data on probabilities to provide a method of hazard evaluation. These summary descriptions are based on more detailed descriptions presented in the AIChE publication cited previously (12). These methods are also highlighted in some AIChE short courses presented at national meetings. A general description of each hazard identification method follows. These same methods apply for hazard evaluation as discussed in Section 4.2 of this manual. 4.1.1 Checklists A checklist is a set standard evaluation elements for equipment, materi- als, or procedures in a chemical process facility. Its purpose is to identify standard hazards at any time in the life cycle of a chemical process from research and development through shut-down. In its most basic configuration, a checklist is merely a memory aid that helps the evaluator remember all the items he should consider. If the checklist is prepared based on pooled corporate or industry experience, it becomes a vehicle for transferring a 48 ------- broader experience base to the evaluator. The level of detail varies with the situation. 4.1.2 Safety Reviews In the context of accidental releases, a Safety Review is a comprehensive facility inspection to identify facility conditions or procedures that could ultimately lead to a toxic chemical release. This technique is applicable to operating facilities, pilot plants, laboratories, storage facilities, or support functions. 4.1.3 Dow and Mond Hazard Indices The Dow and Mond Indices are quantitative methods for developing a relative hazard ranking for different chemical processes facilities. Various characteristics of a facility are assigned scores. Features which can lead to an accident are given a negative score and features that can prevent or mitigate the effects of an accident are given positive scores. Scores are combined to yield a ranking index for the process facility being evaluated. 4.1.4 Preliminary Hazard. Analysis The Preliminary Hazard Analysis (PHA) is a hazard identification method for use in the preliminary phase of plant development. The purposes of the PHA are early identification of potential hazards for design and process development personnel. Its special applicability is for the early phases of new processes where there is little past experience. A list of hazards is developed which is used to develop safety guidelines and criteria to be followed as design and development progress. 49 ------- 4.1.5 "What If" Method A "What If" analysis systematically considers the consequences of unex- pected abnormal events that may occur in a process facility. It can include design, construction, operating, or other deviations from the norm. This examination can include all parts of a process facility. Its comprehensive- ness and success depends on the experience level of the staff conducting the analysis. 4.1.6 Hazard and Operability (HAZOP) Studies A HAZOP study can identify process hazards and Operability problems. A HAZOP study involves the multidisciplinary team that works together by search- ing for deviations from expected design and operating conditions. The team carefully examines the process facility stream by stream, or component by component using standard design "guide words." Consequences of deviations are examined using the guide words. Example guide words are presented in Table 4-2. 4.1.7 Failure Modes, Effects, and Criticality Analysis Failure Modes, Effects, and Criticality Analysis (FMECA) examines the ways in which a process system or its equipment could fail, consequences of failure, and the estimated failure probabilities. FMECA is not efficient for identifying interactions of combinations of equipment failures that lead to accidents because it considers each failure individually and traces its consequences. Criticality rankings can be expressed as probabilities or by various ranking scores based on evaluators' experience. 50 ------- TABLE 4-2. EXAMPLE GUIDE WORDS AND CORRESPONDING DEVIATIONS FOR HAZOP ANALYSIS Guide Word Deviations None No forward flow when there should be, i.e.» no flow or reverse flow More of More of any relevant physical property than there should be, e.g., higher flow (rate or total quantity), higher temperature, higher pressure, higher viscosity, etc. Less of Less of any relevant physical property than there should be, e.g., lower flow (rate or total quantity), lower temperature, lower pressure, etc. Part of Composition of system different from what it should be, e.g., change in ratio of components, component missing, etc. More than More components present in the system than there should be, e.g., extra phase present (vapor, solid), impurities (air, water, acids, corrosion products), etc. Other than What else can happen apart from normal operation, e.g., startup, shutdown, uprating, low running, alternative operation mode, failure of plant services, maintenance, catalyst change, etc. Reverse Variable or activity is reverse of what it should be, e.g., reverse flow. 51 ------- 4.1.8 Fault Tree Analysis Fault Tree Analysis (FTA) is a method that constructs a logic tree of events leading to a specifically defined failure event, the "top event." FTA seeks to develop the chain of interrelated events that can lead to a top event. These chains of events include equipment failures and human errors. The FTA results in identification of combinations of equipment and human failures that are sufficient to result in the top event. The minimum number of independent combinations that can cause the top event are known as minimal cut sets. Probabilities can be assigned to events and the top event probabil- ity determined by Boolean algebra. A.1.9 Event Tree Analysis An Event Tree Analysis is similar to a FTA except that the logic is to trace the consequences of an initiating event forward to its ultimate conse- quence. Rather than beginning with the definition of the top event, the event tree finds the top events resulting from initiating and propagating events. A quantitative evaluation can be developed using probabilities in the same manner as with fault trees. The event tree defines multiple consequences of an initial event, whereas a fault tree identifies multiple causes of a final event. A.1.10 Cause-Consequence Analysis Causeconsequence analysis combines characteristics of both event tree analysis and fault tree analysis. A cause consequence analysis logically relates both multiple consequences and multiple basic causes or initiating events. Like a FTA, the cause-consequence analysis leads to minimal cut sets which are all the combinations of basic events that can result in the various 52 ------- top events. Quantitative analysis can be applied to estimate frequencies or probabilities of various top events. 4.2 METHODS FOR HAZARD EVALUATION Many of the methods for hazard identification discussed in the preceding section also apply to hazard evaluation (also referred to as hazard analysis or "KAZAN"). Hazard evaluation is the next step after hazard identification in the total assessment of risk for accidental releases. The evaluation step attempts to rank the hazards qualitatively, quantitatively, or both, seeks to identify measures that reduce the probability that the hazard will be real- ized, and examines the potential consequences of the hazard if it is realized. As with the method of identification, evaluation methods are also discussed in depth in the technical literature (12, 13, 15). A recent publication of the American Institute of Chemical Engineers presents a comprehensive summary of procedures with considerable discussion of distinguishing features, such as applicability and expected results (12). A summary table is presented, shown in slightly modified form in Figure 4-1. It is clear that the various methods all have some features in common and yet are distinguished by differences that reflect the specific suitability of one method over another in certain situations. Only a few of the methods are specifically suited for quantitative hazard evaluations where probabilities of an accident are to be determined. Another significant difference is that some methods are hardwareoriented while others easily accommodate the effects of human interactions with the process being evaluated. None of the listed methods deal explicitly with consequences outside the process itself, but some methods, such as Fault Tree Analysis, can easily accommodate such an extended analysis. Another approach is to conduct a completely separate consequence analysis, with the accident event being the starting point. 53 ------- Ul - Slaps In Hazard Evaluation Process Identify Deviations From Good Practice Identify Hazards Estimate "Worst Case" Consequences Identify Opportunities to Reduce Consequences Identify Accident Initiating Events Estimate Probabilities of Initiating Events Identify Opportunities to Reduce Probabilities of Initiating Events Identify Accident Event Sequences and Consequences Estimate Probabilities of Event Sequences Estimate Magnitude of Consequences of Event Sequences Identify Opportunities to Reduce Probabilities and/or Consequences of Event Sequences Quantitative Hazard Evaluation Hazard Evaluation Procedures Failure Modes Effects and Crltlcality Analysis Key: Primary Purpose B Secondary Purpose E) Provides Context Only &S Primary Purpose for Previously Recognized Hazards 6-86-24766a Figure 4-2. Relationship between hazard evaluation procedures and hazard evaluation process. Source: Adapted from Reference 12. ------- The consequence analysis can also be qualitative, quantitative or both. Numerous mathematical models have been proposed and some are in common use for predicting the effects of fire, explosion, and accidental releases. Methods for examining the effects of accidental releases are often based on various forms of dispersion models. A summary of procedures available up through the late 1970s is presented in Lees (1). The prediction of affected areas and of concentrations resulting from accidental releases can be combined with health and environmental effects data to estimate the severity of the consequences of any release in the affected area. A recent report reviews major available models (16). A more detailed discussion of these methods is beyond the scope of the present work. The reader is referred to the general technical literature for more details. 55 ------- SECTION 5 OVERVIEW OF THE PRINCIPLES OF CONTROL Both regulators and companies need to be familiar with the fundamental principles of control: the regulator, to intelligently review and evaluate company control plans and practices; companies, to evaluate existing company practices and to implement safer practices. This section of the manual presents an introductory discussion on control technologies as they relate to reducing the probability and consequences of an accidental chemical release. Three fundamental levels of control are addressed: prevention, protection, and mitigation. Specific process design considerations, physical plant design considerations, and procedures and practices are discussed as they relate to prevention. Various protection and mitigation technologies are also discussed. In addition, examples of possible causes of releases and potential controls are illustrated. 5.1 BACKGROUND The control of accidental chemical releases involves reducing the probability and consequences of such releases. Such control can be viewed as consisting of .three fundamental levels: Prevention, Protection, and Mitigation. The purpose of prevention is to reduce the probability of accidental releases. Prevention refers to all those measures taken to ensure that the primary containment of the chemical, that is storage, transfer, and process equipment, is not breached. These measures include process design, physical 56 ------- plant design, and operational procedures and practices, and involve considera- tions ranging from process control and hardware design to operator training and management policy. The ideal result of a successful prevention effort is that accidental releases of a chemical from its primary containment do not occur. In reality, prevention can be successful in reducing the probability of a release to a reasonable minimum. "Reasonable minimum" is an imprecise criterion; however, the inherent characteristics of any process are that equipment can fail, and people make mistakes, so that from time to time an accidental release event will happen. The probability can be reduced if appropriate prevention measures are taken. These prevention measures enhance the control of a process or the ability of the hardware to tolerate severe process conditions, process upsets, and human error. When preventive measures fail, a second level of control deals with protection from releases. In the context of this manual, protection means to contain, capture, neutralize, or destroy a toxic chemical subsequent to release from primary containment, but before it escapes into the environment. Protective systems are defined as add-on equipment and processes systems not considered part of the actual chemical process system itself, but which control a potential release. Examples of protection technologies include diking, flares, and scrubbers. Protection systems will also fail from time to time. A deficiency in a protection system when it is needed may allow a toxic vapor or gas to escape into the environment. Once this occurs, the conse- quences may be reduced by using effective mitigation measures. Mitigation refers to equipment and procedures that can reduce the concentration of a chemical below levels that would otherwise occur and hopefully below levels harmful to sensitive receptors. Measures include technical approaches such as water sprays, or steam curtains for dilution and dispersion, barriers for diversion and dispersion, and procedures such as closing doors and windows, 57 ------- and evacuation in affected areas. It should be noted that mitigation is not a back-up approach to protection as protection is to prevention. The latter two areas are directed toward stopping a release. Mitigation merely attempts to control a release that has already occurred. A detailed discussion of prevention and protection is the subject of the manual on control technologies. Mitigation will be the subject of a separate manual. A summary of major considerations in these three areas is presented in the ensuing subsections. 5.2 PREVENTION Prevention measures can be classified into the general topical areas of: Process design considerations, Physical plant design considerations, and Procedures and practices. These measures include consideration of both operational and hardware aspects of a chemical process system. Operational aspects include both the inherent characteristics of the process itself and human aspects such as operator training, maintenance procedures, and general management policy and proce- dures. Prevention measures are applicable to new facilities as well as existing facilities, where they are the basis for process modification. 5.2.1 Process Design Considerations Process considerations involve the areas listed in Section 3, which can be regrouped as follows: Chemical process characteristics; 58 ------- Control system characteristics; Hazard control for flow, pressure, temperature, quantity measurement, composition, mixing, and energy systems; and Hazard control for fire and explosion. The design of a process in which toxic chemicals are used or produced should be based on sufficient data to ensure a safe operating system. Neces- sary data to be considered in the design process include, but are not limited to, the following: chemical, physical, thermodynamic, and toxicological properties of the individual chemical components used or produced in the process; the process potential for explosive reaction or detonation under normal or abnormal conditions; process reactivity with water or other common contaminants; .possibility of self-polymerization or heating; potential side reactions and conditions under which they are favored; whether reactions are endothermic, exothermic, or thermodynamically balanced; the explosive range of volatile or gaseous components and the possibility of explosive mixtures during storage, processing, or handling; the possibility of dust or mist explosions; and interactions with materials of construction. Flow, temperature, pressure, quantity measurement, and composition control are fundamental process variables. Mixing is a fundamental process phenomenon. These process elements have associated with them the basic potential operational hazards of any process. Prevention measures associated with these elements include the appropriate process control measures discussed above applied to the specific process effects and hazards of these elements. The fundamental hazards of all these variables arise from deviations that exceed the limits of the operational or physical system. For example, excess flow may be a hazard if it causes a change in a process system faster than the operator or control system can respond. The excess flow of a reactant in an exothermic reaction might cause a thermal runaway sooner than emergency cooling or other safety measures could be activated. Or, flow blockage could 59 ------- prevent cooling water flow in a critical circuit. For each of the above variables, there are specific measures that can reduce the chances for devia- tions or minimize their effects. The control characteristics of the process should be understood and the control system should be appropriate for the system. This means that the process dynamics should be properly considered and the control system must be compatible with the available operating and maintenance staff knowledge and skills. Specific technological prevention measures in all control systems include using control components of greater reliability and accuracy and faster response times. A fundamental principle in control system components is redundancy, or the use of independent backup to critical components. The key word here is independentto avoid a common mode failure in critical systems. For a specific process, reducing the probability or magnitude of process deviations or upsets that could lead to an accidental release may involve design changes in a control system ranging from individual components through the entire control strategy and hardware. Fire and explosion protection is basic to release prevention. Preventing the conditions that lead to fire and explosion is inherent in the items already discussed above and also involves physical plant design considerations discussed in the next section. Once a fire has started in or near a process involving toxic chemicals, controlling the fire becomes of paramount concern. Design considerations for fire protection are based on the removal of fuel, oxygen, or heat from the fire. Adequacy and reliability of water supply, possible chemical fire fighting measures, and suitable fire fighting equipment are the primary process design considerations for fire protection beyond initial fire prevention through careful process design. Explosion protection relies on preventing dangerous process conditions such as the formation of explosive mixtures from occurring, preventing contact of potentially explosive mixtures with ignition sources, and applying special- ized explosion suppression systems. Explosion protection also relies on 60 ------- appropriate physical plant design considerations, as discussed in the next subsection. 5.2.2 Physical Plant Design Considerations Physical plant design considerations address hazards and their control in the following areas: Siting and layout, Structures and foundations, Vessels, Piping and valves, Process machinery, and Instrumentation. Hazards were discussed in Section 3. Control considerations are discussed here. At a minimum, codes and standards should be followed in the design of each of these areas. However, additional protection measures above and beyond those specified by the codes and standards should be incorporated into the design based on the specific situation. Problems arise because codes and standards are not developed with specific situations in mind. Thus, code cannot be relied upon unless the basis matches the scenario of concern with great precision. Siting is the first area considered. A plant's location might affect frequency or severity of an accidental release. Siting considerations in- clude, but are not limited to, the following: drainage systems should prevent the runoff of spilled liquid chemicals onto adjacent properties and prevent the spread of toxic and/or flammable liquid chemicals in a manner that mini- mizes adverse effects within and outside of the plant boundaries; minimization of the effects of natural calamities such as freezing, fire, wind, floods, 61 ------- earthquakes, and landslides in contributing to an accidental release should be incorporated into equipment design, for example, different foundation designs in earthquake prone areas; the potential impact of accidents such as fires, explosions, or hazardous chemical releases at adjacent industrial facilities, roads, or railways should be recognized as a possibility; reliable water and power supplies should be available with backups where a failure could cause an accidental chemical release; and traffic flow patterns within the plant and around the perimeter should be designed to prevent congestion and allow access by emergency response vehicles and appropriate movement of personnel in an emergency. The layout of a plant is the next area considered. Layout considerations include, but are not limited to, the following: process units and the equip- ment and piping within a unit should be arranged to minimize congestion; where possible, hazardous processes should be segregated from other hazardous processes or sensitive areas within the plant or plant property; adequate spacing should be available for access by maintenance and emergency response personnel and equipment; explosion barriers should be applied where appropri- ate as described, for example, in the Dow guide (17); escape routes for per- sonnel should be easily accessible; and offices, lunchrooms, or other support structures should be located at the perimeter of the facility. Foundations should ensure the stability of all vessels and non- transportable equipment containing hazardous chemicals. The design should be in accordance with recognized construction and material specification stand- ards in the industry as a minimum requirement. The design should consider all normal and abnormal load and vibration conditions, as well as severe condi- tions caused by freezing, fire, wind, earthquakes, flood, or landslides. Transportable equipment should be secured to prevent the upset or accidental detachment of process lines conveying hazardous chemicals during use and should not be used to permanently replace a stationary piece of equipment unless a given situation dictates a preference or requirement for such trans- portable equipment from a safety standpoint. 62 ------- Structural steel should, at a minimum, be designed and constructed in accordance with appropriate construction and material specification standards in the industry. The design should consider all normal and abnormal dead loads and dynamic loads resulting from wind, collision, earthquake, or other external forces. As a minimum, fireproofing should be used for areas in which hazardous chemicals are manufactured, stored, handled, or generated and such areas should conform with legally applicable codes and standards. Fire protection beyond minimum standards should be considered for hazardous areas in which hazardous chemicals are present. Vessel design and construction should conform to recognized design and material standards for the specific application in the industry as a minimum. Standards and specifications should be reviewed for adequacy of criteria. Stricter standards may sometimes be appropriate. Design should consider the combination of conditions anticipated for quantity, fill rate, pressure, tem- perature, reactivity, toxicity, and corrosivity. As a minimum, all vessels should be equipped with the following safety features: overfill and overpressure protection and, where appropriate, vacuum protection; storage cooling systems for low boiling point liquids and liquefied gases; storage vessels should be surrounded by diking, firewalls, or other containment devices unless such features are deemed to create a more severe secondary hazard in specific cases; vessels and vessel fittings should be protected from damage caused by collision or vibration and should be adequately braced to support the weight of piping; columns should be adequately supported to withstand the maximum wind loads expected in the area; and operators should be trained concerning the vessel's limits for pressure, temperature, fill and emptying rates, and incompatible materials. Additional items such as nitrogen blanketing, improved fire protection, or release reduction equipment (e.g., water or steam curtains) may be appro- priate in certain situations. 63 ------- All pressure vessels and vessel jackets should be fitted with adequate pressure and/or vacuum relief. The relief systems should be designed accord- ing to recognized design procedures and standards appropriate in the industry as a minimum. Stricter procedures and standards may sometimes be appropriate. Containment systems should be designed according to recognized design pro- cedures for containment systems. Valves upstream of pressure or vacuum relief devices should be prevented from being closed in such a way that the vessel will be isolated from all pressure relief or vacuum relief. Where possible, a pressure trip system should be used along with a pressure relief system. This will help minimize the frequency of releases of hazardous chemicals through the pressure relief system. All pressure or vacuum relief devices should be inspected and maintained periodically as part of routine maintenance. Testing a values capacity should be done whenever any corrosion, fouling, or scaling has occurred. The adequacy of a pressure or vacuum relief system should be reevaluated when a vessel or process unit is used to handle more material, or a different material, than that for which it was originally designed. As a minimum, heat exchangers should be constructed in accordance with accepted industry codes and standards. Standards should be reviewed for adequacy of criteria. Stricter standards may sometimes be appropriate. The materials of construction should be selected to minimize corrosion and foul- ing. All exchangers should be equipped with pressure relief, by-pass piping, and adequate drainage facilities. Exchanger design should allow for thermal expansion and construction without causing excessive stress on connections. Turbines, drivers, and auxiliary machinery should be designed, con- structed, and operated in accordance with applicable industry standards and codes. Standards should be reviewed for adequacy of criteria. Stricter controls may sometimes be appropriate. The equipment should have adequate protective devices to shut down the operation and/or inform the operator before danger occurs. Vibration sensors and/or shutdown interlocks may be required on high speed rotating equipment. 64 ------- Heaters and furnaces should be located so as to minimize the possibility of bringing an open flame and/or extreme heat too close to a hazardous area. Basic units and controls should be designed in accordance with applicable standards and codes as a minimum. Standard should be reviewed for adequacy of criteria. Stricter standards may sometimes be appropriate. Examples of some of the basic requirements for furnaces include the following: provision for adequate draft; positive fuel ignition; automatic water level controls; pressure relief devices; and fuel controls. Air heaters should have igniters designed to provide positive ignition, proper safety controls on fuel sources, sight glasses for flame observation, monitoring devices for flame-out detec- tion, and high temperature alarms. All heaters and furnaces should be in- spected regularly. Where heaters and furnaces handle hazardous process materials, appropriate precautions should be taken to prevent releases in the event of tube failures, such as cracking, rupture, or plugging. As a minimum, piping, valves, and fittings should be designed according to recognized industry codes and standards pertaining to working pressures, structural stresses, and corrosive materials to which they may be subjected. The thermal stress of repeated heating and cooling cycles or excessive tem- peratures, either high or low, should be considered. Some additional con- siderations include, but are not limited to, the following: dead ends or unnecessary and rarely used piping branches should be avoided; the type of pipe appropriate for pumping a hazardous chemical should be selected (e.g., using welded or flanged pipe instead of threaded pipe or using a suitable metal or lined metal piping instead of plastic wall piping); backflow protec- tion should be installed where necessary, but backflow prevention should not be relied on as the only means of avoiding a backflow hazard; materials of construction suitable for the application should be selected and checked before installation to confirm the composition; recordkeeping on critical lines should be provided to prevent incorrect future substitutions; a means of remotely shutting off the flow in lines that carry a large volume of hazardous materials should be provided; adequate structural support should be provided to protect against vibration and other loads and to protect piping from 65 ------- potential collisions with vehicles in the vicinity; piping should be pitched to avoid unintentional trapping of liquids; and provisions should be made to ensure that a liquid-full condition cannot exist in a blocked section of line unless such a section of line has pressure relief. Extra precautions should be taken in the design of pumps and compressors to minimize the potential for an accidental release of a hazardous chemical. Extra precautions include, but are not limited to, the following: where a pressurized hazardous material is being pumped or where the consequence of a seal failure could result in the accidental release of designated chemical. seals should be suitable to ensure reliable leak prevention (e.g., double me- chanical seal with a pressurized barrier fluid that is compatible with the process fluid and equipment materials of construction); totally enclosed pump or compressor systems may be appropriate, if safely vented and inerted and monitored for oxygen where enclosure could result in a secondary hazard such as an explosive mixture; remotely operated emergency isolation valves and power shutoff switches may be appropriate on the suction and discharge sides of a pump or compressor; compressors or positive displacement pumps should be fitted with adequate overpressure protection; instrumentation to determine when flow into or out of a pump has ceased may be appropriate; where overheat- ing could result in a fire or explosion, temperature monitoring may be appro- priate; a backup power supply should be used for critical pumping systems; surge protection should be provided for pumps; and pumps, compressors, and their associated piping should have foundations and supports that protect against damage caused by vibration and any static and dynamic loads. Every reasonable effort should be made to maximize the effectiveness of automatic process control systems for preventing an accidental release. All systems and instrumentation should be of the "fail-safe" type. Instruments should be made of materials capable of withstanding the corrosive or erosive conditions to which they are subjected. Central control rooms should be protected from fire and explosion hazards. An owner-operator should evaluate the ability of control systems to operate on manual control and should install 66 ------- a backup power supply in situations where operating on manual control would be impractical. A variety of miscellaneous modifications may be appropriate, depending on the needs of the particular process unit. Examples of these modifications include, but are not limited to the following: the addition of control systems where none are presently employed; redundancy of key components; replacing components to improve accuracy, reliability, repeatability, or response time; the addition of a backup control system; simplification of an existing control system to improve operability; replacing a system that indirectly controls the variable of interest with a system that directly measures and controls the variable of interest; the addition of trip systems for emergency situations; and the redesign of a control system to conform to acceptable design standards. All wiring and electrical equipment should be installed in accordance with the National Electric Code or stricter standards, if applicable. Elec- trical equipment for use in hazardous locations should comply with accept- ability standards of recognized testing organizations. Standards should be reviewed for adequacy of criteria. Stricter standards may sometimes be appropriate. All electrical apparatus should be grounded. Protection devices should have the capability of warning operating personnel when emissions are not being controlled. Plant alarms such as klaxons and sirens can be used to alert or signal such personnel. If a device is only used on an intermittent basis, then a testing program should be in place to ensure that the system will function when necessary. In addition, alarms should be tested, audited, and inspected to ensure reliability. As a minimum, plant fire protection systems should be laid out in accord- ance with recognized codes and standards, such as those prepared by the National Fire Protection Association. A reliable water supply for all por- tions of the plant should be available. Flammable gas detection systems are 67 ------- recommended for locations where flammable chemicals are used at elevated temperatures and pressures. Central fire alarm systems should be in place. In addition to water, firefighting materials, such as spray foams, dry chemi- cals, and carbon dioxide, may be appropriate to handle various specialized types of fires. 5.2.3 Procedures and Practices Operational Controls The following types of reactive materials should be stored so that the potential for mixing in the event of an accidental release is minimized by dikes or other physical barriers: materials that react to form a hazardous chemical; hazardous chemicals that react exothermically and thereby contribute to the rate of evaporation of the chemicals; and hazardous chemicals where reactions will contribute to the potential for an accidental release. Chemi- cals may be mutually reactive or reactive with other materials that may be nearby such as cooling or heating fluids, cleaning agents, and materials of construction. Extra precautions may be required where there is a potential for mixing two incompatible chemicals within a process. Such precautions could include backflow protection, composition monitoring, and interlocks that prevent valves from being opened in combinations that allow for cross-contamination. Use of common lines for handling such incompatible chemicals should be avoid- ed. All materials of construction should be capable of withstanding normal operating conditions, normal shutdown conditions and potential deviations from normal operation. Where a specialized material is required, initial con- struction materials and replacement parts should be tested before use to ensure that the composition is consistent with specifications. 68 ------- Safe procedures should be established to minimize the risk of an acci- dental release of a hazardous material during filling or emptying operations for tanks, vessels, tank trucks, or tank cars. Some considerations include, but are not limited to, the following: before material is added to a vessel, tank, tank truck, or tank car, the operator in charge of the addition should be able to verify what material is in the vessel or was last in the vessel; where hoses are used, a system should be in place to ensure that the proper type of hose is used for each application (e.g., different types of fittings for each application); hoses should be regularly inspected and maintained as necessary; efforts should be made to decrease the possibility of materials being sent to the wrong location; a system should be in place to prevent tank trucks or rail cars from moving away with a hose still connected; when a hose is used to transfer materials, it should be possible to stop the flow if the hose should fail; equipment should be grounded and operators trained in the appropriate methods for chemical transfer so as to avoid static charge accumu- lation. Procedures and equipment should be in place so that every reasonable effort may be made to prevent an accidental release from the storage, han- dling, or treatment of wastes containing the hazardous chemicals. Management Controls Programs to train plant personnel to handle normal operating conditions, upset conditions, emergency conditions, and accidental releases should be used. The programs should include written instruction, classroom-type in- struction, and field drills. Periodic review and drill exercises should be part of such programs. Printed materials describing standard and emergency procedures should be provided to employees and revised as necessary to be consistent with accepted practices and recent plant modifications. A plant-wide fire prevention and protection plan should be used. All operating personnel should be instructed concerning fire prevention and fire response. All facility personnel should be instructed in basic first aid and 69 ------- fire extinguisher use. The formation and training of specialized fire fight- ing teams and first aid teams should be in accordance with or exceed minimum specified requirements. All fire protection and prevention plans should be periodically reviewed and training drills held. The owner/operator of a facility should formulate a comprehensive contin- gency plan to handle major plant disasters. All facility personnel should be trained to participate in plans for controlling facility emergencies related to accidental releases including emergencies such as large windstorms, earth- quakes, floods, power failure, fires, explosions, and accidental releases of hazardous chemicals. The contingency plan should describe coordination between the plant and local police, fire, and other emergency personnel. The plan should be specif- ic in designating responsibilities and in addressing specific high-hazard situations that are possible for the plant. Communications responsibilities and procedures for relaying information during emergencies should also be clearly defined. The plan should include procedures for emergency notifica- tion of community and local governments. Where an accidental release could adversely affect the local community, the plan should include appropriate community emergency response procedures. Simulated emergency exercises involving plant personnel should be per- formed on a regular basis. Disaster exercises that incorporate local emergen- cy response organizations should also be undertaken periodically. Exercises may include tabletop exercises, emergency operations simulations, drills, and full field exercises. An inspection, testing, and monitoring program for process equipment and instrumentation should be considered for areas of high hazard potential. Systems and components to which this program can be applied include, but are not limited to, the following: pressure vessels; relief devices and systems; critical process instruments; process safety interlocks (trips); isolation, 70 ------- dump, and drowning valves; process piping systems; electrical grounding and bonding systems; fire protection systems; and emergency alarm and communica- tions systems. Engineering drawings and design specifications should be available for inspection, if requested. Maintenance staff qualifications, skill level, and numbers should be consistent with the hazard potential at the specific operation. A process safety review consistent with the magnitude of the modification should be made before implementing any modification. Documentation of modifi- cations should be made and be available for inspection, if required. 5.3 PROTECTION Protection measures are equipment and systems that prevent or reduce the quantity of chemical that is discharged in an incipient release that has already escaped primary containment. Protection technologies include flares, scrubbers, diking, and enclosures (i.e. containment buildings). Each of these technologies may be appropriate in specific circumstances, but none of them is universally applicable to accidental releases. Much depends on the specific toxic chemical involved, the quantity released, the rate of release, and how it is released. Flares are commonly used in chemical process plants and in petroleum refineries to dispose of flammable gases and vapors resulting from normal operating upsets. They may be suitable in certain circumstances for the destruction of toxic chemicals that would otherwise be released to the envi- ronment. A prerequisite for destruction in a flare system is that the toxic material be flammable, or that it at least thermally decompose to less toxic compounds at flare flame temperatures. The other requirement is that the nature of the emergency discharge be compatible with the overall design and operating requirements of flares, such as the maintenance of specific gas velocities at the flare tip, and flow fluctuations within the design turn-down 71 ------- capabilities of the particular flare system. There may also be some real difficulty in the safe design of a flare system for the emergency discharge of toxic materials combined with normal process discharges of other process materials. Considerations in this area include the manifold system and how backflows and inappropriate mixing of incompatible materials might be avoided. A dedicated flare system is not necessarily a solution to the problem since keeping a flare on standby for a relatively rare emergency may not be feasi- ble. Flares are an option that can be considered for the right circumstances for treating emergency discharges that are still confined by a pipeline or stack. The use of flares in such an application, however, must be carefully evaluated for possible secondary hazards that could make the use of flares more dangerous than not using them. For example, improper design could lead to flash back. Scrubbers are another alternative for treating confined toxic discharges before they are released to the environment. Scrubbers have a long history of success in the process industries. Many of the considerations that apply to combined versus dedicated flare systems apply also to scrubbers. Scrubbers may be easier to maintain on a standby basis than flares, however. The applicability of scrubbers depends on the solubility of a toxic chemical in a suitable scrubbing medium or the ability of the scrubbing medium to reactively neutralize the toxic chemical. Chemicals soluble in water or in various aqueous solutions are not a particular problem. Other toxic materials that require nonaqueous scrubbing liquids could present more difficulties. For example, it would be hazardous to use a flammable organic liquid as a scrubbing medium since one could easily create a flammable mixture. Most scrubbing systems that would be considered feasible for toxics would probably be based on aqueous scrubbing chemistry. The type of scrubber that is suitable for use depends on the nature of both the discharge circumstances and the scrubbing chemistry. Since a low system pressure drop appears desirable for emergency scrubbing systems, simple 72 ------- spray towers may be appropriate in many applications. However, other types of scrubbers, such as packed beds and Venturis, may also be appropriate in some situations. Both scrubbers and flares can be used when the incipient release is still confined by piping or a stack, as might be the case with an emergency dis- charge from a relief valve. When the release results from equipment failure, such as a vessel or pipeline rupture, containment is required before the chemical can be disposed of by flaring, scrubbing, or in-place neutralization. Such temporary containment can be effected by diking and enclosures. Diking is a physical barrier around the perimeter of process equipment or areas designed to confine the spread of liquid spills and to minimize the liquid surface area. It can be simple earthen berms or it might be concrete walls. The diking might be little more than a high curb, or it could be a high wall rising to the top of a storage tank. The applicability of diking to spills of volatile liquids is readily apparent. By containing the liquid, the dike reduces the surface area available for evaporation, at the same time allowing a liquid to be cooled by evaporation so that the vapor release rate is dimin- ished. In this way, diking can reduce the rate at which a toxic material is released to the air. The material can be allowed to evaporate at a manageable rate, collected into alternate containers, or neutralized in place. Enclosures or containment buildings directly provide secondary contain- ment for materials that have escaped primary containment. Suck buildings can be designed to contain the toxic chemical until it is vented through an appropriate destruction system such as a flare or scrubber, collected into an alternative container, or neutralized in place. The primary difference between diking and a complete enclosure or containment building is the roof. The building confines virtually all of the material, whereas diking permits the continuous release of some of the material. The applicability of either diking or enclosures must be carefully evaluated to determine if there might be secondary hazards associated with 73 ------- their use. For example, if the toxic material is also flammable, containment could create a fire or explosion hazard which could be as or more serious in its consequences than the original release itself. When properly applied, however, diking and enclosure can be effective protection technologies for accidental releases. 5.4 MITIGATION Once a toxic chemical has been released to the air or that has the potential for entering the air, the primary concern becomes reducing the consequences to the plant and the surrounding community. Reducing these consequences is referred to as mitigation. Two aspects of mitigation are measures to control the quantity of toxic material that could reach receptors, and protect the receptors by ensuring that they remain in or are evacuated to locations that will prevent or minimize their exposure to the chemical. An emergency response plan addressing the issues is a key part of mitigation. The other part is the technology of controls. Mitigation technologies include such measures as physical barriers, water sprays, steam curtains, and foams. Mitigation technologies divert, limit, or disperse the toxic chemical that has been released to the atmosphere. An emergency response plan must be based on identifying the consequences of the accidental release based on downwind quantities, concentrations, and duration of exposure at various receptor sites. The plan should include the information required to decide whether evacuation should be undertaken, or whether people in the path of the release might be better protected by remain- ing indoors in their own homes or other places. The plan should include specific first aid steps to be taken for the exposed population. Finally, the plan should lay out the specific responsibilities and activities of all facility personnel and community response teams in addressing the emergency. Physical barriers may be specially constructed for the purpose, may be constructed for another purpose but function as barriers, or they may be 74 ------- natural terrain features. An example of a specially constructed structure is a diversion wall. A functional barrier could be a building. A natural terrain feature that might be a barrier is a hill or a line of trees. The primary function of a physical barrier is to protect especially sensitive receptors and provide additional time in which to respond to the accidental release emergency. A physical barrier located in the right place can also contribute to enhancing the dispersion of the released chemical. Physical barriers do not, however, directly capture or neutralize the chemical. They might improve the performance of other mitigation measures such as water sprays, however. Applicability and overall performance will depend on the nature of a specific release and on the meteorological conditions at the time of the release. Water sprays and steam curtains are methods used to increase the disper- sion rate of the released chemical, divert its direction, serve as a barrier between the toxic cloud or plume and potential receptors, and even absorb the chemical. The applicability and effectiveness of these methods depend on the nature of the release, the properties of the specific chemical, and the capability of extending to the highest effective point of a release. Effec- tiveness will also depend on meteorological conditions at the time these mitigation methods are applied. A final mitigation technology is the use of foams. Foams are chemical mixtures that can be applied to liquid spills with special foam generating apparatus and, by covering the surface of the spill, reduce the rate of evapo- ration. Foams can be applied to spills that would otherwise result in the release of large quantities of toxic vapors as long as the foam is physically and chemically compatible with the spilled material. A fundamental requirement is that the foam have a density lighter than the liquid over which it is applied, and that the material over which the foam is applied does not easily diffuse through the foam. Foams may sometimes permit a spill to be transferred to containers for final disposition. 75 ------- Mitigation technologies and community preparedness are the final line of defense in reducing the risks of accidental releases of toxic chemicals. 5.5 CONTROL TECHNOLOGY SUMMARY The various technologies discussed in this section of the manual are discussed in greater detail in the manual on control technologies. It is apparent that controls applicable for the prevention of, protection from, and mitigation of accidental chemical releases, cover a wide range of both equip- ment and procedural measures. These measures may range from changes in the process employing a toxic chemical to the addition of specialized equipment outside of the immediate needs of the process itself. Table 5-1 summarizes some locations and possible causes of accidental chemical releases, and presents corresponding control measures that might be applied. Selection of appropriate control measures depends on the results of a hazard evaluation that would define the most likely causes for a given process system. For most processes combinations of alternatives could reduce the probability of release and also reduce the consequences of any release that might occur. Additional discussion of this issue is also provided in the manual on control technologies. 76 ------- TABLE 5-1. EXAMPLES OF POSSIBLE RELEASES AND CONTROLS Location of Accidental Release Cause Potential Controls External Causes General equipment failure General process failure Pipebridge Fire at adjacent plant Explosion at adjacent plant Traffic or rail accident from outside the plant Natural disaster, (flood.land- slide, earthquake, windstorm) Fire in adjacent process unit Explosion in adjacent process unit Loss of process control as result of utility failure Trench fire Control room destroyed by fire/explosion Collision with plant vehicle Extra fire protection Protective barriers Coordination of emergency response efforts Protective barriers Coordination of emergency response efforts Protective barriers Reroute traffic flow Protective barriers Strengthened equipment foundations and structural support Alter surface contours to facilitate drainage around the plant Emergency response plans for each potential event Adequate spacing between process units Protective barriers Utility piping arranged in a way that prevents loss in adjacent units when one unit fails Adequate spacing between process units Protective barriers Strengthened equipment foundations and structural support Provide local or plant wide backup for crucial utilities Where possible, improve process operability so that the process can be manually operated or shut down when utilities are lost Arrange utility distribution so that utility losses will only effect a small area within the plant Install covers that are two thirds closed and one third grate Place flame traps periodically throughout the trenches Protective barriers around control room Relocation of control room Where possible, improve process operability so that the process can be manually operated Pressurize control room with clean air supply Construct control room with extra fire protection Protective barriers Warning signs of restricted clearance Rerouting in-plant traffic flow Remote shutoff valves on both sides of bridge (Continued) ------- TABLE 5-1 (Continued) Location of Accidental Release Cause Potential Controls Vessel Overpressure as a result of vessel BLEVE when exposed to fire Operating/Haintenance/Hanagement Error General equipment failure 00 General process failure Vessel Piping Thermal shock Replacing a worn part with a part made of a material that is incompatible with the process Loss of process control as when a valve is incorrectly operated Tank overfill as a result of operator error Internal explosion as a result of static discharge in the presence of a flammable mixture Collapse due to underpressure when the tank is emptied or cooled too quickly Overpressure as a result of incorrectly adjusted relief valve Overpressure caused by reaction between process material and old material held up in a seldom used piping run Adequate deluge system Water spray monitors available to cool the vessel Adequate pressure relief for handling heating from fire Flow and temperature control Improve operator training Periodically inspect and test equipment for signs of fatigue Establish testing procedures to certify materials of construction Where materials of construction are critical, have written details as to what materials of construction are appropriate or inappropriate for a given application Clearly label lines Physically segregate piping according to use Relieve congestion Eliminate unused and excess piping Improve employee training Level gauges and alarms Overflow catch tank Surround tanks with dikes Improve operator training Operator training as to the hazards of static discharge Establish specific procedures for transfer operations Operator training as to the physical limitations of the vessel and how this effects operating procedures Establish specific procedures for filling, emptying, heating and cooling Test all relief valves after any adjustments have been made Allow only certified personnel to work on relief devices Train operators as to potential incompatibilities between process materials Blind off unused sections of pipe (Continued) ------- TABLE 5-1 (Continued) Location of Accidental Release Cause Potential Controls vo Flange Pipe fitting Threaded joint Valve Improper installation Poor weld Improper installation Overpressure caused by water hammer Loading/Unloading operations Mixing incompatible materials Truck leaves without disconnecting hose Instrument Malfunction General equipment failure Loss of reaction control as a result of inadequate control system performance Loss of reaction control as a result of failure of an adequately designed control system Replace with a welded joint Maintenance training Establish a check procedure to certify work before operating Alternate variety of gasket Radiographic weld test Personnel training Replace with a flanged or welded joint Weld seal threaded joints Leak or pressure test all critical joints Personnel training Operator training Establish procedures for verifying heel composition Dedicate tanks for only one use Block wheels during operation Install remotely operated emergency shutoff upstream of flexible line Install additional control systems where none are employed Redundancy of key components Upgrade components to improve accuracy, reliability, repeatibility or response time Backup the entire control system Simplify to improve operability Alter the variables that are monitored to more closely monitor the hazard Add trip systems Redesign the system to conform to present standards Install alarms For critical areas, install alarms that are audibly distinct Provide emegency backup systems such as emergency cooling Periodically inspect and test control systems Design so that the failure of one component will not result in a total control system failure Use only fail-safe equipment For critical areas, regularly replace portions of the system to prevent an on-line failure Use of non-interruptible power supply (Continued) ------- TABLE 5-1 (Continued) Location of Accidental Release Cause Potential Controls Equipment Failure General equipment failure Leak and ignition from hot oil system Substitute with a nonflammable or less flammable material Locate furnace away from process Vibration Loss of process control as a result of internal valve mechanism failure Additional supports Shortened piping (lower the vibration frequency) Pulsation dampeners Pipe loop to allow for expansion Determine if mechanical problem and repair it A more reliable type of valve Periodically test valves OO O Vessel Vessel shell Heat exchanger tube Loss of process control as a result of check valve failure Overpressure as a result of relief device failure Corrosion Overpressure of trapped fluid Drain line from storage tank Valve failure Pipe break Bolted or rivoted seams Thermal expansion Stress corrosion Multiple check valves More sophisticated backflow protection Regularly inspect check valve internals Size pressure relief devices using accepted practices Consider two-phase flow when sizing Install backup relief device Install a trip system as a first line of defense Design the vessel to fail in a manner that minimizes the release Enclose the vessel in a protective enclosure Fabricate the tank with an additional corrosion allowance Upgrade the materials of construction Use double walled construction Seal all insulation around fittings Shell and tube side pressure relief Periodic inspection of tube integrity Add remotely operated emergency isolation valve Add a second drain valve in the line Limit the diameter of the drain line to 3M inch to restrict flow Install a pipe loop to allow for expansion Use supports that allow for lateral movement Use welded seams (Continued) ------- TABLE 5-1 (Continued) Location of Accidental Release Cause Potential Controls Welded seam 00 Threaded joint Valve stem Valve Pump or compressor Design Error General equipment failure Vessel Poor fabrication Corrosion Thermal shock Failure due to temperature or pressure cycles Corrosion Wear Overpressure Overpressure caused by water hammer Seal failure Overpressure as a result of a valved off relief device Overpressure as a result of overfill Loss of reaction control as result of a loss of mixing Overpressure as a result of undersized relief device Radiographic weld testing Leak and/or pressure test equipment Use ASME code vessels Use ASME code vessels Use alternate type of weld Apply protective measures specific to the chemicals and type of corrosion involved Use ASME code vessels Set controls to restrict the rate and frequency of heating and cooling cycles Regularly replace crucial equipment before failure Replace with a flanged or welded joint Weld seal necessary threaded joints Tighten packing Choose a more reliable type of valve Limit the closing rate of the valve Upgrade type of seal Install double mechanical seal with sealing fluid Enclose the pump or compressor in a ventillated enclosure Substitute with a sealless variety of pump Interlock two parallel relief devices so that only one may be closed at a time Restrict fillrate by limiting the size of fill lines Use identical capacity for fill lines and drain lines Monitor agitation directly by monitoring the mechanical drive assembly on the mixer or indirectly by monitoring temperature or flow Size using accepted methods Resize every time a system is used for a new service Consider the potential for two phase flow (Continued) ------- TABLE 5-1 (Continued) Location of Accidental Release Cause Potential Controls Vessel (continued) 00 NJ Heat exchanger tube Vent or vented enclosure system or vented enclosures Piping Pump or compressor Loading/Unloading operation Internal tank explosion caused by a static discharge in the presence of a flammable mixture Tank collapse as a result of emptying or cooling too quickly Stress failure of a nozzle caused by inadequate pipe support Deflector plates at liquid entry Nitrogen blanketing Restricted feedrate Properly ground all equipment Use of explosion pressure relief Install breather vent or nitrogen blanketing Restrict the maximum possible empty or cooling rate Added support for piping Additional reenforcement around the nozzle Wherever possible, place vessel fittings above the normal liquid level Overpressure of trapped fluid Provide shell and tube side pressure relief Internal explosion caused by ignition of a flammable mixture Incorrect materials of construction Overpressure as a result of a reaction between process material and old material held up in a seldom used piping run Blocked discharge, resulting in an overpressure Truck overfill Purge vents with inert gas Dilute with inert gas until the concentration is below the flammable limit Monitor for flammable mixtures Proper material specifications based on lab and pilot testing Inspect all parts to validate the material of construction and their integrity before installation during construction or maintenance Simplify piping, eliminate dead ends or seldom used sections of pipe Install overpressure protection where mixing of incompatible materials is likely to occur Provide upgraded overpressure protection Monitor flow Monitor temperature of the fluid in the pump case Install remotely operated shutoff valves Install level monitoring controls ------- SECTION 6 GUIDE TO FACILITY INSPECTIONS The preceding sections of this manual have broadly discussed the identi- fication, evaluation, and control of hazards. In addition to procedures already discussed, there remains the actual inspection of physical facilities. This section of the manual presents a brief example guide to facility inspections. General procedures including one possible approach to setting up and conducting an inspection is discussed. Specific procedures involving detailed inspection are also covered. Regulators may find this material useful as a guide to establishing their own procedures for facility inspec- tions. Companies may find the information useful for the same purpose or for comparison with existing procedures. In either case, while the broad aspects of the procedures are applicable to most facilities that handle toxic chemicals, there may be variations in detail that are site-specific. These procedures are intended to initiate a thought process for an inspector knowl- edgeable about chemical processes. 6.1 BACKGROUND Inspection of process facilities is an inherent part of reducing the probability of accidental chemical releases. Such inspections may be carried out by regulatory agencies or by companies themselves. The kind of inspection will usually differ for these two bodies; an inspection by a regulatory agency will generally be less detailed and focus on a few key items, whereas that by company will generally be more detailed and broader. The hazard identification procedures discussed earlier can be used to identify key areas for inspection. An inspection should include all 83 ------- functional parts of a physical facility where a release could conceivably occur. These parts were generally identified in Figure 1-4, Section 1 of this manual. The purpose of an inspection by a regulatory agency is to ensure that equipment and procedures for prevention and control of accidental releases are consistent with what a company has reported to the agency, and to determine if there may have been oversights in critical areas. The regulatory agency inspection will primarily identify problem areas. The purpose of an inspec- tion by a company is similar, except that the time and resources available are likely to allow a more detailed look at the facility. The company's inspec- tion will be much more focused on setting priorities for specific corrective actions rather than just identifying problem areas. 6.2 GENERAL PROCEDURE There are many ways to set up an inspection evaluation protocol and conduct inspections. This section discusses one possible approach. The overall procedure involves the following steps: Establishment of an inspection team; Determination of preliminary information requirements and acquisition of information including preparation of a facility questionnaire if necessary. The questionnaire will be com- pleted by responsible parties at the facility to be inspected and returned to the inspection team if the team is from outside the facility; Review of the questionnaire and other preliminary information, including process flow diagrams, piping and instrumentation diagrams, operating manuals, and descriptions of maintenance 84 ------- records to become familiar with the facility and identify critical areas for special attention; Meeting between the outside inspection team and a team of plant personnel including management to arrange a specific inspection plan, or planning meeting for the internal inspec- tion team; A walk-through overview tour of the facility; In-depth inspections of specific areas according to the considerations discussed below in Subsection 6.2 and any other specific considerations that may be appropriate; A meeting between the outside inspection team and plant personnel at the conclusion of the inspection to review results, or a meeting of the internal inspection team for the same purpose; Preparation of a written inspection report which: states the purpose and summarizes the findings, identifies hazards found during the inspection, discusses the risk implications of those hazards, and discusses possible remedies to correct deficiencies and reduce hazards. 85 ------- 6.3 SPECIFIC PROCEDURES Specific inspection procedures involve detailed examination of all parts of the process facility where toxic materials are used, manufactured, or stored. This inspection covers a number of specific elements which should include, but are not necessarily limited to: Process characteristics and process chemistry, Facility siting, Plant layout, Pressure relief systems, Maintenance and structural integrity, Fire protection, Electrical system, Transportation practices, and Contingency plan and emergency response coordination. Details of specific considerations in each of these areas are presented in Appendix B of this manual. It must be emphasized that these are guidelines only, and are representative of, but not necessarily all inclusive of, the kinds of considerations and observations that should be made during inspec- tions. The technical literature presents many other examples of how an inspection protocol would be set up. 86 ------- SECTION 7 COSTS OF ACCIDENTAL RELEASE PREVENTION With a commitment to and the knowledge required for accidental release prevention in place, the inevitable question is the cost of hazard identifica- tion and evaluation procedures, inspections, and control measures themselves. It is beyond the scope of this manual to exhaustively analyze the economic implications of accidental release prevention, but some general, very rough costs can be presented to provide a feel for the significance of economic issues. This section provides cost data associated with the various hazard identification and evaluation procedures, inspections, and control technolo- gies presented in previous sections of this manual. An example of the costs associated with the application of different combinations of controls to a specific system is illustrated. The implications of the costs of different control options is also discussed in light of policy planning. 7.1 COSTS OF HAZARD IDENTIFICATION, EVALUATION, AND INSPECTION Attempting to assign specific costs to these activities is extremely difficult without specifics on the number, size, and type of facilities involved. As was shown in Table 4-1, formal hazard identification and evalua- tion procedures can be broadly classified in relative terms as low, medium, and high cost activities. Costs for any procedure depend on the complexity and size of the system being analyzed, and on the quality of the initial information on the system. The literature from which the table was developed attempted to assign staffing and time requirements to each of the procedures listed. Careful 87 ------- analysis of these requirements suggests that some approximate costs can be developed as a lower bound for such activities. Results are shown in Table 7-1. Costs for inspections are also highly variable, and again depend on system complexity, size, and quality of the initial information available. A minimal inspection might take at least four hours by one or two people, and a more detailed inspection might last two to three weeks with a team of three or four people. On this basis, estimated costs are as presented in Table 7-2. These costs are intended as rough guidelines only, and can be expected to vary significantly in specific situations. 7.2 COSTS OF CONTROL TECHNOLOGIES Costs of control technologies range from the costs of an individual component such as an additional thermocouple to costs of a complete alterna- tively designed process system for handling a toxic chemical. A fundamental concept in evaluating the costs of control technologies for accidental release prevention is that increased safety may result from increasing levels of controls. As controls are added to a system, costs will increase. It is possible to compare costs for systems with different levels of controls and evaluate the relative improvements in safety that might result. This could be done through estimates of the reduction in accident probability by quantita- tive fault or event tree analyses. Costs of control technologies are addressed in more detail in a companion volume in this series on control technologies. The ensuing discussion pre- sents an overview of control technology cost issues. Table 7-3 summarizes cost ranges for some individual components that could be involved in enhancing the safety of a facility handling toxic chemi- cals, whether a storage or process facility. Costs for such enhancement could 88 ------- TABLE 7-1. ESTIMATED LOWER BOUND COSTS FOR VARIOUS HAZARD IDENTIFICATION AND EVALUATION PROCEDURES3 Basis: One process unit Staffing Procedure (personnel) Checklist Safety Review Ranking Procedures Preliminary Hazard Analysis What-If Analysis Hazard and Operability Study (HAZOP) Failure Mode, Effects, and Criticality Analysis (FMECA) Fault Tree Analysis (FTA) Event Tree Analysis Cause Consequence Analysis Human Error Analysis 1 3 3 3 3 4 2 4 4 4 1 Timec (days or weeks) ld-2w 3d-3w 3d-lw Id-lw 3d-lw 2w 6w 2w - 6w 2w - 6w 2w - 6w Iw - 6w Iw 1.040 4,680 4,680 1,560 4,680 20,800 10,400 20,800 20,800 10,400 2,600 Costd ($) - 10,400 - 23,400 - 7,800 - 7,800 - 7,800 - 62,400 - 31,200 - 62,400 - 62,400 - 62,400 aBased on staffing and time estimates in Reference 12. "One process unit" is roughly defined as a process system consisting of from one to perhaps three major unit operations (e.g., a complex chemical reactor system, or a simple reactor, a few heat exchangers, and a distillation column). The basis for the time and staffing for the various methods was not well defined in Reference 12. c"d" = days; "w" = weeks Based on an average loaded rate of $65/hour per staff person. 89 ------- TABLE 7-2. ESTIMATED COSTS FOR TYPICAL INSPECTIONS3 Team Size (Personnel) 3 3 3 Preparation 0,5 2 5 Time (Days) On-Site 0.5 5 15 Reporting 1.0 2 10 Cost ($) 3,120 14,040 46,800 Preparation time, on-site, and reporting for team only based on loaded labor rate of $65/hour. Does not include plant personnel time required to assist inspection team. Does not include team travel costs or subsistence costs, if any, at site. 90 ------- TABLE 7-3. COSTS OF SOME INDIVIDUAL INSTRUMENTATION AND CONTROL COMPONENTS FOR PROCESS SYSTEM SAFETY MODIFICATIONS*1 Capital Cost Range ($) Flowmeters Flow indicators Check valves Pressure sensors Pressure indicators Rupture disks Relief valves Temperature sensors Indicators Auxiliary cooling water capacity 2,500 400 400 200 200 150 7.000 200 1,000 30 - 5,100 - 1,000 - 600 - 500 - 600 - 300 - 12,000 - 300 - 1,700 - 80 per gpm Auxiliary refrigerated brine capacity Load cell systems Level detection systems Flow switches Pressure switches Density measurement pH measurement Viscosity measurement 3,000 per 12,000 1,100 ca. ca. 500 4,000 2,000 - 8,000 ton - 16,000 - 15.000 500 500 - 5.000 - 5,000 - 12,000 Annual Cost Range ($/yr) 400 60 60 30 30 30 600 30 150 5 per 450 per 2,400 80 ca. ca. 90 700 350 - 800 - 150 - 90 - 80 - 100 - 50 - 1,000 - 50 - 250 - 12 gpm - 1.200 ton - 3,200 - 2,300 80 80 - 900 - 900 - 2,200 (Continued) 91 ------- TABLE 7-3 (Continued) Capital Cost Range ($) Chemical species analyzers Controllers Control valves Complete control loops 700 800 3,000 6,000 - 40,000 - 6,000 - 6,000 - 15,000 Annual Cost Range ($/yr) 130 70 500 300 - 7,300 - 500 - 900 - 1,300 oasis: All costs were based on specific standard sizes which are documented in a companion manual in this series on control technologies. Costs are intended as rough guides to general magnitude only. Specific types will be found in the manual on control technologies. 92 ------- involve something as simple as adding a sensor where one was not previously used, or adding an extra one for backup, to something as complex as the design and implementation of an entirely different control system. More extensive application of control technologies could involve numerous changes in individual components, and even complete add-on subsystems such as scrubbers. Table 7-4 presents an example of how different levels or combina- tions of controls might affect the costs of a toxic gas storage tank system, based on the conceptual drawing in Figure 7-1. This type of analysis can be applied to any system where the evaluation of the cost implications of acci- dental release control measures are desired. All of these costs are to illustrate concepts and the general magnitude of costs. Actual costs will vary widely depending on the size and type of facility, exact specifications of equipment used, and the individual organ- ization that builds or modifies the facility. 7.3 COST IMPLICATIONS FOR POLICY PLANNING Costs of identification, evaluation, inspection, and control technologies can be used to roughly estimate costs of various programs for accidental release prevention and control by either regulatory agencies or companies. The costs given previously in Tables 7-1 and 7-2 can be used to estimate time requirements that might be associated with some of the regulatory aspects of hazard control plans evaluations by regulation, and compliance and preparation of plans by affected companies. Cost estimates such as shown in Table 7-4 provide a measure of what specific regulatory requirements involving process equipment would cost companies, excluding, of course, many indirect costs. This methodology can also be used to provide companies with a rough measure of cost impacts of various process control options. A complete analysis of cost implications of accidental release control is beyond the scope of this manual, but the overview presented here should be useful for preliminary planning purposes. 93 ------- TO HYDROGEN FLOURIDE ABSORPTION SYSTEM PRESSURE RELIEF VALVE PUMP BLEED AND SAMPLE WITH CAP TO LIMESTONE PACKED TILE DRAIN PRESSURE RELIEF DEVICE COMPRESSED GAS LEVEL GAUGE WITH HIGH LEVEL ALARM (LOCAL) LEVEL GAUGE WITH HIGH LEVEL ALARM (REMOTE TO CONTROL ROOM) PRESSURE RELIEF DEVICE MATERIAL PLACARD = V ANHYDROUS HF PERSON IN ATTENDANCE W / PROPER PROTECTIVE EQUIPMENT COMPRESSED GAS DERAIL SPILL COLLECTION PAN Figure 7-1. Example of a toxic gas storage system. ------- TABLE 7-4. EXAMPLES OF CONTROL COSTS FOR A TOXIC STORAGE SYSTEM3 Capital Cost Annual Cost Prevention/Protection Measure (1986 $) (1986 $/yr) Continuous moisture monitoring 7,500-10.000 900-1.300 Flow control loop 4.000-6.000 500-750 Temperature sensor 250-400 30-50 Pressure relief - relief valve 1.000-2.000 120-250 - rupture disk 1.000-1.200 120-150 Interlock system for flow shut-off 1,500-2.000 175-250 pH monitoring of cooling water 7.500-10,000 900-1,300 Alarm system 250-500 30-75 Level sensor - liquid level gauge 1,500-2,000 175-250 - load cell 10,000-15,000 1,300-1,900 Diking (based on a 10,000 gal. tank) - 3 ft. high 1.200-1.500 150-175 - top of tank height. 10 ft. 7.000-7,500 850-900 Increased corrosion inspection 200-400 aSee Table 7-5 for design basis. Details of estimating procedures are provided in a companion manual on control technologies of this series. 95 ------- TABLE 7-5. SPECIFICATIONS ASSOCIATED WITH TOXIC STORAGE SYSTEM Item Specification Continuous moisture monitoring Flow control loop Temperature sensor Pressure relief - relief valve - rupture disk Capacitance or infrared absorption system 2-inch globe control valve, Monel* trim, flowmeter and PID controller Thermocouple and associated thermowell 1-inch x 2-inch, Class 300 inlet and outlet flange, angle body, closed bonnet with screwed cap, carbon steel body, Monel* trim 1-inch Monel* disk and carbon steel holder Interlock system for flow shut-off pH monitoring system Solenoid valve, switch, and relay system Electrode, electrode chamber, amplifier - transducer and indicator Alarm system Level sensor - liquid level gauge - load cell Diking - 3 ft. high - 10 ft. high Indicating and audible alarm Differential pressure level gauge Electronic load cell 6-inch_reinforced concrete walls, 5.2 yd 10-inch_reinforced concrete walls, 36.3 yd 96 ------- SECTION 8 REFERENCES 1. Lees, F.P. Loss Prevention in the Process Industries. Butterworth's, London, England, 1980. 2. Industrial Economics, Inc., et al. Acute Hazardous Events Data Base. Executive Summary. EPA-560/5-85-029(a.), U.S. Environmental Protection Agency, 1985. 3. One-Hundred Largest Losses, A Thirty-Year Review of Property Damage Losses in the Hydrocarbon-Chemical Industries. Ninth Edition, Marsh and McLennan Protection Consultants, Chicago, IL, 1986. 4. Kletz, T.A. Talking About Safety. The Chemical Engineer, April 1976. 5. Chemical Emergency Preparedness Program, Interim Guidance. Revision 1, 9223.0-1A, U.S. Environmental Protection Agency, Washington, DC, 1985. 6. Hazard Survey of the Chemical and Allied Industries. Technical Survey No. 3, American Insurance Association, 1979. 7. Kirk, R.E. and D.F. Othmer. Encyclopedia of Chemical Technology. Third Edition, John Wiley & Sons, Inc., 1980. 8. Weast, R.C. (ed.). CRC Handbook of Chemistry and Physics. 63rd Edition, CRC Press, Inc., Boca Raton, FL, 1982. 9. Green, D.W. (ed.). Perry's Chemical Engineers' Handbook. Sixth Edition, McGraw-Hill Book Company, New York, NY, 1979. 10. Dean, J. (ed.). Lange's Handbook of Chemistry. Twelfth Edition, McGraw-Hill Book Company, New York, NY, 1979. 11. NIOSH/OSHA Pocket Guide to Chemical Hazards. DHEW (NIOSH) Publication No. 78-210, September 1985. 12. Battelle Columbus Division. Guidelines for Hazard Evaluation Procedures. The Center for Chemical Plant Safety, American Institute of Chemical Engineers, New York, NY, 1985. 13. Process Safety Management, Control of Acute Hazards. Chemical Manufacturers' Association, Washington, DC, May 1985. 14. Kletz, T.A. Eliminating Potential Process Hazards. Chemical Engineering, April 1, 1985. 97 ------- 15. Ozog, H. Hazard Identification, Analysis and Control. Chemical Engineering, February 18, 1985. 16. McNaughton, D.J. et al. Evaluation and Assessment of Models for Emergency Response Planning. TRC Environmental Consultants, Inc., Hartford, CT, February 1986. 17. Fire and Explosion Index. Hazard Classification Guide. Fourth Edition. Dow Chemical Company, Midland, MI, 1976. 18. Fisher, H.G. DIERS Research Program on Emergency Relief Systems. Chemical Engineering Progress, August 1985. 19. Chemical Emergency Preparedness Program, Interim Guidance. U.S. EPA, Revision 1, 922.3.01A. 20. National Fire Codes, 1986, National Fire Protection Association, Quincy, MA. 21. UL Handbook for Fire Ratings. Underwriters' Laboratories, Chicago, IL. 22. Perry, R.H. and Chilton, C.H. Chemical Engineer's Handbook. Fifth Edition, McGraw-Hill Book Company, New York, NY, 1973. 98 ------- APPENDIX A This appendix contains a listing of acutely toxic chemicals which appeared in a U.S. EPA publication addressing community preparedness for chemical emergencies (19). There are actually two separate lists entitled Acutely Toxic Chemicals" and "Other chemicals." Some of the chemicals on the second list are also acutely toxic. Both lists appear separately in this appendix. At the time this manual was prepared word was received that three chemicals from the second list had been deleted. The modified list actually is the one used in this appendix. 99 ------- 11/01/85 Acutely Toxic Chemicals Alphabetic List of Common Names and CAS Numbers Common Name CAS Number Acetone cyanohydrin Acetone thiosemicarbazide Acrolein Acrylyl chloride Aldicarb Aldrin Allyl alcohol Allylamine Aluminum phosphide Aminopterin Amiton Amiton oxalate Ammonium chloroplatinate Amphetamine Aniline, 2,4,6-trimethyl- Antimony pentafluoride Antimycin A Antu Arsenic pentoxide Arsenous oxide Arsenous trichloride Arsine Az inphos-ethy1 Az inphos-methy1 Bacitracin Benzal chloride Benzenamine, 3-(trifluoromethyl)- Benzene, 1-(chloromethyl)-4-nitro- Benzenearsonic acid Benzenesulfonyl chloride Benzotrichloride Benzyl chloride Benzyl cyanide Bicyclo[2.2.1]heptane-2-carbonitrile, 5-chloro., Bis(chloromethyl) ketone Bitoscanate Boron trichloride Boron trifluoride Boron trifluoride compound with methyl ether (1; Bromadiolone Butadiene Butyl isovalerate Butyl vinyl ether C.I. basic green 1 Cadmium oxide Cadmium stearate Calcium arsenate Camphechlor Cantharidin Carbachol chloride 1) 00075- 01752- 00107- 00814- 00116- 00309- 00107- 00107- 20859- 00054- 00078- 03734- 16919- 00300- 00088- 07783- 01397- 00086- 01303' 01327' 07784' 07784 02642 00086 01405 00098 00098 00100 00098 00098 00098 00100 00140 15271 00534 04044 10294 07637 00353 28772 00106 00109 00111 00633 01306 02223 07778 86-5 30-3 02-8 68-6 -06-3 00-2 -18-6 -11-9 -73-8 -62-6 -53-5 -97-2 -58-7 -62-9 -05-1 -70-2 -94-0 -88-4 -28-2 -53-3 -34-1 -42-1 -71-9 -50-0 -87-4 -87-3 -16-8 -14-1 -05-5 -09-9 -07-7 -44-7 -29-4 -41-7 -07-6 -65-9 -34-5 -07-2 -42-4 -56-7 -99-0 -19-3 -34-2 -03-4 -19-0 -93-0 -44-1 100 ------- 11/01/85 Acutely Toxic Chemicals Alphabetic List of Conation Names and CAS Numbers Common Name CAS Number Carbamic acid, methyl-, 0-[[(2,4-dimethyl... 26419-73-8 Carbofuran 01563-66-2 Carbophenothion 00786-19-6 Carvone 02244-16-8 Chlordane 00057-74-9 Chlorfenvinfos 00470-90-6 Chlorine 07782-50-5 Chlormephos 24934-91-6 Chlormequat chloride 00999-81-5 Chloroacetaldehyde 00107-20-0 Chloroacetic acid 00079-11-8 Chloroethanol 00107-07-3 Chloroethyl chloroformate 00627-11-2 Chloromethyl ether 00542-88-1 Chloromethyl methyl ether 00107-30-2 Chlorophacinone 03691-35-8 Chloroxuron 01982-47-4 Chlorthiophos 21923-23-9 Chromic chloride 10025-73-7 Cobalt 07440-48-4 Cobalt carbonyl 10210-68-1 Cobalt, [[2,2'-[l,2-ethanediylbis(nitrilomethy... 62207-76-5 Colchicine 00064-86-8 Coumafuryl 00117-52-2 Coumaphos 00056-72-4 Coumatetralyl 05836-29-3 Cresylic acid 00095-48-7 Crimidine 00535-89-7 Crotonaldehyde 00123-73-9 Crotonaldehyde 04170-30-3 Cyanogen bromide 00506-68-3 Cyanogen iodide 00506-78-5 Cyanophos 02636-26-2 Cyanuric fluoride 00675-14-9 Cycloheximide 00066-81-9 Cyclopentane 00287-92-3 Decaborane(14) 17702-41-9 Demeton 08065-48-3 Demeton-S-methyl 00919-86-8 Dialifos 10311-84-9 Diborane 19287-45-7 Dibutyl phthalate 00084-74-2 Dichlorobenzalkonium chloride 08023-53-8 Dichloroethyl ether 00111-44-4 Dichloromethylphenylsilane 00149-74-6 Dichlorvos 00062-73-7 Dicrotophos 00141-66-2 Diepoxybutane 01464-53-5 Diethyl chlorophosphate 00814-49-3 Diethyl-p-phenylenediamine 00093-05-0 101 ------- 11/01/85 Acutely Toxic Chemicals Alphabetic List of Common Names and CAS Numbers Common Name CAS Number Diethylcarbamazine citrate Digitoxin Diglycidyl ether Digoxin Dimefox Dimethoate Dimethyl phosphorochloridothioate Dimethyl phthalate Dimethyl sulfate Dimethyl sulfide Dimethyl-p-phenylenediamine Dimethyldichlorosilane Dimethylhydrazine Dimetilan Dinitrocresol Dinoseb Dinoterb Dioctyl phthalate Dioxathion Dioxolane Diphacinone Diphosphoramide, octamethyl- Disulfoton Dithiazanine iodide Dithiobiuret EPN Emetine, dihydrochloride Endosulfan Endothion Endrin Ergocalciferol Ergotamine tartrate Ethanesulfonyl chloride, 2-chloro- Ethanol, 1,2-dichloro-, acetate Ethion Ethoprophos Ethyl thiocyanate Ethylbis(2-chloroethyl)amine Ethylene fluorohydrin Ethylenediamine Ethyleneimine Ethylmercuric phosphate Fenamiphos Fenitrothion Fensulfothion Fluenetil Fluorine Fluoroacetamide Fluoroacetic acid Fluoroacetyl chloride 01642- 00071- 02238- 20830- 00115- 00060- 02524- 00131- 00077- 00075- 00099- 00075- 00057- 00644- 00534- 00088- 01420- 00117- 00078- 00646- 00082- 00152- 00298- 00514- 00541- 02104- 00316- 00115- 02778- 00072- 00050- 00379- 01622- 10140- 00563- 13194- 00542- 00538- 00371- 00107- 00151- 02235- 22224- 00122- 00115- 04301- 07782- 00640- 00144- 00359- 54-2 63-6 07-5 75-5 26-4 51-5 03-0 11-3 78-1 18-3 98-9 78-5 14-7 64-4 52-1 85-7 07-1 84-0 34-2 06-0 66-6 16-9 04-4 73-8 53-7 64-5 42-7 29-7 04-3 20-8 14-6 79-3 32-8 87-1 12-2 48-4 90-5 07-8 62-0 15-3 56-4 25-8 92-6 14-5 90-2 50-2 41-4 19-7 49-0 06-8 ------- 11/01/85 Acutely Toxic Chemicals Alphabetic List of Common Names and CAS Numbers Common Name CAS Number Fluorouracil Fonofos Formaldehyde cyanohydrin Formetanate Formothion Formparanate Fosthietan Fuberidazole Furan Gallium trichloride Hexachlorocyclopentadiene Hexachloronaphthalene Hexamethylenediamine, N,N'-dibutyl- Hydrazine Hydrocyanic acid Hydrogen fluoride Hydrogen selenide Indomethacin Iridium tetrachloride Iron, pentacarbonyl- Isobenzan Isobutyronitrile Isocyanic acid, 3,4-dichlorophenyl ester Isodrin Isofluorphate Isophorone diisocyanate Isopropyl chloroformate Isopropyl formate Isopropylmethylpyrazolyl dimethylcarbamate Lactonitrile Leptophos Lewisite Lindane Lithium hydride Malononitrile Manganese, tricarbonyl methylcyclopentadienyl Mechlorethamine Mephosfolan Mercuric acetate Mercuric chloride Mercuric oxide Mesitylene Methacrolein diacetate Methacrylic anhydride Methacrylonitrile Methacryloyl chloride Methacryloyloxyethyl isocyanate Metham idopho s Methanesulfonyl fluoride Methidathion 00051- 00944- 00107- 23422- 02540- 17702- 21548- 03878- 00110- 13450- 00077- 01335- 04835- 00302- 00074- 07664- 07783- 00053- 10025- 13463- 00297- 00078- 00102- 00465- 00055- 04098- 00108- 00625- 00119- 00078- 21609- 00541- 00058- 07580- 00109- 12108- 00051- 00950- 01600- 07487- 21908- 00108- 10476- 00760- 00126- 00920- 30674- 10265- 00558- 00950- 21-8 22-9 16-4 53-9 82-1 57-7 32-3 19-1 00-9 90-3 47-4 87-1 11-4 01-2 90-8 39-3 07-5 86-1 97-5 40-6 78-9 82-0 36-3 73-6 91-4 71-9 23-6 55-8 38-0 97-7 90-5 25-3 89-9 67-8 77-3 13-3 75-2 10-7 27-7 94-7 53-2 67-8 95-6 93-0 98-7 46-7 80-7 92-6 25-8 37-8 103 ------- 11/01/85 Acutely Toxic Chemicals Alphabetic List of Common Names and CAS Numbers Common Name CAS Number Methiocarb Methomyl Methoxyethylmercuric acetate Methyl 2-chloroacrylate Methyl chloroformate Methyl disulfide Methyl isocyanate Methyl isothiocyanate Methyl mercaptan Methyl phenkapton Methyl phosphonic dichloride Methyl thiocyanate Methyl vinyl ketone Methylhydraz ine Methylmercuric dicyanamide Methyltrichlorosilane Metolcarb Mevinphos Mexacarbate Mitomycin C Monocrotophos Muscimol Mustard gas Nickel Nickel carbonyl Nicotine Nicotine sulfate Nitric acid Nitric oxide Nitrocyclohexane Nitrogen dioxide Nitrosodimethylamine Norbormide Organorhodium complex Orotic acid Osmium tetroxide Ouabain Oxamyl Oxetane, 3,3-bis(chloromethyl) Oxydisulfoton Ozone Paraquat Paraquat methosulfate Parathion Parathion-methyl Paris green Pentaborane Pentachloroethane Pentachlorophenol Pentadecylamine 02032-65-7 16752-77-5 00151-38-2 00080-63-7 00079-22-1 00624-92-0 00624-83-9 00556-61-6 00074-93-1 03735-23-7 00676-97-1 00556-64-9 00078-94-4 00060-34-4 00502-39-6 00075-79-6 01129-41-5 07786-34-7 00315-18-4 00050-07-7 06923-22-4 02763-96-4 00505-60-2 07440-02-2 13463-39-3 00054-11-5 00065-30-5 07697-37-2 10102-43-9 01122-60-7 10102-44-0 00062-75-9 00991-42-4 PMN-82-147 00065-86-1 20816-12-0 00630-60-4 23135-22-0 00078-71-7 02497-07-6 10028-15-6 01910-42-5 02074-50-2 00056-38-2 00298-00-0 12002-03-8 19624-22-7 00076-01-7 00087-86-5 02570-26-5 104 ------- 11/01/85 Acutely Toxic Chemicals Alphabetic List of Common Names and CAS Numbers Common Name CAS Number Peracetic acid Perchloror.'.ethylmercaptan Phenarsaz^ae oxide Phenol Phenol, 2,2'-thiobis(4-chloro-6-methyl- Phenol, 2,2'-thiobis[4,6-dichloro- Phenol, 3-(l-methylethyl)-, methylcarbamate Phenyl dichloroarsine Phenylhydrazine hydrochloride Phenylmercury acetate Phenylsilatrane Phenylthiourea Phorate Phosacetim Phosfolan Phosmet Phosphamidon Phosphine Phosphonothioic acid O-(4-nitrophenyl.. methyl-, Phosphonothioic acid, methyl-, 0-ethyl O-[4-... Phosphonothioic acid, methyl-, S-[2-[bis... Phosphoric acid, dimethyl 4-(methylthio)phenyl... Phosphorous trichloride Phosphorus Phosphorus oxychloride Phosphorus pentachloride Phosphorus pentoxide Phylloquinone Physostigmine Physostigmine, salicylate (1:1) Picrotoxin Piperidine Piprotal Pirimifos-ethyl Platinous chloride Platinum tetrachloride Potassium arsenite Potassium cyanide Potassium silver cyanide Promecarb Propargyl bromide Propiolactone, .beta.- Propionitrile Propionitrile, 3-chloro- Propyl chloroformate Propylene glycol, allyl ether Propyleneimine Prothoate Pseudocumene Pyrene 105 00079- 00594- 00058- 00108- 04418- 00097- 00064- 00696- 00059- 00062- 02097- 00103- 00298- 04104- 00947- 00732- 13171- 07803- 02665- 02703- 50782- 03254- 07719- 07723- 10025- 10026- 01314- 00084- 00057- 00057- 00124- 00110- 05281- 23505 10025 13454 10124 00151 00506 02631 00106 00057 00107 00542 00109 01331 00075 02275 00095 00129 21-0 42-3 36-6 95-2 66-0 18-7 00-6 28-6 88-1 38-4 19-0 85-5 02-2 14-7 02-4 11-6 21-6 51-2 30-7 13-1 69-9 -63-5 12-2 -14-0 87-3 -13-8 -56-3 -80-0 -47-6 -64-7 -87-8 89-4 -13-0 -41-1 -65-7 -96-1 -50-2 -50-8 -61-6 -37-0 -96-7 -57-8 -12-0 -76-7 -61-5 -17-5 -55-8 -18-5 -63-6 -00-0 ------- 11/01/85 Acutely Toxic Chemicals Alphabetic List of Common Names and CAS Numbers Common Name CAS Number Pyridine, 2-methyl-5-vinyl- 00140- Pyridine, 4-amino- 00504- Pyridine, 4-nitro-, 1-oxide 01124- Pyriminil 53558- Rhodium trichloride 10049- Salcomine 14167- Sarin 00107- Selenium oxychloride 07791- Selenous acid 07783- Semicarbazide hydrochloride 00563- Silane, (4-aminobutyl)diethoxymethyl- 03037- Sodium anthraquinone-1-sulfonate 00128- Sodium arsenate 07631- Sodium arsenite 07784- Sodium azide (Na(N3)) 26628- Sodium cacodylate 00124- Sodium cyanide (Na(CN)) 00143- Sodium fluoroacetate 00062- Sodium pentachlorophenate 00131- Sodium selenate 13410- Sodium selenite 10102- Sodium tellurite 10102- Strychnine 00057- Strychnine, sulfate 00060- Sulfotep 03689- Sulfoxide, 3-chloropropyl octyl 03569- Sulfur tetrafluoride 07783- Sulfur trioxide 07446- Sulfuric acid 07664- TEPP 00107- Tabun 00077- Tellurium 13494- Tellurium hexafluoride 07783- Terbufos 13071- Tetraethyllead 00078- Tetraethyltin 00597- Tetranitromethane 00509- Thallic oxide 01314- Thallous carbonate 06533- Thallous chloride 07791- Thallous malonate 02757- Thallous sulfate 07446- Thallous sulfate 10031- Thiocarbazide 02231- Thiocyanic acid, (2-benzothiazolylthio)methyl... 21564- Thiofanox 39196- Thiometon 00640- Thionazin 00297- Thiophenol 00108- Thiosemicarbazide 00079- 106 76-1 24-5 33-0 25-1 07-7 18-1 44-8 23-3 00-8 41-7 72-7 56-3 89-2 46-5 22-8 65-2 33-9 74-8 52-2 01-0 18-8 20-2 24-9 41-3 24-5 57-1 60-0 11-9 93-9 49-3 81-6 80-9 80-4 79-9 00-2 64-8 14-8 32-5 73-9 12-0 18-8 18-6 59-1 57-4 17-0 18-4 15-3 97-2 98-5 19-6 ------- 11/01/85 Acutely Toxic Chemicals Alphabetic List of Common Names and CAS Numbers Common Name CAS Number Thiourea, (2-chlorophenyl)- 05344-82-1 Thiourea, (2-methylphenyl)- 00614-78-8 Titanium tetrachloride 07550-45-0 Toluene 2,4-diisocyanate 00584-84-9 Toluene 2,6-diisocyanate 00091-08-7 Triamiphos 01031-47-6 Triazofos 24017-47-8 Trichloro(chloromethyl)silane 01558-25-4 Trichloro(dichlorophenyl)silane 27137-85-5 Trichloroacetyl chloride 00076-02-8 Trichloroethylsilane 00115-21-9 Trichloronate 00327-98-0 Trichlorophenylsilane 00098-13-5 Trichlorphon 00052-68-6 Triethoxysilane 00998-30-1 Trimethylchlorosilane 00075-77-4 Trimethylolpropane phosphite 00824-11-3 Trimethyltin chloride 01066-45-1 Triphenyltin chloride 00639-58-7 Tris(2-chloroethyl)amine 00555-77-1 Valinomycin 02001-95-8 Vanadium pentoxide 01314-62-1 Vinylnorbornene 03048-64-4 Warfarin 00081-81-2 Warfarin sodium 00129-06-6 Xylylene dichloride 28347-13-9 Zinc phosphide 01314-84-7 Zinc, dichloro[4,4-dimethyl-5-[[[(methylamino)... 58270-08-9 trans-l,4-Dichlorobutene 00110-57-6 107 ------- OTHER CHEMICALS Name CAS Number Acrylamide Acrylonitrile Adiponitrile Ammonia Aniline Bromine Carbon disulfide Chloroform Cyclohexylamine Epichlorohydrin Ethylene oxide Formaldehyde Hydrochloric acid Hydrogen peroxide Hydrogen sulfide Hydroquinone Methyl bromide Nitrobenzene Phosgene Propylene oxide Sulfur dioxide Tetramethyl lead Vinyl acetate monomer 79-06-1 107-13-1 111-69-3 7664-41-7 62-53-3 77 26-95-6 75-15-0 67-66-3 108-91-8 106-89-8 75-21-8 50-00-0 7647-01-0 7722-84-1 7783-06-4 123-31-9 74-83-9 98-95-3 75-44-5 75-56-9 7446-09-5 75-74-1 108-05-4 108 ------- APPENDIX B EXAMPLE DETAILED PROCEDURES FOR HAZARD EVALUATION FACILITY INSPECTIONS B.I Process and Process Chemistry Evaluation Purpose The purpose of this evaluation is to identify the most critical areas in the process facility, based on the fundamental process chemistry and the sequence of unit processes and unit operations. Process chemistry considera- tions also include chemical reactions that might occur with materials that might unintentionally enter the process as contaminants. Procedures Procedures for this part of the evaluation include the following: Review of chemical equations for the process to identify fundamental hazard potential associated with basic process chemistry. Review of written process descriptions and process procedures to identify critical process areas or procedures. Review of process flow diagrams (PFD) and/or piping and instrumentation diagrams (PID) for the critical process areas identified above. Visual inspection of process areas, units, and specific critical equipment items for oversights or deficiencies using the information discussed in ensuing subsections as a guide. 109 ------- Comparison of process characteristics of the inspected process with other processes in the plant and the chemical industry as a whole to judge relative hazard potential. Application of various formal hazard identification and evaluation procedures to determine qualitatively how an accidental release might occur. Key Factors Materials characteristics: evaluated to determine which materials in each process are potentially the most dangerous. Comparison of physical properties at both process and ambient conditions, including boiling point, melting point, vapor pressure, viscosity, and vapor density. Flammability as characterized by flashpoint, upper and lower explosive limits, and auto-ignition temperatures. Also, the chemical compatibility of mixtures in storage areas and during handling. Acute toxicity as characterized by the health effects of exposure by inhalation or skin contact. The evaluation of reactivity according to the following parameters: a. Whether reactions are exothermic, endothermic or thermodynamically balanced. b. Potential for uncontrolled reactions due to such things as decomposition, excessive temperature, backflow, or spontaneous polymerization. 110 ------- c. Process reactivity with water or other possible contaminants. d. Potential side reactions and conditions under which they are favored. Corrosiveness considered in the context of the appropri- ateness of construction materials. Range of process conditions: the hazard potential is normally increased the larger the process and hence inventory of toxic material and the more severe the process conditions. Evaluation of process capacities in terms of operating throughput and in-process inventories of toxic materials. Classification of the reaction type based on a unit operation or unit process approach, for example, halo- genation, polymerization, etc. Some types may show a history of more hazards than others. Categorization of reaction and separation process temperatures as low if less than 200°F, moderate between 200 and 500°F, or high temperature if above 500°F. Categorization of process pressures reaction and separa- tion as low if less than 100 psig, moderate between 100 and 500 psig, or high pressure if above 500 psig. Evaluation of the process conditions relative to the physical properties of the chemicals. Mode of processing and process configuration: certain process types and configurations may be inherently more hazardous than 111 ------- others and hazards vary according to process characteristics (e.g., reaction time, volume, and type of reaction). Evaluation of the implications of a process being batch, semi-batch, or continuous. For example a large inventory batch processes may be more of a hazard than a small inventory continuous processes. Evaluation of process configuration in terms of opera- tional sequences and physical placement of equipment. Evaluation of process complexity in terms of the number of process steps and the nature of individual unit operations. Thermodynamics of Key Reactions Exothermic reactions: considered more hazardous than endothermic or balanced reactions. Qualitative evaluation of the hazard potential of an exothermic reaction according to whether it has a weak. moderate, or strong exotherm. Types of Instrumentation and Control Systems Evaluation of the control system in terms of the reliability and responsiveness to deviations and corrective actions. Consideration of relative reliability of pneumatic or electronic systems for given application. 112 ------- Computer control systems: considered to be safer than reliance solely on manual controls, but computer systems should have some kind of manual backup. Backup for increasing reliability: emergency cooling and heating systems, redundancy of the instruments, the instrument air supply, electrical power supply, and the computer system. Evaluation of alarms and emergency shutdown systems for type, complexity, location and reliability. Process Isolation Evaluation of the ability to isolate, quench, or dump the process materials in an emergency: location of shut-off valves and whether manual or automated shut-off is used. Assessment of the possible effects of a fire, explosion, or release in a nearby process on the process being inspected. Operator Training Evaluation of operator training for routine operations by review of operator training programs, operating manuals, and observations of and discussions with selected opera- tors, and observations of operators carrying out their duties. Evaluation of emergency awareness and preparedness for operator response to emergency situations including 113 ------- drills and tests in the same general manner as for routine operations. B.2 Facility Siting Evaluation Purpose The purpose of this evaluation is to assess the potential impact of a facility's location on the frequency or severity of an accidental release and the vulnerability of the surrounding community to an accidental release. Procedures Review of surrounding community: the evaluation of plant location relative to the surrounding community by direct observation and by maps and other written information. Review of climatic conditions: evaluation of the potential for severe climatic conditions and natural disasters from discussions with plant personnel, by direct observation and from government records for the area. Review of municipal utility reliability: evaluation of the reliability of municipal utilities (electricity, water, gas, etc.) from discussions with plant personnel, direct observa- tions of main supply lines and information of past utility failures. Key Factors Location in the community: evaluation of the plant location within the community in terms of proximity to other businesses and population centers, land use and terrain features in 114 ------- surrounding areas, wind patterns, and surface groundwater in the area. Other businesses and population centers near the plant are potential receptors of any accidental releases, fires, or explosions in the subject facility. The potential danger varies with the specific hazard and magnitude of that hazard. The exact extent of the hazard zone depends on the quantity released. In general, however, as a rough guideline, receptors within a few hundred yards of a ( facility may be considered sensitive receptors, while receptors beyond about 2-5 miles may be considered to be on the outer limits of typical hazard zones. It is emphasized here, however that toxic materials can be dangerous in clouds traveling many miles, and these distances are only for rough evaluation purposes. An estimate of total population, including temporary population such as workers during certain parts of the day, within various distances of the plant (i.e., plant shutdown and construction personnel): the basis for estimating the number of people outside the plant who might be affected by a release. Especially sensitive receptors such as schools, parks, and hospitals. Land use in surrounding areas: noted in the context of the considerations just discussed, and especially promi- nent terrain features such as physical plants (i.e., columns and reactors), rivers, forests, and hills which 115 ------- could affect the dispersion of airborne chemical releases. Directions and speeds of seasonal and diurnal wind patterns for the facility. This is usually shown in a diagram called a windrose. Data for windroses are available for most major metropolitan areas and some other areas from the National Weather Service. The presence of surface and groundwaters in the area: noted in the context of the potential for contamination by sudden accidental releases of chemicals. Evaluation of the potential impact of an accidental release or other hazard coming from an adjacent business. Traffic flow patterns around the perimeter of the facil- ity: especially points of congestion and the potential impact of traffic congestion on the movement of emergency response equipment and evacuated plant personnel. Climatic conditions Evaluation of the potential for flood, landslide, brush fire, earthquake, severe wind or hail, subfreezing temperatures, or other climatic conditions including consideration of how such events might cause an accidental release. Assessment of the need for other protective measures to reduce the potential for an accidental release resulting from climatic conditions. 116 ------- Review of municipal utility reliability Review of past reliability of municipal utilities. Consideration of unusual causes for utility failure, including downed power lines resulting from a vehicle collision with power line poles, or the loss of all utilities because of an earthquake. Evaluation of backup utilities in the event of a facility-wide utility failure. B.3 Facility Layout Evaluation Purpose The purpose of the plant layout evaluation is to determine if specific features of the layout could contribute to an accidental release. A primary consideration in the evaluation of the layout is the potential for an acci- dental release or other accident in one section of the facility to adversely affect other sections of the facility. As far as possible, each section within a facility should be protected from the effects of accidents in other sections of the facility. Procedures Review of the total facility plot plan and plot plans of individual process areas. Tour of facility: to complement information obtained from plot plans. Discussions with plant personnel: information obtained directly from plant personnel, as required. 117 ------- Key Factors Overall Plant Configuration Review of the overall configuration of the facility, as well as individual process units. Evaluation of the compatibility between materials in adjacent process units, especially considering how the possible release of a chemical, fire, or explosion in one unit could affect adjacent units and lead to additional accidental releases. Evaluation of the compatibility of chemicals between process units and adjacent storage areas, and between the adjacent storage areas themselves Evaluation of the location of individual facility process and storage areas relative to utility and other plant areas, considering such items as ignition sources, an incident in a process or storage area affecting a criti- cal utility system, and potential effects on other areas from incidents in process and storage areas. Evaluation of the distance between various parts of the facility and property lines and of special terrain features. Process areas: should be well separated from utilities, storage, office, and laboratory areas. Process and storage areas for flammable materials: should be in the prevailing downwind direction from 118 ------- ignition sources, or otherwise located away from ignition sources to the extent possible. Hazardous units: separation distances from all critical areas such as control rooms and process computer instal- lations should at least be similar to those specified for flammable materials as given in Lees (1) for example. Administrative buildings and warehouses: preferably located at the periphery of the plant. Control rooms: should be protected from potential fire or explosion damage and from the adverse affects of an accidental release. Where possible, process control rooms should be located at the perimeter of the unit they control. Spacing of Process and Storage Areas Inter- and intra-unit spacing: consideration of the distance between risk areas, and between equipment and systems within risk areas. Spacing of equipment: should consider the nature of the materials, quantity, operating conditions, sensitivity of the equipment, the need to combat fires, and the concen- tration of personnel and hardware valuables in a given area. Storage tanks: should be reasonably spaced and appropri- ately diked. Applicable codes and standards should be adhered to as a minimum requirement. 119 ------- Toxic materials in processes or storage areas: special considerations of spacing and isolation. Easy isolation and containment of hazardous materials in an emergency: for example, is a critical shutoff valve too close to the area of immediate impact in an accident? Vehicular Access and Clearances Entrances and exits to various facility areas: should be adequate and free from uncontrollable obstruction in an emergency. For example, would a rail car accident on plant property block the only access road in or out so that emergency equipment could not respond to such an accident? Access: there should be a minimum of at least two means of access or egress to the facility and critical areas within the facility. Overhead clearances: observed for possible collapse and obstruction of access or egress in emergencies; also observed as the possible cause of a chemical release incident due to a collision with vehicular traffic. Security Security considerations are included in the facility layout evaluation because of the possibility of deliberate or acci- dental sabotage. The facility property should be fenced and access limited through gates under ready observation or direct control of facility security personnel. 120 ------- B.4 Pressure Relief System Evaluation Purpose The purpose of this evaluation is to evaluate the adequacy of pressure relief systems designed to prevent rupture of vessels, pipelines, or equipment which would result in the uncontrolled release of toxic, explosive, or flamm- able materials. Procedures Design and Procedures Review Review of the need for and extent of pressure relief systems by examining process flow diagrams, process and storage conditions, and process instrumentation diagrams. Review of maintenance and engineering records on relief systems. Questioning of appropriate plant personnel about current installations, practices, and procedures. Field Inspection Visual inspection of relief systems in a convenient priority sequence determined by a consideration of hazard potential, location in the plant, and inspection sched- ule. Examination of process equipment for the presence of protection and its overall adequacy. 121 ------- Examination of individual relief devices and systems for proper configurations and specifications. Checking of nominal pressure and temperature ratings on vessels and other equipment against actual use condi- tions. Examination of the physical condition of pressure relief equipment. Key Factors Evaluation of the appropriateness and applicability of the relief system includes the following considerations: - Relief systems: should be in place and functional on all equipment where it is required by codes and standards, and other equipment where the hazard for rupture from overpressure exists. Safety relief valves: should be provided on the dis- charge side of positive displacement pumps, between positive displacement compressors and block valves, between back-pressure turbine exhaust flanges and block valves, and on any equipment where liquid can be blocked in and later warmed, or where chemical reactions, exter- nal fire, overfilling, or other process malfunction could result in equipment internal overpressure. Vacuum relief devices: should be used where vacuum drawn on equipment, if blocked in, could cause equipment collapse from external pressure. 122 ------- Relief devices: should be of the proper type and specifications for the application. State-of-the-art equipment should be used where possible on equipment containing large inventories of toxic materials. Specifications: including sizes, construction materials, relief set pressure, set pressure tolerances, and service temperature range. These must be compatible with and specific to process conditions. Consideration should be given to the possibility of solids formation which could plug relief device inlets, outlets, and working mechanisms, (e.g. polymerization of monomer vapors from condensation on cold surfaces). Sizing Sizing: based on the maximum relief rate after consider- ation of four relief situations: a. Fire exposure b. Reaction/decomposition overpressure c. Maximum fill rate d. Thermal expansion Relief devices: should be sized using accepted pro- cedures of the American Petroleum Institute (Recommended Practice for the Design and Installation of Pressure Relieving Systems in Refineries, Part I - Design, API, 1973) the National Fire Protection Association (NFPA 30 and NFPA 68), the American Society of Mechanical Engi- neers (ASME) Boiler and Pressure Vessel Code, Section VIII, consistent with type of service. Sizing for 123 ------- reaction/decomposition cases can be done using methods developed by the Design Institute for Emergency Relief Systems (DIERS), which was sponsored and published by the American Institute of Chemical Engineers (AIChE) (18). Conf igurat ion Evaluation of the possible hazards of manifolding, such as discharge of incompatible materials. Overall installation: should provide for ease of re- moval, inspection, testing, and replacement of the relief devices. Relief devices: should not be blocked by shut-off valves upstream or downstream unless a fail-safe system is provided with parallel relief such that both relief lines cannot be out of service at the same time, or some other means is used to protect the shut-off valves from improper closure. The former is sometimes accomplished using a 3-way, 2-port valve upstream of dual relief valves such that only one can be isolated at a time. Protection from shut-off is accomplished using breakable seals or even locks on shut-off handles to indicate or prevent unauthorized closure. Outlets not leading into common manifolds or flares: should be directed in a safe manner. This means that they should not be directed toward personnel or equipment where the discharge could cause fire, explosion, serious contamination, or other accidents. This is especially important in the ignited pressure relief of flammable 124 ------- materials where impingement of flame on vessels or other equipment could have serious consequences. Vents: should normally terminate outside of buildings and be at a height that minimizes exposure hazards. Discharge piping: should be supported independently of the relief valve to withstand dynamic forces involved when relief valve opens. Drain connections, weep holes, or rain guards: should be provided on relief discharge piping where rain, snow, or condensation could accumulate and plug the discharge. Low inertial covers may be provided in some cases. Rupture disks used in series with safety relief valves: a pressure gauge or other pressure indicator should be provided between the rupture disk and relief valve to indicate disk integrity. A pressure reading indicates that the rupture disk must be replaced. Blockage: auxiliary devices which might plug, such as check valves, or flame arresters should not be installed on relief system piping. Pipe plugs or caps should not be present on relief valves. Backpressure effects: should be considered for effect on relief valve operation, especially when several valves discharge into a common system. Location: Safety relief valves should be located as close as practical to the equipment they protect to minimize pressure drop and valve "chattering." 125 ------- Inlet piping: Should not be less than same nominal pipe size as relief valve inlet. Discharge piping: Should not be less than same nominal pipe size as relief valve outlet. Should be run as directly as possible with minimum changes of direction. Common headers: Should have a cross sectional area at least equal to the total of the connected valves. Pressure reducing stations: For steam, air gas, etc., should be fitted with safety relief valves on low pres- sure side. Safety relief valve should be sized to carry bull load of reducing valve and its bypass. Inspection and Testing Safety relief valves: should be periodically inspected for structural integrity and for signs of corrosion or plugging. Materials that undergo polymerization, or are extremely corrosive may require especially frequent inspections. Safety relief valve repair firms, including in-house testing units, should have a current certificate of authorization from the National Board of Boiler and Pressure Vessel Inspectors and have a "VP" stamp. Pressure indicators on rupture disk installations: should be periodically checked for indications of rupture disk activation or leakage. 126 ------- Safety relief valves: should be tested for opening at the required set pressure and for proper reseating. Inspection frequencies: should follow a fixed schedule commensurate with the type of service and risk associated with a system failure. Safety relief valves should be inspected at least once in five years and as much as annually or more in high hazard applications. Records of inspections and testing: should be main- tained. B.5 Maintenance and Structural Integrity Evaluation Purpose The purpose of this evaluation is to assess the adequacy of maintenance procedures and the structural integrity of equipment. Procedures Discussions with maintenance personnel are held and written maintenance procedures and records are examined. The physical facility as a whole and individual equipment items believed to be most hazardous are examined during a site tour. Maintenance equipment and facilities are also observed. Key Factors Maintenance Organization and Scheduling System: the overall maintenance organization and scheduling system is reviewed with key maintenance personnel by examining written procedures and records. 127 ------- Staffing levels should be appropriate for the size of the facility. Changes in staff levels are compared to changes in the physical facility. For example, has staffing kept pace with and is it of the appropriate type for recent plant modifications or additions? Examination of staff qualifications and skill levels relative to the .hazard potential of the specific opera- tion. Evaluation of the duties and responsibilities of contract versus in-house maintenance. In-house supervision or auditing of contract maintenance should be sufficient to ensure satisfactory contractor performance. Review of systems for work order initiation and implemen- tation are reviewed. Review of procedures for maintenance scheduling and ranking to ensure that high hazard areas are properly recognized. Evaluation of the extent and adequacy of preventive main- tenance. The frequency of such maintenance is considered in light of the kinds of equipment and systems involved, their potential inherent reliability, and the conse- quences of failure. Inspection, Testing, and Monitoring Program (ITM Program) Determination of the presence or lack of an inspection testing and monitoring program for process equipment and instrumentation. 128 ------- Evaluation of the ITM program in terms of four areas: a. Vessels, piping, and other process equipment, b. Rotating equipment, and c. Instrumentation. d. Utility systems (steam, water, air, electrical. etc.) Factors considered for a formal ITM program: a. Severity of service (defined by operating tempera- tures and pressures and corrosiveness of materials used in the equipment), b. Hazard potential of specific chemical and equipment used, and c. Size of process facility and ITM program resource requirements. Visual inspections of the presence and extent of corro- sion, cracks, and improper installation such as inade- quate foundations, missing supports, excessive vibration, etc. Testing: may include determination of wall thickness, corrosion rates, the presence of cracks or pinholes, pressure tests, and temperature tests. Testing methods: include ultrasonics, radiography, liquid penetrant, magnetic particle, eddy current, acoustic emission, visual leak testing, and others. Special tests may be required for vessels lined with glass, rubber, or other polymeric materials. Assessment of the need for continuous monitoring methods or programs. 129 ------- Inspections for rotating equipment: include vibration analysis and monitoring, unusual sounds, and leakage around rotating parts, in addition to inspection items used for other equipment. Instrumentation ITM: depends on how important the instrumentation is to the process and the kinds of instruments involved. For example, thermocouples may be more reliable than resistance temperature devices. Maintenance Record Keeping Engineering drawings and design specifications on equip- ment should be retained and readily available. Records of inspections, tests, repairs, and modifications should also be available. Equipment records should include a detailed safety check list for inspections, testing, and maintenance. Such check lists should cover special precautions and proce- dures to be taken before, during, and after maintenance work. Maintenance work order and scheduling records should be maintained. Physical Condition of Equipment Visual examination of the physical condition of equipment for signs of excessive corrosion, structural weathering, and physical flaws such as cracks or other physical damage. 130 ------- Examination of the integrity of insulation, especially of storage tanks and other equipment containing hazardous materials where accumulated moisture under damaged insulation could cause external corrosion. Examination of instrumentation and control equipment to ensure that housings and enclosures are in place to prevent dirt, moisture, and corrosion from impairing the accurate functioning of the equipment. Examination of control valves for worn or sticking stems, and of other valves for excessive corrosion, indicating they might be inoperable in an emergency. Examination of the integrity of foundations and struc- tural steel supports for evidence of cracks, subsidence, and corrosion. Examination of rotating equipment for evidence of vibra- tion, leaks, and unusual or abnormal noises. Design Specifications and Plant Practices Design specifications for pressure and temperature: must be adequate for the intended service, and plant practices must be consistent with pressure and temperature specifi- cations. Unfired pressure vessels as a minimum standard should be ASME Code, Section VIII Divisions 1 or 2 constructed and stamped. Other equipment should be designed and constructed in accordance with recognized codes and standards as a minimum requirement. Minimum standards may not be adequate for toxic materials. 131 ------- Safety controls for overpressure and overtemperature: should be present and in good working order. Type and location of sensors: as far as possible, a sensor should directly measure the variable that must be controlled. Where backup systems are present: both the backup and the primary system should be in good working order. The most effective backup system: one that functions on a different principle than the primary system. Materials of construction and corrosion allowances: must be appropriate for the service at hand. Proper construction and installation of equipment: including provision for ease of inspection and mainte- nance . Piping systems: should be designed with allowance for stresses and movement due to thermal expansion, and systems should be properly supported and guided. Piping systems: should be uncluttered, with valves and lines labelled or easily identifiable. Systems: should be designed so that the failure of one valve or sensor does not result in an accidental release. All instrumentation should be fail-safe. 132 ------- Valves and fittings: should be appropriate to their intended service. Threaded fittings are inappropriate for most piping handling hazardous materials. Backflow protection: must be present in lines where backflow is a hazard. A single backflow device is rarely sufficient and some devices provide more reliable protec- tion than others. Flexible hoses: should be used only where necessary. Some type of operational audit system, or physical systems should be in place to prevent using hoses in situations they are not designed for. Hoses should be inspected regularly for signs of wear or abuse. Freeze protection: should be provided where required, especially in cold water lines, instrument connections, and lines in dead-end service such as piping at standby pumps. Lubrication and cooling systems for process machinery: should be in good working order. Oil filters should be used for lubrication to critical components. B.6 Fire Protection Evaluation Purpose The purpose of the fire protection evaluation is to assess the potential contribution of fire or explosion to an accidental release. The fire protec- tion system is evaluated for its ability to control or extinguish a fire, limit its extent, and limit the ensuing damage. The fire protection system must especially protect facilities containing toxic chemicals. A fundamental 133 ------- principle is to maintain operations outside the explosive range of flammable materials. Procedures Review of Drawings Examination of the plant process diagrams and layout drawings to identify areas where combustible, flammable, or explosive materials are used and stored. Review of drawings of the fire protection systems to identify the location of the water supply, the distribu- tion system, sprinkler systems, fire monitors, hydrants, and special fire fighting equipment. Review of Written Procedures Review of emergency response plans to evaluate lines of authority, communications, and general procedures. Documentation of fire protection team personnel assign- ments and training procedures. Discussions with Personnel: interviews with personnel respon- sible for fire protection concerning history, current pro- cedures, problem areas, and future plans. Site Inspection: inspection of fire protection systems in light of the many considerations listed below under Key Factors. 13A ------- Comparison of specific practices with applicable fire codes, discussion of good practices that may not be explicitly covered by codes, and evaluation of practices in the context of site-specific considerations. Selected National Fire Protection Association Codes with special significance for chemical process plants include, but are not restricted to, the following (20): Code Title 11 Foam Extinguishing Systems 12 Carbon Dioxide Systems 12A & B Halon Systems 13 Sprinkler Systems Installation 14 Standpipe and Hose Systems 15 Water Spray Fixed Systems 16 Foam-Water Sprinkler and Spray Systems 17 Dry Chemical Systems 19B Respiratory Equipment for Firefighters 20 Centrifugal Fire Pumps 22 Water Tanks 24 Private Fire Service Mains 30 Flammable and Combustible Liquids Code 385 Tank Vehicles for Flammable and Combustible Liquids 386 Portable Shipping Tanks 43A Storage of Liquid and Solid Oxidizing Materials 43C Storage of Gaseous Oxidizing Agents 493 Intrinsically Safe Apparatus 496 Purged Enclosures for Electrical Equipment 50 Bulk Oxygen Systems 50A & B Gaseous and Liquid Hydrogen Systems 135 ------- Code Title 54 National Fuel Gas Code 58 Liquified Petroleum Gases, Storage and Handling 59 Liquified Natural Gas, Storage and Handling 61A Manufacturing and Handling Starch 63 Industrial Plants Dust Explosions 654 Plastics Industry Dust Hazards 66 Pneumatic Conveying Systems 69 Explosion Prevention Systems 71-72 (Signaling Systems and Fire Detectors) 76A Essential Electrical Systems 231 General Storage Indoor 231C Rack Storage of Materials 512 Truck Fire Protection 1961-1963 (Fire Hose and Connections) 1 Fire Prevention Code 13A Sprinkler Systems Maintenance 27 Private Fire Brigades 291 Fire Hydrants Uniform Makings 329 Underground Leakage of Flammable and Combustible Liquids 497 Electrical Installations in Chemical Plants 68 Explosion Venting Guide 70B Electrical Equipment Maintenance 80A Protection from Exposure Fires 136 ------- Key Factors Water Supply and Distribution Water sources: must be of adequate capacity, quality, and reliability. Supply pressure and a backup supply of adequate capacity are fundamental considerations. Redundancy of supply: may be advisable in some high risk situations. Water bodies may require pretreatment, such as filtration and chlorination to remove dirt and debris and control organisms that could plug the system. In-plant reservoirs or reserve supplies should typically provide at least 4 hours of coverage. This depends on the availability of other sources and the nature of potential fires. Distribution system: should consist of a looped or gridded network of large-diameter pipe, feeding all of the fire protection systems and equipment requiring water. Underground piping or appropriate freeze protec- tion should be used, depending on climate. Where above ground portions of the system are run, they should be secure from mechanical, fire, and explosion damage, and freezing weather. Pumps: must provide adequate pressure and volume for the plant requirements. Additional pumps may be required because of plant expan- sion or modifications. 137 ------- Pumps should be automatically started, but in either case startup must be reliable and secure in an emergency. Adequate protection must be provided to ensure that lines, pumps, valves, and discharge devices do not freeze and impair the fire water supply. Pump suction supply: normally sized to provide maximum flow rate for a minimum of four hours. Evaluation of the sizing of the distribution system in light of the size of the facility and nature of the operation: normally a system is not sized to cover simultaneous fires in all areas. However, sizing of various portions of the system should account for the actual layout of a specific plant since in some facili- ties simultaneous demands on a fire protection system may be greater than at others. A minimum diameter for underground mains is 6 inches. System pressures: sprinkler and water spray systems should normally require between 50 to 100 psig. Monitors, large hose systems and some foam systems may require 100 to 150 psig. Fire trucks supplied by a main can normally use 20 to 50 psig. Fire pumps: should have capacities of 150% delivery requirement at 65% of rated head. Fire pumps: should preferably have automatic start controls and a backup drive in the event of electrical power failure. Diesel drives are usually preferred, but if electric pumps are used, backups should be steam or 138 ------- diesel; again diesel is usually preferred. Electric pumps should be UL listed. Adequacy of coverage considers but is not limited to the following: fire protection for indoor and outdoor storage of flammable liquids in drums, adequate spacing and fire protection for flammable materials storage tanks, fire protection in warehouses, fire protection of cooling towers. Sectional control valves in the underground fire mains should divide the grid system into sections, limiting the area subject to a single impairment. The number of sprinkler risers and hydrants out of commission during any change or repair should be specified depending on the size of the area to be covered. With any one section shut off, at least one water supply should be available for the remainder of the system. The distribution system should ensure protection of structures and tankage. Sprinkler and Deluge Systems Sprinkler and deluge systems: used for localized and broad area protection. Automatic sprinkler protection: necessary for all buildings containing combustible construction, or flam- mable and combustible materials. Evaluation of adequacy in terms of areas covered, the density of coverage (flowrate per unit area), the 139 ------- physical conditions of the system components, and frequency of testing. Sprinkler waterflow alarms: should give an audible local alarm and automatically transmit water flow signals to a central supervised location for any flow of water through the sprinkler piping. Automatic detectors: should be used where the quantity of combustibles is limited or sprinklers are not compati- ble with the hazard to be protected. Hydrants and Monitors Hydrants provide hose connections to the fire protection water system. Monitors provide a fixed, quick response discharge point for fire protection water streams. Sufficient hydrants having at least two 2.5 inch hose streams should be provided at any point in the property where fire may occur regardless of wind direction. This will require spacing hydrants 225 to 250 feet apart at plant with ordinary hazards. At plants having highly combustible occupancies, the spacing may need to be reduced to 100 to 150 feet. For facilities with non- combustible buildings and non-hazardous occupancies, hydrant spacing may be extended to 250 to 300 feet. For average conditions locate hydrants 50 feet from the building or equipment protected. Fire protection monitors: should be used to protect equipment containing flammable liquids that is not in a building or structure protected by automatic sprinklers. 140 ------- Their principle advantage is to provide a quick stream of water which can be operated by one man while hose lines are being laid. Spacings of 200 to 250 feet. Assessment of the possibility of blockage of streams from fire monitors. Such blockage can occur when plant modifications are made. For example, an additional tank being put in behind an existing tank protected by a monitor. The new tank is blocked from the monitor stream by the existing tank. Portable monitors should be used in such cases. Building Protection and Portable Fire Extinguishers Evaluation of fire protection for buildings in terms of type of construction and contents. Small hose stations: located inside buildings so that every square foot of floor area is within 20 feet of a hose nozzle attached to not more than 75 feet of 1.5 inch woven jacketed rubber lined hose or equivalent. The nozzles should be the combination spray and solid stream with shutoff. Small hose: preferably attached to risers independent of the sprinkler system if hose streams are considered needed when sprinklers are not operating. If this cannot be arranged, small hose may be attached to 2.5 inch or larger pipe on a wet pipe system. Portable fire extinguishers: available in sufficient number, located where they are readily accessible, and in good operating condition. 141 ------- Fire walls, partitions, and barricades: provided to separate personnel areas, high value property, critical process units, and critical utility and auxiliary units. Foam Systems and Other Special Protection Special fire hazard protection: includes foam systems, carbon dioxide, dry chemicals, and explosion suppression systems. Fire extinguishing agents: compatible with process materials. Fire Proofing and Structural Protection Fire proofing as a surface coating material: gunite or other synthetic material. A UL standard is for two hours of protection (21). However, hourly rating should be chosen as appropriate for situation. Fire proofing: used on structural steel and on walls of vessels in a chemical process area, applied by spraying or spread coating onto the structure. It should be present in all areas where equipment may be exposed to fire. It should be used on all main load-bearing structural members that support either process piping or equipment within hazardous areas. Fireproofing on vessel walls is not a common practice. Evaluation of the adequacy of fire protection in terms of type, thickness, coverage, and integrity of the coating. Gaps or peeling are a basis for rejection. 142 ------- Fireproofing should extend at least 30 feet above potential pool fires. Fire proofing should be provided for valve operators for all emergency safety devices. Mobile Fire Apparatus Mobile fire apparatus: may consist of fire trucks or hand carts. Fire apparatus: located in areas protected from but accessible to plant areas where fires are likely. Equipment: should be in sound condition and subjected to periodic tests. Evaluation of the adequacy of the equipment in terms of capacity and presence of the right kinds of equipment for the types of fires likely to occur in the specific facility. If ponded water is a source of supplementary water, an inlet system needs to be in place to ensure that blockage of suction hose can not occur. Alarm Systems Alarm Systems: consist of various combinations of sensors and alarm devices and should be appropriate to the intended fire hazard. Sensors may be based on detection of flammable vapors or heat, for example. The selection would depend on the specific situation. 143 ------- Evaluation of sensor locations relative to locations of flammable materials and ignition sources. Evaluation of the physical condition of sensors and alarm systems. Evaluation of system adequacy in terms of location, coverage, and sensitivity. Flow alarms: should be provided on sprinkler systems to indicate their activation. Fire Emergency Response Organization Lines of authority and communications for fire emergen- cies: should be clearly defined and readily available to all plant personnel. Procedures, individual assignments, and emergency num- bers: should be clearly posted in operator control room and other areas where personnel are likely to be in an emergency situation. Training procedures: should be clearly defined and written. Training program should include both formal classroom type instruction as well as field drills with equipment. For high hazard areas good practice suggests simulated incidents as well. Training frequency should be consistent with the risk associated with a given process area. A cadre of assigned individuals should form the core of a fire fighting team. The size of this team will depend on 144 ------- the size of the plant and the level of risk and must be adequate to at least contain an incident, if outside help is available. If outside help is not available the team must be of sufficient size and training to fully control an incident on its own. Maintenance of Fire Protection Equipment A regular program of scheduled inspections, tests, and preventive maintenance on fire protection equipment should be adhered to. Plant Layout Considerations 1. Adequate spacing, diking, and drainage:- should be provided for process equipment and tanks of flammable and combustible materials. 2. Flammable storage pumps, compressors, and other equipment should be specific distances from ignition sources. Location near toxic materials should be avoided where possible. 3. Adequate drainage: should be provided to avoid large concentrations of flammable materials in the event of spills. It should be pitched to drain away from high hazard structures with a minimum of 1% grade. B.7 Electrical System Evaluation Purpose The purpose of the electrical system evaluation is to determine to what extent the electrical system could contribute to an accidental release through 145 ------- design, operation, or reliability deficiencies. All portions of the electri- cal system should be installed in accordance with the National Electric Code or stricter standards. Individual components should comply with the accept- ability criteria of recognized testing organizations. Procedures The overall electrical system is reviewed through discussions with plant personnel, by a plant inspection tour, and by evaluation of written data and drawings. Key Factors Reliability Total power requirement and sources of electrical power to the plant: evaluation of the reliability of the sources (public utility system, private system, cogenera- tion system), including the history of outages, and examination of the physical source of power into the plant from outside power sources or from generating facilities within the plant for location and physical condition. Evaluation of locational factors: proximity to flood- prone areas or areas within exposure zones of fire, explosions, or frequency of lightening. Evaluation of the nature and extent of redundancy backup power system: focusing primarily on critical areas, including major power sources such as diesel generators for a whole process area, and battery backup units for individual processes or specific critical control ele- ment s. 146 ------- Evaluation of historical reliability: including the frequency and duration of outages at the plant. Determination of whether the facility has considered implications of power outages for the process unit as a whole as well as individual components such as instrumen- tation for specific intervals ranging from say, one minute to two hours. Evaluation of voltage variations in light of possible effects on sensitive equipment. Could power surges damage a critical component in a control system such as software on a disk drive in a process control computer? Evaluation of the configuration of the distribution system in terms of the adequacy of loops or independent circuit to different process area. Within a process area, electrical load blocks should correspond to process load blocks. Electrical system: should be physically protected to minimize exposure to fire, corrosion, and mechanical damage; should be simple in schematic and physical layout to minimize human error in isolation load transfer; and should be accessible for ease of repair and maintenance. Electrical system: should have adequate instrumentation for monitoring and the efficient diagnoses of failures, and protection by fuses and circuit breakers should be adequate. 147 ------- Bonding and grounding: should be provided to protect personnel and protect systems from static buildup and lightening. Maintenance and testing: the nature, frequency, and adequacy for power transformers, circuit breakers, relays and other devices, whether by the utility company, outside contractors, or the company, is evaluated. National Electric Code (NEC) Compliance The electrical system in a chemical plant must conform to the specifications for hazardous locations as specified in Section 501-5(a) of the National Electric Code (NEC). Process and storage areas are viewed in terms of the NEC hazardous location class, division, and grouping system. For example, Class I - Division II - Group D describes areas where flammable liquids and gases are handled, but are normally confined within closed systems, and where chemicals are typical organics. Other common categories for chemical plants include chemicals in Groups B and C. Class II areas, which is for atmospheres containing combustible dust, and Class I - Division I service, which is for atmospheres which continuously or intermittently contain high concentrations of flammable gases or vapors. Key principles to be checked: isolation of the elec- trical system components and containment of the flame front should ignition occur inside of equipment. In practice this is accomplished by sealed conduits, circuit breakers, lights, motors, and switches. 148 ------- Evaluation of proper pressurization and venting of closed areas. Inspectors: should be alert to the use of any portable electrical equipment not conforming to NEC codes. Evaluation of equipment maintenance conditions by obser- vations of specific components of the electrical system such as: outside electric lines, insulators, support structures, switchgear, distribution panels, circuit breakers, lighting, grounding systems, motor starters and control centers, generators, transformers, relays, and lightening arresters. B.8 Transportation Practices Evaluation Purpose The purpose of this evaluation is to assess the potential for a transpor- tation incident causing an accidental release on plant property or elsewhere. Areas of concern include: loading and unloading procedures, adequate design of vehicles to handle the materials they transport, inspection and maintenance practices, and practices regulating the movement of vehicles within the plant. Procedures Review of written guidelines and procedures pertinent to in-plant transportation practices. Inspection of loading and unloading areas, along with equipment and selected vehicles that happen to be present at the time of the visit. 149 ------- Discussions with both supervisory and operating personnel associated with transportation. Key Factors Review of General Transportation Procedures. Determination of vehicle type and of the rationale for the use of these vehicles. The compatibility of the vehicle with the type of service is evaluated in terms of materials being hauled in adherence to Department of Transportation requirements as well as special procedures and requirements established by the individual plant and company. Evaluation of construction materials, and vehicle tank specifications in terms of pressure ratings, temperature ratings, wall thicknesses, valving, and on-vehicle sensors and instrumentation relative to the kinds of materials being shipped. Evaluation of special practices, such as refrigerated and insulated vehicles for temperature sensitive products from a "what-if mentality. Brief visual inspections of vehicles may be made at the time of the inspection to look for malfunctioning, poorly maintained, or incorrect equipment, such as inappropriate pressure relief devices. Review of plant procedures for routine inspections. 150 ------- Consideration of extra precautions taken for pressurized tank vehicles and high hazard materials. Review of certification procedures, usually through discussions with plant personnel. Such procedures would cover verification of the previous contents of the vehicle, cleaning after the last load, and similar considerations. Review of numbers, frequency of shipments, and sizes of shipments. Review of Loading and Unloading Operations Examination of the use and scope of loading checklists. Methods of overfill protection: common procedures for overfill protection include level sensors, automatic shut-off actuated by quantity totalizers, scales and load sensors, and reliance on operators. For hazardous materials an overfill protection system should have a back up. Spill control measures: provisions should be available for both containment and cleanup, and where highly volatile materials or gases are involved, the plant should have a contingency plan for responding to air borne releases. Availability of automatic shut-offs actuated by abnormal conditions and remote shut-offs: in case equipment can not be reached during an emergency. 151 ------- The responsibilities of the plant personnel and the driver: should be clearly defined and understood. For high hazard loading and unloading operations a plant representative should always be present. Review of labeling, stenciling, placarding, and other informational practices for compliance with DOT require- ments and a plant's own special requirements. Review of controls on in-plant routing and stationing of vehicles. Potential hazards related to these factors include the potential for vehicular collisions with equipment in tight areas and vehicle accidents caused by poor locational practices. As an example of the latter, a fully loaded tank trailer parked off the pavement on soft ground, could overturn as a result of the wheels sinking on one side and the vehicle falling over. Definition of procedures for the management of rail car traffic on the plant premises. Special provisions for protection against derailment incidents are noted. Review of procedures for dealing with liquid heels in tank vehicles. It is common practice not to sample or analyze the heels in vehicle tanks dedicated to a single service. Plant procedures for avoiding cross- contamination of products in transportation vehicles and receiving racks are evaluated. Evaluation of equipment condition and its use. For example, do hoses show signs of significant abrasion and where? Are couplings appropriate for the type of ser- vice? What precautions are taken to maintain cleanliness 152 ------- in filling and unloading equipment where contamination could be hazardous? Is equipment being used as it was intended, or has jerry-rigging occurred as products have changed? Evaluation of precautions used for static electricity grounding. Check valves and/or other precautions: should be in place to prevent backflow and siphoning conditions form occurring. Color coding or other means of designating multiple lines and spouts: desirable at multi-material loading and unloading facilities. Are flow rate limiters in use? Is there thermal expansion relief for blocked-in valve lines? Evaluation of procedures to prevent drive-away with the attendant breakage of lines and accompanying chemical releases. Recalibration of gaging and metering equipment: should be carried out periodically. Off-Site Risks Review of driver qualification, training, and certifica- tion procedures. 153 ------- Review of accident histories for clues as to potential causes and impacts of future incidents. Changes in equipment or procedures occasioned by previous incidents are noted. Review of routing procedures in the context of DOT regulations, special local rules, and other considera- tions that may be specific to the plant and the materials it handles. a. DOT regulations b. Other considerations B.9 Contingency Plan and Emergency Response Coordination Purpose The purpose of the emergency response evaluation is to ensure that adequate procedures and equipment are in place to reduce the effects of an accident on people and property both within and outside the plant. Plant personnel and, where necessary, personnel from local emergency response agencies should be trained to participate in plans for controlling plant emergencies during large windstorms, earthquakes, floods, power failure, fires, explosions, and accidental releases. Procedures Review of Written Procedures: written procedures are reviewed and the accessibility of these procedures to plant personnel are observed. Written procedures are evaluated in terms of comprehensiveness and specificity to the peculiarities of the individual facility. Recognition of the most significant hazards is noted. 154 ------- Discussions with Plant Personnel: the interviewing of selec- ted plant personnel to evaluate their perceptions, to gauge their knowledge and attitudes toward emergency response, and to obtain additional factual information for use in the evaluation. Key Factors Evaluation of contingency plans for dealing with various emergencies in terms of the following: The plan should be comprehensive and cover fire, explo- sion, and chemical releases. The plan should be specific. It should clearly designate responsibilities for individual unit personnel as well as plant personnel involved in fire fighting teams, medical teams, evacuation teams, etc. It should also address specific high hazard situations such as incidents in specific units or process areas, and specific kinds of incidents such as the accidental large release of a toxic chemical. Plans should be up to date. A process plant is rarely a static entity. Changes and modifications made over the years may affect process hazard potential. Corresponding changes in emergency response plans should also be made and clearly dated to allow evaluation of the appropriate- ness of the current plan. Evaluation of the availability of the plan to plant personnel: this includes physical distribution of the 155 ------- plan and the way it is stored and treated by plant personnel. Responsibilities for personnel: should be clearly defined. The definition of responsibilities for the evening and night-time work shifts is especially impor- tant, since staffing on these shifts is usually less than in the day time. Personnel Training Personnel training programs: should include written materials and include both formal "class room" instruc- tion as well as field drills. Instruction and drills: commonly cover routine fire fighting and some times non-catastrophic spills. For areas with high hazard potential, specific drills for dealing with potential catastrophic incidents are impor- tant. Evaluation of operator awareness: by questioning them about what incidents they consider to be the greatest hazards in their areas and how they might respond to such incidents. Emergency Communications Systems Communications systems available for dealing with emer- gencies: may include telephones, radios, signals, and alarms. 156 ------- Evaluation of the effectiveness and reliability of the communications system. Because telephone lines may be out of service in an emergency, radio communication is an important backup. Definition of communications responsibilities and plans for relaying information in times of emergency. Consideration of alternatives to telephone and radio communications, such as area wide alarm signals. Emergency Response Equipment Emergency response equipment availability: may include air packs, chemical suits, medical packs, and mobile tool kits. Evaluation of the effectiveness and reliability of the equipment. The total available supply of emergency breathing air is critical. Coordination with Outside Agencies and the Community Evaluation of the availability of support facilities, equipment, and personnel. Support facilities include hospitals, emergency aid stations, and fire stations. Equipment includes fire vehicles, ambulances, and specialized tools. Numbers and skills of support personnel are noted. Because chemical plant operations can sometimes be esoteric to the outside community, the hazard potential of a facility may be reduced if outside authorities and emergency services are properly informed and are familiar with the plant and its operations. 157 ------- Local fire departments should be aware of the methods and equipment necessary, to fight a chemical fire for each chemical in use. The plant's program in this regard is evaluated. Consideration of plant participation in joint training activities with the community. Consideration of the proximity of support facilities and response times. Response times longer than 15-20 minutes are reaching the extreme of utility for an emergency response. Consideration of -accessibility to the plant and various areas within the plant, especially to how emergency access and egress may differ from normal entrance and exit patterns. Review of plans for emergency notification of the com- munity and for community evacuation. While a community evacuation plan is beyond the control of the plant, recognition of the need for such a plan and steps the plant may have taken to have the community develop such a plan are noted. Mutual aid from neighboring industry: is it available? Evaluation of general community relations and of histori- cal relations by discussions with plant personnel. This may be important in engaging community support in emer- gencies, as well as in securing the plant against pos- sible sabotage. 158 ------- APPENDIX C GLOSSARY This glossary defines selected terms used in the text of this manual which might be unfamiliar to some users or which might be used differently by different authors. Accidental release; The unintentional spilling, leaking, pumping, purging, emitting, emptying, discharging, escaping, dumping, or disposing of a toxic material into the environment in a manner that is not in compliance with a plant's federal, state, or local environmental permits and results in toxic concentrations in the air that are a potential health threat to the surrounding community. Alkane: A chemical compound consisting only of carbon and hydrogen in which the carbon atoms are joined to each other by single bonds. Assessment; The process whereby the hazards which have been identified are evaluated in order to provide an estimate for the level of risk. Autocatalytic; A chemical reaction which is catalyzed by one of the products of the reaction. Carcinogen; A cancer causing substance. Containment/Control; A system to which toxic emissions from safety relief discharges are routed to be controlled. A caustic scrubber and/or flare can be containment/control devices. These systems may serve the dual function of destructing continuous process exhaust gas emissions. 159 ------- Contingency Plan; A plan which describes the actions that facility personnel will take to minimize the hazards to human health or the environment from fires, explosions or accidental releases of hazardous materials. Control System; A system designed to automatically maintain all controlled process variables within a prescribed range. Creative Checklist; A list of major hazards and nuisances designed so that when an individual item from the list is associated with a particular material or a significant part of a unit, an image of a specific hazard or nuisance is generated as a stimulus to the imagination of members of a multidisciplinary team. Creative Checklist Hazard and Operability Study; A Hazard and Operability Study which uses a Creative Checklist to stimulate a systematic, yet creative search for hazards. Emergency Response Plan; A plan of action to be followed by source operators after a toxic substance has been accidentally released to the atmosphere. The plan includes notification of authorities and impacted population zones, minimizing the quantity of the discharge, etc. Event Tree; A logic diagram which depicts all pathways (success and failure) originating from an initiating event. Exothermic; A term used to characterize the evolution of heat. Specifically refers to chemical reactions from which heat is evolved. Facility; A location at which a process or set of processes are used to produce, refine or repackage chemicals, or a location where a large enough inventory of chemicals are stored so that a significant accidental release of a toxic chemical is possible. 160 ------- Fault Tree; A logic diagram which depicts the interrelationships of various primary events and subevents to an undesired top event. Fire Monitor; A mechanical device holding a rotating nozzle, which emits a stream of water for use in firefighting. Fire monitors may be fixed in place or may be portable. A fire monitor allows one person to direct water on a fire whereas a hose of the same flowrate would require more than one person. Guide Word Hazard and Operability Study; A Hazard and Operability Study which uses Guide Words to stimulate a systematic yet creative search for hazards. Hazard; A source of danger. The potential for death, injury or other forms of damage to life and property. Hazard and Operability Study; The application of a formal systematic critical examination to the process and engineering intentions of the new facilities to assess the hazard potential of maloperation of individual items of equipment and the consequential effects on the facility as a whole. Hygroscopic; Readily taking up and retaining moisutre (water). Identification; The recognition of a situation, its causes and consequences relating to a defined potential, e.g. Hazard Identification. Lachrymator; A substance which increases the flow of tears. Mitigation; Any measure taken to reduce the severity of the adverse effects associated with the accidental release of a hazardous chemical. Mutagen; An agent that causes biological mutation. Plant; A location at which a process or set of processes are used to produce, refine, or repackage, chemicals. 161 ------- Prevention; Design and operating measures applied to a process to ensure that primary containment of toxic chemicals is maintained. Primary containment means confinement of toxic chemicals within the equipment intended for normal operating conditions. Primary Containment; The containment provided by the piping, vessels and machinery used in a facility for handling chemicals under normal operating conditions. Probability/potential; A measure, either qualitative or quantitative, that an event will occur within some unit of time. Process; The sequence of physical and chemical operations for the production, refining, repackaging or storage of chemicals. Process machinery; Process equipment, such as pumps, compressors, heaters, or agitators, that would not be categorized as piping and vessels. Protection; Measures taken to capture or destroy a toxic chemical that has breached primary containment, but before an uncontrolled release to the environment has occurred. Pyrophoric; A substance that spontaneously ignites in air at or below room temperature without supply of heat, friction, or shock. Qualitative Evaluation; Assessing the risk of an accidental release at a facility in relative terms; the end result of the assessment being a verbal description of the risk. Quantitative Evaluation; Assessing the risk of an accidental release at a facility in numerical terms; the end result of the assessment being some type of number reflects risk, such as faults per year or mean time between failure. 162 ------- Reactivity: The ability of one chemical to undergo a chemical reaction with another chemical. Reactivity of one chemical is always measured in reference to the potential for reaction with itself or with another chemical. A chemical is sometimes said to be "reactive", or have high "reactivity", without reference to another chemical. Usually this means that the chemical has the ability to react with common materials such as water, or common materials of construction such as carbon steel. Redundancy; For control systems, redundancy is the presence of a second piece of control equipment where only one would be required. The second piece of equipment is installed to act as a backup in the event that the primary piece of equipment fails. Redundant equipment can be installed to backup all or selected portions of a control system. Risk; The probability that a hazard may be realized at any specified level in a given span of time. Secondary Containment! Process equipment specifically designed to contain material that has breached primary containment before the material is released to the environment and becomes an accidental release. A vent duct and scrubber that are attached to the outlet of a pressure relief device are examples of secondary containment. Teratogenic: Causing anomalies of formation or development. Toxicity; A measure of the adverse health effects of exposure to a chemical. 163 ------- APPENDIX D TABLE D-l. METRIC (SI) CONVERSION FACTORS Quantity Length: Area: Volume: Mass (weight) : Pressure: Temperature : Caloric Value; Enthalpy: Specific-Heat Capacity: Density : Concentration: Flowrate: Velocity: Viscosity: To Convert From in ft ft2 in3 ft3 gal Ib short ton (ton) short ton (ton) atm mm Hg psia psig °F °C Btu/lb Btu/lbmol kcal/gmol Btu/lb-°F lb/ft3 Ib/gal oz/gal quarts/gal gal /min gal/day ft /min ft /min ft/sec centipoise (CP) To cm m cm2 m2 cm m3 m3 kg Mg metric ton (t) kPa kPa kPa kPa* °c* K* kJ/kg kJ/kgmol kJ/kgmol kJ/kg-°C kg/m3 kg/m3 kg/m3 cm3/m3 m /min m /day m /min m/min m/sec Pa-s (kg/m-s) Multiply By 2.54 0.3048 6.4516 0.0929 16.39 0.0283 0.0038 0.4536 0.9072 0.9072 101.3 0.133 6.895 (psig)+14.696)x(6.895) (5/9)x(°F-32) °C+273.15 2.326 2.326 4.184 4.1868 16.02 119.8 25 , 000 0.0038 0.0038 0.0283 0.3048 0.3048 0.001 *Calculate as indicated Source: Adapted from Reference 22. 164 U.S. GOVERNMENT PRINTING OFFICE: 1987 7l»8-121'67017 ------- |