68862
United States
Environmental Protection
Agency
Office of Emergency and
Remedial Response
Emergency Response Division
Environmental
Response
Team
&EPA Chemical Safety Audits
Environmental Response Training Program
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FOREWORD
This manual is for reference use of students enrolled in scheduled training courses of the U.S.
Environmental Protection Agency (EPA). While it will be useful to anyone who needs information
on the subjects covered, it will have its greatest value as an adjunct to classroom presentations
involving discussions among the students and the instructional staff.
This manual has been developed with a goal of providing the best available current information;
however, individual instructors may provide additional material to cover special aspects of their
presentations.
Because of the limited availability of the manual, it should not be cited in bibliographies or other
publications.
References to products and manufacturers are for illustration only; they do not imply endorsement
by EPA.
Constructive suggestions for improvement of the content and format of the manual are welcome.
U.S. Environmental Protection Agency
Office of Emergency and Remedial Response
Environmental Response Team
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CHEMICAL SAFETY AUDITS
(165.19)
4 Days
This course introduces safety auditing for highly hazardous chemicals and is based on the U.S.
Environmental Protection Agency's (EPA) Chemical Safety Audit Program and the Occupational
Safety and Health Administration's (OSHA) Process Safety Management (29 CFR 1910.119). The
course covers basic chemical systems and processes, chemical process hazards, process safety
systems, process safety management, emergency response, chemical hazard mitigation, chemical
hazard evaluation, hazard evaluation techniques, and incident (hazardous material release)
investigation. Interviewing techniques, computer modeling, and report writing are also covered.
Participants receive practical auditing experience by forming an audit team and conducting a mock
chemical safety audit at a fictitious chemical plant. The mock audit follows protocol established in
EPA's Guidance Manual for EPA Chemical Safety Audit Team Members.
This introductory course provides an overview of chemical process safety and chemical safety
auditing. Participants responsible for reviewing emergency response and safety programs at chemical
plants, petrochemical plants, refineries, or chemical storage facilities in their area of responsibility
will benefit from this course.
After completing this course, participants will be able to:
Describe EPA's Chemical Safety Audit Program.
Describe chemical processes, process hazards, process safety systems, safety
management, emergency response, hazards evaluation, and incident investigation in
process plants.
Discuss interviewing, computer modeling, and report-writing techniques.
List the required and suggested activities covered in the Guidance Manual for EPA
Chemical Safety Audit Team Members.
Perform a chemical safety audit using EPA protocol, interviewing techniques, and
report-writing skills.
After completing this course, participants will be more familiar with chemical processes, hazards,
hazard evaluation, the EPA chemical safety audit process, and EPA auditing protocol.
111
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CONTENTS
Chemical Safety Audit Program Fact Sheet
Section 1
Section 2
Section 3
Section 4
Viewgraphs
Chemical Process Hazards
Process Safety Management
Chemical Safety Audit Manual Review
Computer Modeling
Process Safety: Equipment
Process Safety: Operations
Hazard and Release Mitigation
Maintenance Procedures and Training Requirements
Conducting Interviews
Incident Investigation
Hazard Evaluation
Hazard Evaluation Techniques
Emergency Response
Process Inspection Techniques
Audit Report Writing
Guidance Manual for EPA Chemical Safety Audit Team Members
Chemical Safety Audit Program Resource Guide
Group Exercises
Ground Rules and General Information
Exercise 1Facility X Overview, Information Review, and Hazards
Identification
Technical Information About Facility X
Exercise 2Process Systems, Operations, and Maintenance
Interviews and Interviewing Techniques
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Tips for Conducting an Effective Interview
Exercise 3--Safety, Training, and Emergency Response Planning
Interviews
Exercise 4Audit Report Preparation and Presentation
Section 5 Chemical Safety Audit Report Worksheet
VI
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vvEPA
FACT SHEET MARCH 1993
CHEMICAL SAFETY AUDIT PROGRAM
BACKGROUND
The Chemical Safety Audit (CSA) program has evolved
from the efforts of the U.S. Environmental
Protection Agency (EPA) under the Chemical Accident
Prevention (CAP) program. The CAP program emerged
from concerns raised by the release of methyl
isocyanate at Bhopal, India, and of aldicarb oxime
at Institute, West Virginia. Awareness of the
critical threat to public safety posed by similar
incidents led to an emphasis on preparedness and
planning for response to chemical accidents.
Simultaneous with- the development of preparedness
activities by EPA was the passage and
implementation of the Emergency Planning and
Community Right-to-Know Act -- Title III of the
Superfund Amendments and Reauthorization Act (SARA)
by Congress in 1986. Because prevention is the
most effective form of preparedness, the CAP
program promotes an effort to enhance prevention
activities. The primary objectives of the CAP
program are to identify the causes of accidental
releases of hazardous substances and the means to
prevent them from occurring, to promote industry
initiatives in these areas, and to share activities
with the community, industry, and other groups.
Many of the key concerns of the CAP program arise
from the SARA Title III section 305(b) study
entitled Review of Emergency Systems. As part of
the information gathering efforts to prepare this
study, EPA personnel conducted a number of facility
site visits to learn about chemical process safety
management practices. The study covers
technologies, techniques, and practices for
preventing, detecting, and monitoring releases of
extremely hazardous substances, and for alerting
the public to such releases. One of the key
recommendations resulting from the study was the
continuation and expansion of the audit program.
As a follow-up to this national prevention study,
EPA has undertaken cooperative initiatives with
federal agencies, states, industry groups,
professional organizations, and trade associations,
as well as environmental groups and academia.
These joint efforts will serve to determine and
implement a means to share information on release
prevention technology and practices, and to enhance
the state of practice in the chemical process
safety arena.
PROGRAM GOALS
The CSA program is part of this broad initiative
and has been designed to accomplish the following
chemical accident prevention goals:
Visit facilities handling hazardous substances
to gather information on and learn about safety
practices and technologies;
Heighten awareness of the need for, and promote,
chemical safety among facilities handling
hazardous substances, as well as in communities
where chemicals are located;
Build cooperation among facilities, EPA, and
other authorized parties by coordinating joint
audits; and
Establish a database for the assembly and
distribution of chemical process safety
management information obtained from the
facility audits.
PROGRAM AUTHORITY
The Comprehensive, Environmental Response,
Compensation and Liability Act (CERCLA or
Superfund) was enacted December 11, 1980, and
amended by SARA on October 17, 1986. CERCLA
authorizes the federal government to respond where
there is a release or a substantial threat of a
release into the environment of any hazardous
substance, pollutant, or contaminant that may
present danger to the public health or welfare or
to the environment.
CERCLA Sections 104(b) and 104(e), as amended by
SARA in 1986, provide authorities for entering a
facility and accessing information to conduct a
chemical safety audit by EPA. While CERCLA
provides authority for states to use statutory
authorities for entry and information gathering,
such authorities may only be accessed pursuant to a
contract or cooperative agreement with the federal
government. Since there is no such arrangement,
states, as well as local governments, must use
their own authorities for audit participation.
As a matter of EPA policy under the CSA program,
all facilities that will receive an audit should
have experienced a release of a hazardous
substance, pollutant, or contaminant, or there
should be reaion to believe that there exists a
threat of such a release. The audits are intended
to be nonconfrontational and positive, such that
information on safety practices, techniques, and
technologies can be identified and shared between
EPA and the facility. Involvement in the CSA
program by Local Emergency Planning Committees
(LEPCs) and State Emergency Response Commissions
(SERCs) formed under SARA Title II! is encouraged
to enhance the goals of both of these programs.
However, as stated above, state and local
government participation in the audit, itself, must
be performed under state and local authorities.
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EPA Fact Sheet
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AUDIT SCOPE
REPORT DISTRIBUTION
The audit consists of interviews with facility
personnel, and on-site review of various aspects of
facility operations related to the prevention of
accidental chemical releases. Specific topics
addressed include:
Awareness of chemical and process hazards;
Process characteristics;
Emergency planning and preparedness;
Hazard evaluation and release detection
techniques;
Operations and emergency response training;
Facility/corporate management structure;
Preventive maintenance and inspection programs;
and
Community notification mechanisms and
techniques.
Observations and conclusions from audits are
detailed in a report prepared by the audit team.
The report identifies and characterizes the
strengths of specific Chemical Accident Prevention
program areas to allow the elements of particularly
effective programs to be recognized. Copies of the
report are provided to the facility so that weak
and strong program areas may be recognized. The
audit is conducted following the Guidance Manual
for EPA Chemical Safety Audit Team Members, issued
by EPA Headquarters. This guidance contains
recommended actions, as well as mandatory
procedures that must be followed to ensure the
health and safety of program auditors and program
integrity. Each member of the audit team should
have a copy of the manual, and a copy of the manual
is transmitted to the audited facility.
AUDIT TEAM COMPOSITION
An EPA audit team primarily consists of EPA
employees, and other designated representatives
including contractors and the American Association
of Retired Persons (AARP) enrol lees. Other
federal, state, and local government personnel may
also be team members. The audft team can vary in
size, depending upon the level of detail of the
audit (e.g., number of chemicals and/or processes
under investigation; national significance).
FACILITY SELECTION
At present, there are no established procedures for
selecting a facility for an audit. Each EPA region
has flexibility in identifying facilities. Options
to consider in selecting a facility include:
Previous history of the facility;
SERC and/or LEPC referral;
Proximity to sensitive population(s);
Public sensitivity;
Regional accident prevention initiatives;
Opportunity for sharing new technology;
Population density; and
Concentration of industry in the area.
Standard distribution by EPA regional offices of
the audit report will be at a minimum to:
SERC and LEPC in which the facility is located;
Facility owner/operator and facility CEO;
EPA Headquarters; and
Any other federal, state, and local agencies or
departments that assisted in conducting the
audit.
Distribution is available to other EPA offices,
other federal, state, and local agencies or
departments, and other private and public sector
organizations.
ACCOMPLISHMENTS
During the first four years of the CSA program, the
regions have conducted audits at over 150
facilities in 46 states and Puerto Rico. EPA has
analyzed the conclusions and recommendations listed
in the audit reports to identify trends within and
across industries, processes, and chemicals to
assist in the further development of the CSA and
CAP programs, particularly in light of the
accidental release provisions of section 112(r) of
the Clean Air Act. At the same time, follow-Lp
activities performed by several of the regional
offices indicate that the majority of the
recommendations to improve chemical process safety
practices suggested by the audit teams have been
implemented or are scheduled to be implemented at
audited facilities.
CSA PROGRAM BENEFITS
Identification of effective, field-proven
chemical accident prevention technologies and
practices.
Better understanding of the causes of chemical
releases.
Greater awareness by facilities of chemical
safety and understanding of available
techniques, and specific suggestions for
improved programs.
Identification of problem areas in industry
where more attention is needed.
Cooperation and coordination of chemical safety
programs with other federal and state agencies;
through joint audits and training.
For more information on the Chemical Safety Audit
program, contact the Chemical Emergency
Preparedness Program (CEPP) office in your EPA
regional office.
EPA Fact Sheet
Vlll
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CHEMICAL PROCESS HAZARDS
PERFORMANCE OBJECTIVES
At the end of this lesson, participants will be able to:
Describe chemical process hazards, including:
Overpressurization
Loss of flow
High level
High temperature
Improper mixing
Loss of containment.
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f
L
Chemical Process
Hazards
CHEMICAL HAZARDS
Flammability
Explosivity
Radioactivity
CHEMICAL HAZARDS (cont.)
Reactivity
Corrosivity
Toxicity
NOTES
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Chemical Process Hazards
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NOTES
PROCESS HAZARDS
Process variables
Process operations/design
PROCESS VARIABLES
Pressure
Flow
Level
Temperature
PRESSURE
Overpressure
Underpressure
Shock/stress - "water hammer"
Chemical Process Hazards
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FLOW
Fluctuating flow
Overflow
Underflow
Reversed flow
LEVEL
Overfilling
Underfilling
TEMPERATURE
High temperature
Low temperature
/VOTES
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Chemical Process Hazards
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NOTES
PROCESS
OPERATION/DESIGN
Mixing
Containment
Design
Human factors
MIXING
Uneven mixing
Loss of agitation
Vibration
CONTAINMENT
Loss of Containment
Overfilling tanks
Pump seal leaks
* Corrosion
Spills
Chemical Process Hazards
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DESIGN
Utilities failure
Control system failure
Underdesign/redesign
Natural disasters
HUMAN FACTORS
Human error
Terrorism
Revenge
AUDIT TEAM PERSPECTIVE
What hazards does the facility
recognize?
What value does the facility place on
perceived hazards?
How does the facility manage
hazards?
NOTES
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Chemical Process Hazards
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PROCESS SAFETY MANAGEMENT
PERFORMANCE OBJECTIVES
At the end of this lesson, participants will be able to:
Describe EPA's and industry's responses to major chemical
releases that occurred in the past
List the key elements of industry's chemical process safety
management system
Describe EPA's role in chemical process safety management.
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NOTES
PROCESS SAFETY
MANAGEMENT
CHEMICAL PROCESS SAFETY
MANAGEMENT
Chemical process safety
Chemical process safety management
EPA's role
CHEMICAL PROCESS SAFETY
Operation of facilities handling
hazardous materials in a manner
free from episodic or catastrophic
incidents
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Process Safety Management
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NOTES
MAJOR INCIDENTS
Fixborough, England (1974)
Mexico City, Mexico (1984)
Bophal, India (1984)
MAJOR INCIDENTS (cont.)
Chernobyl, USSR (1986)
Shell Norco Refinery, USA (1988)
Phillips Petroleum Refinery, USA
(1989)
EPA RESPONSE TO
MAJOR INCIDENTS
Chemical Emergency Preparedness
Program (1985)
SARA Title III (1986)
Process Safety Management
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NOTES
EPA RESPONSE TO
MAJOR INCIDENTS (cont.)
Clean Air Act (1988)
- Review of emergency systems
- Section 305(b)
- Accidental Release Information
Program
INDUSTRY'S RESPONSE
Community Awareness and
Emergency Response program
(CAER)
Center for Chemical Process Safety
CHEMICAL PROCESS
SAFETY MANAGEMENT
Management systems to identify,
understand, and control process
hazards to prevent incidents and
injuries
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Process Safety Management
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NOTES
KEY ELEMENTS
Management philosophy and goals
Process knowledge
Design
KEY ELEMENTS (cont.)
Process risk management
Management of change
Process and equipment integrity
KEY ELEMENTS (cont.)
Emergency preparedness and
planning
Human factors
Training
Process Safety Management
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NOTES
KEY ELEMENTS (cont.)
Incident investigation
Standards, codes, and laws
Audits and corrective action
Research
ESTABLISHING
MANAGEMENT SYSTEMS
Company policy and goals
Measures of performance
Incentives
Resource commitment
EPA's ROLE
Act as a catalyst
Provide guidance
Provide technical assistance
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Process Safety Management
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NOTES
EPA's ROLE (cont.)
Develop knowledge base
Encourage industry to improve
practices
Develop a regulatory program
(as needed)
Process Safety Management
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CHEMICAL SAFETY AUDIT
MANUAL REVIEW
PERFORMANCE OBJECTIVES
At the end of this lesson, participants will be able to:
Describe the background and authority for the Chemical
Safety Audit program
Describe EPA policy and procedures relative to:
Facility consent or invitation
Handling of confidential business information
Attorney-client privilege
Response actions
Relationship of chemical safety auditing to enforcement
and compliance with EPA regulatory programs
Describe the roles and responsibilities of chemical safety
audit team members
List seven actions that are required activities under the EPA
chemical safety audit program protocol.
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NOTES
CHEMICAL SAFETY
AUDIT
MANUAL REVIEW
GUIDANCE MANUAL FOR EPA
CSA TEAM MEMBERS
Revised June 1993
Purpose
Provides EPA policies and
procedures for implementing
the Chemical Safety Audit
(CSA) program
GUIDANCE MANUAL FOR EPA
CSA TEAM MEMBERS (cont.)
Contents
Introduction
Program authority under CERCLA
Role of audit team members
Preparing for the audit
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NOTES
GUIDANCE MANUAL FOR EPA
CSA TEAM MEMBERS (cont.)
Contents
Conducting the audit
Audit protocol/report preparation
guidance
Audit follow-up activities
SECTION 1: INTRODUCTION
Program background and overview
Required vs. recommended activities
CSA program fact sheet
SECTION 2: PROGRAM
AUTHORITY UNDER CERCLA
Statutory authority
Confidential information
Attorney-client privilege
Chemical Safety Audit Manual Review
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NOTES
PROGRAM AUTHORITY
UNDER CERCLA (cont.)
Response actions
Relationship to
enforcement/compliance
regulatory programs
STATUTORY AUTHORITY
CERLCA Sections 104(b) and 104(e)
as amended by SARA in 1986
Authority to EPA and designated
representatives
Authority not applicable to other
federal agencies and departments or
state and local governments
CONFIDENTIAL INFORMATION
Facilities can claim that information is
confidential under CERCLA Section
104(e)
EPA employees and authorized
representatives can access and view
confidential business information
under CERCLA
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Chemical Safety Audit Manual Review
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NOTES
ATTORNEY-GHENT PRIVILEGE
Facility may withhold information
based on attorney-client privilege
Procedures to follow
- Continue audit unless absence
of requested information makes
it impossible to do so
- Contact EPA's Office of
Regional Counsel (ORC)
ATTORNEY-CLIENT
PRIVILEGE (cont.)
Procedures to follow
- Provide ORC with
Name of document(s) withheld
Reason why document was
withheld
Facility attorney, address, and
telephone number
RESPONSE ACTIONS
If threat of release is observed during
audit, the following actions must be
taken:
- Regroup the team
- Inform facility
- If facility fails to appropriately
respond, contact the Regional
Response Center to determine
scope of action
Chemical Safety Audit Manual Review
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/VOTES
RESPONSE ACTIONS (cont.)
If release occurs at a facility:
- Follow facility procedures for
protection
- When and if appropriate, contact
National and/or Regional
Response Center
ENFORCEMENT/COMPLIANCE
REGULATORY PROGRAMS
EPA CSA is not an enforcement or
compliance inspection
Findings and recommendations are
not mandatory
Observed violations should be
referred to the respective program
office for further action
ROLE OF AUDIT
TEAM MEMBERS
Audit team composition
Training and safety requirements
Non-EPA audit team participation
Liability
Conflict of interest
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NOTES
AUDIT TEAM
COMPOSITION
Team composition considerations
- Size (3 - 6 members)
- Expertise
AUDIT TEAM
COMPOSITION (cont.)
Sample team
- Team leader
- Deputy team leader
- Chemical process hazards
reviewer
AUDIT TEAM
COMPOSITION (cont.)
Sample team
- Chemical accident prevention
reviewer
- Safety and training reviewer
- Emergency planning and response
reviewer
Chemical Safety Audit Manual Review
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NOTES
AUDIT TEAM
COMPOSITION (cont.)
Expertise and responsibilities
Team leader - leads site visit,
including logistics, team assignments,
liaison with facility personnel, and
quality assurance of site visit report
AUDIT TEAM
COMPOSITION (cont.)
Expertise and responsibilities
Deputy team leader- provides
logistical support and assumes
other responsibilities as directed
by the team leader
AUDIT TEAM
COMPOSITION (cont.)
Expertise and responsibilities
Chemical process hazards reviewer -
evaluates chemical hazards, process
engineering, and maintenance
procedures
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Chemical Safety Audit Manual Review
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NOTES
AUDIT TEAM
COMPOSITION (cont.)
Expertise and responsibilities
Chemical accident prevention
reviewer - evaluates hazard
assessment and modeling
techniques, release prevention
systems, and mitigation systems
AUDIT TEAM
COMPOSITION (cont.)
Expertise and responsibilities
Safety and training reviewer -
evaluates operator safety and
worker right-to-know training
programs
AUDIT TEAM
COMPOSITION (cont.)
Expertise and responsibilities
Emergency planning and response
reviewer - evaluates facility
emergency planning and response
procedures
Chemical Safety Audit Manual Review
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NOTES
AUDIT TEAM
COMPOSITION (cont.)
Select the appropriate mix of skills
- Process and safety system
technologies
- Operating procedures
- Training programs
- Management programs
Identify specific roles for each team
member
AUDIT TEAM
COMPOSITION (cont.)
Team member representatives
- EPA employees
- Technical Assistance Team (TAT)
members
- American Association of Retired
Persons (AARP) enrollees
- Other federal, state, and local
governments
AUDIT TEAM
COMPOSITION (cont.)
» Role of team members
- EPA employees - coordinate audit
program and lead audit team
- Contractors/TAT - provide
technical support as defined
by EPA
- AARP enrollees - provide
technical and general support role
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Chemical Safety Audit Manual Review
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NOTES
TRAINING AND SAFETY
REQUIREMENTS
Required for EPA team members
24- or 40-hour health and safety
course, in accordance with EPA
Order 1440.2
Site safety plan
Annual medical monitoring
EPA CSA training course
NON-EPA AUDIT TEAM
PARTICIPATION
Other federal, state, and local
agencies; State Emergency
Response Commission (SERC);
and Local Emergency Planning
Committees (LEPCs)
NON-EPA AUDIT TEAM
PARTICIPATION (cont.)
Authorized entry under applicable
federal, state, or local statutes
Support role
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NOTES
LIABILITY
Federal employees
- Federal Employees Liability
Reform and Tort Compensation
Act of 1988
- Suit can be brought against
the United States government
LIABILITY (cont.)
Contractors/TAT
- No coverage for audit activities
AARP enrollees
- No provisions currently exist
to indemnify AARP enrollees
from personal liability
Non-EPA personnel
- Require own liability coverage
CONFLICT OF INTEREST
All persons are prohibited from any
involvement with an audit if any of
the following situations exist:
Prior interest
Financial interest
Prior consultant
Other
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Chemical Safety Audit Manual Review
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NOTES
SECTION 4:
PREPARING FOR THE AUDIT
Facility selection
Facility notification
Facility background information
Site visit preparation
FACILITY SELECTION
Basic requirements
- Any facility that releases a
CERCLA hazardous substance,
pollutant, or contaminant or
any facility at which there
is a "reason to believe" that
a threat of such a release
exists
FACILITY SELECTION (cont.)
Basic requirements
- ORC and SERC/state have been
consulted to identify any
legal actions currently being
pursued or anticipated
Chemical Safety Audit Manual Review
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NOTES
FACILITY SELECTION (cont.)
Information sources
- National or Regional Response
Center
- Accidental Release Information
Program (ARIP)
- Emergency Response Notification
System (ERNS)
FACILITY SELECTION (cont.)
Information sources
- U.S. Coast Guard's Marine Safety
Office
- Federal Emergency Management
Agency (FEMA)
- Occupational Safety and Health
Administration (OSHA) and
National Institute of Occupational
Safety and Health (NIOSH)
FACILITY SELECTION (cont.)
Information sources
- SERC
- LEPCs
- State and local government
referrals
- Media reports and news clippings
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NOTES
FACILITY SELECTION (cont.)
Considerations
One hazardous substance
Facility type and size
Demographics
- Sensitive populations
- Highly populated areas
- High concentration of industry
FACILITY SELECTION (cont.)
Considerations
Catastrophic release of national
significance
Facility compliance and release
history
Natural disaster potential
Public sensitivity
FACILITY NOTIFICATION
Suggested activities
- Telephone call to facility
- Follow-up letter summarizing
telephone discussion
- Preaudit meeting
Available tools
- CSA manual
- Boilerplate letters
Chemical Safety Audit Manual Review
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NOTES
FACILITY BACKGROUND
INFORMATION
Obtain facility documents
- Material safety data sheets
- Facility layout maps
- Emergency response plans
- Standard operating procedures
Contact state and community (e.g.,
SERC, LEPCs)
SITE VISIT PREPARATION
Establish scope of audit (specific
team member responsibilities)
Identify health and safety issues
Establish objectives and agenda for
each day
SECTION 5:
CONDUCTING THE AUDIT
Entry
Opening meeting
Onsite activities
» Exit briefing
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NOTES
ENTRY
Team arrival at predetermined time
and place
Blank sign-in sheet vs. "waiver" or
"visitor release"
Facility revocation of consent to enter
OPENING MEETING
Meeting between audit team and key
facility personnel
Meeting agenda includes:
- Introductions of team and
facility personnel
- Overview of audit purpose and
scope
- Proposed procedures and
schedule
ONSITE ACTIVITIES
Plant tours
Assignment of specific tasks to
interview, review, and observe
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NOTES
EXIT BRIEFING
Meeting with team and facility
personnel
Summary of observations and
findings
SECTION 6: AUDIT PROTOCOL/
REPORT PREPARATION GUIDANCE
Protocol and report format
Report contents
Writing the report
Standard report disclaimer
SECTION 6: AUDIT PROTOCOL/
REPORT PREPARATION GUIDANCE
Review and finalization procedures
Report distribution
Report profile
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NOTES
PROTOCOL AND
REPORT FORMAT
Continuity in report preparation
Detailed guidance on the types of
information to review during the audit
and what should be present in the
final report
Report format organized for easy
access
REPORT CONTENTS
Facility information
Chemical and process hazard
information
Chemical accident prevention
REPORT CONTENTS (cont.)
Accidental release/incident
investigation
Emergency preparedness and
planning
Public alert and notification
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NOTES
WRITING THE REPORT
Postvisit Meeting
Team members
- Review and edit notes
- Use report outline to organize
notes and delegate writing
responsibilities
- Review observations and findings
- Determine recommendations
WRITING THE REPORT (cont.)
Tips on writing style
- Provide factual, relevant, complete,
objective, and clear information
- Refrain from judgments of
adequacy or inadequacy
» Follow-up information
- Pre-identify audit team member to
contact facility to clarify information
STANDARD REPORT
DISCLAIMER
Accompanies all audit reports and
follows cover page
Clarifies time frame, source of report,
contents, and limits of contents
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NOTES
REVIEW AND FINALIZATION
PROCEDURES
Approve as "Final" by designated EPA
official
Deny access to draft information
- "DRAFT"
- "Pre-decisional Document, Not
Disclosable Under FOIA"
- "Do Not Cite or Quote"
REPORT DISTRIBUTION
Standard distribution includes
- SERC and LEPC in which the
facility is located
- Facility chief executive officer
- EPA headquarters
- Other federal, state, and local
agencies that assisted in the audit
Public document
REPORT PROFILE
Prepare report profile as shown in
Attachments 11 and 12
Submit profile to EPA headquarters
with the final report
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NOTES
AUDIT FOLLOW-UP ACTIVITIES
Approaches
- Mail worksheets
- Revisit
Information required
- Name and address of facility
- List of recommendations
- Schedule of recommendations that
have been or will be implemented
AUDIT FOLLOW-UP
ACTIVITIES (cont.)
Information required
- Rationale for any
recommendations that
have not been implemented
- Facility attitude toward audit
- Successful and problematic
audit activities
7/93
21
Chemical Safety Audit Manual Review
-------
COMPUTER MODELING
PERFORMANCE OBJECTIVES
At the end of this lesson, participants will be able to:
Describe the applications of hazardous chemical release
modeling programs
Describe the limitations of hazardous chemical release
modeling programs
Describe, in general, the strengths and limitations of
CAMEO, CHARM, and SAFER
Describe emergency information programs using EIS as an
example
Describe the U.S. EPA Chemical Safety Audit database.
-------
NOTES
COMPUTER MODELING
COMPUTER MODELING
Applications for computer modeling
Limitations of modeling
Popular models
- Strengths
- Considerations
Facility viewpoint on modeling
APPLICATIONS FOR
COMPUTER MODELING
Hazards identification
Vulnerability analysis
Risk analysis
Emergency response planning
7/93
Computer Modeling
-------
NOTES
HAZARDS IDENTIFICATION
1 Facility and site data
1 Transportation and community data
1 Chemical data
VULNERABILITY ANALYSIS
Modeling releases
Establishing vulnerability zones
Running real-time models and
simulations
RISK ANALYSIS
Based on likelihood and severity
Ranking of hazards
Handling judgments and concerns
Computer Modeling
7/93
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NOTES
EMERGENCY
RESPONSE PLANNING
Assemble hazard, vulnerability, and
risk data
Facilitate community involvement
Use real-time models and simulations
LIMITATIONS OF MODELING
General
Technical
GENERAL LIMITATIONS
Garbage in - garbage out (GIGO)
Purchase and setup costs
Qualifications and training of
operators
Compatibility with other systems
7/93
Computer Modeling
-------
NOTES
TECHNICAL LIMITATIONS
Meteorology
Topography
Physical and chemical properties
Source strength and time of duration
POPULAR MODELS
Strengths and Limitations
CAMEO
CHARM
SAFER
CAMEO
(NOAA/EPA)
Capabilities
Chemical and response information
Modeling and mapping
Facility and community information
Reporting and recordkeeping
Computer Modeling
7/93
-------
NOTES
CAMEO (cont.)
Considerations
Operating cost
Appropriateness of air model
Compatibility with other systems
CHARM
(Radian Corp.)
Capabilities
Complex air release model
Chemical information
Plume isopleth drawing
Real-time input
CHARM (cont.)
Considerations
Map editing only
Technical expertise required
to operate
Difficulty with complex terrain
7/93
Computer Modeling
-------
NOTES
SAFER
(Dupont)
Capabilities
Release modeling and tracking
Material inventory and training
SAFER (cont.)
Considerations
Difficulty with buoyant cloud
releases
Difficulty with building wake
effects
MAINTENANCE AND
UPGRADES
Maintenance
- Chemical inventories
- Equipment changes
Upgrades
- Real-time applications
- Multiple users
Computer Modeling
7/93
-------
NOTES
FACILITY VIEWPOINT
ON MODELING
What model(s) have they chosen?
How well do these models meet their
needs?
FACILITY VIEWPOINT
ON MODELING (cont.)
What strengths and limitations are
evident?
What changes (if any) are planned
and why?
7/93
Computer Modeling
-------
PROCESS SAFETY: EQUIPMENT
PERFORMANCE OBJECTIVES
At the end of this lesson, participants will be able to:
Describe the purpose of process safety systems
Describe the functions of process safety systems designed for
prevention and process safety systems designed for
mitigation
Describe instrumentation and control systems and system
components
Describe prevention equipment used for physical separation
and containment
Describe prevention designs used for physical separation and
containment
Describe mitigation equipment used as barriers and
emergency shutdown systems
Describe mitigation designs used as barriers and emergency
shutdown systems.
-------
NOTES
PROCESS SAFETY:
EQUIPMENT
PROCESS SAFETY
Safety systems and equipment
Safety operations
SAFETY SYSTEMS
AND EQUIPMENT
Place process systems in a safe
condition
Protect workers
Protect facility
Protect environment
Meet codes, standards, and
regulations
7/93
Process Safety: Equipment
-------
NOTES
DESIGN
Prevention
- Designed to prevent an
accident
Mitigation
- Designed to minimize the
effects of an accident
PREVENTION
Instrumentation and control
Fail-safe components
Physical separation
Redundant components
Containment
INSTRUMENTATION
AND CONTROL
Pneumatic (air operated)
Electromechanical
Computer based
Process Safety: Equipment
7/93
-------
NOTES
INSTRUMENTATION
AND CONTROL (cont.)
Sonsors
Position indicators
Alarms
INSTRUMENTATION
AND CONTROL (cont.)
Safety/relief valves
Controllers
Distributed control systems
FAIL-SAFE COMPONENTS
Explosion-proof switches
Fail-safe valves
- Fail open
- Fail closed
- Fail as is
7/93
Process Safety: Equipment
-------
NOTES
PHYSICAL SEPARATION
Separated by
Distance
Walls
Doors
Inert gas
REDUNDANT COMPONENTS
Backup pumps
DC (battery) backup for AC controls
(essential service systems)
CONTAINMENT
Double-walled vessels
Sealed compartments
Containment walls, berms, and dikes
(mitigation)
Fire seals
(mitigation)
Process Safety: Equipment
7/93
-------
NOTES
MITIGATION
Barriers
Emergency shutdown systems
Site selection
BARRIERS
Flare towers
Water curtains
Scrubbers
EMERGENCY
SHUTDOWN SYSTEMS
Systems that activate to place a
process, a process unit, or an
entire facility in the safest possible
condition
7/93
Process Safety: Equipment
-------
NOTES
EMERGENCY
SHUTDOWN SYSTEMS (cont.)
Independent from process system
On-line testing capabilities
Manual or automatic operation
Highly reliable
SITE SELECTION
Proximity to sensitive ecosystems
Meteorology
Topography and seismology
Availability and reliability of utilities
RELATIONSHIP TO CHEMICAL
SAFETY AUDITS
What hazards has the facility
identified?
What actions has the facility taken to
prevent or mitigate chemical
releases?
Process Safety: Equipment
7/93
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PROCESS SAFETY: OPERATIONS
PERFORMANCE OBJECTIVES
At the end of this lesson, participants will be able to:
List five facets of facility operations that should be reviewed
during a chemical safety audit
List three major sections of standard operating procedures
Describe the purpose of lockout/tagout, hot work permit, and
confined space entry procedures
Describe the four major steps used in emergency planning.
-------
NOTES
PROCESS SAFETY:
OPERATIONS
FACILITY OPERATIONS
Management
Operating procedures
Emergency planning
Maintenance
MANAGEMENT
Design control/configuration control
Control of change
Information flow
Safety-conscious culture
7/93
Process Safety: Operations
-------
NOTES
OPERATING PROCEDURES
Standard operating procedures
Availability of materials
Lockout/tagout
Confined space entry
STANDARD
OPERATING PROCEDURES
Startup and shutdown
Loading and unloading
Normal operations
AVAILABILITY
OF MATERIALS
Procedures
Piping and instrumentation diagrams
(P&IDs)
Material safety data sheets
Process Safety: Operations
7/93
-------
NOTES
LOCKOUT/TAGOUT
OSHA 1910.147
Isolation
Lockout
Controlling energy
CONFINED SPACE ENTRY
OSHA 1910.146
Permit required
Permit system
Training
Hot work permits
EMERGENCY PLANNING
Preplanned response procedures
Protective actions
Drills and exercises
Accident assessment
7/93
Process Safety: Operations
-------
NOTES
PREPLANNED
RESPONSE PROCEDURES
Emergency operating procedures
- Properly integrated
- Really used
Notification procedure
Community involvement
PROTECTIVE ACTIONS
Shelter
Evacuation
DRILLS AND EXERCISES
Tabletop exercises
Simulations
Community involvement
Process Safety: Operations
7/93
-------
NOTES
ACCIDENT ASSESSMENT
Identification
Analysis
Corrective actions
MAINTENANCE
Maintenance procedures
Routine testing and inspections
Preventive maintenance
Predictive maintenance
AUDIT TEAM PERSPECTIVE
Understand how the process works
Capacities and design conditions
Construction materials
Variables monitored, controlled,
and recorded
Chemical production rates and use
rates
7/93
Process Safety: Operations
-------
NOTES
AUDIT TEAM
PERSPECTIVE (cont.)
Identify prevention and mitigation
elements
Identify possible hazards or
hazardous situations
QUESTIONS TO ASK
What hazards has the facility
identified?
What actions has the facility taken to
deal with the hazards?
Why has the facility taken the actions?
QUESTIONS TO ASK (cont.)
What effective safety measures
are used by the facility?
Are there any possible
improvements?
- From other facilities?
- From observations during the
audit?
Process Safety: Operations
7/93
-------
HAZARD AND RELEASE MITIGATION
PERFORMANCE OBJECTIVES
At the end of this lesson, participants will be able to:
Describe how hazard and release mitigation are taken into
account for each of the following:
Compatibility
Warning signs and labels
Facility layout
List four ways of reducing hazardous materials in a chemical
plant
List eight types of equipment used in chemical plants to
mitigate hazards and releases
List five operational activities that are examples of proactive
hazard mitigation
-------
NOTES
HAZARD AND RELEASE
MITIGATION
HAZARD AND
RELEASE MITIGATION
Facility design
Hazardous materials reduction
Mitigation equipment
Mitigation operations
Areas for review
FACILITY DESIGN
Compatibility
- Equipment and process chemicals
- Equipment and process conditions
- Process chemicals with each other
- Replacement parts
7/93
Hazard and Release Mitigation
-------
NOTES
FACILITY DESIGN (cont.)
Warning signs and labels
- Hazards clearly marked
- NFPA fire diamond and HMIS
- Color coding
FACILITY DESIGN (cont.)
Facility layout
- Separation
- Isolation
- Sensitive populations
HAZARDOUS MATERIALS
REDUCTION
Reduce inventories
- Raw materials
- Finished products
- Shipping and receiving
Hazard and Release Mitigation
7/93
-------
NOTES
HAZARDOUS MATERIALS
REDUCTION (cont.)
Reduce transfers
- Small or large releases
- Aggregate or bulk storage
HAZARDOUS MATERIALS
REDUCTION (cont.)
Substitute less hazardous chemicals
Reduce hazardous chemical
concentration
MITIGATION EQUIPMENT
Alarms
- Alert; follow with reactive mitigation
- Emergency alarms
Controls
- Automatic controls
- Activated controls
Connections
- "Murphy" connections
7/93
Hazard and Release Mitigation
-------
NOTES
MITIGATION
EQUIPMENT (cont.)
Flares
Scrubbers
Water curtains
Flame arresters
Explosion isolation devices
MITIGATION OPERATIONS
Prevent releases if possible
Mitigate releases that occur
MITIGATION
OPERATIONS (cont.)
Operational activities
- Standard operating procedures
(SOPs)
- Standard maintenance procedures
- Process inspections
- Security
- Emergency procedures
Hazard and Release Mitigation
7/93
-------
NOTES
AREAS FOR REVIEW
Design
Is the process equipment suitable for
its use?
Is the process equipment compatible
with other equipment, process
chemicals, and process conditions?
AREAS FOR REVIEW
Design (cont.)
Are replacement parts compatible
with process equipment?
Are warning signs and labels posted,
easy to read, and accurate?
AREAS FOR REVIEW
Design (cont.)
Are hazardous chemicals separated
or isolated from incompatible
chemicals?
Are hazardous chemicals separated
from sensitive populations?
7/93
Hazard and Release Mitigation
-------
NOTES
AREAS FOR REVIEW
Reduction
Can raw material or product
inventories be lowered?
Can the number of hazardous material
transfers be reduced? Is it wise to
reduce them?
AREAS FOR REVIEW
Reduction (cont.)
Would aggregate storage lead to
smaller releases?
Can less hazardous chemicals be
substituted?
Can hazardous chemical
concentrations be reduced?
AREAS FpR REVIEW
Equipment
What kinds of mitigative alarms and
controls are in use? Are they effective
and appropriate?
What other kinds of mitigative
equipment are in use? Is the
equipment effective and appropriate?
Hazard and Release Mitigation
7/93
-------
NOTES
AREAS FOR REVIEW
Operations
Is prevention and mitigation stressed
in facility policies and procedures?
Is prevention and mitigation
consistent throughout the facility's
documentation?
INFORMATION SOURCES
Facility practices
- Facility release history
- Process inspections
- Hazards analyses
- Procedures manuals
- Facility diagrams (P&IDs, etc.)
INFORMATION
SOURCES (cont.)
Mitigation recommendations
- Past experience
- Previous audits
- Facility personnel
7/93
Hazard and Release Mitigation
-------
MAINTENANCE PROCEDURES AND
TRAINING REQUIREMENTS
PERFORMANCE OBJECTIVES
At the end of this lesson, participants will be able to:
List four training requirements that are critical for a safe
workplace
Define three types of preventive maintenance
List three critical elements of performance-based training
Define job/task analysis
Define needs analysis and its three essential components
Describe each of the following types of emergency training:
1. Evacuation training
2. Emergency response training
3. Hazardous materials (HAZMAT) training.
-------
NOTES
MAINTENANCE
PROCEDURES
AND
TRAINING
REQUIREMENTS
MAINTENANCE PROCEDURES
Repair procedures
Preventive maintenance
Lockout/tagout
MAINTENANCE
PROCEDURES (cont.)
Confined space entry
Hot work permits
Management of change
7/93
Maintenance Procedures
-------
NOTES
REPAIR PROCEDURES
Types of maintenance
- Mechanical
- Pipe fitting
- Welding/boilermaking
- Electrical
- Instrumentation and control
REPAIR PROCEDURES (cont.)
Sources of procedures
- Written procedures
- Technical manuals
- Equipment manuals
PREVENTIVE MAINTENANCE
Periodic maintenance
Preventive maintenance
Predictive maintenance
Maintenance Procedures
7/93
-------
NOTES
LOCKOUT/TAGOUT
29 CFR 1910.147
Isolation (control of energy)
- Disconnect
- Block
- Blind
Immobilization
Group lockout/tagout
LOCKOUT/TAGQUT (cont.)
29 CFR 1910.147
Training
Written procedures
- Standard procedures
- Inspections
- Documentation
CONFINED SPACE ENTRY
29 CFR 1910.146
Written permit
Hazards monitoring
Protective equipment
7/93
Maintenance Procedures
-------
NOTES
HOT WORK PERMITS
Written permit
Flammable atmospheres
Protective equipment
MANAGEMENT OF CHANGE
29CFR119
Technical basis for change
Impact on safety and health
Modifications to SOPs
MANAGEMENT OF
CHANGE (cont.)
29CFR119
Necessary time period for the change
Authorization requirements
Maintenance Procedures
7/93
-------
NOTES
TRAINING REQUIREMENTS
Performance-based training
Hazard communication training
Emergency response training
Contractor training
PERFORMANCE-BASED
TRAINING
» Job/task analysis
Training needs assessment
Performance-based objectives
JOB/TASK ANALYSIS
Job/task based
Skills criteria
Knowledge criteria
7/93
Maintenance Procedures
-------
NOTES
TRAINING NEEDS
ASSESSMENT
Employee based
Skills levels
Knowledge levels
PERFORMANCE-BASED
OBJECTIVES
Compare criteria to levels
Identify deficiencies
Develop training objectives
HAZARD COMMUNICATION
TRAINING
29 CFR 1910.1200
Identify hazardous materials
Acquire information
- Marking and labeling
- Material safety data sheets
Establish training objectives
Maintenance Procedures
7/93
-------
NOTES
EMERGENCY RESPONSE
TRAINING
Evacuation training - 29 CFR
1910.38(a)
Emergency response training - 29
CFR 1910.120
- Awareness level
- Operations level
EMERGENCY RESPONSE
TRAINING (cont.)
Hazardous materials (HAZMAT)
training
- Technician
- Specialist
- Incident commander
AREAS FOR REVIEW
Maintenance
Training
7/93
Maintenance Procedures
-------
NOTES
MAINTENANCE
Accuracy
Effectiveness
Safety
MAINTENANCE
Accuracy
Are procedures written for existing
equipment?
Are manufacturers' suggested
procedures being used?
MAINTENANCE
Effectiveness
Is type of maintenance supported by
documentation?
Have investigation recommendations
been implemented?
Maintenance Procedures
7/93
-------
NOTES
MAINTENANCE
Safety
Are lockout, confined space, and hot
work procedures in place, used, and
documented?
Is maintenance included in safety
training?
TRAINING
Planning
Materials
Application
TRAINING
Planning
Does training meet job requirements
and staff needs?
Does training meet applicable safety
requirements?
7/93
Maintenance Procedures
-------
NOTES
TRAINING
Materials
Are training materials up to date?
Are training materials at proper
educational level?
TRAINING
Application
Is training documentation up to date?
Have results of inspections been
included in training?
Maintenance Procedures
10
7/93
-------
CONDUCTING INTERVIEWS
PERFORMANCE OBJECTIVES
At the end of this lesson, participants will be able to:
Describe the role of interviewing in chemical safety auditing.
List two incentives and two disincentives for interviewee
participation
Describe interviewing techniques that establish style and
climate
-------
/VOTES
CONDUCTING
INTERVIEWS
INTERVIEWING
One-way process
Two-way process
INTERVIEWER/INTERVIEWEE
RELATIONSHIP
Trusted
Feared
Respected
Beneficial
7/93
Conducting Interviews
-------
NOTES
CSA INTERVIEWS
Incentives to participate
- Personal safety
- Self worth
- Personal goals
Disincentives to participate
- Looking foolish
- Retaliation
INTERVIEWS
Style
- Lawyer - Perry Mason
- Sensationalizer - Geraldo Rivera
- Accuser - Mike Wallace
- Friend - Barbara Walters
Climate
- Intimidating (threatening)
- Nonthreatening
RESPONSES TO QUESTIONS
CONCERNING MISTAKES
Minimize the problem
Blame someone else
Emphasize the improbability of the
mistakes
Conducting Interviews
7/93
-------
NOTES
RESPONSES TO QUESTIONS
CONCERNING MISTAKES (cont.)
Be defensive
Say the problem has already been
corrected
Protest being unfairly singled out
HOW DO YOU GET PEOPLE TO
SHARE INFORMATION?
Be empathetic
Let them save face
Be nonthreatening
Praise them
HOW DO YOU GET PEOPLE TO
SHARE INFORMATION? (cont.)
Show appreciation when they share
information
Start with easy questions
Make questions easy to answer
7/93
Conducting Interviews
-------
NOTES
PHRASING THE QUESTION
In what ways do you think your
present safety features are
inadequate?
1 What do you think are the best
aspects of your current safety
procedures? How do you think the
procedures could be improved?
BEGINNING THE INTERVIEW
Set the climate
Explain the purpose
Introduce everyone
RECORDING AN INTERVIEW
Take notes
Tape record the interview
Assign a note taker
Write or record from memory
immediately after the interview
Conducting Interviews
7/93
-------
NOTES
DURING THE INTERVIEW
Types of Questions
Open-ended
Close-ended
Probing
Mirror
Loaded or leading
AFTER THE INTERVIEW
Thank the interviewee
Review notes
Ask follow-up questions
7/93
Conducting Interviews
-------
INCIDENT INVESTIGATION
PERFORMANCE OBJECTIVES
At the end of this lesson, participants will be able to:
Define root cause, primary effect, cause-and-effect chain,
culture, and climate
Describe root cause analysis, cause tree analysis, barrier
analysis, change analysis, and personnel performance
analysis.
-------
INCIDENT
INVESTIGATION
ROOT CAUSE
Definition
Root cause
The cause that, if removed, will prevent the
primary effect
Primary effect
The effect or problem you are trying to
prevent
CAUSE-AND-EFFECT CHAIN
Cooling"
water
valve
fails
r^iin,-, X V Runaway"
a, 9A Rector A reaction-
water ' ' heats upl J Reactor
stops
Root .:. Effect/ :.. Effect/
Cause""'*" cause
explodes
Primary
Effect
NOTES
7/93
Incident Investigation
-------
NOTES
ROOT CAUSE CRITERIA
Prevent recurrence
Meet facility's goals
Within facility's control
SOURCES OF CAUSE
The source of all causes is design
error
The source of all causes is human
error
The source of all causes is nature
SOURCES OF CAUSE (cont.)
Assigning all causes to one source
prevents workable solutions
Incident Investigation
7/93
-------
NOTES
BASIC ELEMENTS
OF ANALYSIS
Define the problem
Collect information
Perform analysis
Verify results
DEFINING THE PROBLEM
What is the problem?
When did it happen?
- Relative to time
- Relative to other parts of the
problem
DEFINING THE
PROBLEM (cont.)
Where did it happen?
- Physical location
- Relative to associated components
What is the significance?
- Relative to the goals of the facility
7/93
Incident Investigation
-------
NOTES
CAUSE-AND-EFFECT CHAIN
Cooling'
water
valve
fails
^-^
Root
Cause*
Cooling,
water
stops
Effect/
cause *
Reactor
heats up\
Effect/
''cause*
Runaway1*1
reaction-
Reactor
explodes
Primary
Effect
DEFINING THE PROBLEM
What is the problem?
A reactor overheated and exploded
When did it happen?
When the pneumatic cooling water
valve failed and moved to the "closed"
position
Incident Investigation
7/93
-------
NOTES
DEFINING THE
PROBLEM (cont.)
When did it happen?
The cooling water valve failed when
the instrument air supply line to the
valve broke
Where did it happen?
At the cooling water valve controller
DEFINING THE
PROBLEM (cont.)
What is the significance?
The instrument air supply line for the
cooling water valve broke
The cooling water valve moved to the
closed position
COLLECT INFORMATION
Evidence Preservation Checklist
Hardware
- Equipment
- Tools
- Materials (removed and installed)
7/93
Incident Investigation
-------
NOTES
COLLECT
INFORMATION (cont.)
Hardware
- Location and placement of objects
- Environmental factors (noise, heat,
etc.)
Note: Hardware evidence should be
preserved "as found" if possible
COLLECT
INFORMATION (cont.)
Documentation
Regulations and orders
Procedures
Work instructions
Photographs
COLLECT
INFORMATION (cont.)
Documentation
Design drawings
Operator logs
Charts/computer records
Maintenance records
Incident Investigation
7/93
-------
NOTES
COLLECT
INFORMATION (cont.)
Personnel
- Personnel statements
- List of involved people
- Work history
Chronology of events
PERFORM ANALYSIS
For best results, use two or more
analytical techniques
Use cause and effect as one
technique
Write the summary as cause and
effect, starting with the primary effect
PERFORM ANALYSIS (cont.)
Cause-and-effect analysis
Cause tree analysis
Barrier analysis
Change analysis
Personnel performance analysis
7/93
Incident Investigation
-------
NOTES
CAUSE-AND-EFFECT
ANALYSIS
The reactor overheated and exploded
because cooling water flow stopped,
which was caused by the cooling water
valve closing, which was caused
by 1) the instrument air supply line
breaking and 2) the valve being
installed in the fail closed position
CAUSE TREE ANALYSIS
Cooling Water Valve Failed Closed
Design
Maintenance
Inspection
Valve designed to fail
closed
Valve installed to fail
closed
No one noticed that the
valve was fail closed
BARRIER ANALYSIS
No one noticed the fail closed valve
Not in the inspection procedure
- Problem: Improper procedure
In procedure, but not checked
- Problem: Lack of knowledge
(training)
- Problem: Lack of time
(management policy)
Incident Investigation
7/93
-------
NOTES
CHANGE ANALYSIS
The instrument air supply line broke
We replaced the supply line
6 months ago
We had to reroute it around the
new "H" beam
CHANGE ANALYSIS (cont.)
Investigation shows that vibration
between the supply line and the "H"
beam caused wear
The line wore through and ruptured
PERSONNEL
PERFORMANCE ANALYSIS
Used exclusively for "people
problems"
Requires a solid understanding of
human nature
Helpful in identifying culture and
climate
7/93
Incident Investigation
-------
NOTES
CULTURE AND CLIMATE
Culture is the sum of organizational
attitudes as expressed by behavior,
decisions, and beliefs
Climate is the working environment
that results from management policies
and actions
CULTURE AND CLiMATE (cont.)
A direct result of management style
Often a major source of root causes
Established within the first 1 or 2
years
PROBLEM CLIMATES
Broke/fix
"If it ain't broke, don't fix it"
Regulatory fixation
"I don't care if it's wrong, the regulator
said to do it"
Not made here
"What do they know? We've got our
own experts"
Incident Investigation
10
7/93
-------
NOTES
PROBLEM CLIMATES (cont.)
Management by fear
"Just do what you're told"
Blame someone
"He really fouled up"
Shoot the messenger
"I'm not going to tell them it didn't
work"
CULTURAL CHANGES
Major reorganization of top level
management is usually the only way
cultural changes occur
VERIFY ROOT CAUSE
Verify that the corrective action will
actually prevent recurrence
Verify that the corrective action is
commensurate with the stated root
cause
7/93
11
Incident Investigation
-------
NOTES
FALSE ROOT CAUSES
"The root cause was human error"
Human error is a category, not a cause
(it is too broad)
FALSE ROOT CAUSES (cont.)
"The root cause was bearing failure"
This statement stopped too soon.
Why did the bearing fail?
ROOT CAUSE CATEGORIES
Personnel performance problems
Rules known but not used
Lack of attention
Inadequate communication
Inadequate training
Incident Investigation
12
7/93
-------
NOTES
ROOT CAUSE
CATEGORIES (cont.)
Rule problems
Not defined
Incomplete
Incorrect
Not enforced
ROOT CAUSE
CATEGORIES (cont)
Hardware problems
Design deficiency
Manufacturing deficiency
Installation deficiency
Note: Wearout and/or maintenance are
NOT root causes
MAXIMS OF ROOT CAUSE
If you do not find and correct the root
cause, you are doomed to repeat it
If you repeat a problem, by definition
you have a programmatic deficiency
7/93
13
Incident Investigation
-------
NOTES
MAXIMS OF
ROOT CAUSE (cont.)
Satisfying the need to be needed will
prevent more personnel problems
than any other act
The essence of root cause analysis is
to think cause and effect
Incident Investigation
14
7/93
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HAZARD EVALUATION
PERFORMANCE OBJECTIVES
At the end of this lesson, participants will be able to:
Define the following hazard evaluation/analysis terms:
Hazards
Accidents
Consequences
Probability
Frequency
Likelihood
Risk
Describe the uses, advantages, and disadvantages of process
safety checklists
Describe the uses, advantages, and disadvantages of safety
reviews/audits
Describe the uses, advantages, and disadvantages of
preliminary hazard analyses.
-------
NOTES
HAZARD EVALUATION
HAZARD EVALUATION
Identifies and describes hazards and
hazard scenarios
Estimates the likelihood and
consequences of hazard scenarios
Establishes relative risks of hazards
Suggests approaches to risk
reduction
HAZARD EVALUATION (cont.)
Definitions
Techniques
- Checklist
- Safety review
- Preliminary hazards analysis
7/93
Hazard Evaluation
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NOTES
DEFINITIONS
Hazards
- Unsafe acts or conditions that
create the potential for an
accident with undesirable
consequences
DEFINITIONS (cont.)
Hazards
- Loss of containment of flammable,
combustible, highly reactive, or
toxic materials
- Uncontrolled electrical hazards or
mechanical overpressure
DEFINITIONS (cont.)
Accident
- Unplanned sequence of events
that has an undesirable
consequence
Consequence
- The impact of the accident in
terms of the effects on people,
property, or environment
Hazard Evaluation
7/93
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NOTES
DEFINITIONS (cont.)
Probability
- The statistical chance of an
event occurring in a given
period of time
Frequency
- The number of occurrences per
unit of time
DEFINITIONS (cont.)
Likelihood
- Probability or frequency
Risk
- A measure of potential human
injury, economic loss, or
environmental impact in terms of
its likelihood and consequences
CHECKLIST
Simple to implement
Covers questions about design and
operation
Designs questions with "yes" or "no"
answers
Identifies common hazards to ensure
compliance
7/93
Hazard Evaluation
-------
NOTES
CHECKLIST (cont.)
Applies to equipment, materials, or
procedures associated with facility
changes
Does not help identify new or
unrecognized hazards
Prepared by experienced engineer
CHECKLIST (cont.)
Requires knowledge of system/facility
and SOPs
Used during any stage of a project
Should be audited and updated
regularly
CHECKLIST
Advantages
Easy to use
Gives quick results
Level of detail can be varied
Communicates information well
Hazard Evaluation
7/93
-------
NOTES
CHECKLIST
Disadvantages
Limited to author's experience
Repetition can lead to errors
Provides minimum level of hazard
evaluation
SAFETY REVIEW
Formal onsite examination of facility
Simple to implement
Identifies facility conditions or
operating procedures that could lead
to an accident
SAFETY REVIEW (cont.)
Reviews major risk situations, not
general housekeeping
Output consists of recommendations
and justifications for needed actions
7/93
Hazard Evaluation
-------
NOTES
SAFETY REVIEW (cont.)
Includes interviews with operators,
maintenance staff, engineers, and
management
Can use other techniques, such as
checklists and fault trees
SAFETY REVIEW (cont.)
Input should include applicable codes
and standards; PFDs; P&IDs;
procedures; maintenance, inspection,
and testing records; and process
material characteristics
May take several people 1 week or
more
SAFETY REVIEW
Advantages
Studies actual equipment and
operating procedures
Sensitizes facility staff to hazard
awareness
Hazard Evaluation
7/93
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NOTES
SAFETY REVIEW
Disadvantages
Method lacks formal structure
Reviewers need to be experienced
PRELIMINARY HAZARDS
ANALYSIS (PHA)
Formal in its implementation
Originally developed to identify
hazards during early design
Focuses on hazardous materials and
major plant systems
PHA (cont.)
Developed by creating a list of
hazards related to materials,
equipment, and operating
environment
Identify the hazard
- List the potential cause and effect
- List possible corrective or
preventive measures
7/93
Hazard Evaluation
-------
NOTES
PHA (cont.)
Requires input data such as unit
design criteria and standards,
and equipment and material
specifications
Prioritizes system for more detailed
analysis
PHA (cont.)
Advantages
- Safety engineers can perform
task quicker
- Provides early identification
of hazards
Disadvantage
- Will not provide a detailed
hazard analysis
Hazard Evaluation
7/93
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HAZARD EVALUATION TECHNIQUES
PERFORMANCE OBJECTIVES
At the end of this lesson, participants will be able to:
Describe "What If analysis
Describe HAZOP studies
Describe FMECA
Describe fault tree analysis
Describe event tree analysis.
-------
NOTES
HAZARD EVALUATION
TECHNIQUES
HAZARD EVALUATION
"What If" analysis
HAZOP studies
FMECA
Fault tree analysis
Event tree analysis
"WHAT IF" ANALYSIS
Examines possible deviations from:
- Design
- Construction
- Modification
- Operating intent
7/93
Hazard Evaluation Techniques
-------
NOTES
"WHAT IF" ANALYSIS (cont.)
Questions
- What if Pump A stops running?
- What if the operator opens
Valve B instead of Valve A?
"WHAT IF" ANALYSIS (cont.)
Used to identify
- Hazards
- Hazards scenarios
- Consequences
- Methods of risk reduction
Loose structure - concept adapted to
specific application
"WHAT IF" ANALYSIS (cont.)
Questions from previous analyses are
used as a guide
Questions are almost invariably added
as analysis proceeds
Commonly used to examine proposed
changes to an existing facility/unit
Hazard Evaluation Techniques
7/93
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NOTES
"WHAT IF" ANALYSIS (cont.)
Analyzes materials, products,
operating procedures, and
management practices
Questions usually start with the inputs
to the process and follow their flow
"WHAT IF" ANALYSIS (cont.)
Input information
- Facility/unit documentation
- Process documentation
- Operating procedures
- Operations interviews
- Maintenance interviews
Users should be experienced
"WHAT IF" ANALYSIS (cont.)
Advantages
- Easy to use
- Flexible
Disadvantages
- Loose structure
- Results depend on users'
experience
7/93
Hazard Evaluation Techniques
-------
NOTES
HAZARDS AND OPERABILITY
(HAZOP) STUDIES
More structured than "What If"
analysis
Description
- Multidisciplinary team
- Deviations from design intent
- Brainstorming
HAZOP STUDIES (cont.)
Description
- Systematically guided through
facility/unit design
- Structure provided by "guide
words"
HAZOP STUDIES (cont.)
Results include
Identification of hazards
Operability problems
Recommended changes to improve
safety
Hazard Evaluation Techniques
7/93
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NOTES
HAZOP STUDIES (cont.)
Deviations are shown by applying
guide words to process parameters at
nodes (processing points)
For each deviation, the team identifies
credible causes and significant
consequences
HAZOP STUDIES (cont.)
Guide words
No
More
Less
As well as
Part of
Reverse
Than
HAZOP STUDIES (cont.)
Parameters
Flow
Pressure
Temperature
Level
7/93
Hazard Evaluation Techniques
-------
NOTES
HAZOP STUDIES (cont.)
Nodes
Main feed pumps
Reactor
Reactor Feed A
Reactor cooling water
HAZOP STUDIES (cont.)
HAZOP studies are performed in team
meetings
Nodes are specified by the team
leader before the meeting
(example: cooling water flow)
HAZOP STUDIES (cont.)
Guide words applied
- No cooling water flow
- More cooling water flow
- Less cooling water flow
- Part of cooling water flow
The focus is problem identification,
not necessarily problem solution
Hazard Evaluation Techniques
7/93
-------
NOTES
HAZOP STUDIES (cont.)
Advantages
- Provides greatest assurance
that all hazards have been
identified
- Can provide both hazard and
operability information
HAZOP STUDIES (cont.)
Disadvantages
- Effort involved can be significant
- Effort is proportional to complexity
of facility/unit and depth of detail
FAILURE MODES, EFFECTS,
AND CRITICALITY ANALYSIS
FMECA
Tabulates
- Facility/unit equipment
- Equipment failure modes
- Result of failure
- Modes that contribute to accidents
- Criticality ranking of accident
(likelihood + severity)
7/93
Hazard Evaluation Techniques
-------
NOTES
FMECA (cont.)
Advantage
- Systematic, element by element
procedure that helps ensure
completeness
FMECA (cont.)
Disadvantages
- Not efficient at identifying
combinations of equipment
failures
- Human errors are not usually
examined
FAULT TREE ANALYSIS
Formal, deductive technique that
focuses on one particular incident
(top event)
Graphically displays combinations of
equipment failures and human errors
that result in an accident
Hazard Evaluation Techniques
7/93
-------
NOTES
FAULT TREE ANALYSIS (cont.)
Can be used to determine the basic
cause(s) of an incident
Can be used to estimate the
likelihood of an incident
Requires a complete understanding of
system function, failure modes, and
their effects
AND Gate
[ Fault Event
FAULT TREE ANALYSIS (cont.)
Advantages
- Thorough
- Systematic
Disadvantages
- Binary (not efficient at identifying
failures with more than two inputs)
- Can be time consuming
7/93
Hazard Evaluation Techniques
-------
NOTES
EVENT TREE ANALYSIS
Formal, inductive technique that
focuses on a sequence of events that
leads to an incident
Considers the response of operators,
safety systems, etc., to an initiating
event
Produces chronological sets of
failures that define an incident
Operator shutdown
Reactor temp
alarm alerts
Loss of °Pe'ator
cooling B
water
(Initiating
Event)
Failurel
restarts system
cooling stops
water reaction
C D
r
L
r
L
A
AC
ACD
AB
ABD
EVENT TREE ANALYSIS (cont.)
Advantages
- Graphical, systematic
representation
- Easy to perform
- Easy to understand
Disadvantage
- Binary representation of failures
Hazard Evaluation Techniques
10
7/93
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EMERGENCY RESPONSE
PERFORMANCE OBJECTIVES
At the end of this lesson, participants will be able to:
List four key elements of an emergency action plan
Describe three types of emergency evacuation plans
Describe each of the following key elements comprising an
emergency response plan:
1. Safe distances
2. Site security and control
3. Evacuation routes and procedures
4. Emergency medical treatment
5. Alerting and response procedures
6. Critique and follow-up
7. PPE and emergency equipment
8. Medical surveillance
9. Training
List three events that initiate reporting requirements for
emergency response actions
Define reportable quantity.
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NOTES
EMERGENCY RESPONSE
EMERGENCY RESPONSE
Emergency action plans
29CFR1910.38(a)
Emergency response plans
29 CFR1910.120/SARA Title III
Release notification
Areas for auditor review
EMERGENCY ACTION PLANS
For evacuation only
(outside agencies handle the
response)
Written plan
(if more than 10 employees)
Covers all reasonably expected
emergencies
7/93
Emergency Response
-------
NOTES
ACTION PLAN ELEMENTS
Account for all employees
Assign rescue and medical duties
List personnel to be contacted for
further information
Include types of evacuations
TYPES OF
EVACUATION PLANS
Full and immediate evacuation
Nonessential personnel evacuation
Partial evacuation
(e.g., locally contained fires)
SAFE REFUGES
Inside the facility
(protected interior or exterior areas)
Offsite evacuations
Emergency Response
7/93
-------
NOTES
ALARMS
29 CFR 1910.165
Perceivable
(audible and/or visible)
Distinctive
Established activating procedure
Operational at all times
TRAINING FOR EVACUATION
Train designated personnel to assist
in evacuation
Review the evacuation plan
- When the plan is developed
- Whenever the employee's actions
change
- Whenever the plan changes
REQUIREMENTS FOR
EMERGENCY ACTION PLANS
Shall be kept in the workplace
Shall be available for employee review
Shall include handling small releases
(handled by employees in the
immediate area of the release - is
NOT an emergency response)
7/93
Emergency Response
-------
NOTES
EMERGENCY
RESPONSE PLANS
Safe distances
Site security and control
Evacuation routes and procedures
Decontamination procedures
EMERGENCY
RESPONSE PLANS (cont.)
Emergency medical treatment
Alerting and response procedures
Critiques and follow-up
- Proactive critiques
- Plan reviews
- Actual responses
EMERGENCY
RESPONSE PLANS (cont.)
Personal protective equipment (PPE)
and emergency equipment
Medical surveillance
Training
Emergency Response
7/93
-------
NOTES
TRAINING
Responder awareness level
- Emergency recognition
- Alarm activation
- PPE and emergency equipment
TRAINING (cont.)
Responder operations level
- Hazards and risk assessment
- Control and containment
- Decontamination
- SOPs and termination procedures
HAZMAT TRAINING
Emergency response personnel
Technician
Specialist
Incident commander
7/93
Emergency Response
-------
NOTES
REPORTING REQUIREMENTS
Hazardous substances
Extremely hazardous substances
Exposures beyond facility boundaries
HAZARDOUS SUBSTANCES
Reportable quantities
40 CFR Table 302.4
Reported to the National Response
Center
EXTREMELY HAZARDOUS
SUBSTANCES
Reportable quantities
40 CFR 355 Appendices A and B
Reported to:
- National Response Center
- LEPC Emergency Coordinator
- SERC
Emergency Response
7/93
-------
/VOTES
EXPOSURES BEYOND
FACILITY BOUNDARIES
Chemical name
Time and duration of release
Release medium/media
EXPOSURES BEYOND
FACILITY BOUNDARIES (cont.)
Health risks and precautions
Name and telephone number for
additional information
AREAS FOR REVIEW
Is plan complete and appropriate?
Is plan coordinated with local, state,
and regional plans?
7/93
Emergency Response
-------
NOTES
AREAS FOR REVIEW (cont.)
Has training been completed and
documented?
Have critiques been done?
- Tabletop exercises
- Simulations
Emergency Response
7/93
-------
PROCESS INSPECTION TECHNIQUES
PERFORMANCE OBJECTIVES
At the end of this lesson, participants will be able to:
List five essential steps in preparing for an inspection
List seven background documents that may be reviewed in
preparation for an inspection
List five criteria commonly used to inspect valves and piping
List six areas of evaluation during inspection of process
controls
List five operating practices that should be examined during
operations inspections
List seven items that should be examined during evaluation
of a plant's emergency response plan
List eight maintenance or repair practices to be evaluated
during maintenance inspections
Describe how to follow a logical order of progression while
performing inspections.
-------
/VOTES
PROCESS INSPECTION
TECHNIQUES
INSPECTION TECHNIQUES
Preparing for inspections
Process equipment inspections
Operations inspections
Maintenance inspections
Helpful hints
PREPARING FOR
INSPECTIONS
Review background documents
- SOPs, emergency procedures
- Block diagrams, P&IDs
- Training manuals
- Management policies
7/93
Process Inspection Techniques
-------
NOTES
PREPARING FOR
INSPECTIONS (cont.)
Review background documents
- Release reports
- Incident investigation reports
- Process hazards analyses
PREPARING FOR
INSPECTIONS (cont.)
Review technical literature
Review process hazards
Determine scope of audit
Prepare health and safety plan
PROCESS EQUIPMENT
INSPECTIONS
Overall impression
- Condition
- Housekeeping
- Accessibility of safety/
emergency equipment
Process Inspection Techniques
7/93
-------
NOTES
PROCESS EQUIPMENT
INSPECTIONS (cont.)
Process equipment layout
- Separation of flammables/
incompatible chemicals
- Access for emergency respirators
PROCESS EQUIPMENT
INSPECTIONS (cont.)
Tanks and vessels
- Condition and spacing
- Containment
- Marking/labeling
- Grounding
- Alarms and controls
PROCESS EQUIPMENT
INSPECTIONS (cont.)
Valves and piping
- Condition
- Suitability
- Labeling/color coding
- Accessibility
- Conformance with P&IDs
7/93
Process Inspection Techniques
-------
NOTES
PROCESS EQUIPMENT
INSPECTIONS (cont.)
Safety/emergency equipment
- Condition
- Suitability
- Accessibility
- Compatibility
PROCESS EQUIPMENT
INSPECTIONS (cont.)
Process controls
- Condition
- Control logic
- Suitability
- Visibility
- Manual operation
- Conformance with P&IDs
OPERATIONS INSPECTIONS
Operating practices
- Conformance with policies and
procedures
- Overtime requirements
- Supervision
- Training
- Communication with maintenance
and contractors
Process Inspection Techniques
7/93
-------
NOTES
OPERATIONS
INSPECTIONS (cont.)
Supervision and management
- Management philosophy
- Management training
- Supervisor availability
- Incident documentation
- Process hazards analyses
- Process audit procedures
OPERATIONS
INSPECTIONS (cont.)
Safety and accident prevention
- Incident investigation reports
- Documentation of safety meetings
- Management attitudes
- Employee attitudes
OPERATIONS
INSPECTIONS (cont.)
Training
- Conformance with requirements
- Task analyses
- Needs analyses
- Job-/task-based objectives
- Schedules and documentation
- Contractor training
7/93
Process Inspection Techniques
-------
NOTES
OPERATIONS
INSPECTIONS (cont.)
Emergency response
- Response plan suitability
- Response plan availability
- HAZMAT training
- Response initiation policies
- Emergency notification policies
- Coordination with local authorities
- Exercises and simulations
MAINTENANCE INSPECTIONS
Repair practices
- Repair procedures
- Lockout/tagout procedures
- Hot work procedures
- Confined space procedures
- Suitability of spare parts
- Compatibility of spare parts
- Coordination with operations
- Coordination with contractors
MAINTENANCE
INSPECTIONS (cont.)
Preventive maintenance
- Periodic, preventive, or
predictive maintenance
- Documentation
- Inspection policies
Process Inspection Techniques
7/93
-------
HELPFUL HINTS
Determine the scope of the inspection
before the site visit
Use a logical order for the inspection
- For equipment, follow the flow
path
- For operations, start with general
concerns and work toward specific
concerns
HELPFUL HINTS (cont.)
Make checklists and take notes
First impressions are often accurate
NOTES
7/93
Process Inspection Techniques
-------
AUDIT REPORT WRITING
PERFORMANCE OBJECTIVES
At the end of this lesson, participants will be able to:
Describe the writing style and consistency requirements for
the 13 major report sections shown in the EPA chemical
safety audit program protocol
Describe the report disclaimer and requirements for limiting
access to draft reports, for handling confidential information,
and for finalizing and distributing the report.
-------
NOTES
AUDIT REPORT WRITING
AUDIT REPORT WRITING
Preparing to write
Writing the report
Distributing the report
PREPARING TO WRITE
Postvisit meeting
Follow-up information
Standard report disclaimer
7/93
Audit Report Writing
-------
NOTES
POSTVISIT MEETING
Reassemble the team as soon as
possible
Details can fade from memory
Details can become confused
FOLLOW-UP INFORMATION
Team leader designates someone to
ask follow-up questions as needed
Follow-up
- Letter
- Telephone call
- In person
STANDARD REPORT
DISCLAIMER
Describes the scope and limitations of
the audit
Required part of the audit report
Found in Section 6.2, page 46, of the
guidance manual
Audit Report Writing
7/93
-------
NOTES
WRITING THE REPORT
Writing style
Flexibility
Report sections
WRITING STYLE
Factual
Relevant
Complete
Objective
WRITING STYLE (cont.)
Clear
Consistent
- Statements in the report
ARE NOT contradictory
- The report appears to be
written by one person
7/93
Audit Report Writing
-------
NOTES
FLEXIBILITY
All 13 sections of the audit report
MUST be addressed
If a section is not relevant or was not
audited, state this in the report
Subsections DO NOT have to be
addressed separately
REPORT SECTIONS
Introductory and background
information
- Sections 1 - 4
Chemical hazards and process
information
- Sections 5 - 6
REPORT SECTIONS (cont.)
Accident prevention and emergency
preparedness
- Sections 7-11
Conclusions and recommendations
- Sections 12-13
Appendices
Audit Report Writing
7/93
-------
NOTES
INTRODUCTORY AND
BACKGROUND INFORMATION
Section 1 - Introduction
Section 2 - Summary of findings and
conclusions
Section 3 - Background
Section 4 - Facility background
information
CHEMICAL HAZARDS AND
PROCESS INFORMATION
Section 5 - Chemical hazards
Section 6 - Process information for
hazardous chemicals
ACCIDENT PREVENTION AND
EMERGENCY PREPAREDNESS
Section 7 - Chemical accident
prevention
Section 8 - Accidental release
incident investigation
7/93
Audit Report Writing
-------
NOTES
ACCIDENT PREVENTION AND
EMERGENCY PREPAREDNESS
Section 9 - Facility emergency
preparedness activities
Section 10 - Community and facility
emergency response
planning activities
ACCIDENT PREVENTION AND
EMERGENCY PREPAREDNESS
Section 11 - Public alert and
notification procedures
CONCLUSIONS
Section 12 - Conclusions
- Based on facts
- Positive and negative
- Highlight safety practices
Audit Report Writing
7/93
-------
NOTES
RECOMMENDATIONS
Section 13 - Recommendations
- Observed and documented facility
practices
- Factual, clear, and nonjudgmental
- Technically feasible
APPENDICES
Useful and relevant to the report
Referenced in the body of the report
Examples - list of audit team
members, MSDS, maps and charts,
accidental release report(s), and
unique SOPs
DISTRIBUTING THE REPORT
Information access
Report recipients
7/93
Audit Report Writing
-------
NOTES
INFORMATION ACCESS
Mark preapproval (draft) report as
follows:
1. "Pre-decisional Document, Not
Disclosable Under FOIA"
2. "Do Not Cite or Quote"
INFORMATION ACCESS (cont.)
Confidential information
- Available to EPA, TATs, and AARP
- Not available to state or local
team members
REPORT DISTRIBUTION
Handled by Regional CEPPO
Distributed to:
- SERCsandLEPCs
- Facility owner and operator
- EPA headquarters
- Any assisting agencies
Audit Report Writing
7/93
-------
Guidance Manual for
EPA Chemical Safety Audit Team Members
Chemical Emergency Preparedness and Prevention Office
Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency
June 1993
-------
Note: This Manual supersedes all previous versions.
-------
Table of Contents
Item Page
1. Introduction
1.1 Purpose of this Manual 1
1.2 Program Background and Overview 1
1.3 CSA Program and Section 112 (r) of the Clean Air Act 4
2. Program Authority Under CERCLA
2.1 Purpose of the Statute 5
2.2 Facility Entry and Information Gath ^ring Tools 5
2.2.1 Statutory Authority 5
2.2.2 EPA Policy and Practice 5
2.2.3 Confidential Information 6
2.2.4 Attorney-Client Privilege 6
2.3 Response Actions if a Release or a Threat of a Release Exists 7
2.4 Relationship to Enforcement/Compliance Regulatory Programs 8
2.5 Relationship Between CERCLA and SARA Title III 9
3. Role of Audit Team Members
3.1 Audit Team Composition 11
3.2 Training and Safety Requirements 14
3.3 Non-EPA Personnel Participation on Audit Team 15
3.4 Liability 16
3.4.1 Federal Employees 16
3.4.2 AARP Enrollees 16
3.4.3 Technical Assistance Team Contractors 17
3.4.4 Federal, State/SERC, and Local/LEPC Government Personnel 17
3.5 Conflict of Interest 17
4. Preparing for the Audit
4.1 Facility Selection 19
4.2 Facility Notification 20
4.3 Facility Background Information 21
4.4 Preparing for the Site Visit 21
-------
Item Page
5. Conducting the Audit
5.1 Entry 23
5.2 Opening Meeting 23
5.3 On-Site Activities 24
5.4 Exit Briefing 24
6. Audit Protocol/Report Preparation Guidance
6.1 Purpose and Structure 25
6.2 Writing the Report 44
6.2.1 Post-Visit Meeting 44
6.2.2 Tips for Writing the Report 44
6.2.3 Follow-up Information 46
6.2.4 Standard Report Disclaimer 46
6.3 Review and Finalization Procedures 47
6.3.1 Access to Draft Information 47
6.3.2 Facility Confidential Information 47
6.4 Report Distribution 47
6.5 Preparing the Report Profile 48
7. Audit Follow-Up Activities
7.1 Follow-Up Approaches 51
7.2 Specific Information Required 52
Exhibits
1. Outline of Protocol/Report Preparation Guidance 26
2. Annotated Protocol/Report Preparation Guidance 29
-------
Attachments
1. Chemical Safety Audit Program Fact Sheet
2. CERCLA Provisions Overview and CERCLA Statute
3. Model Site Safety Plan for Chemical Safety Audits
4. Sources of Information Concerning Hazardous Substance Releases
5. Sample First Letter to Facility Owner/Operator
6. Sample Letter to Facility Owner/Operator Who has not Responded or Consented
to the Audit
7. Standard Report Disclaimer
8. Standard Language for Audit Report Introduction
9. Documentation Pertaining to the Processes and Operations Using Hazardous
Substances
10. Description of Standard Operating Procedure Manuals
11. Blank CSA Report Profile
12. Annotated CSA Report Profile
-------
1. Introduction
1.1 Purpose of this Manual
The purpose of this Manual is to provide guidance to the U.S. EPA regional
offices in implementing the Chemical Safety Audit (CSA) program, which is an outgrowth
of the efforts of the Environmental Protection Agency (EPA) under the Chemical
Accident Prevention (CAP) program. This document is intended solely as guidance. It
does not represent final agency action nor is it ripe for judicial review. This is not
intended, nor can it be relied upon, to create any rights enforceable by any party in
litigation with the United States. The Agency may change this guidance at any time
without public notice.
This Manual, commonly referred to as the "Blue Book," includes a discussion of
the following topics:
Audit authority under CERCLA;
Roles and responsibilities of audit team members;
Audit preparation;
Conducting the audit;
Audit protocol and report preparation; and
Audit follow-up activities.
It is recommended that each audit team member have a copy of this Manual to
be used in conjunction with the Training Manuals provided at the Chemical Safety Audit
Training Course. This Manual contains recommended actions, as well as mandatory
procedures that must be followed to ensure the health and safety of program auditors as
well as program integrity. All required/mandatory procedures or activities presented in
this Manual are identified with the words "[Required Activity]" at the end of the
sentence in which they are presented. Unless noted as a required activity, the described
procedure is considered a recommendation, and the regional office has discretion in its
implementation.
1.2 Program Background and Overview
The Chemical Accident Prevention (CAP) program emerged from concerns raised
by the release of methyl isocyanate at Bhopal, India, and of aldicarb oxime at Institute,
West Virginia. Awareness of the critical threat to public safety posed by similar incidents
led to an emphasis on preparedness and planning for response to chemical accidents.
Simultaneous with the development of preparedness activities by EPA was the passage
and implementation of the Emergency Planning and Community Right-to-Know Act --
Title III of the Superfund Amendments and Reauthorization Act (SARA) in 1986.
Because prevention is the most effective form of preparedness, the CAP program
promotes the effort to enhance chemical accident prevention activities. The primary
objectives of the CAP program are to identify the causes of accidental releases of
hazardous substances and the means to prevent them from occurring, to promote
-------
industry initiatives in these areas, and to coordinate activities with the community,
industry, and other groups (e.g., academia, professional organizations, and trade
associations).
Many of the key concerns of the CAP program arise from the SARA Title III
section 305(b) study entitled Review of Emergency Systems. This study, published in
June 1988, made a number of recommendations on the future course of prevention
activities by EPA, and identified several aspects of current practices that will require
careful consideration in an overall prevention strategy. The study identified the
importance of facility management commitment to implementing and maintaining systems
to prevent, mitigate, and prepare for potential chemical accidents. First, while it is
evident that risk awareness among the larger chemical producers is high, many large
distributors and users of hazardous chemicals, as well as many smaller operations, have
not yet attained a comparable level of accident consciousness. The study also indicated
the need for new technologies in certain key areas: process area monitoring devices,
back-up detectors, mitigation devices, and practices to adequately identify disabled
equipment of these types. Third, the report suggested that a great degree of caution
must be exercised in analyses using real-time dispersion models, and indicated that
employee familiarity with hazard evaluation methods was limited, which in turn suggests
that improper or ineffective techniques may be in practice. Finally, the examination of
management practices revealed a failure to place sufficient emphasis on safety-related
issues such as standard operating procedures, employee training, preventive maintenance,
and post-accident investigation, as well as a general lack of commitment to safety.
As a follow-up to this national prevention study, EPA has undertaken cooperative
initiatives with other federal agencies, states, industry, professional organizations, and
trade associations, as well as environmental groups and academia. These joint efforts
have and will continue to serve to determine and implement a mechanism for developing
and sharing information on release prevention technology and practices, and to enhance
the state of practice in the chemical process safety arena. In addition, EPA analyzes and
disseminates information on accident prevention practices and technologies garnered
from the Accidental Release Information Program, Acute Hazardous Events, Emergency
Release Notification System, and National Response Center databases; on-scene
coordinator reports; and EPA audits and inspections. Finally, with the inclusion of the
facility risk management provisions in the Clean Air Act Amendments of 1990, the
accident prevention goals of the CSA program have been formalized.
The Chemical Safety Audit program is part of the CAP initiative and has been
designed to accomplish the following chemical accident prevention goals:
Visit facilities handling hazardous substances to gather information on
safety practices and technologies;
Heighten awareness of the need for, and promote, chemical safety among
facilities handling hazardous substances, as well as in communities where
chemicals are located;
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Build cooperation among facilities, EPA, and other authorized parties by
coordinating joint audits; and
Establish a database for the assembly and distribution of chemical process
safety management information obtained from the facility audits.
The chemical safety audit itself consists of interviews with facility personnel and
on-site review of various aspects of facility operations related to the prevention of
accidental chemical releases. Specific topics addressed include:
Awareness of chemical and process hazards;
Process characteristics;
Emergency planning and preparedness activities;
Hazard evaluation and release modelling efforts;
Release detection and monitoring techniques;
Training of operators and emergency response personnel;
Facility and corporate management structure;
Preventive maintenance and inspection programs; and
Community notification mechanisms and techniques.
Observations and conclusions from the audits are detailed in a report prepared by
the audit team. The report identifies and characterizes the strengths and weaknesses of
specific chemical accident prevention program areas to allow the elements of particularly
effective programs to be recognized, and to share information on problematic practices.
Copies of the report are given to the facility and to its corporate management so that
weak and strong program areas may be recognized. The audit reports are intended to
contribute to the study of emergency systems begun in the Review of Emergency
Systems, and in turn, to produce improvements in the ability of the audited facilities --
and industry in general -- to prevent or mitigate releases of hazardous substances and to
share this information with the community and other interested groups. In this fashion,
the CSA program serves as a vital component of EPA's Chemical Accident Prevention
Program. Attachment 1 contains the Chemical Safety Audit Program Fact Sheet, which
summarizes the audit program background, goals, and scope. It can be used as a
separate document to inform interested parties about the audit program.
It should be noted that the CSA program is not a compliance or inspection
program. The audits are intended to be non-confrontational and positive, so that
information on safety practices, techniques, and technologies can be identified and shared
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between EPA and the facility. However, if serious problems are discovered during the
audit, EPA has a variety of legal authorities to use in response to them, which are
discussed later in the body of this Manual. Violations observed during the course of an
audit may also be referred to the respective EPA program office or federal agency or
department for determination of what actions are to be taken following the audit.
1.3 CSA Program and Section 112(r) of the Clean Air Act
The future direction of both the CAP program and the CSA program will be very
much affected by the passage of the Clean Air Act (CAA) Amendments of 1990. The
accidental release prevention requirements found in section 112(r) of the Clean Air Act
require EPA to promulgate regulations that require certain facilities to take steps to
prevent accidental releases of chemicals and mitigate the severity of releases that do
occur.
The facilities that will be covered by these regulations will be defined by a list of
substances and threshold quantities that EPA will promulgate. The Accidental Release
Prevention (ARP) regulations will require that facilities develop and implement a risk
management plan (RMP) including a hazard assessment (off-site consequence analysis
and a five-year accident history), a prevention program, and an emergency response
program - within three years after promulgation of the regulation. The RMP will be
registered with EPA, and submitted to the Chemical Safety and Hazard Investigation
Board, the state, and local emergency planning and response authorities. The RMP will
also be made available to the public.
The CAA also requires EPA to establish an auditing system to review, and if
necessary require revision of the RMPs submitted by facilities. The auditing system in
the RMP rule outlines criteria for selecting facilities for audits. A more detailed auditing
strategy is being proposed in the guidance to states for implementation of the ARP
program. CAA section 507 further requires states to provide small businesses with
technical assistance on how to comply with the Act.
The role of the CSA program in advancing EPA's accident prevention initiative,
particularly its relevance in the context of the new section 112(r) requirements, will
continue to evolve. In the short term, the regions should continue to perform audits
under the current CSA format until they and the states begin administering the ARP
program under section 112(r). The goal is to ensure that the states' auditing and
inspection programs and technical assistance capability are adequate to assume the
primary responsibilities of the ARP program.
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2. Program Authority under CERCLA
2.1 Purpose of the Statute
The Comprehensive, Environmental Response, Compensation, and Liability Act
(CERCLA or Superfund) was enacted December 11, 1980, and amended by the
Superfund Amendments and Reauthorization Act (SARA) on October 17, 1986.
CERCLA authorizes the federal government to respond where there is a release or a
substantial threat of a release into the environment of any hazardous substance,
pollutant, or contaminant that may present danger to the public health or welfare or to
the environment. Attachment 2 contains an overview of major CERCLA provisions
related to the CSA program. These include CERCLA sections 104(a), 104(b), 104(e),
and 106(a). The statutory text is also included, 42 U.S.C.A. sections 9601, 9604, and
9606.
2.2 Facility Entry and Information Gathering Tools
2.2.1 Statutory Authority
CERCLA sections 104(b) and 104(e), as amended by SARA in 1986, provide
authorities for entering a facility and accessing information. While CERCLA provides
authority for states to use statutory authorities for entry and information gathering, such
authorities may only be accessed pursuant to a contract or cooperative agreement with
the federal government. Since no state currently has such an arrangement, states, as well
as local governments, must use their own authorities for audit participation. [Required
Activity]
2.2.2 EPA Policy and Practice
When entering pursuant to CERCLA, EPA auditors must ensure that the facility
has experienced a release of a hazardous substance, pollutant, or contaminant, or that
there is "reason to believe" that there exists a threat of such a release. The audits are
intended to be non-confrontational and positive, cooperative efforts, such that
information on safety practices, techniques, and technologies can be identified and shared
between EPA and the facility. Consequently, and in conformance with other EPA
program policies, audits will be performed under the above authority pursuant to the
consent of the facility owner or operator. Consensual entry, however, can be revoked at
any time during the audit. When withdrawal of consent takes place, the audit team shall
leave the facility, regardless of the fact that the team has the authority to be there.
[Required Activity] In either situation (i.e., entry refusal prior to audit or during audit),
if consent is lacking, an order can be issued to require entry. Section 4.2 of this Manual
provides guidance on obtaining entry upon consent and actions to be taken if the facility
refuses entry.
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An audit can also be conducted at facility invitation. When entering at the
invitation of the facility (i.e., not pursuant to CERCLA authority or other statutory
authorities), the audit scope can potentially be limited, since the facility determines what
information will be made available to the audit team. In addition, invitational entry can
be revoked by the facility at any time during the audit. The audit team has no legal
authority (i.e., as compared to consensual entry) to continue the audit, and must leave
the facility. [Required Activity]
The only exception to the described facility discretion concerning entry withdrawal
for both consensual and invitational entry is if the audit team identifies a release or
threat of a release of a CERCLA hazardous substance from a facility into the
environment. If either of these situations are observed, the audit team must follow the
prescribed procedures in section 2.3 of this Manual. [Required Activity]
.2.3 Confidential Information
During the course of an audit, team members may encounter information that
may be entitled to confidential treatment. Facilities can claim confidentiality on
information under CERCLA section 104(e), as amended. If confidential business
information (CBI) at a facility has been collected under another authority (e.g., TSCA,
CWA), CERCLA section 104(e) allows authorized team members to handle this
confidential business information as CERCLA CBI.
This information will be handled in accordance with 40 CFR Part 2. Authorized
representatives and Agency employees can access and view CBI under CERCLA.
Contractors who are pre-identified by contractor name and contract number to the
facility can have access to this data (refer to section 4.2 of this Manual). On February 5,
1993, EPA's Office of General Counsel issued a rule (58 FR 7187) that authorizes the
disclosure of CBI information (collected under a variety of environmental statutes,
including CERCLA section 104) to enrollees in the Senior Environmental Employment
(SEE) Program. Thus, members of the American Association of Retired Persons
(AARP) now have the same access to CBI as EPA employees.
There are no specific training courses for handling CERCLA CBI, either on-site
or off-site. In general, all confidential information must be marked as such and placed in
a locked filing cabinet or a safe. It is advisable, however, that audit participants take a
regional CBI course.
2.2.4 Attorney-Client Privilege
In the event that a facility withholds information based upon "attorney-client
privilege," the regional Office of Regional Counsel (ORC) should be immediately notified
and provided the following information:
Name of document(s) withheld;
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Specific reason why withheld; and
Name of facility attorney, address, and telephone number.
If a request for information during the course of the audit is refused, the audit
should continue unless the absence of the requested document(s) makes it impossible to
do so. The Office of Regional Counsel should be consulted of the refusal after the site
visit and requested to pursue the matter as necessary.
2.3 Response Actions if a Release or a Threat of a Release Exists
During an audit, the team may observe a release or the potential for a release of
a CERCLA hazardous substance from a facility into the environment.
If a release is observed, the team members must take the following actions:
[Required Activity]
Follow facility emergency evacuation procedures to safety; and
Regroup; the Team Leader must notify the Regional Emergency Response
Section to inform the on-duty On-Scene Coordinator (OSC) of events
occurring at the facility. This action is not intended to serve as the facility's
notification under any statute or regulation.
If the threat of a release is observed, the Team Leader must take the following
actions: [Required Activity]
Regroup, if necessary with the entire audit team at the facility management
office;
Inform the facility owner/operator of the observed situation; and
If the facility owner/operator fails to take appropriate actions to mitigate
the potential threat of release, the Team Leader must notify the Regional
Emergency Response Section to apprise the OSC of events occurring at the
facility.
In both of the above situations, notification to the Regional Emergency Response
Section must be made regardless of whether the Team Leader or members of the audit
team are OSCs. The communication with the region will determine the scope of the
response action to be taken to mitigate the release or threat of release.
At this point, the audit must not continue until the release or threat of release has
been mitigated, as determined by the OSC. The OSC and/or Remedial Project Manager
(RPM) shall have the authority vested in them by the National Contingency Plan, 40
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CFR Part 300. In addition, the OSC and/or RPM may take any necessary response
actions when he/she determines that conditions at the site may present an imminent and
substantial endangerment.
2.4 Relationship to Enforcement/Compliance Regulatory Programs
An EPA chemical safety audit is not an enforcement inspection or multi-media
compliance audit, such as a RCRA compliance inspection or an environmental audit.
Nor should an audit be confused with compliance inspections conducted by the
Occupational Safety and Health Administration (OSHA) of the Department of Labor. A
chemical safety audit is a visit to a facility to learn about and share technologies,
techniques, and management practices for preventing and mitigating chemical accidents.
Relationship to OSHA
OSHA's primary responsibility is to protect workers, ensuring a safe and healthy
environment for employees. OSHA conducts inspections to identify facility compliance
with specific requirements and standards for employee health and safety and for accident
investigations, especially where worker injuries or death occur. EPA and OSHA have
established a Memorandum of Understanding on facility inspections, as well as
coordinating activities through a variety of other means.
Relationship to EPA Regulatory Programs
The audit findings are presented in a final report. If appropriate, the report can
include recommended process safety practices that the facility may want to consider
adopting. Report findings and recommendations are not mandatory actions that the
facility must adopt, as are those identified during an enforcement/compliance inspection.
The audit focus is not on reviewing facility compliance with other regulatory programs;
other media program offices already perform these activities. Use of CERCLA sections
104(b) and 104(e) provide EPA with the authority to enter a facility and access
information for the purpose of conducting the safety audit.
Audit team members, however, will often consist of representatives from other
EPA media program offices who are charged with the authority to conduct enforcement
or compliance inspections and audits. In this situation, the role of this media program
official must be determined prior to notifying the facility of the audit. [Required Activity]
Facility notification involves citing the CERCLA entry and information gathering
authorities. If this media program official intends to exercise authorities other than
CERCLA sections 104(b) and 104(e), then the facility must be notified that these
additional authorities will be exercised. In this situation, there are two separate EPA
activities being conducted at the facility: a chemical safety audit and an
enforcement/compliance inspection. This additional use of other authorities must be
presented in the same letter that cites use of CERCLA authorities. [Required Activity]
Facility notification procedures are presented in section 4.2 of this Manual.
8
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During the conduct of a chemical safety audit that is not coupled with an
enforcement inspection as presented above, program violations may be observed. These
violations should be referred to the respective program office or federal
agency/department for determination of what actions are to be taken following the audit.
2.5 Relationship Between CERCLA and SARA Title III
The CSA program is being conducted under CERCLA authority. While the idea
of the CSA program originated from the activities undertaken to prepare the section
305 (b) study mandated by Congress under SARA Title III (see the introduction to this
Manual), and from similar audits conducted following catastrophic releases, there is no
statutory link between the CSA program and the SARA Title III program.
The CERCLA and SARA Title III programs, however, have similar release
notification provisions. A release or spill of a chemical above a certain threshold amount
(the chemical's designated "reportable quantity" or "RQ") will often require two separate
notifications: if the chemical is a CERCLA "hazardous substance," the National
Response Center (NRC) must be notified under CERCLA sectidn 103(a), and, if the
chemical is a CERCLA hazardous substance and/or an "extremely hazardous substance"
(EHS) under SARA Title III, the emergency coordinator of the local emergency planning
committee(s) (LEPC) and the state emergency response commission(s) (SERC) likely to
be affected by the release must be notified under SARA Title III section 304(a).
CERCLA hazardous substances are listed at 40 CFR Part 302; EHSs under SARA Title
III are listed at 40 CFR Part 355.
Although the two lists overlap considerably, they are not identical; approximately
138 EHSs are also CERCLA hazardous substances. It should be noted that all EHSs are
proposed to be designated as CERCLA hazardous substances. In situations where the
release is above the RQ of a chemical that is listed both as an EHS under SARA Title
III and as a hazardous substance under CERCLA, notifications under both authorities
must be given by the facility; this is because each notification is a separate requirement,
and the contents and recipients of the notifications differ.
In addition, similar goals are shared by both the CSA program and the SARA
Title III program. These include the following:
Increased level of preparedness for responding to accidental releases of
chemicals both at a facility and in a community;
Increased awareness and understanding of chemical hazards; and
Increased levels of safety practices related to producing, treating, handling,
disposing, and transporting of hazardous substances at a facility.
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Involvement in the CSA program by representatives of LEPCs and SERCs, either
as audit team members, information sources, or both, is encouraged to enhance the goals
of both these programs. However, state and local government participation in the audit,
itself, must be performed under state and local authorities.
10
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CHEMICAL SAFETY AUDIT PROGRAM
RESOURCE GUIDE
Prepared for:
Chemical Emergency Preparedness and Prevention Office
Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency
Prepared by
ICP Incorporated
April 1991
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CHEMICAL SAFETY AUDIT PROGRAM RESOURCE GUIDE
This Chemical Safety Audit (CSA) Resource Guide contains references to
background and resource materials to help support the efforts associated with
the CSA Program. The guide provides audit team members access to additional
information to prepare for and conduct an audit and to write the audit report.
The resources include books, journals, reports, and videos covering manv
topics in chemical safety. The guide contains information from various
organizations, associations, and agencies such as the Environmental Protection
Agency, the National Fire Protection Association, the Chemical Manufacturers
Association, the American Institute of Chemical Engineers, the American
Society of Safety Engineers, and the Occupational Safety and Health
Administration.
Each reference lists the resource name, publisher or organizational
sponsor, publication date, a short description of the document, information on
obtaining the resource, and its cost. On the last page of this document is a
list of organizations with frequent publications referenced in the resource
guide. While this guide provides a comprehensive listing of resources, it is
not an exhaustive list.
This guide follows the general format of the protocol found in the
guidance manual of the Chemical Safety Audit Program. The protocol provides
detailed guidance on the types of information that should be reviewed during
an audit and discussed in the subsequent audit report. Resources are
organized by each of the major areas of the protocol to assist audit team
members in locating additional resource materials identified in this document.
Audit team members can consult the resources applicable to specific topics or
a particular focus of the audit. For example, an audit team member
responsible for examining the public alert system in a facility can use the
resources specified in this guide under the topic Public Alert and
Notification Procedures.
This guide can be used at any time in the audit process. Consulting
these resources in preparation for an audit can help the audit team members to
conduct more informed and thorough investigations of the facility. Also, the
resources can be used after an audit to compare facility practices with
standard practices specified in the literature. In addition, the resources
referenced in this guide may help in writing the audit report by validating
facts and bolstering the report's technical credibility.
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ti
TABLE OF CONTENTS
Page
1.0 General 1
2.0 Chemical Hazards 4
2.1 Overview of Hazards for Chemical(s) being Audited 4
2.2 Facility Management of Chemical Hazard Data 8
3.0 Process Information for Hazardous Chemical(s) 9
3 .1 Storage and Handling 10
3.2 Process Description 14
3.3 Process Hazards 17
4.0 Chemical Accident Prevention 20
4.1 Management Activities 20
4.2 Process Operation and Maintenance 22
4.3 Hazard Evaluation and Modeling 23
4.4 Release Prevention Systems 27
4.5 Mitigation Systems 28
5.0 Accident Release Incident Investigation 30
6.0 Facility Emergency Preparedness and Planning Activities 31
6 .1 Facility Emergency Response Plan 31
6.2 Emergency Response Exercises and Simulations 33
6. 3 Fire, Evacuation, and Rescue Corridors 34
6.4 Emergency Equipment Provisions 37
6.5 Emergency Response Chain of Authority 39
6.6 Emergency Response Management Procedures 39
6.7 Emergency Communication Network Within the Facility... 40
6.8 Emergency Responre Personnel Training Requirements.... 41
6.9 Follow-up Release Procedures/Investigation 42
7.0 Community and Facility Emergency Response Planning Activities 43
7.1 Facility Planning and Oucreach Activities with Community 43
7.2 Local/Community Emergency Response Plan 45
8.0 Public Alert and Notification Procedures 50
Alphabetical Index of Reference Titles 51
Frequently Mentioned Organizations 63
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1.0 GENERAL
Chemical Special Emphasis Program: Final Report. OSHA, March 1987
OSHA conducted forty Chemical Special Emphasis Program (ChemSEP)
inspections on chemical manufacturing processes. This report indicates
helpful aspects of a comprehensive approach to inspections, which
includes management systems.
Available from OSHA/NIOSH as OSHA/RP-87/002. See last page for address
and telephone number.
Conducting Fire Inspections' A Guidebook for Field Use. National Fire
Protection Association, 1989.
This guidebook provides background information and inspection checklists
for all types of occupancy to help ensure thorough inspections.
Available from National Fire Protection Association as Item No. FM-CFI-
89 for $28.00. See last page for address and telephone number.
Inspection for Accident Prevention, First Edition, American Petroleum
Institute, 1984.
This publication provides an overview of inspection methods practiced by
petroleum refineries to prevent accidents at all levels, from the field
to the equipment issue room. 11 pages.
Available from American Petroleum Institute as item # 855-20020 for
$10.00. See last page for address and telephone number.
NFPA Inspection Manual. National Fire Protection Association, 1989.
This manual covers background facts and practical information about
building features and NFPA codes and standards.
Available from the National Fire Protection Association as Item No. FM-
IM-89 for $29.95. See last page for address and telephone number.
Plant/Operation Progress: articles on chemical process safety, American
Institute of Chemical Engineers, July and October 1990.
These two monthly issues contain a series of articles on various
strategies, issues, and technologies in chemical safety. Topics include
management practice, process safety audits, public participation in risk
assessment, and accident prevention.
Journal is available commercially or from libraries.
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Recommendations to Chlor-Alkali Manufacturing Facilities for the Prevention of
Chlorine Releases. Edition 1, The Chlorine Institute, Inc., October 1990.
This publication is intended to provide useful information to chlor-
alkali manufacturing facilities to allow the organizations involved in
such production to help comprehensively address the issue of preventing
the occurrence, or minimizing the consequences, of uncontrolled releases
of chlorine. It provides specific guidance in the development of a
comprehensive process safety/risk management program.
Publication is available as publication #86 from the Chlorine Insitute
for $7.00. See last page for address and telephone number.
Review of Emergency Svstems. Environmental Protection Agency, 1988.
This document is a report to Congress on facility systems for
monitoring, detecting, and preventing releases of extremely hazardous
substances at facilities that produce, use or store them.
Available free of charge from EPA. See last page for address and
telephone number.
Technical Safety Audit, F. Owen Kubias. Paper presented at Chemical
Manufacturers Association Process Safety Management Workshop, May 5-7, 1985.
This paper describes the Technical Safety Audit process as
designed by Glidden Co. to identify plant conditions, processing
conditions or operating procedures which may lead to accidents.
The audit uses checklists, raw materials evaluations, and "what
if" analysis.
Available from the Chemical Manufacturers Association. See last page
for address and telephone number.
"Total Plant Safety Audit," Jeff Conrad. Chemical Engineering. May 14, 1984,
pp. 83-84, p. 86.
This article describes a hypothetical chemical plant safety audit,
including a thorough evaluation of a plant's design, layout,
appearance and operating procedures. It includes sample
questions, a hypothetical audit team list, and advice on procedure
evaluation and report follow-up.
Journal is available commercially or from libraries.
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What Went Wrong? Case Histories of Process Plant Disasters. T.A. Kletz. Gulf
Publishing Company, Houston, Texas, 1988.
This book examines Che causes and aftermaths of noteworthy process plant
disasters. It centers on recognition of danger signals and
implementation of prevention methods.
Available as ISBN 0-87201-339-1 commercially or from libraries.
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2.0 CHEMICAL HAZARDS
Flammable and Combustible Liquids Code Handbook. National Fire Protection
Association, 1990.
This handbook provides guidelines to minimize flammable and combustible
liquids risks, including expert commentary explaining and interpreting
specific requirements.
Available from National Fire Protection Association as Item No. FM-30-
HB90 for $49.50 See last page for address and telephone number.
Liquefied Petroleum Gases Handbook. National Fire Protection Association,
1989.
This handbook includes the entire text of Storage and Handling of LP-
Ga se s . plus commentary and explanations to help apply requirements.
Available from National Fire Protection Association as Item No. FM-
58HB89 for $49.50. See last page for address and telephone number.
Occupational Safetyard Health Guidelines for Chemical Hazards, NIOSH, 1988.
This publication includes a compilation of the 35 occupational safety
and health guidelines developed for the purpose of disseminating the
information to workers, employers, and to professionals in the field of
occupational safety and health.
Available from OSHA/NIOSH as DHHS/PUB/NIOSH-89-11&-SUPPL-1-OHG. See
last page for address and telephone number.
2.1 OVERVIEW OF HAZARDS FOR CHEKICAL(S) BEING AUDITED
Air Contaminants -- Permissible Exposure Limits (Title 29 Code of Federal
Regulations Part 1910.1000), Occupational Safety and Health Administration,
1989.
This publication lists the updates of 29 CFR 1910.1000 after study of
industrial experience and available scientific data. The revised
personal exposure limits will protect workers against a wide variety of
health effects. The final regulation includes 600 substances.
Available as OSHA 3112 free of charge from the Occupational Safety and
Health Administration. See last page for address and telephone number.
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Basic Classificacion of Flammable and Combustible Liquids. National Fire
Protection Association, 1987.
This publication specifies physical and chemical properties of flammable
and combustible liquids and establishes the classification system.
Available from the National Fire Protection Association as Item No. FM-
321-87 for $13.25. See last page for address and telephone number.
Classification of Class I Hazardous Locations for Electrical Installations in
Chemical Plants. National Fire Protection Association, 1986.
This document lists steps to determine the location, type, and scope of
hazards presented by electrical installations in operations where
flammable or combustible liquids are processed or handled..
Available from the National Fire Protection Association as Item No. FM-
497A-86 for $15.50. See la-;t page for address and telephone number.
Classification of Gases. Vapors and Dusts for Electrical Equipment in
Hazardous (Classified) Locations. National Fire Protection Association, 1986.
This document provides group classifications for selected gases, vapors,
and dusts to aid engineers in specifying the proper electrical equipment
for hazardous (classified) locations.
Available from the National Fire Protection Association as Item FM-497M-
86 for $13.25. See last page for address and telephone number.
A, Condensed Guide to Chemical Hazards (CHRIS I). U.S. Coast Guard.
This document provides chemical-specific information on 1,016 chemicals
for hazard assessment and response techniques as applied to marine
environments .
Available from U.S. Coast Guard as COMDTINST M16465 . 11A/SN#050-012-0024-
0. See last page for address and telephone number.
Dangerous Properties of Industrial Materials. Irving Sax and Richard J. Lewis,
Sr., American Society of Safety Engineers, 1988.
i^ reference book lists 20,000 chemicals and their exposure standards,
including a. Toxic Hazard Review section.
Available from the American Society of Safety Engineers as Order 8809
for $395.00. See last page for address and telephone number.
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Encvclopedia of Chemical Technology (3rd. Edition), R.E. Kirk and D.F. Ochmer.
New York: John Wiley and Sons, 1980.
This encyclopedia consists of articles which describe the
properties and manufacturing process of any substance. Those
articles cross reference one or more articles where the uses of
that substance are described. CAS numbers are included.
Available commercially or from libraries.
Explosive Materials Code, National Fire Protection Association 1990.
This publication identifies reasonable levels of safety for explosive
materials.
Available from the National Fire Protection Association as Item No. FM-
495-90 for $15.50. See last page for address and telephone number.
Fire Hazard Properties of Flammable Liquids, Gases._and Volatile Solids.
National Fire Protection Association, 1984.
This handbook provides a summary of available data on the fire hazard
properties of more than 1,600 substances. Listed alphabetically with
500 synonyms.
Available from the National Fire Protection Association as Item No. FM-
325M-84 for $17.50. See last page for address and telephone number.
Fire Protection Guide on Hazardous Materials. National Fire Protection
Association, 1986.
This document lists hazard information and classification for most
common hazardous materials.
Available from trhe National Fire Protection Association as Item No. FM-
SPP-1E for $60.50. See last page for address and telephone number.
Havley^s Condensed Chemical Dictionary, revised by Irving Sax and Richard J.
Lewis, Sr., American Society of Safety Engineers, 1987.
This publication provides-a compendium of technical data on chemicals
and chemical phenomena, chemical manufacturing equipment and components,
energy sources and their potential, pollution, and waste control.
Available from the American Society of Safety Engineers as Order 8706
for $57.95. See last page for address and telephone number.
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Hazardous Chemical Reactions, National Fire Protection Association, 1986.
This publication describes 3,500 recognized dangerous chemical
reactions.
Available from the National Fire Protection Association as Item No. FM-
491M-86 for $22.50. See last page for address and telephone number.
Hazardous Chemicals Data. National Fire Protection Association, 1987.
This publication specifies life and fire hazard precautions for
chemicals which pose a health hazard, reactivity rating, or fire
fighting problem.
Available from the National Fire Protection Association as Item No. FM-
49-75 for $17.50. See last page for address and telephone number.
Hazardous Chemicals Desk Reference, Irving Sax and Richard J. Lewis, Sr.,
American Society of Safety Engineers, 1987.
This document is a quick-access guide with information on 4700 hazardous
chemicals used in industry. Includes effects, synonyms, exposure
limits.
Available from the American Society of Safety Engineers as Order 8717
for $79.95. See last page for address and telephone number.
NIOSH/OSHA Pocket Guide to Chemical Hazards, NIOSH/OSHA. U.S. Government
Printing Office, 1985.
This book is a tabular-form quick-reference source relating to
general industrial hygiene and medical surveillance practices. It
gives chemical names and pseudonyms, exposure limits and
recommendations, chemical and physical properties, analytical
methods, respiratory and personal protection equipment
recommendations, signs and symptoms of exposure, and procedures
for emergency treatment.
This book is available as DHHS(NIOSH) Publication No. 85-114 from:
Superintendent of Documents
U.S. Government Printing Office
Washington, B.C. 20402-9325
GPO Stock No. 017-033-00342-4
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-8-
Rapid Guide to Hazardous Chemicals in the Workplace, Irving Sax and Richard J
Lewis, Sr., American Society of Safety Engineers, 1986.
This document provides an on-the-job guide to 700 hazardous chemicals,
with hazard ratings, exposure standards and workplace control
recommendations.
Available from the American Society of Safety Engineers as Order 8678
for S26.00. See last page for address and telephone number.
2.2 FACILITY MANAGEMENT OF CHEMICAL HAZARD DATA
Guidelines on Technical Management of Chemical Process Safety, the Center for
Chemical Process Safety of the American Institute of Chemical Engineers, 1989.
This book describes twelve basic elements that must be considered in the
development of a management system in the context of plant design,
construction, operation, and management.
Available for S100.00 from the American Institute of Chemical Engineers.
See last page for address and telephone number.
"Industrial Chemical Safety Testing: Ona Company's Approach," Y.H. Atallah
and D.M. Whitacre. Ecotoxicology and Environmental Safety, vol. &, No. &.,
pp. 357-361, 1980.
This article reviews a testing program for the safety of industrial
chemicals. The need for a testing program is discussed and the
development of a three tier system to identify potentially hazardous
chemicals is described. The criteria for defining the tiers are
discussed, including the developmental stage of the product, route and
magnitude of human exposure, magnitude of environmental exposure, and
potential adverse health and environmental effects.
Journal is available commercially or from libraries.
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-Q.
3.0 PROCESS INFORMATION FOR HAZARDOUS CHEMICALS
Guidelines or. Technical Management of Chemical Process Safety, the Center for
Chemical Process Safety of the American Institute of Chemical Engineers, 1989.
This book describes twelve basic elements that must be considered in the
development of a management system in the context of plant design,
construction, operation, and management.
Available for $100.00 from the American Institute of Chemical Engineers.
See last page for address and telephone number.
Instructional Videotapes on Chemical Process Safety. American Institute of
Chemical Engineers, 1989.
These videotapes provide instruction on the application of safety
procedures in plants and laboratories. The content is highly applicable
to chemical process plants and is deemed useful for industrial training.
Available from AIChE as Pub. V-2 for $1250.00. See last page for
address and telephone number.
Piping Design for Process Plants. Howard F. Rase. New Ycrk: John Wiley and
Sons, inc. 1963.
This book describes and illustrates piping designs for various
processes. It also includes standards for piping, pipe
specification, fabrication, and arrangement.
Available at libraries (out of print).
Process-Control Systems: Application/Design/Adjustment, F.3. Shinskey. New
York: McGraw-Hill Book Co., 1979.
This textbook describes theory and applications of chemical
process systems. It centers on control and feedback systems.
Available as ISBN 0-07-0556891-X commercially or from libraries.
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3.1 STORAGE AND HANDLING
Cleaning or Safeguarding Small Tanks and Containers. National Fire Protection
Association, 1987.
This guide describes procedures for the safe removal of flammable
vapors, liquids, gases, or solids from small tanks or containers chat
cannot be entered, and other safety measures.
Available from National Fire Protection Association as Item FM-327-87
for $13.25. See last page for address and telephone number.
Fire Protection Considerations for the Design and Operation of Liquified
Petroleum Gas (LPG) Storage Facilities, First Edition. American Petroleum
Institute, 1989.
This publication addresses the design, operation, and maintenance of
liquified petroleum gas (LPG) storage facilities from the standpoint of
prevention and control of releases, fire protection design, and fire
control measures. The history of LPG storage facility failure, facility
design philosophy, operating and maintenance procedures, and various
fire protection and firefighting approaches are presented. The storage
facilities covered are LPG installations (storage vessels and associated
loading/unloading/transfer systems) at marine and pipeline terminals,
natural gas processing plants, refineries, petrochemical plants, and
tank farms. 35 pages.
Available from American Petroleum Institute as item # 855-25105 for
$25.00. See last page for address and telephone number.
Fire Protection in Refineries. Sixth Edition. American Petroleum Institute,
1984.
This document centers on fire protPction problems and steps to ensure
the safe storage, handling, processing, and shipping of petroleum and
petroleum products in refineries. The general principles mentioned in
the publication are based in large measure upon composite experience in
a large number of refineries. 31 pages.
Available from the American Petroleum Institute item // 855-20010 for
$12.00. See last page for address and telephone number.
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ii
Flammable and Combustible Liquids Code, National Fire Protection Association,
1990.
This document lists updated requirements for storage and handling of
flammable and combustible liquids.
Available from National Fire Protection Association as Item FM-30-90 for
$17.50. See last page for address and telephone number.
General__Storage, National Fire Protection Association 1990.
This publication describes requirements for the storage of the broad
range of combustibles (Classes I through IV) and plastics (Groups A, B,
and C).
Available from the National Fire Protection Association as Item No. FM-
231C-186 for $15.50. See last page for address and telephone number.
Guidelines for Safe Storage and Handling of Highly Toxic Hazard Materials.
Arthur D. Little, Inc. & Richard LeVine, American Institute of Chemical
Engineers, 1987.
These guidelines are designed for engineers and technical personnel
concerned with the safe manufacture and use of chemicals. Information
is based on existing regulations, codes and standards in use worldwide
as well as safety requirements developed by individual companies.
Available from AIChE as ISBN 0-8169-0400-6 for $80.00. See last page
for address and telephone number.
Overfill Protection for P_etrole.ua_Sc_Qrage_ Tanks , First edition. American
Petroleum Institute, 1987
This publication suggests methods of preventing petroleum storage tanks
from being overfilled and covers manual and automatic systems that
provide protection against tank overfills, as well as safety,
environmental protection, optimization of the work place, maintenance,
and installation and training information. 21 pages.
Available from American Petroleum Institute as item $ 855-23500 for
$12.00. See last page for address and telephone number.
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-12-
Packager Trainine Proeram. the Chlorine Institute, 1990.
This slide/video program is designed as a. training tool for new and
established employees at chlorine packaging plants. It gives a detailed
view of the steps involved with tank, car unloading, cylinder and ton
container inspections, and valve reconditioning.
Available as "P-Slides" or "P-Video" from the Chlorine Institute for
$200.00 (slides) or $175.00 (VHS video). See last page for address and
telephone number.
Production. Storage, and Handline of Liquefied Natural Gas (LNG). National
Fire Protection Association 1990.
This publication describes site selection, design, construction, and
fire protection at LNG facilities.
Available from the National Fire Protection Association as Item No. FM-
59A-90 for $15.50. See last page for address and telephone number.
Refrigerated Liquid Chlorine Storage, edition 1, the Chlorine Institute, July
1984.
This pamphlet provides information applicable to the design,
construction, location, installation, and operation of refrigerated
liquid chlorine storage systems.
Available as publication #78 from the Chlorine Institute for $7.00. See
last page for address and telephone number.
Safe Handling and Storage of Compressed Gases. The Compressed Gas Association.
This audio-visual training program covers procedures for labeling and
storage, precautionary safety warnings, personnel safety equipment,
handling procedures, etc.
The Compressed Gas Association, Inc.
1235 Jefferson Davis Highway
Arlington, VA 22202-3269
703-979-4341
Available from the Compressed Gas Association on VHS, Beta, 3/4 inch, or
slide format as item AV-1 for.$140.
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-13-
Safe Tank Cleaning (Audio-Visual Tape), American Petroleum Institute.
This tape covers the preparation, ventilation, and cleaning procedures
of stationary petroleum and petrochemical storage tanKs. Included in
the program are: planning for tank cleaning, necessary permits,
preferred ventilation methods, criteria for cank entry by personnel,
flammability/toxicity hazards, and special considerations dictated by
tank design and tank contents.
Available from American Petroleum Institute as title code 3^*01. See
last page for address and telephone number.
Storage and. Handling of Liquefied Petroleum Gases, National Fire Protection
Association 1989.
This publication includes requirements for the safe storage and handling
of LP-Gases, including systems, liquid transfer, truck transportation,
engine fuel systems, and buildings or structures housing LP-Gas
distribution facilities.
Available from the National Fire Protection Association as Item No. FM-
58-89 for $17.50. See last page for address and telephone number.
Storage and Handling of Liquified Petroleum Gases at Utility Gas Plants.
National Fire Protection Association 1989.
This publication describes safe design, construction, and operation of
LP-Gas equipment at plants supplying LP-Gas/air mixtures for utility
application.
Available from the National Fire Protection Association as Item No. FM-
59-89 for $15.50. See last page for address and telephone number.
Storage of Flammable .and Combustible Liquids Within, Underground Mecal and Non-
Hetal Mines (Other than Coal'). National Fire Protection Association, 1990.
This publication includes requirements for the safe storage of flammable
and combustible liquids in underground mines other than coal mines.
Includes information on the design, installation, inspection, and
operation of storage facilities and equipment.
Available from the National Fire Protection Association as Item No. FM-
122-90 for $13.25. See last page for address and telephone number.
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Storage Vessels and Other Equipment. Series G: Design of Equipment, Volume 2,
American Institute of Chemical Engineers, 1986.
This book consists of self-study modules designed to be used in
independent study, continuing education courses, and traditional
classes .
Available from AlChE as ISBN 0-816669-0409-X for $40.00. See last page
for adc-3ss and telephone number.
3.2 PROCESS DESCRIPTION
Atmospheric Monitoring Equipment for Chlorine, edition 4, the Chlorine
Institute, February 1988.
This publication lists known equipment for monitoring chlorine
concentrations at breathing zones and ambient environments.
Available as Publication #73 from the Chlorine Institute for $12.00.
See last page for address and telephone number.
Blower and Exhaust Systems for Dust. Stock, and Vapor Removal or Conveying.
National Fire Protection Association, 1990.
This publication describes safety requirements for fans, ducts, duct
clearances, design, and dust collecting systems for removal or conveying
of flammable vapors, corrosive fumes, dust stock, and refuse.
Available from the National Fire Protection Association as Item No. FM-
91-90 for $15.50. See last page for address and telephone number.
Chlorine Pipelines, edition 2, the Chlorine Institute, April 1982.
This pamphlet contains information on the transportation of gaseous and
liquid chlorine in pipelines.
Available from the Chlorine Institute as publication #74 for $7.00. See
last page for address and telephone number.
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"Emergency Relief System (ERS) Design," Chemical EnEineering Progress. August
1985, pp. 53-56.
This article describes a practical approach for estimating vent size and
load requirements for downstream equipment. It is simple enough to be
used by nonspecialist engineers and can be applied to virtually unknovm
systems.
Journal is available commercially or from libraries.
Industrial Process Design for Pollution Control, volumes 1-7, American
Institute of Chemical Engineers, 1967-1975.
This series describes various process design strategies to minimize or
control emissions.
Available from AlChE for $18.00 per volume. See last page for address
and telephone number.
Mobile Lidar Svstem Developments and Operating Procedures. George W. Bethke.
EPA Environmental Sciences Research Lab, November 1979.
This report presents complete operating procedures for an improved
system of analysis, presentation, and recording of smoke plume
data.
Available from EPA (as document EPA 600/2-79-197) or NT1S (as PB80-
132715). See last page for address and telephone number.
National Fuel Gas Code. National Fire Protection Association, 1990.
This document updates safety requirements for fue] gas equipment
installations, piping, and venting. Provisions apply to all fuel gas
systems on residential, commercial, and industrial premises using
natural gas and LP-Gas at pressures up to and including 125 psi.
Available from the National Fire Protection Association as Item No. FM-
54-88 for $19.50. See last page for address and telephone number.
Operation of Chlorine Vaporizing Equipment, edition 3, the Chlorine Institute,
May 1987.
This publication contains information intended to assist in
selection, design, and safe operation of vaporizers.
Available from the Chlorine Institute as publication #9 for S10.00. See
last page for address and telephone number.
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-16-
Piping Design £or Process Plants. Howard F. Rase. New York: John Wiley and
Sons, inc. 1963.
This book describes and illustrates piping designs for various
processes. It also includes standards for piping, pipe
specification, fabrication, and arrangement.
Available at libraries (out of print).
Piping Systems ^for Drv Chlorine, edition 5, the Chlorine Institute, March
1985.
This booklet contains information on selected pipes, valves, and
fittings suitable for use with dry chlorine (gas or liquid).
Available as publication //6 from the Chlorine Institute for $10.00. See
last page for address and telephone number.
Process Instruments and Controls Handbook. D.M. Considine, ed. McGraw-Hill,
1985.
This handbook consists of 83 separate articles in 19 chapters which
cover temperature, pressure, flow, level, force, and other process
systems and instruments. It examines various instruments for systems
indication or control and explains their objectives, methods, and
limitations.
Available as ISBN 0-07-012436-1 commercially or from libraries.
Process Operations. Series G: Design of Equipmsnt, Volume 3, American
Institute of Chemical Engineers, 1987.
This is a self-study module designed co be used in independent study,
continuing education courses, and traditional classes.
Available from AIChE as ISBN 0-8169-0416-6 for $40.00. See last page
for address and telephone number.
Remote Monitoring of Gaseous Pollutants bv Differential Absorption Laser
Techniques. S.A. Ahmed et. al. New York: City University of New York Dept. of
Electrical Engineering. February 1980.
This report describes the single-ended laser radar (LIDAR) system
for detecting pollutants.
Available from EPA (as document EPA 600/2-80-049) or NTIS (as PB80-
179351). See last page for address and telephone number.
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The .State-of- the-Art Continuous Emission Monitoring Systems for. Power Plants
J.A. Ramberger, ed., American Society of Mechanical Engineers, 1988.
This publication describes recent developments in Continuous Emission
Monitoring and Systems for power plants.
American Society of Mechanical Engineers
22 Lawn Drive, Box 2300
Fairfield, New Jersey 07007-2300
201-882-1167, ext. 228
Available from ASME as Order No. H00441 for $16.00.
3 . 3 PROCESS HAZARDS
"Alarm and Shutdown Devices Protect Process Equipment," Edward J. Rasmussen.
Chemical Engineering. May 12, 1975, pp. 74-80.
This article describes operating conditions and suitable
applications for alarm and shutdown devices. It covers devices
monitoring pressure, flow, level, temperature, and vibration.
Journal is available commercially or from libraries.
Control of Emissions from Seals and Fittings .in Chemical Process Industries.
Van Wagenen, Harold. OSHA/NIOSH, 1982.
This book describes methods and equipment to reduce fugitive emissions
from seals and fittings.
Available as publication PB-82-18G-988/A04 from NTIS. See last page for
address and telephone number.
"Design for Process Safety," J.H. Tomfohode, Hydrocarbon Processing. December
1985, pp. 71-77.
This article examines a. number of design items which frequently become
the precursors of serious incidents. It reviews functional and safety
considerations and potential vulnerabilities. Main topics include
drains and vents, piping and equipment "pockets," small piping systems,
piping and equipment pressure rating specification "breaks," and various
safeguards.
Journal is available commercially or from libraries.
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-18-
Electrical Installations in Hazardous Locations. National Fire Protection
Association, 1988.
This publication is a working tool for inspectors, engineers,
manufacturers, and safety professionals evaluating the safety of
hazardous location electrical installations. Provides facts, and
practical advice for solving problems involving for example, the
prevention of ignition from static electricity and/or lightning.
Available from National Fire Protection Association as Item No. FM-HLH-
88 for $49.50. See last page for address and telephone number.
International Symposium on Runaway Reactions. American Institute of Chemical
Engineers, 1989.
This symposium focuses on basic considerations in chemical reactor
stability, evaluating reactor system safety, and design and operating
considerations for safe chemical reactor relief.
Available from AIChE as ISBN 0-8619-0460-X for $100.00. See last page
for address and telephone number.
Plant/Operation Progress: articles on chemical process safety issue, American
Institute of Chemical Engineers, July and October 1990.
These two monthly issues contain a series of articles on various
strategies, issues, and technologies in chemical safety. Topics include
management practice, process safety audits, public participation in risk
assessment, and accident prevention.
Journa.1 is available commercially or from libraries.
Prevention Reference Manual: User's Guide Overview for Controlling Accidental
Releases of Air Toxics. D.S. David, G.B. DeWolf, and J.D. Quass. EPA Air and
Energy Engineering Research Lab, July 1987.
The User's Guide, the first in a series of manuals, presents an
overview of available methods for identifying, evaluating, and
controlling hazards in facilities that use, manufacture, or store
acutely toxic chemicals that could be released into the
environment. Hazardous chemicals and their key characteristics
are discussed, followed by a discussion of the potential hazards
in process and physical plant design and in operational
procedures.
Available from EPA (as document EPA 600/8-87-028) or NTIS (as PB 87-
232112). See last page for address and telephone number.
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"Safety-relief-valve malfunction: Symptoms, causes, and cures," William A.
Scully. Chemical Engineering. August j.0, 1981, pp. Ill
This article examines common problems with safety relief valves
and lists four to twelve items to check in the event of leakage,
chattering, and premature popping of valves
Journal is available commercially or from libraries.
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-20-
4.0 CHEMICAL ACCIDENT PREVENTION
Loss .Prevention, volumes 1, 2, 4, 5, 6, 7, and 11, American Institute of
Chemical Engineers, 1967-1977.
These books discuss design strategies to prevent chemical releases
Available from AIChE for $22.00-$28.00. See last page for address and
telephone number.
Plant/Operation Progress: articles on chemical process safety, American
Institute of Chemical Engineers, July and October 1990.
These two monthly issues contain a series of articles on various
strategies, issues, and technologies in chemical safety. Topics include
management practice, process safety audits, public participation in risk
assessment, and accident prevention.
Journal is available commercially or from libraries.
Review of Emergency Systems, Environmental Protection Agency, 1988.
This document is a report to Congress on facility systems for
monitoring, detecting, and preventing releases of extremely hazardous
substances at facilities that produce, use or store them.
Available free of charge from EPA. See last page for address and
telephone number.
4.1 MANAGEMENT ACTIVITIES
Guidelines on Technical Management of Chemical Process. Safety. the Center for
Chemical Process Safety of the American Institute of Chemical Engineers, 1989.
This book describes twelve basic elements that must be considered in the
development of a management system in the context of plant design,
construction, operation, and management.
Available for $100.00 from, the American Institute of Chemical Engineers.
See last page for address and telephone number.
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Hazardous Material Spills Conference Proceedings. American Institute of
Chemical Engineers, L988.
Conference proceedings from a Chicago, Illinois meeting on prevention,
preparedness, and response. Papers deal with current developments in
legislation, regulation, programs, and technology. Topics include
emergency planning, disposal techniques, information management,
computer applications, training, and prevention.
Available from AIChE as ISBN 0-8169-0453-7 for $85.00. See last page
for address and telephone number.
Hazardous Uaste and Emergency Response. Occupational Safety and Health
Administration, 1989.
This 20-page publication discusses OSHA's requirements for hazardous
waste operations and emergency response at uncontrolled hazardous waste
sites and TSD facilities and summarizes the steps an employer must take
to protect the health and safety of workers in these environments.
Available as OSHA 3114 free of charge from the Occupational Safety and
Health Administration. See last page for address and telephone number.
"Implementing Process Safety Management Systems," Plant/Operations Progress,
October 1990, p. 226.
This article provides guidelines for putting management procedures to
work for process safety.
Available commercially from the American Institute of Chemical Engineers
or from libraries.
National Occupational Exposure Survey, voliime 3: Analysis of Management
Interview Responses, OSHA/NIOS.-L March 1988.
This volume provides analysis of industrial management responses to a
questionnaire regarding occupational safety by industry and plane size.
These analyses provide estimates of the numbers of employee and
facilities in the US operating under specific management policies in the
areas of safety and health.
Available from OSHA/NIOSH as DHHS/PUB/NIOSH-89-103. See last page for
address and telephone number.
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-22-
4.2 PROCESS OPERATION AND MAINTENANCE
Ammonia Plant Safety, volumes 13 through 29. American Institute of Chemical
Engineers, 1971-1989.
This series consists of papers presented at the annual meetings of
AIChE. They center on accidents, safety developments, and technical
improvements pertaining to safety in the ammonia industry.
Available from AIChE for $28.00-555.00. See last page for address and
telephone number.
Blower and Exhaust Svstems for Dust. Stock, and Vapor Removal or Conveying:,
National Fire Protection Association, 1990.
This publication describes safety requirements for fans, ducts, duct
clearances, design, and dust collecting systems for removal or conveying
of flammable vapors, corrosive fumes, dust stock, and refuse.
Available from National Fire Protection Association as Item No. FM-91-90
for $15.50. See last page for address and telephone number.
Cleaning or Safeguarding Small Tanks and Containers, National Fire Protection
Association, 1987.
This guide describes procedures for the safe removal of flammable
vapors, liquids, gases, or solids from small tanks or containers that
cannot be entered, and other safety measures.
Available from National Fire Protection Association as Item FM-327-87
for $13.25. See last page for address and telephone number.
"Safety-relief-valve malfunction: Symptoms, causes, and cures," William A.
Scully. Chemical Eneineering. August 10, 1981, pp. 111-114.
This article examines common problems with safety relief valves
and lists four to twelve items to check in the event of leakage,
chattering, and premature popping of valves.
Journal is available commercially or from libraries.
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4.3 HAZARD EVALUATION AND MODELING
Engineering Applications of Risk Analysis, F.A. Elia, Jr., and A. Moghissi,
American Society of Mechanical Engineers, 1988.
This book centers on understanding che concept of risk by the
engineering profession, regulatory authorities, and the general public.
Available as Order No. G00438 for $20.00 through:
American Society of Mechanical Engineers
22 Lawn Drive, box 2300
Fairfield, New Jersey 07007-2300
201-882-1167, ext. 228
Environmental Fate of Chlorine in the Atmosphere, edition 1, the Chlorine
Institute, April 1990.
This publication describes what happens to elemental chlorine when
released into the air. This report was prepared by Alliance
Technologies, Chapel Hill, North Carolina.
Available as publication #84 from the Chlorine Institute for $20.00.
See last page for address and telephone number.
"Evaluating Emergency Response Models for the Chemical Industry," by Daniel J
McNaughton, Gary G. Worley, and Paul M. Bodner. Chemical Engineering
Progress, January 1987, p. 46.
This article reviews the evaluation models and identification
databases suitable for validating the models. Vaporization and
dispersion models are among the models discussed.
Available commercially or from libraries.
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Guideline on Air Quality Models (revised). Environmental Protection Agency
1986.
This guideline recommends air quality modeling techniques that mav be
applied to air pollution control strategy evaluation and new source
reviews, including prevention of significant deterioration. It is
intended for use by EPA Regional offices in judging the adequacy of
modeling analyses performed by EPA, by State and local agencies, and bv
industry and its consultants. It also identifies modeling techniques
and data bases that EPA considers acceptable.
Available as EPA 450/2 -78-027R free of charge from the Environmental
Protection Agency or as PB86-2A5248 from the National Technical
Information Service. See last page for addresses and telephone numbers.
Guidelines for Chemical Process Quantitative Risk Analysis. Center for
Chemical Process Safety of the American Institute of Chemical Engineers. New
York: American Institute of Chemical Engineers.
This book provides the tools for reducing acute risks in a chemical
plant handling hazardous materials. It enables the manager or engineer
to make quantitative estimates of risk.
Available as ISBN 0-8169-0402-2 from the American Institute of Chemical
Engineers. See last page for address and telephone number.
Guidelines for Hazard Evaluation Procedures, prepared by Batelle Columbus
Division for the Center for Chemical Process Safety of the American Institute
of Chemical Engineers. ISBN # 0-8169-0399-9. New York: American Institute of
Chemical Engineers, 1985.
This book centers on procedures for design, construction, and
operation, including identification and analysis of hazards not
easily identified from pas~ experience. Largely, it lists
qualitative procedures for hazard identification, although some of
the procedures also can be used for quantitative analysis. The
most significant aspect of this book is in helping to apply the
proper hazard evaluation method to each process.
Available from the AIChE. See last page for address and telephone
number.
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Guidelines on Risk Analysis, edition 1, the Chlorine Institute, August 1989.
This publication provides information on the most recent safety concepts
concerning risks posed in the chlor-alkali industry.1 It also defines
risk analysis and how it is most applicable to the industry.
Available as publication #83 from the Chlorine Institute for $25.00
See last page for address and telephone number.
Handbook of Chemical Hazard Analysis Procedures, Federal Emergency Management
Agency.
This book describes a wide range of planning activities for
investigating the hazards in using and transporting dangerous chemicals.
It includes methods to investigate local hazards, chemical fire hazards,
probability analysis procedures, and planning for all types of hazardous
materials releases .
Available from the Federal Emergency Management Agency. See last page
for address and telephone number.
Hazardous Materials Incident Analysis, Federal Emergency Management Agency.
This 12-hour audiovisual course introduces a systematic method of
analyzing and assessing the potential effect of hazardous materials
involved in fires and other emergencies. Includes 454 color slides, 4
cassette tapes, 4 overhead transparency masters, and instructor's and
student's guides.
Available for loan by the Chemical Manufacturers Association as Item A-
0« at:
NCRIC
Chemical Manufacturers Associacion
2501 M Street, NW
Washington, DC 20037
Major Industrial Hazards: Their Appraisal and Control. John Withers, American
Society of Safety Engineers, 1988.
This document presents methods of risk estimation, measurement of
potential hazards against likely benefits, and other aspects of hazard
evaluation.
Available from American Society of Safety Engineers as Order 8803 for
$61.00. See last page for address and telephone number.
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-26-
Manaeing Risk - Systemic Loss Prevention for Executives, Vernon L. Grose,
American Society of Safety Engineers, 1987.
This publication presents risk analysis and cost with strong emphasis on
bottom line performance.
Available from American Society of Safety Engineers as Order 8715 for
S39.95. See last page for address and telephone number.
Proceedings of _the_. International Conference on Vapor Cloud Modeling. Center
for Chemical Process Safety of the American Institute of Chemical Engineers,
1987.
This book consists of proceedings of a conference held in Cambridge,
Massachusetts from November 2-4, 1987. This book covers field-scale
test modeling, source modeling, dispersion models, fire and explosion
modeling, and other topics.
Available as ISBN 0-8169-0424-3 from the American Institute of Chemical
Engineers. See last page for organization address and telephone number.
Profitable_R.lsk Control: The Winning Edge. William Allison, American Society
of Safety Engineers.
This publication centers on identifying risks to avoid accidents.
Topics considered include performance measurements, hazard
identification, loss control, and cost evaluation. Includes 100 release
case histories, with causes and effective risk controls.
Available from American Society of Safety Engineers as Order 8667 for
$35.00. See last page for address and telephone number.
Risk Assessment and Management: A Framework for Decision-Making, Environmental
Protection Agency, 1984.
This report centers on risk assessment and risk management at EPA. It
gives an overview of EPA's approach to decision-making for environmental
toxic chemical problems.
Available as EPA IMSD/87-0002 from the National Technical Information
Service. See last page for address and telephone number.
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-71 -
Technical Guidance for Hazards Analysis' Emergency Planning for Extremely
Hazardous Substances. Environmental Protection Agency, 1987.
This guide provides technical assistance on the assessment of lethal
hazards related to potential airborne releases of extremely hazardous
materials. The purpose of the document is to assist local emergency
planners in hazards analysis and specifically with local emergency
planning requirements.
Available free of charge from the Emergency Planning and Community
Right-To-Know Information Services. See last page for address and
teleohone'number..
4.4 RELEASE PREVENTION SYSTEMS
"Alarm and Shutdown Devices Protect Process- Equipment," Edward J. Rasmuss
Chemical Engineering. May 12, 1975, pp. 7^:-80.
This article describes operating conditions and suitable
applications for alarm and shutdown devices. It covers devices
monitoring pressure, flow, level, temperature, and vibration.
Journal is available commercially or from libraries.
Explosion Prevention Systems. National Fire Protection Association 1986.
This publication provides requirements for explosion prevention systems
based on reduced concentration of combustible material, as well as inert
gas systems, explosion suppression systems, and pressure containment.
Available from National Fire Protection Association as Item No. FM-69-86
for $15.50. See last page for address and telephone number.
"Safety-relief-valve malfunction: Symptoms, causes, and cures," William A.
Scully. Chemical Engineering. August 10, 1981, pp. 111-114.
This article examines common problems with safety relief valves
and lists four to twelve items to check in the event of leakage,
chattering, and premature popping of valves.
Journal is available commercially or from libraries.
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4.5 MITIGATION SYSTEMS
1990 Emereencv Response Guidebook/Guidebook for Hazardous Materials Incident:!
U.S. Department of Transportation. U.S. Government Printing Office, 1990.
This is a guidebook for emergency service vehicles for incidents
with hazardous materials. It includes advice for firefighters on
extinguishing methods and standard procedures for initial actions
to be taken to protect themselves and the public.
Available as DOT P 5800.4 fronr
U.S. Department of Transportation
Materials Transportation Bureau, DMT-11
Washington, DC 20590
Evaluation of the Efficiency of Industrial Flares: Background-Experimental
Design-Facility. D. Joseph et. al. Energy and Environmental Research Corp.,
August 1983.
The report summarizes the technical literature on the use of
industrial flares and reviews available emission estimates.
Technical critiques of past flare efficiency studies are provided.
Available from EPA (as document EPA 600/2-83-070) or NTIS (as PB83-
263723). See last page for address and telephone number.
Guidelines for Vapor Release Mitigation Richard W. Prugh, American Institute
of Chemical Engineers, 1988.
These guidelines provide information to help development and
communication of improved safety methods, practices, designs, and
procedures in the chemical process industry.
Available from AIChE as ISBN 0-8icS-0401-4 for $80.00. See last page
for address and telephone number.
Hazardous Materials Response Handbook. National Fire Protection Association,
1989.
This handbook covers haz-mat standards, expert commentary, and
supplements dealing with haz-raat response plans, decontamination, and
team training.
Available from National Fire Protection Association as Item No. FM-
472HB89 for $49.50. See last page for address and telephone number.
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Installation of Air Conditioning and Ventilating Svstems. National Fire
Protection Association, 1989.
This publication specifies installation requirements for air
conditioning and ventilating systems that restrict the spread of smoke
heat, and fire through duct systems, and minimize ignition sources.
Available from National Fire Protection Association as Item No. FM-90A-
89 for $15.50. See last page for address and telephone number.
Release Containment in Chlorine Plants. edition 1, the Chlorine Institute,
December 1983.
This pamphlet describes methods and techniques which have been commonlv
used in the chlorine industry to contain accidental chlorine releases
which could possibly occur in chlorine production plants.
Available as publication MIR-147 from the Chlorine Institute for 52.00
See last page for address and telephone number.
Responding to Hazardous Materials Incidents. National Fire Protection
Association, 1989.
This publication presents procedures and practices for mitigating
incidents. Covers decontamination, methods of mitigation, chemical
protective clothing, and safety.
Available from National Fire Protection Association as Item No. FM-471-
89 for $15.50. See last page for address and telephone number.
"The Use of Water Spray Barriers to Disperse Spills of Heavy Gases," Kieth
Moodie, Plant/Operations Progress. October, 1985, pp. 234-241.
This article describes the performance characteristics of full-scale
water-spray barriers when dispersing accidental spills of heavy gases.
Data from a series of trials establish that water spray barriers can
achieve a worthwhile enhancement of the rate of dispersion and dilution
of heavy gas spills.
Journal is available commercially or from libraries.
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5.0 ACCIDENT RELEASE INCIDENT INVESTIGATION
Accident Investigation for Supervisors. Ted Ferry, American Society of Safetv
Engineers.
This is a guide for accident investigation on short notice with limited
resources, and without major study. Includes systems approaches to
accident investigation, organization, interviews, and reports.
Available from American Society of Safety Engineers as Order 8726 for
S20.00. See last page for address and telephone number.
Accident Investigation Techniques. American Society of Safety Engineers, 1988.
This fifteen-minute audio-visual set describes key elements of the
accident investigation process. Includes a leader's guide, script,
cassette tape, point summary, and 70 slides.
Available from American Society of Safety Engineers as Order 8923 for
$135. See last page for address and telephone number.
Investigating Accidents WiEhT._STEP, Kingsley Hendrick and Ludwig Benner, Jr..
American Society of Safety Engineers, 1987.
This guide serves as a model for accident investigation from initiation
Co follow-up actions.
Available from American Society of Safety Engineers as Order 8701 for
S106.00. See last page for address and telephone number.
Modern Accident Investigation and Analysis. Ted Ferry, American Society of
Safety Engineers, 1988.
This book centers on accident investigation as a management tool.
Available from American Society of Safety Engineers as Order 8502 for
$57.50. See last page for address and telephone number.
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6.0 FACILITY EMERGENCY PREPAREDNESS AND PLANNING ACTIVITIES
A Guide to the Safe Handling of Hazardous Materials Accidents. STP 825,
American Society for Testing and Materials
This guide discusses Department of Transportation hazard classes, terms
used in describing the classes or the materials, and incident control
tactics. Includes a supplement, "Initial Emergency Assessment Initial
Response Action."
Available from American Society for Testing and Materials as ISBN 0-
803100261-5 or PCN 04-825000-31 for $24.00. See last page for address
and telephone number.
How to Prepare for Workplace EmerEencies. Occupational Safety and Health
Administration, 1988.
This 12-page booklet details the basic steps needed to prepare the
handle emergencies in the workplace. It is not intended to serve as an
all-inclusive safety program, but rather to provide guidelines for
planning for emergencies. It includes sections on evaluation, command,
communications, and other topics.
Available as OSHA 3088 free of charge from the Occupational Safety and
Health Administration. See last page for address and telephone number.
6.1 FACILITY EMERGENCY RESPONSE PLAN
Community Awareness and Emergency Response (CA2R~) : The Next Phase. Chemical
Manufacturers Association, 1990.
This document provides approaches and checklists for developing and
implementing local community awareness and emergency response plans.
Contains summaries of various approaches to coordinated emergency
response planning.
Available for §15.00 from the Chemical Manufacturers .Association. See
last page for address and telephone number. Request by title.
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Emergencv Response Plans for Chlorine Facilities, edition 3, the Chlorine
Institute, October 1990.
This publication includes information essential to the preparation or
updating of formal, written emergency control plans applicable to
chlorine-producing, chlorine-packaging, and chlorine-consuming
facilities.
Available as publication #64 for $10.00 from the Chlorine Institute.
See last page for address and telephone number.
"Emergency Response Procedures for Anhydrous Ammonia Vapor Release," Maurice
L. Greiner. Ammonia Plan Safety and Related Facilities. American Institute of
Chemical Engineers CEP Technical Manual v. 24 (1984), pp. 109-114.
This publication provides a detailed review of downwind ammonia
vapor adsorption tactics, developed for firefighters. It includes
a description of ammonia hazards and characteristics, case
histories, and personal protection information.
Available from AIChE. See last page for address and telephone number.
Guide for Development of State and Local Emergency Operations Plans. Federal
Emergency Management Agency, 1985.
This civil preparedness guide provides information for emergency
management planners and for State and local government officials on
FEMA's concept of emergency operations planning under the Integrated
Emergency Management System.
Available as Document number CPG-1/Item #8-0044 free of charge from the
Federal Emergency Management Agency. See last page for address and
telephone number.
Guide for the Review of State and Local Emergency Operations Plans. Federal
Emergency Management Agency, 1988.
This civil preparedness guide provides State Emergency Management Agency
personnel with a practical and uniform means to identify provisions to
be addressed in State and local emergency operations plans. It also
provides FEMA personnel with a standard, comprehensive, and practical
instrument to use in reviewing and determining the consistency of draft
plans.
Available free of charge as CPG 1-8 from the Federal Emergency
Management Agency. See last page for address and telephone number.
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Hazardous M_aterials Response Handbook, National Fire Protection Association,
1989.
This handbook covers haz-mac standards, expert commentary, and
supplements dealing wich haz-mat response plans, decontamination, and
team training.
Available from National Fire Protection Association as Item No. FM-
472HB89 for $49.50. See last page for address and telephone number.
Preparing for Emergency Planning. National Association of Manufacturers, 1986
This is a guide for plant managers that describes basic provisions of
hazardous substance laws.
Available from the National Association of Manufacturers as Catalog #046
for $21.95. See last page for address and telephone number.
A Primer for Preparedness for Acute Chemical Emergencies. Kathleen J. Tierney
Columbus: The Disaster Research Center of The Ohio State University, 1980.
This paper integrates social scientific research on planning for
chemical emergencies with general community disaster planning.
The result is a guide for community and facility action.
Available from the Disaster Research Center of The Ohio State
University, Columbus, Ohio 43104.
6.2 EMERGENCY RESPONSE EXERCISES AND SIMULATIONS
Guide to Exercises in Chemical Emergency Preparedness Programs. Environmental
Protection Agency, 1988.
This series of three bulletins provides an overview of the major types
of exercises and describes some resources currently available for
conducting exercises.
Available free of charge from the Emergency Planning and Community
Right-To-Know Information Services. See last page for address and
telephone number.
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Hazardous Materials Exercise Evaluation Methodology CHM-EEM) and Manual.
Federal Emergency Management Agency, 1989.
This two-pare document is designed to assist State and local governments
in the comprehensive evaluation of hazardous materials exercises. The
document is the product of a year-long cooperative effort between FEMA
Headquarters and its regional offices. It is a series of modules for
the evaluation of 15 major exercise objectives covered by the plans
prepared using FEMA's Hazardous Materials Emergency Planning Guide, or
NRT-1.
Available as HM-EEM free of charge from the Federal Emergency Management
Agency. See last page for address and telephone number.
Haz-mats! Case Studies for Emergency Responders. National Fire Protection
Association, 1989.
This is a training film that centers on response procedures and
strategies. This film uses four haz-mat emergencies to teach emergency
response teams. Includes Instructor's Guide with reports, lesson plans,
drills, and other materials.
Available from National Fire Protection Association as Item No. FM-FL-73
(Film) for $649.50, or Item No. FM-FL-73V (3/4 », VHS, or Betamax
videotape) for $549.50. See last page for address and telephone number.
6.3 FIRE, EVACUATION, AND RESCUE CORRIDORS
1990 Emergency Response Guidebook for Hazardous Materials Incidents. U.S.
Department of Transportation. U.S. Government Printing Office, 1990.
This is a guidebook for emergency service vehicles for incidents
with hazardous materials. It includes advice for firefighters on
extinguishing methods and standard procedures for initial actions
to be taken to protect themselves snd the public.
Available as DOT P 5800.4 from:
U.S. Department of Transportation
Materials Transportation Bureau, DHT-11
Washington, DC 20590
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35-
Automatic Fire Detectors, National Fire Protection Association 1990.
This publication includes minimum performance, location, mounting,
testing, and maintenance requirements of automatic fire detectors.
Available from National Fire Protection Association as Item No. FM-72E-
90 for $19.50. See last page for address and telephone number.
Evacuation: An Assessment of Planning and Research. Federal Emergency
Management Agency, 1987.
The purpose of this research was to assess issues and criticism of
evacuation planning for all hazards under an integrated emergency
management concept, and to review research that addresses those issues.
The work identifies gaps in knowledge about evacuation planning issues
and the research that could fill those gaps.
Available free of charge from FEMA as item // 8-0664. See last page for
address and telephone number.
Evaluation of Firefighting. Foams as Fire Protection for Alcohol Containing
Fuels, First Edition. American Petroleum Institute, 1985.
This publication details the results of an API-sponsored study of the
fire procection provided by fire fighting foams on fires containing
alcohol or polar additives. These additives are known to be foam-
destructive. This publication clarifies information on generic foam
classes and application rates required to suppress fires involving these
solvents, which are commonly added to unleaded gasolines. 71 pages.
Available from American Petroleum Institute as publication Publ 2309,
item # 855-2300 for $17.00. See last page for address and telephone
number.
Hazardous Chemicals Data. National Fire Protection Association.
This publication specifies life and fire hazard precautions for
chemicals which pose a health hazard, reactivity rating, or fire
fighting problem.
Available from the National Fire Protection Association as Item No. FM-
49-75 for $17.50. See last page for address and telephone number.
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Life Safety Code, National Fire Protection Association 1988.
This publication describes construction, protection, and occupancy
features necessary to minimize danger to life from fire, smoke, fumes,
and panic. Identifies criteria for the design of egress facilities to
permit prompt escape from buildings, or where desirable, into safe areas
within the building.
Available from National Fire Protection Association as Item No. FM-
10188SB for $24.50. See last page for address and telephone number.
Portable Fire Extinguishers (Audio-Visual Tape), American Petroleum institute.
This tape covers the design and operation of water, carbon dioxide,
foam, halon, dry chemical, and dry powder extinguishers. Program also
discusses fire-fighting techniques for portable extinguishers.
Available as Title code 3503 through:
Howell Training Company
5201 Langfield Road
Houston, TX 77040
1-800-527-1581
Proceedings of the Conference on In-Place Protection During Chemical
Emergencies: November 30-December 1, 1988, U.S. EPA, FEMA, and Resources for
the Future, 1989.
This book describes discussions and conclusions reached at a conference
on in-place procection (i.e., going indoors and staying in). Results
show that in-place protection may be more appropriate in certain
instances of chemical release. The major aim of the conference was to
begin to identify and develop guidance and training that the federal
government can provide to local planners and responders for use in in-
place protection. Sections discuss field expsrier.ee, related research,
industry perspective, public planning and preparedness, and emergency
response.
Available for $4.00 from Resources for the Future, 1616 P Street, NW,
Washington, D.C., 20046, or at 202-328-5060.
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6.4 EMERGENCY EQUIPMENT PROVISIONS
"Emergency Response Procedures for Anhydrous Ammonia Vapor Release," Maurice
L. Greiner. Ammonia Plan Safety and Related Facilities. American Institute of
Chemical Engineers CEP Technical Manual v. 24 (1984), pp. 109-114.
This publication provides a detailed review of downwind anunonia
vapor adsorption tactics, developed for firefighters. It includes
a description of ammonia hazards and characteristics, case
histories, and personal protection information.
Available from AlChE. See last page for address and telephone number.
Evaluation of Firefighting Foams as Fire Protection for Alcohol Containing
Fuels. First Edition. American Petroleum Institute, 1985.
This publication details the results of an API-sponsored study of the
fire protection provided by fire fighting foams on fires containing
alcohol or polar additives. These additives are known to be foam-
destructive. This publication clarifies information on generic foam
classes and application rates required to suppress fires involving these
solvents, which are commonly added to unleaded gasolines. 71 pages.
Available from American Petroleum Institute as publication Publ 2309,
item # 855-2300 for $17.00. See last page for address and telephone
number.
NFPA 11C: Mobile,Foam Apparatus. National Fire Protection Association.
This document outlines the minimum requirements for the design,
approval, testing, inspection, operation, and maintenance of mobile foam
apparatus.
Available from National Fire Protection Association as Item No. FM-11C-
90 for $13.25. See last page for address and telephone number.
NFPA 12: Carbon Dioxide Extinguishing Systems. National Fire Protection
Association.
This document covers design, installation, testing, approval, operation
and maintenance for total flooding, local application, and hose line
systems.
Available from National Fire Protection Association as Item No. FM-11C-
90 for $13.25. See last page for address and telephone number.
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Personal Protective Equipment, Occupational Safety and Health Administration,
1990.
This 18-page booklet discusses those types of equipment most commonly
used for protection of the head, including eyes and ears; the torso;
arms and hands; and feet. The use of equipment to protect against life-
threatening hazards is also discussed.
Available as OSHA 3077 free of charge from the Occupational Safety and
Health Administration. See last page for address and telephone number.
Portable Fire Extinguishers (Audio-Visual Tape), American Petroleum Institute.
This tape covers the design and operation of water, carbon dioxide,
foam, halon, dry chemical, and dry powder extinguishers. Program also
discusses fire-fighting techniques for portable extinguishers.
Available as Title code 3503 through:
Howell Training Company
5201 Langfield Road
Houston, TX 77040
1-800-527-1581
Respiratory Protection. Occupational Safety and Health Administration, 1988.
This 15-page booklet presents information on respiratory equipment that
complements relevant safety and health regulations and manufacturers'
requirements.
Available as OSHA 3079 free of charge from the Occupational Safety and
Health Administration. See last page for address and telephone number.
Standards on Vapor-Protective Suits for Hazardous Cherleal Emergencies.
National Fire Protection Association, 1990.
This document lists minimum design, performance, testing, and
documentation requirements for vapor-protective suits for protection
from exposure to specified chemicals in vapor and liquid splash
environments.
Available from National Fire Protection Association as Item No. FM-1991-
90 for §13.25. See last page for address and telephone number.
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6.5 EHERGENCY RESPONSE CHAIN OF AUTHORITY
Hazardous Materials' Managing the Incident, by Gregory G. Noll, Michael S.
Hiiaebrand, James G. Yvorra, 1988.
This textbook describes each step a command-level emergency responder
must cake to manage a haz-mat incident, including coordination with
various other responders. Volumes available: Textbook ($25.00),
Instructor's Guide ($15.00), and Workbook ($14.00).
Available by title from Fire Protection Publications. See last page for
address and telephone number.
National Interagencv Incident Management System: Incident Command Svstem
Position Manuals. 1989.
These booklets describe roles and responsibilities of various actors in
the response to a hazardous materials incident. The volumes cover the
Operations Section, Planning Section, Logistics Section, Command
Section, and Finance Section of a response effort.
Available as a set for $20.00 from Fire Protection Publications. See
last page for address and telephone number.
6.6 EMERGENCY RESPONSE MANAGEMENT PROCEDURES
The CEO's Disaster Survival Kit: a Common-Sense Guide for Local Government
Chief Executive Officers. Federal Emergency Management Agency, 1988.
This book serves to assist CEOs in basic organization planning for an
incident. It encourages the CEO to develop management tools and to plan
for his or her roles and responsibilities in the event of a disaster.
Available as FA-91 free of charge from the Federal Emergency Management
Agency. See last page for address and telephone number.
CHLOREP: Situation Assessment and Planning. National Safety Council.
This 15-minute VHS demonstrates CHLOREP, a procedure for alerting proper
authorities and containing chlorine leaks.
National Safety Council
&UU North Michigan Ave.
Chicago, Illinois 60611
Available from the National Safety Council as item No. 19010-2222 for
$350.00.
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-4C-
"Emergency Response Procedures for Anhydrous Ammonia Vapor Release," Maurice
L. Greiner. Ammonia Plan, Safety and Related Facilities, .American Institute of
Chemical Engineers CE? Technical Manual v. 24 (1984), pp. 109-114.
This publication provides a detailed review of downwind ammonia
vapor adsorption tactics, developed for firefighters. It includes
a description of ammonia hazards and characteristics, case
histories, and personal protection information.
Available from AlChE. See last page for address and telephone number.
Evacua_tion' An Assessment of planning and Research, Federal Emergency
Management Agency, 1987.
The purpose of this research was to assess issues and criticism of
evacuation planning for all hazards under an integrated emergency
management concept, and to review research that addresses those issues.
The work identifies gaps in knowledge about evacuation planning issues
and the research that could fill those gaps.
Available free of charge from FEMA as item // 8-0664. See last page for
address and telephone number.
Hazardous Materials Response Handbook, National Fire Protection Association,
1989.
This handbook covers haz-mat standards, expert commentary, and
supplements dealing with haz-mat response plans, decontamination, and
team training.
Available from National Fire Protection Association as Item No. FM-
472HB89 for $49.50. See last page for address and telephone number.
6.7 EMERGENCY COMMUNICATION NETWORK WITHIN TEE FACILITY
Installation. Maintenance, and Use of Notification Appliances for Protective
Signaling Systems. National Fire Protection Association, 1989.
This guide provides recommendations for the performance of notification
appliances that are used with protective signaling systems.
Available from National Fire Protection Association as Item No. FM-72G-
89 for $13.25. See last page for address and telephone number.
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6.8 EMERGENCY RESPONSE PERSONNEL TRAINING REQUIREMENTS
Airport/Community Emergency Planning, National Fire Protection Association
1986.
This publication provides recommendations for emergency planning
procedures, including how no plan for using personnel from all concerned
agencies in an emergency and how to establish adequate emergency
training programs.
Available from National Fire Protection Association as Item No. FM-424M-
86 for $17.50. See last page for address and telephone number.
The Digest of Federal Training Programs in Hazardous Materials. Federal
Emergency Management Agency, 1987.
This document is a catalog of information on all of the Federal training
now available concerning hazardous materials.
Available as Document number FEMA 134/July 1987 free of charge from the
Federal Emergency Management Agency. See last page for address and
telephone number.
Guide for Fighting Fires in and Around Petroleurn Storage,Tanks, Second
Edition. American Petroleum Institute, 1988.
This is a guide'for training employees to successfully attack and
extinguish various types of petroleum storage tank fires. 30 pages.
Available from American Petroleum Institute as item # 855-20210 for
S8.00. See last page for address and telephone number.
Proceedings of the 1989 National Conference on Hazardous Materials
Federal Emergency Management Agency, 19S9.
The purpose of the conference was to facilitate the exchange of ideas
and information about hazardous materials training.
Available free of charge from FEMA as item ft 6-0358. -See last page for
address and telephone number.
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Professional Competence of Responders to Hazardous Materials Incidents.
National Fire Protection Association, 1989.
This document lists training and capabilities that are required at
various levels of response to hazardous materials incidents, including
the First Responder Awareness and Operational levels; the Technical
level; and the Specialist level. The Appendix deals with management of
an incident.
Available from National Fire Protection Association as Item No. FM-472-
89 for $13.25. See last page for address and telephone number.
6.9 FOLLOW-UP RELEASE PROCEDURES
Accident Investigation for Supervisors. Ted Ferry, American Society of Safety
Engineers.
This is a guide for accident investigation on short notice with limited
resources, and without major study. Includes systems approaches to
accident investigation, organization, interviews, and reports.
Available from American Society of Safety Engineers as Order 8726 for
$20.00. See last page for address and telephone number.
Modern Accident Investigation and Analysis. Ted Ferry, American Society of
Safety Engineers, 1988.
This book centers on accident investigation as a management tool.
Available from American Society of Safety Engineers as Order 8502 for
$57.50. See last page for address and telephone number.
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-43-
7.0 COMMUNITY AND FACILITY EMERGENCY RESPONSE PLANNING ACTIVITIES
Community Awareness and Emergency Response (CAER) Resource Disk. Chemical
Manufacturers Association, 1990.
This comprehensive resource guide for implementing the CAER process is
stored on an IBM-compatible computer disk. Provides the CAER
"Responsible Care Code of Management Practices" with examples of
activities for each element, cross-referenced with associated printed
and audio-visual materials, It also includes a database of CAER groups,
SERCs , EPA, and OSHA offices. Specify 5 1/4-inch or 3 1/2-inch disk.
Available for $22.50 from the Chemical Manufacturers Association. See
last page for address and telephone number. Request by title.
Plant/Operation Progress: articles on chemical process safety, American
Institute of Chemical Engineers, July and October 1990.
These two monthly issues contain a series of articles on various
strategies, issues, and technologies in chemical safety. Topics include
management practice, process safety audits, public participation in risk
assessment, and accident prevention.
Journal is available commercially or from libraries.
7.1 FACILITY PLANNING AND OUTREACH ACTIVITIES WITH COMMUNITY
Community Awareness and Emergency Response (CAER) Resource Disk. Chemical
Manufacturers Association, 1990.
This comprehensive resource guide for implementing the CAER process is
stored on an IBM-compatible computer disk. Provides- the CAER
"Responsible Care Code of Management Practices" with examples of
activities for each element, cross-referenced with associated printed
and audio-visual materials, It also includes a database of CAER groups,
SERCs, EPA, and OSHA offices. Specify 5 1/4-inch or 3 1/2-inch disk.
Available for $22.50 from the Chemical Manufacturers'Association. See
last page for address and telephone number. Request by title.
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Communitv Awareness and Hmergencv Response (CAERV The Next Phase. Chemical
Manufacturers Association, 1990.
This document provides approaches and checklists for developing and
implementing local community awareness and emergency response plans.
Contains summaries of various approaches to coordinated emergency
response planning.
Available for $15.00 from the Chemical Manufacturers Association. See
last page for address and telephone number. Request by title.
Emergency Response Plans for Chlorine Facilities, edition 3, the Chlorine
Institute, October 1990.
This publication includes information essential to the preparation or
updating of formal, written emergency control plans applicable to
chlorine-producing, chlorine-packaging, and chlorine-consuming
facilities.
Available as publication //64 for $10.00 from the Chlorine Institute.
See last page for address and telephone number.
Plant Manager's Network Guide. Chemical Manufacturers Association, 1990.
This booklet provides facility managers with ideas to develop outreach
activities with their colleagues at nearby plants, or with leaders from
other industries, to help the chemical industry become a visible,
active, and valuable member of the community.
Available free of charge from the Chemical Manufacturers Association.
See last page for address and telephone number. Request by title
A Primer for Preparedness for Acute Chemical Emergencies. Kathleen J. Tierney.
Columbus: The Disaster Research Center of The Ohio State University, 1980.
This paper integrates social scientific research on planning for
chemical emergencies with general community disaster planning.
The result is a guide for community and facility action.
Available from the Disaster Research Center of The Ohio State
University, Columbus, Ohio 43104
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-45-
Pjroceedings of the Conference on In-Place Protection Durin£ Chemical
Emergencies: November 30-December 1, 1988, U.S. EPA, FEMA, and Resources for
the Future, 1989.
This book describes discussions and conclusions reached at a conference
on in-place protection (i.e , going indoors and staying in) Results
show that in-place protection may be more appropriate in certain
instances of chemical release. The major aim of the conference was to
begin to identify and develop guidance and training that the federal
government can provide to local planners and responders for use in in-
place protection. Sections discuss field experience, related research.
industry perspective, public planning and preparedness, and emergency
response.
Available for $4.00 from Resources for the Future, 1616 P Street, N'W,
Washington, D.C., 20046, or at 202-328-5060.
7.2 LOCAL/COKMUNITY EMERGENCY RESPONSE PLAN
Airport/Communitv Emergency Planning. National Fire Protection Association
1986.
This publication provides recommendations for emergency planning
procedures, including how to plan for using personnel from all concerned
agencies in an emergency and how to establish adequate emergency
training programs.
Available from National Fire Protection Association as Item No. FM-424M-
86 for $17.50. See last page for address and telephone number.
Chemical Emergency Preparedness, Program: Interim Guidance. Washington, DC:
Environmental Protection Agency. November 1985.
This document provides the public and scate arid, local officials
with information to assist them in planning how to respond to
accidental releases of acutely toxic chemicals. Includes
information on organizing the community, gathering site-specific
information, contingency plan development, and contingency plan
appraisal.
Available from libraries (out of print) as document EPA 560/7-85-012.
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.46-
Criteria for Review of Hazardous Materials Emergency Plans. National Response
Team of the National Oil and Hazardous Substances Contingency Plan, 1988.
This document provides guidance that may be used in the review of
emergency response plans.
Available as document NRT-lA from the Emergency Planning and Community
Right-To-Know Information Services. See last page for address and
telephone number.
Developing a Hazardous Materials Exercise Program: a Handbook for State and
Local Officials f.NRT-_2). National Response Team, 1990.
This publication describes different types of response and planning
exercises, how they are conducted, how to draw on them, and additional
resources to help in preparing for emergency response. It includes
step-by-step management exercises for decisionmaking.
Available free of charge as NRT-2 from the Emergency Planning and
Community Right-To-Know Information Services. See last page for address
and telephone number.
Evacuation: An Assessment of Planning and Research. Federal Emergency
Management Agency, 1987.
The purpose of this research was to assess issues and criticism of
evacuacion planning for all hazards under an integrated emergency
management concept, and to review research that addresses those issues.
The work identifies gaps in knowledge about evacuation planning issues
and the research that could fill those gaps.
Available free of charge from FEMA as item # 8-0664. See last page for
address and telephone number.
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Fire Service Emergency Management Handbook. International Association of Fire
Chiefs.
This is a guide for fire chiefs and emergency medical personnel to
strengthen planning and to aid effective emergency management at the
community level. It includes principles of developing, evaluating, and
revising community emergency planning activities; fire and emergency
medical service responsibilities; and effective emergency management
organization are covered. It also covers special problems such as
funding and providing technical resources. Checklists for planning
emergency situations are provided. 228 pages.
Available for $9.00 through:
International Association of Fire Chiefs Foundation
Suite 10B
101 East Holly Avenue
Sterling, VA 22170
Guide for Development of State, and Local Emergency Operations Plans. Federal
Emergency Management Agency, 1985.
This civil preparedness guide provides information for emergency
management planners and for State and local government officials on
FEMA's concept of emergency operations planning under the Integrated
Emergency Management System.
Available as Document number CPG-I/Item #8-0044 free of charge from the
Federal Emergency Management Agency. See last page for address and
telephone number.
Guide for the Review of State and Local Emergency Operations Flans. Federal
Emergency Management Agency, 1988.
This civil preparedness guide provides State Emergency Management Agency
personnel with a practical and uniform means to identify provisions to
be addressed in Stace and local emergency operations plans. It also
provides FEMA personnel with a standard, comprehensive, and practical
instrument to use in reviewing and determining the consistency of draft
plans.
Available as CPG 1-8 free of charge from the Federal Emergency
Management Agency. See last page for address and telephone number.
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-48
Hazard Identification. Capability Assessment, and Multi-Year Development Plan
for Local Government. Federal Emergency Management Agency, 1987.
This publication lists instructions and forms for completing local
Hazard Identification, Capability Assessment, and Multi-Year Development
Plan.
Available free of charge from FEMA as item ft 8-0423. See last page for
address and telephone number.
Hazardous Materials Emergency Planning Guide. National Response Team, 1987.
This book, known as NRT-1, provides local authorities with a detailed
overview of efforts required for selecting and organizing an emergency
planning team, defining the tasks of that team, developing the plan and
individual plan elements, and testing and maintaining the plan.
Available as NRT-1 free of charge from the Emergency Planning and
Community Right-To-Know Information Services. See last page for address
and telephone number.
Hazardous Materials: Managing the Incident, by Gregory G. Noll, Michael S.
Hildebrand, James G. Yvorra, 1988.
This textbook describes each step a command-level emergency responder
must take to manage a haz-mat incident, including coordination with
various other responders. Volumes available: Textbook ($25.00),
Instructor's Guide ($15.00), and Workbook ($14.00).
Available by title from Fire Protection Publications. See last page for
address and telephone number.
Integrated Emergency Management Information System flEMIS). Federal Emergency
Management Agency.
This computer system combines a resource data base, multiple simulation
models, communicacions, and color graphics to provide a fully integrated
planning, exercising, and real-time tool for the management of accident
and disaster response.
Available from the Federal Emergency Management Agency. See last page
for address and telephone number.
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National Interazencv Incident Management Svstenr .Incident Command System
Position Manuals. 1989.
These booklets describe roles and responsibilities of various actors in
the response to a hazardous materials incident. The volumes cover the
Operations Section, Planning Section, Logistics Section, Command
Section, and Finance Section of a response effort.
Available as a set for $20.00 from Fire Protection Publications. See
last page for address and telephone number'.
Technical Guidance for Hazards Analysis' Emergency Planning for Extremely
Hazardous Substances, Environmenfal Protection Agency, 1987.
This guide provides technical assistance on the assessment of lethal
hazards related to potential airborne releases of extremely hazardous
materials. The purpose of the document is to assist local emergency
planners in hazards analysis and specifically with local emergency
planning requirements.
Availab'le free of charge from the Emergency Planning and Community
Right-To-Know Information Services. See last page for address and
telephone number.
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-50-
8.0 PUBLIC ALERT AND NOTIFICATION PROCEDURES
"Alarm and Shutdown Devices Protect Process Equipment," Edward J. Rasmussen
Chemical Engineering. May 12, 1975, pp. 74-80
This article describes operating conditions and suitable
applications for alarm and shutdown devices. It covers devices
monitoring pressure, flow, level, temperature, and vibration.
Journal is available commercially or from libraries.
Emergency Warning Svstems Guidebook. Chemical Manufacturers Association, 1990.
This guidebook offers generic advice on types of warning systems
available and guidelines for selecting a system. Compiled by industry
representatives experienced in designing and implementing emergency
warning systems and reviewed and approved by FEMA and the EPA.
Available for $7.50 from che Chemical Manufacturers Association. See
last page for address and telephone number. Request by citle.
Guide to Preparing Emergency Public Information. Federal Emergency Management
Agency, 1987.
This guide is intended to assist those who prepare public information
documents, and centers on improving the content and distribution of
emergency preparedness messages.
Available as FEMA REP-11 from the Federal Emergency Management Agency.
See last: page for address and telephone number.
Installation, Maintenance, and Use of frotification Appliances for Protective
Signaling Systems. National Fire Protection Association, 1P89.
This guide provides recommendations for the performance of notification
appliances that are used with protective signaling systems.
Available from National Fire Protection Association as Item No. FM-72G-
89 for $13.25. See last page for address and telephone number.
Review of Emergency Svstems. Environmental Protection Agency, 1988.
This document is a report to Congress on facility systems for
monitoring, detecting, and preventing releases of extremely hazardous
substances and to alert the public to a release.
Available from EPA. See last page for address and telephone numoer.
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ALPHABETICAL INDEX OF REFERENCE TITLES
1990 Emergency Response Guidebook/Guidebook for Hazardous Materials Incidents
4.5 Mitigation Systems -- p. 28, 6.3 Fire, Evacuation, and Rescue Corridors -
p. 34.
Accident Investigation for Supervisors, 5.0 Accident Release Incident
Investigation -- p 30, 6.9 Follow-up Release Procedures/Investigation -- p
42.
Accident Investigation Techniques. 5.0 Accident Release Incident Investigation
-- p. 30.
AirContaminants -- Permissible Exposure Limits (Title 29 Code of Federal
Regulations Part 1910.1000), 2.1 Overview of Hazards for Chemical(s)' being
Audited -- p, 4.
Airport/CommunityEmergency Planning, 6.8 Emergency Response Personnel
Training Requirements -- p. 41, 7.2 Local/Community Emergency Response Plan
p. 45.
"Alarm and Shutdown Devices Protect Process Equipment", 3.3 Process Hazards
p. 17, 4.4 Release Prevention Systems -- p. 27, 8.0 Public Alert and
Notification Procedures -- p. 50.
Ammonia Plant Safety. 4.2 Process Operation and Maintenance -- p. 22.
Atmospheric Monitoring Ecuipment for Chlorine. 3.2 Process Description -- p.
14.
Automatic Fire Detectors. 6.3 Fire,' Evacuation, and Rescue Corridors -- p. 35,
Basic Classification of Flammableand Combustible Liquids. 2.1 Overview of
Hazards for Cheraical(s) Being Audited -- p. 5.
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Blower and Exhaust Systems for Dust. Stock, and Vapor Removal or Conveying
3.2 Process Description -- p. 14, 4.2 Process Operation and Maintenance -- p.
22.
The CEO's Disaster Survival Kit: a Common-Sense Guide for Local Government
Chief Executive Officers, 6.6 Emergency Response Management Procedures -- p.
39.
Chemical_ Emergency Preparedness Program: Interim Guidance, 7.2 Local/Community
Emergency Response Plan -- p. 45.
Chemical Special Emphasis Program: Final Report. 1.0 General -- p. 1.
CHLORE?' Situation Assessment and Planning. 6 6 Emergency Response Management
Procedures - - p. 39.
Chlorine Pipelines. 3.2 Process Description -- p. 14.
Classification of Class I Hazardous Locations for Electrical Installations in
Chemical Plants. 2.1 Overview of Hazards for Chemical(s) Being Audited -- p.
5.
Classification of Gases, Vapors and Dusts for Electrical Equipment in
Hazardous (Classified) Locations. 2.1 Overview of Hazards for Chemical(s)
Being Audited -- p. 5.
Cleaning or Safeguarding Small Tanks and Containers, 3.1 Storage and
Handling -- p. 10, 4.2 Process Operation and Maintenance -- p. 2?.
Community Awareness and Emergency Response (CAER): The Next Phase. 6.1
Facility Emergency Response Plan -- p. 31, 7.1 Facility Planning and Oucreach
Activities with Community -- p. 44.
Community Awareness and Emergency Response (CAER) Reso_urce Disk. 7.0 Community
and Facility Emergency Response Planning Activities -- p. 43, 7.1 Facility
Planning and Outreach Activities with Community -- p. 43.
A Condensed Guide to Chemical Hazards (CHRIS I), 2.1 Overview of Hazards for
Chemical(s) Being Audited -- p. 5.
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Conducting Fire Inspections: A Guidebook for Field Use. 1.0 General --pi
Control of Emissions from Seals and Ficrings ir Chemical Process Industries,
3.3 Process Hazards --p. 17.
Criteria for Review of Hazardous Materials Emergency Plans, 7.2
Local/Communicy Emergency Response Plan -- p. 46.
Dangerous Properties of Industrial Materials. 2.1 Overview of Hazards for
Chemical(s) Being Audited -- p. 5.
"Design for Process Safety," 3.3 Process Hazards, p. 17.
Developing a Hazardous Materials Exercise Program: A Handbook for State and
Local Officials (NRT-2). 7.2 Local/Communicy Emergency Response Plan -- p. 46.
The Digest of Federal Training Programs in Hazardous Materials. 6.8 Emergency
Response Personnel Training Requirements -- p. 41.
Electrical Installations in Hazardous Locations. 3.3 Process Hazards -- p. 18
"Emergency Relief System (ERS) Design,I: 3.2 Process Description -- p. 15.
Emergency Response Plans for Crlorine Facilities, 6.1 Facility Lmergency
Response Plan -- p. 32, 7.1 Facility Planning and Outreach Activities with
Community -- p. 44.
"Emergency Response Procedures for Anhydrous Ammonia Vapor Release", 6.1
Facility Emergency Response Plan -- p. 32, 6.4 Emergency Equipment
Provisions -- p. 37, 6.6 Emergency Response Management Procedures -- p. 40,
Emergency Warning Systems Guidebook. 8.0 Public Alert and Notification
Procedures -- p. 50.
Encyclopedia of Chemical Technology. 2.1 Overview of Hazards for Chemical(s)
Being Audited -- p. 6.
Engineering Applications of Risk Analysis. 4.3 Hazard Evaluation and
Modeling - - p. 23.
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Environraental Fate of Chlorine in the Atmosphere. 4.3 Hazard Evaluation and
Modeling -- p. 23.
Evacuation' An Assessment of Planning and Research, 6.3 Fire, Evacuation, and
Rescue Corridors -- p. 35, 6.6 Emergency Response Management Procedures -- p.
40, 7.2 Local/Community Emergency Response Plan -- p. 46.
"Evaluating Emergency Response Models fox the Chemical Industry", 4.3 Hazard
Evaluation and Modeling -- p. 23.
Evaluation of Firefighcing Foams as Fire Protection for Alcohol Containing
Fuels, First Edition, 6.3 Fire, Evacuation, and Rescue Corridors -- p. 35, 6.4
Emergency Equipment Provisions -- p. 37
Evaluation of the Efficiency of Industrial Flares: Background-Experimental
Design-Facility, 4.5 Mitigation Systems -- p. 28.
Explosion Prevention Systems. 4.4 Relears Prevention Systems -- p. 27.
Explosive Materials Code. 2.1 Overview < £ Hazards for Chemical(s) Being
Audited - - p. 6.
Fire Hazard Properties of Flammable Liquids, Gases, and Volatile Solids. 2.1
Overview of Hazards for Chemical(s) Being Audited -- p. 6.
Fire Protection Considerations for the Design and Operation of Liquified
Petroleum Gas CLPG) Storage Facilities. First Edition. 3.1 Storage and
Handling -- p. 10.
Fire Protection Guide on Hazardous Materials. 2.1 Overview of Hazards for
Chemical(s) Being Audited -- p. 6.
Fire Protection in_Refineries. Sixth Edition. 3.1 Storage and Handling -- p.
10.
Fire Service Emergency..Management Handbook, 7.2 Local/Community Emergency
Response Plan -- p. 47.
Flammable and Combustible Liquids Code. 3.1 Storage and Handling -- p. 11
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55-
Flammable and Combustible Liquids Code Handbook. 2.0 Chemical Hazards -- p 3
General Storage, 3.1 Storage and Handling - p. 11.
Guide for Development of State and Local Emergency Operations Plans, 6.1
Facility Emergency Response Plans -- p. 32, 7.2 Local/Community Emergency
Response Plans -- p. 47.
Guide for Fighting Fires in and Around Petroleum Storage Tanks, Second
Edition, 6.8 Emergency Response Personnel Training Requirements -- p. 41
Guide for the Review of State and Local Emergency Operations Plans , 6.1
Facility Emergency Response Plans -- p. 32, 7.2 Local/Community Emergency
Response Plans -- p. 47.
Guide co.Exercises in Chemical Emergency Preparedness Programs. 6.2 Emergency
Response Exercises and Simulations -- p. 33.
Guide to Preparing Emergency Public Information, 8.0 Public Alert and
Notification Procedures -- p. 5C.
A Guide to the Safe Handling of Hazardous Materials Accidents, STP 825. 6.0
Facility Emergency Preparedness and Planning Activities -- p. 31.
Guideline on Air Quality Models (revised). 4.3 Hazard Evaluation and
Modeling -- p. 24.
Guidelines for Chemical Process Quantitative Risk Ana1 yrir. ^.3 Hazard
Evaluation and Modeling -- p. 24.
Guidelines for Hazard Evaluation Procedures. 4.3 Hazard Evaluation and
Modeling -- p. 24.
Guidelines for Safe Storage and Handling of Highly Toxic Hazard Materials. 3.1
Storage and Handling -- p. 11.
Guidelines for Vapor Release Mitigation. 4.5 Mitigation Systems -- p. 28.
Guidelines on Risk Analysis. 4.3 Hazard Evaluation and Modeling -- p. 25.
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Guidelines on Technical Management of Chemical Process Safety. 2.2 Facility
Management: of Chemical Hazard Data -- p. 8, 3.0 Process Information for
Hazardous Chemical(s) -- p. 9, 4.1 Management Activities -- p. 20.
Handbook of Chemical Hazard Analysis Procedures. 4.3 Hazard Evaluation and
Modeling - - p. 25.
Havlev's Condensed Chemical Dictionary. 2.1 Overview of Hazards for
Chemical(s) Being Audited -- p. 6.
Haz-mats' Case Studies for Emergency Responders. 6.2 Emergency Response
Exercises and Simulations -- p. 34.
Hazard Identification. Capability Assessment, and Multi-Year Development Plan
for Local Government. 7.2 Local/Communit} Emergency Response Plan -- p. 48.
Hazardous Chemical Reactions. 2.1 Overview: of Hazards for Chemical(s) Being
Audited -- p. 7.
Hazardous Chemicals Data, 2.1 Overview of Hazards for Chemical(s) Being
Audited -- p. 7, 6.3 Fire, Evacuation, and Rescue Corridors -- p. 35.
Hazardous Chemicals Desk Reference. 2.1 Overview of Hazards for Chemical(s)
Being Audited -- p. 7.
Hazardous Materials Emergency Planning Guide. 7.2 Local/Comunity Emergency
Response Plan -- p. 48.
Hazardous Materials Exercise Evaluation Kethodology (HM-EEM) and Manual. 6.2
Emergency Response Exercises and Simulations -- p. 34.
Hazardous Materials Incident Analysis, t.3 Hazard Evaluation and Modeling --
p. 25.
Hazardous Materials: Managing the Incident. 6.5 Emergency Response Chain of
Authority -- p. 39, 7.2 Local/Community Emergency Response Plan -- p. 48.
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Hazardous Materials Response Handbook. 4.5 Mitigation Systems -- p. 28, 6.1
Facility Emergency Response Plan -- p. 33, 6.6 Emergency Response Management
Procedures -- p. 40.
Hazardous Material Spills Conference Proceedings. 4.1 Management Activities
p. 21.
Hazardous Waste and Emergency Response . 4.1 Management Activities -- p 21
How to Prepare for Workplace Emergencies 6.0 Facility Emergency Preparedness
and Planning Activities -- p. 31.
"Implementing Process Safety Management Systems", 4.1 Management Activities
p. 21.
"Industrial Chemical Safety Testing: One Company's Approach", 2.2 Facility
Management of Chemical Hazard Data - - p. 8.
Industrial Process Design for Pollution Control. 3.2 Process Description -- p
Inspection for Accident Prevention. 1.0 General -- p. 1.
Installation, Maintenance, and Use of Notification Appliances for Protective
Signaling Systems. 6.7 Emergency Communication Network Within the Facility -
p. 40, 8.0 Public Alert and Notification Procedures -- p. 50.
Installation of Air Conditioning and Ventilating Systems. 4.5 Mitigation
Systems -- p. 29.
Instructional Videotapes on Chemical Process Safety. 3.0 Process Information
for Hazardous Chemical(s) -- p. 9.
Integrated Emergency Management Information System (IEMIS). 7.2
Local/Community Emergency Response Plan -- p. 48.
International Symposium on Runaway Reactions. 3.-3 Process Hazards -- p. 18.
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-58-
Investigating Accidents With STEP. 5.0 Accident Release Incident Investigation
-- p. 30.
Life Safety Code, 6.3 Fire, Evacuation, and Rescue Corridors -- p. 36.
Liquefied Petroleum Gases Handbook, 2.0 Chemical Hazards -- p. 4.
Loss Prevention. 4.0 Chemical Accident Prevention -- p. 20.
Major Industrial Hazards: Their Appraisal and Control. 4.3 Hazard Evaluation
and Modeling -- p. 25.
Managing Risk - Svscemic Loss Prevention for Executives. 4.3 Hazard Evaluation
and Modeling -- p. 26.
Mobile Lidar Svstem Developments and Operating Procedures. 3.2 Process
Description -- p. 15.
Modern Accident Investigation and Analysis. 5.0 Accident Release Incident
Investigation -- p. 30, 6.9 Follow-up Release Procedures/Investigation -- p
42.
National Fuel Gas Code. 3.2 Process Description -- p. 15.
National Interagencv Incident Management Svstem Incident Command System
Position Manuals. 6.5 Emergency'Response Chain of Authority -- p. 39, 7.2
Local/Community Emergency Response Plan -- p. 49.
National Occupational Exposure Survey. 4.1 Management Activities -- p. 21.
NFPA Inspection Manual. 1.0 General -- p. 1.
NFPA 11C: Mobile Foam Apparatus. 6.4 Emergency Equipment Provisions -- p. 37.
NFPA 12: Carbon Dioxide Extinguishing Systems, 6.4 Emergency Equipment
Provisions -- p. 37.
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NIOSH/OSHA Pocket Guide to Chemical Hazards. 2.1 Overview of Hazards for
Chemical(s) Being Audited --p. 7.
Occupational Safecv and Health Guidelines for Chemical Hazards. 2.0 Chemical
Hazards -- p. 4.
Operation of Chlorine Vaporizing Equipment. 3.2 Process Description -- p. 15
Overfill Protection for Petroleum Storage Tanks. First edition. 3.1 Storage
and Handling -- p. 11.
Packager Training Program, 3.1 Storage and Handling -- p. 12.
Personal Protective Equipment. 6.4 Emergency Equipment Provisions -- p. 38
Piping Design for Process Plants. 3.0 Process Information for Hazardous
Chemical(s) - p. 9, 3.2 Process Description -- p. 16.
Piping Systems for Dry Chlorine. 3.2 Process Description -- p. 16.
Plant Manager's Network Guide. 7.1 Facility Planning and Outreach Activities
with Community -- p. 44.
Plant/Operation Progress: articles on process safety, 1.0 General -- p. 2, 3.3
Process Hazards -- p. 18, 4.0 Chemical Accident Prevention -- p. 20, 7.0
Community and Facility Emergency Response Planning Activities -- p. 43.
Portable Fire Extinguishers (Audio-Visual Tape), 6.3 Fire, Evacuation, and
Rescue Corridors -- p. 36, 6.4 Emergency Equipment Provisions -- p. 38.
Preparing for Emergency Planning. 6.1 Facility Emergency Response Plan -- p.
33.
Prevention Reference Manual: User's Guide Overview for Controlling Accidental
Releases of Air Toxics. 3.3 Process Hazards -- p. 18.
A Primer for Preparedness for Acute Chemical Emergencies. 6.1 Facility
Emergency Response Plan -- p. 33, 7.1 Facility Planning and Outreach
Activities with Coujnunity -- p. 44.
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-6C-
Proceedines of the 1989 National Conference on Hazardous Materials Training,
6.8 Emergency Response Personnel Training Requirements -- p. 41.
Proceedings of the Conference on In-Place Protection During Chemical
Emerger.c ies, 6.3 Fire, Evacuation, and Rescue Corridors -- p. 36, 7.1 Facilit'
Outreach and Planning Activities with the Community -- p, 45.
Proceedings of the International Conference on Vapor Cloud Modeling, 4.3
Hazard Evaluation and Modeling -- p. 26.
Process-Control Systems: Application/Design/Adlustment. 3.0 Process
Information for Hazardous Chemical(s) -- p. 9.
Process Instruments and Controls Handbook. 3.2 Process Description -- p. 16.
Process Operations. 3.2 Process Description --p. 16.
Production. Storage, and Handling of Liquefied Natural Gas (LNG~) . 3.1 Storage
and Handling -- p. 12.
Professional Competence of Res-ponders to Hazardous Materials Incidents . 6.8
Emergency Response Personnel Training Requirements -- p. 42.
Profitable Risk Control: The Winning Edge. 4.3 Hazard Evaluation and
Modeling -- p. 26.
Rapid Guide to Hazardous ..Chemicals in the _WorkpIac3. 2.1 Overview of Hazards
for Cheraical(s) Being Audited -- p. 8.
Recommendations to Chlor-Alkali Manufacturing Facilities for the Prevention of
Chlorine Releases. 1.0 General -- p. 2.
Refrigerated Liquid Chlorine StoraEe. 3.1 Storage and Handling -- p. 12.
Release Containment in Chlorine Plants. 4.5 Mitigation Systems -- p. 29.
Remote Monitoring of Gaseous Pollutants bv Differential Absorption Laser
Techniques. 3.2 Process Description -- p. 16.
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-61-
Respiratorv Protection. 6.4 Emergency Equipment Provisions -- p. 38.
Responding to Hazardous Materials Incidents. 4.5 Mitigation Systems -- p. 29
Review of Emergency Systems, 1.0 General -- p. 2, 4.0 Chemical Accident
Prevention -- p. 20, 8.0 Public Alert and Notification Procedures -- p. 50.
Risk Assessment and ManaEement: A Framev/ork for Decision-Making. 4.3 Hazard
Evaluation and Modeling -- p. 26.
Safe HandlinE and Storage of Compressed Gases. 3.1 Storage and Handling -- p.
12.
Safe Tank Cleaning. 3.1 Storage and Handling --p. 13.
"Safety-relief-valve malfunction: Symptoms, causes, and cures", 3.3 Process
Hazards -- p. 19, 4.2 Process Operation and Maintenance -- p. 22, 4.4 Release
Prevention Systems -- p. 27.
Standards on Vapor-Protective Suits for Hazardous Chemical Emergencies. 6.4
Emergency Equipment Provisions -- p. 38.
The State-of-the-Art Continuous Emission Monitoring Systems for Power Plants.
3.2 Process Description -- p. 17.
Storage and Handling of Liquefied Petroleum Gases. 3.1 Storage and' Handling -
P. 13.
Storage and Handling of Liquified Petroleum Gases at Utility Gas Plants. 3.1
Storage and Handling --p. 13.
Storage of Flammable and Combustible Liquids Within Underground Metal and Non-
Metal Mines (Other than Coal). 3.1 Storage and Handling -- p. 13.
Storage Vessels and Other Equipment. 3.1 Storage and Handling --p. 14.
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-62-
Technical Guidance for Hazards Analysis: Emergency Plannine for Extremely *
Hazardous Substances. 4.3 Hazard Evaluation and Modeling -- p. 28, 7/2
Local/Community Emergency Response Plan -- p. 49.
Technical Safety Audit, 1.0 General -- p. 2.
"Total Plant Safety Audit", 1.0 General -- p. 2.
"The Use of Water Spray Barriers to Disperse Spills of Heavy Gases," 4.5
Mitigation Systems -- p. 29.
What Went Wrong7 Case Histories of Proces.'; Plant Disasters. 1.0 General --
p. 3.
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-63-
FREQUENTLY MENTIONED ORGANIZATIONS
American Institute of Chemical
Engineers (AIChE)
Publications Sales, Dept. CAT-90
345 East 47 Street
New York, NY 10017
212-705-7657
American Petroleum Institute (API)
1220 L Street, NW
Washington, DC 20005
202-682-8375
American Society for Testing and
Materials (ASTM)
1916 Race St.
Philadelphia, PA 19103-1187
215-229-5585
American Society of Safety Engineers
(ASSE)
Department F
1800 East Oakton Street
Des Plaines, IL 60018-2187
708-692-4121 ext. 18
Chemical Manufacturers Association
2501 M Street, NW
Washington, DC 20037
202-887-1100
The Chlorine Institute, Inc.
2001 L Street, NW
Washington, DC 20036
202-775-2790
Federal Emergency Management Agency
(FEMA)
Publications Office
P.O. Box 70274
Washington, DC 20024
202-646-2500
Fire Protection Publications
Oklahoma State University
Stillwater, Oklahoma 74078-0118
1-800-654-4055
National Association of
Manufacturers (NAM)
Publications Coordinator
1331 Pennsylvania Avenue, N~W
Suite 1500 - North Lobby
Washington, DC 20004-1703
National Fire Protection Association
(NFPA)
1 Batteryraarch Park
P.O. Box 9101
Quincy, MA 02269-9101
1-800-344-3555
National Technical Information
Service (NTIS)
U.S. Department of Commerce
5285 Port Royal Road
Springfield, VA 22161
703-487-4650
Occupational Safety and Health
Administration
U.S. Department of Labor
OSHA Publications Office, N3101
200 Constitution Avenue, NW
Washington, DC 20210
202-523-9667
U.S. Coast Guard
2100 Second Street, SW
Washington, DC 20593-0001
U.S. Environmental Protection Agency
Public Information Center
401 M Street, SW
Washington, DC 20460
202-382-2080
Emergency Planning and Community
Right-To-Know Information Service
U.S. Environmental Protection Agency
OS-120
401 M Street, SW
Washington, DC 20460
1-800-535-0202
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GROUP EXERCISES
Ground Rules and General Information
During the course of the workshop, four group exercises will be conducted. The exercises will allow
the participants to practice the various phases of a chemical safety audit. The exercises build on one
another. As part of the final exercise, each group will present a verbal audit report.
The exercises are based on a mock audit conducted at Facility X. Facility X manufactures urea from
ammonia and carbon dioxide. The urea is then prilled (pelletized), coated, bagged, and sold as
nitrogenous fertilizer. The chemical safety audit was triggered by a recent release of 500 pounds
of ammonia.
Participants will be divided into groups of 5-7 individuals. Each group will conduct each of the
following exercises:
Exercise 1 - TuesdayFacility X overview, information review, and hazards
identification
Exercise 2 - WednesdayProcess systems, operations, and maintenance interviews;
information acquisition and interviewing techniques
Exercise 3 - ThursdaySafety, training, and emergency response planning
interviews
Exercise 4 - FridayAudit report preparation and presentation
The following information about Facility X will be provided:
1. A map indicating the position of the facility with respect to the surrounding
community.
2. A facility map showing the layout of the equipment and major production areas.
3. A diagram of the urea manufacturing process.
4. A copy of the Tier II form submitted by the facility under Section 312 of SARA Title
III.
5. A copy of the Accidental Release Information Program (ARIP) report submitted to
EPA as a result of the ammonia release.
6. MSDS information on the chemicals used or produced in the urea manufacturing
process.
7. An audit report worksheet.
Additional information will be provided during the exercise interviews.
7/93 1 Group Exercises
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Exercise 1Facility X Overview, Information Review, and Hazards
Identification
Exercise 1 starts with a facility overview, followed by team assignments and review of
documentation. The purpose of the exercise is to establish the roles of each team member, review
the written information about Facility X, identify facility chemical hazards, and complete Sections
1, 3, 4, and 5 of the audit report.
Tasks to be accomplished:
1. Establish roles (team leader, etc.) for all team members.
2. Identify any relevant chemical hazards and safety issues shown in the overview and
Facility X written information.
3. Using the Chemical Safety Audit Manual and the Facility X written information,
complete the following sections of the audit report: Section 1 - Introduction,
Section 3 - Background, Section 4 - Facility Background Information, and Section 5 -
Chemical Hazards.
4. Identify audit information that is needed for each additional section of the audit
report.
5. Assign topics (e.g., safety, training, and process operations) to individual team
members.
6. Identify possible sources of needed information.
7. As much as possible, establish information gathering objectives for each team
member. The objectives are to be met during the Wednesday and Thursday exercises
(Exercises 2 and 3).
7/93 * Exercise 1
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TECHNICAL INFORMATION
ABOUT
FACILITY X
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SOME FACTS ABOUT FACILITY X
1. Facility X is located in the northwest United States along the Pacific
Coast. Some relevant weather data are:
Average temperature: 53 °F
Average relative humidity: 73%
Mean wind speed: 7.9 miles per hour from ESE
2. The facility is 20 years old and employs 110 persons. The urea plant
design capacity is 500 tons per day. Currently, it is operating at 70 percent
capacity.
3. The audit was triggered by a series of releases of ammonia, the last one
being approximately 500 Ibs. (The reportable quantity for ammonia is 100 Ibs.)
The most recent ammonia release occurred because of a relief valve
malfunction. The relief valve is set at a pressure 10 percent above the
reactor pressure. The pressure increased, and the valve opened but failed to
reseat.
4. The corporate safety person (a Vice President) is responsible for 22
plants located at various locations within the U.S.
5. The plant supervisor maintains records of the personnel who have
attended training programs at the facility. Training programs include courses
on employee safety, emergency response, and equipment operator certification.
This person also maintains all records of accident investigations,
including accidental releases, and follows up each incident with the plant
manager within 30 days to gather full details of investigations along with
recommendations for improvement of safety.
In addition, this person was responsible for instituting an employee
suggestion program to encourage safety-related suggestions accompanied by
monetary rewards. In general, this person maintains a healthy attitude
towards safety and maintains an open door policy.
6. The corporate policy on hazards analysis requires that cause -
consequences analyses or HAZOP be conducted on an annual basis. However,
owing to budget constraints, such analyses have not been carried out at this
plant.
7. Equipment maintenance at this plant is usually done on an as-needed
basis. However, the plant conducts regular equipment inspections and testing
as well as comprehensive investigations of equipment failures.
8. As an active member of CAER-, emergency response plans at this facility
are revised and updated every six months.
9. The plant has its own fully-equipped fire brigade.
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U.S. ENVIRONMENTAL PROTECTION AGENCY
ACCIDENTAL RELEASE PREVENTION QUESTIONNAIRE
INITIAL REPORT
SECTION I. FACILITY PROFILE
1. FACILITY NAME: Facility X
2. Dun & Bradstreet Number: I I I- I I I I- I I I I I
3a. FACILITY MAILING ADDRESS:
1 Industry St.
Street
Pacific Town
City
Washington
State
99999
Zip Code
b.Facility physical address:
1 Industry St.
Street
Pacific Town
City
Washington
State
qqoqq
Zip Code
Latitude Longitude
4.
DEG
1
NflN
1
DEG
1
MIN
|
1
-------
5. NAME AND ADDRESS OF OWNER
OR CHIEF EXECUTIVE OFFICER: .
Bill Smith
6a. RESPONDENT:
b. DATE QUESTIONNAIRE
COMPLETED:
Name
1 Industry St.
Street
Pacific Town
City
Washington
99999
State
Zip Code
Virginia Williams
Name
Personnel Safety Manager
Title
1 Industry St.
Street
Pacific Town
City
Washington
State
99999
Zip Code
( 206) 555-6666
Telephone
February 1990
7. Indicate the total number of employees typically at the facility (include all full-time and part-time
employees, all employees on paid sick leave, paid holidays, paid vacations, managers ana corporate
officers at the facility). 110 _
8. Identify the four-digit Standard Industrial Classification (SIC) that best describes your facility
operations and the primary product or service of this facility.
a. SIC code: _2. Jl _i Ji
b. Primary product Of service: Manufactures urea fnr nif-i-noonnny f^rtiliigr
c. For facilities with multiple SIC codes, please identify the additional SIC codes.
- 2 -
-------
SECTION II. HAZARDOUS SUBSTANCE RELEASE PROFITS
The following section asks several questions concerning the accidental release of hazardous substances. If
exact responses cannot be provided, please provide estimates using your best professional judgment.
9. Indicate the date release began.
j__2 - J_ JL - JL JL
(month) (day) (year)
Indicate date release ceased.
_L JL - _L JL - JL JL
(month) (day) (year)
10. Indicate time of day release began.
_L _Q. : A. JL
_X A.M.
P.M.
Indicate the time of day release ceased.
JL _L : 5_ 5_
JLA.M.
P.M.
lla. Check the item below that best describes the status of the process line where the event occurred at
the time of release.
1. £. In operation
2. Temporarily inactive
3. Testing/Trial Run
4. Scheduled startup
5. Scheduled shutdown
6. New construction
7. During Maintenance
8. Production Changeover
b. Check the item below that best describes the current status of the process line where the event
occurred.
1. _x_ In operation
2. Temporarily inactive
3. Permanently closed
If item 2 or 3 is marked, answer Question lie; otherwise go to question 12.
- 3 -
-------
c. Is the shut down of operations at the process line related to the accidental release of hazardous
substances?
_Yes
_No
12a. Were federal authorities notified?
X_ Yes
_No
b. If yes, please indicate which federal authorities were notified:
1. _% National Response Center telephone number called C 800) 424-8802
2. Coast Guard telephone number called ( 1
3. EPA telephone number called ( )_
4. Other (specify)
c. Indicate the date and time of day federal authorities were notified.
J-JL - _L JL - JL JL (Date)
(month) (day) (year)
_L L _! J. (Time)
_A.M.
P.M.
13a. Were state authorities notified?
_No
b. If yes, identify all state authorities notified concerning the release. (If more than one, please attach
list on separate page)
(Name) (Title)
Washington Emergency Response Commission _
(Agency)
Olympia _ _______ _
(City)
Washington _ ______ _ - _
(State)
(800) 633-7585 _ __
(Telephone)
- 4 -
-------
c. Indicate the date and time of day state authorities were notified.
_L J. - _L A - J_ _2_ (Date)
(month) (day) (year)
_0 _9_ : 0_ 0_ (Time)
_iA.M.
_P.M.
14a. Were local authorities notified?
_Yes
_X No
b. If yes, identify all local authorities notified concerning the release. (If more than one, please attach list
on separate page)
(Name) (Title)
(Agency)
(Cty)
(State)
(Telephone)
c. Indicate the date and time of day local authorities were notified.
- - (Date)
(month) (day) (year)
: (Time)
_A.M.
P.M.
15a. Was the general public notified?
_Yes
x No
- 5 -
-------
b. If yes, indicate the person that notified the general public of the release. (If more than one, please
attach list on separate page)
(Name) (Title)
(Agency)
(State)
(Telephone)
16. For this particular release, what type(s) of communication technologies were used by the facility to
alert and notify the public to evacuate or take other safety measures?
a. Door-to-door notification
b. Loudspeakers/public address system
c. Tone alert radio/pagers
d. Siren/alarms
e. Modulated power lines
f. Aircraft
g. Radio
h. Television
i. Cable override
j. Telephone
k. jc None
1. Other (please describe)
17a. Were members of the general public evacuated? b. Were members of the general public
sheltered in place?
_Yes _ Yes
X No jj. No
If yes, please indicate number evacuated. If yes, please indicate number sheltered
in place.
18. To the best of your ability, indicate the weather conditions at the time of release for each item below.
Approximations are acceptable.
a. Wind Speed (miles per hour) 1 - 2_
b. Wind Direction _ESE_
c. Humidity (percent) ? 3_
d. Temperature (Fahrenheit) s 2_
e. Precipitation? Yes £_ No
- 6 -
-------
19. Briefly describe the circumstances that led up to the release (if helpful include a skeu,h).
A system pipeline leading away from the reactor became partially blocked for
unknown reasons. This resulted in a pressure buildup in the reactor. When the
reaction vesselreached10% aboveitsnormal operating pressure,thereliefvalve
opened. Within a few ininutes, the pressure returned to
normal but the relief valve failed to reseat. In response to the release, the system
was shut down, the relief valve was replaced, and the system lines were checked
for blockages.
20. Please check the one item below that best describes the location of the release within your facility.
a. x_ Process vessel
b. Storage vessel
c. Valves on process vessel
d. Valves on storage vessel
e. Piping on process vessel
f. Piping on storage vessel
g. Pumps
h. Joints
i. Unknown
j. Other (please describe)
21. How was the release first discovered? (check as many as apply)
a. Indication by process control device (gauge or monitor)
b. Chemical specific detector
c. x_ General operator observation
d. Observation by foreman or supervisor
e. Injury/death
f. Explosion/fire
g. Major environmental damage
h. Third party notification (i.e., POTW, community, other facility)
i. Other (describe below)
- 7 -
-------
22. Please check the one item below that best describes the primary cause of the release event, (please
check one item only)
a. _x_ Equipment failure
b. Operator error
c. Bypass condition
d, Upset condition (explain below)
e. Fire
f. Maintenance activity
g. Unknown
h. Other (Please describe)
23. Please check any items below that describe additional causes of the release event, (check as many
items as apply)
a. Equipment failure
b. Operator error
c. Bypass condition
d. X_ Upset condition (elaborate below)
e. Fire
f. Maintenance activity
g. Unknown
h. Other (Please describe)
System overpressurization initiall rrp.at-prl t-hP -rnhio
24. Check the items that describe the end effects of the release event, (check as many as apply)
a. Spill
b. X_ Vapor release
c. Explosion
d. _ Fire
e. Other (describe)
- 8 -
-------
25a. In the table below, please estimate the quantity of each substance released to each media. Be sure to
specify the measurement unit.
Chemical
la. Name Ammonia
b. CAS# 7664-41-7
c. Physical
State Gas
d. Concentration 100%
Media
Air
Surface Water
Land
Sewer to Treatment
Facility
Quantity
500
Unit
Bounds
2a. Name_
b.CAS t
c. Physical
State
d. Concentration
Sa.Name
b.CAS #
c. Physical
State
d. Concentration
4a. Name_
b.CAS #
c. Physical
State
Air
Surface Water
Land
Sewer to Treatment
Facility
Air
Surface Water
Land
Sewer to Treatment
Facility
Air
Surface Water
Land
Sewer to Treatment
Facility
d. Concentration
- 9 -
-------
b. Please check the items below that describe your methods or source of information for your responses in
Question 25a. (check as many as apply)
_X physical properties and ambient conditions
on-line instrument
engineering estimate
tank/system inventory
chemical analysis
effluent measured
inventory check
computer simulation
_X_ process records
no release to media
other (please describe)
26a. Did any substances identified in Question 25, migrate beyond the legal boundaries of your facility (for
example, a vapor release was carried by prevailing wind beyond the fence line of your facility)?
_X_ Yes (If yes, please answer Question 26.b and c)
No (If no, skip Question 26.b and answer Question 26c)
b. In the table below specify the quantities of substances that migrated beyond your facility boundaries.
Chemical
1. Name: Ammonia
Physical state: Gas
Media
Air
Surface Water
Land
POTW
Quantity
500
Unit
pounds
2. Name:
Physical state:
Air
Surface Water
Land
POTW
3. Name:
Physical state:
Air
Surface Water
Land
POTW
4. Name:
Physical state:
Air
Surface Water
Land
POTW
c. Please check the items below that describe your methods or source of information for your responses in
question 26b.
- 10 -
-------
X_ physical properties and ambient conditions
on-line instrument
engineering estimate
tank system inventory
_ chemical analysis
effluent measured
computer simulation
inventory check
process records
assumed
other (please describe)
27. Did injuries occur among facility employees or contractors as a result of the event?
_Yes
a. If yes, please indicate number of injuries.
b. How many of these received hospital treatment?
Number treated unknown
c. Did deaths occur among facility employees or contractors as a result of the event?
_Yes
_XNo
If yes, please indicate number of deaths.
28. Did injuries occur among the general public as a result of the event?
_Yes
_XNo
Don't know
a. If yes, please indicate number of injuries.
- 11 -
-------
b. How many of these received hospital treatment?
Number treated unknown
c. Did deaths occur among the general public as a result of the event?
_Yes
_X No
Don't know
If yes, please indicate number of deaths.
29. Please indicate the environmental effects that occurred as a result of the release:
a. Fish kills
b. Vegetation damage
c. Soil contamination
d. Groundwater contamination
e. _ Wildlife kills
f. 2L None
g. Other (please specify)
- 12 -
-------
SECTION III. CLEANUP AND PREVENTION PROFILE
30. Please describe the immediate response activities taken to contain or minimize the release.
Operators shut down the system and decided not to manually attempt to
reseat the valve. Instead, the valve was replaced eventually, and the
entire system was inspected for damage. Building fans helped to remove the
released ammonia from the work areas. _______________
31. Did your facility undertake cleanup of the release?
Yes (If yes, skip Question 32a.)
_X_ No (NA)
32a. Please supply the name and address of the party responsible for cleanup.
(Name) (Title)
(Agency)
_
(State)
(Telephone)
b. Has cleanup of the release been completed?
Yes (If yes, please answer Questions 32c.)
No (If no, please answer Question 32d.)
c. Indicate the date cleanup activity ceased.
(month) (day) (year)
d. Please indicate the approximate date completion of cleanup activity is expected.
(month) (day) (year)
33. How did you dispose of the waste generated during the spill and cleanup?
On site N/A
Off site N/A
- 13 -
-------
34a. Prior to this release event, which types of formalized hazard assessments were performed? (Check as
many items as apply). For those items checked, piease indicate the frequency performed (i.e.,
quarterly, annually, one time, or on occasion).
Frequency
_X. Cause-consequence analysis annual*
Dow and Mond Hazard Indices
Event tree analysis
Failure modes, effects, and criticality analysis
Fault tree analysis
_x FIAZOP/hazard and operability studies annual*
__ Human error analysis
Probabalistic risk assessment
What if analyses
None
Other (please describe)
* Facility policy outlines annual hazard assessments, however, budget
constraints have prevented conducting hazard assessments at this plant.
b. What is your opinion of the effectiveness of each of the assessment techniques used?
Both HAZOP and cause-consequence have been used at other corporate plants
with great success. HAZOPs, although expensive to conduct, are particu-
larly valuable for identifying hazards.
35. Prior to this release event, which of the following pre-release controls have been employed specifically
to identify/prevent the type of release that occurred? (Check as many items as apply)
a. _x_ Prevemaiive maintenance
b. _X_ Regular equipment inspections and testing
c. _x_ Hazard assessment
d. Comprehensive audit
e. Regular assessment of equipment designs
f. _X_ Process controls for operations monitoring and/or warning
g. Regular upgrading of equipment
h. Comprehensive investigation on similar equipment failure
i. 2L Standard operating procedures
j. Release prevention equipment
k. Equipment installation checks
1. Other (please describe)
- 14 -
-------
36. Prior to this release, what management activities related to safety and loss prevention have been
employed? (Check as many as apply)
a. £_ Employee safety training (e.g., OSHA training programs)
b. 2L Emergency Response training
c. £_ Employee testing
d. 2L Certification of operators on equipment/system
e. x_ Membership in CAER or other similar programs
f. x_ Release control program
g. 2L Accident investigation reports
h. Research/conferences
i. _x_ Safety loss prevention office/officer
j. Corrective action process for deviation from rules
k. Program to improve system design
1. None
m. Other (please describe)
37. For this particular release, what method(s) of pre-release protection equipment (systems to capture,
neutralize, or destroy a toxic chemical before it is released into the environment) is used by the facility?
(Check as many items as apply)
a. Containment (i.e., diking, dump tank - explain below)
b. Neutralization
c. Scrubber
d. Flares/incineration
e. Adsorbers
f. Spray curtain
g. _X_ Emergency Equipment (i.e., fire fighting)
h. None
i. Other (please describe)
38. For this particular release, what systems or procedures were employed by the facility to minimize
accident potential? (Check all that apply)
a. Backup systems
b. Redundant systems
c. Minimize inventory
d. Valve lock out
e. Automatic shut off
f. Bypass and surge systems
g. Manual override
h. Limit capacity of equipment
i. _X Standard Operating Procedures (logs, checklists)
j. _x Alarms
k. Interlocks
1. None
m. Other (please describe)
- 15 -
-------
39. In response to this release, which of the following pre-release controls have been implemented or
modified to identify/prevent future potential releases? (Check as many as apply)
a. x_ Preventative maintenance
b. X_ Regular equipment inspections and testing
c. x_ Hazard assessment
d. Comprehensive audit
e. Regular evaluation of equipment designs
f. Increased process controls for operations monitoring and/or warning
g. Upgrading equipment
h. Revised standard operating procedures
i. Follow accident report investigation recommendations
j. Develop or refine emergency response planning
k. Other (please describe)
40. Describe the changes in the content of your training programs as a result of this release.
Training was believed to be adequate for this tvpe of incident.
41. Describe the immediate equipment repairs and/or replacements, management practices, operational
changes, etc. made as a result ol the release.
The operators and maintenance crew replaced the relief valve, conducted a
check; on the proper operation of the valve, and inspected the system tor
damage.
42. What additional long term preventative measure(s) will be taken to minimize the possibility of
recurrence?
The plant conducts more frequent inspection of relief valves. '
- 16 -
-------
Material Safety Data Sheet
May be used to comply with
OSHA's Hazard Communication Standard,
29 CFR 1910.1200. Standard must be
consulted tor specific requirements.
U.S. Department of Labor
Occupational Safety and Health Administration
(Non-Mandatory Form)
Form Approved
OMB No. 1218-0072
IDENTITY (As. Used on taOe/ and List)
AMMONIA
More: Blank spaces are not permitted. It any item is not aooi/caote or nc
information is available, tne soace must oe marxed to mdica'e tnai
Section 1
Manufacturer s Name
Facility X
Address (Number.
Street. City, State, and ZIP
One Industry
Pacific Town
Code)
Street
, WA 99999
Emergency lelepnone Number
(206)
Telephone Number lor Information
(206)
555-6666
555-5555
Date Prepared
February 28,
1990
Signature of Preparer (optional)
Section II Hazardous Ingredients/Identity Information
Hazardous Components (Specific Chemical Identity: Common Name
-------
Section V Reactivity Data
Stability Unstable
Statue Yes
Conditions to Avoid Mixing wich
other chemicals and water
Incompatibility (Materials io Avo/rfj . , _,
Strong oxidizers, calcium, hypochlonte bleaches, goiu, mercury, silver, and halogens
Hazardous Decomposition or Byproaucts
Hazaroous
Polymerization
May Occur
Will Not Occur
Yes
Conditions to Avoid
Section VI Health Hazard Data
Roule(S) ol Entry
Inhalation?
Yes
Skin?
Yes
ingestion?
Yes
Healin Hazards (Acute and ChronKl
Eye and respiratory tract Irritant
Carcinogeniciry.
NTP?
(ARC Monographs?
OSHA Regulated?
Signs and Symptoms ol Exposure
Meoicai Conditions
Generally Aggravated by Exposure
Emergency and First Aid Proceoures
Section VII Precautions for Safe Handling and Use
Steps to Be Taken in Case Material Is Released or Spilled
Venr.ilate area of spill or leak to disperse gas. If in gaseous form stop flow of gas.
If source of leak is a cylinder and cannot be stopped, remove to open air and repair leak
or allow cylinder to empty. If in liquid form allow to vaporize.
Waste Disposal Method
Precautions to Be Taken in Handling and Stonng
Other Precautions
In case of release or spill, keep unneccessary people away, isolate hazard area
and deny entry. Stay upwind out of low area. Evacuate area endangered by gas.
Section VIII Control Measures
Respiratory Protection (Specify Type)
Positive pressure, pressure-demand, full facepiece SCBA or pressure-demand supplied air
Ventilation
Local Exhaust
Mechanical (General)
Protective Gloves
Special
Other
Eye Protection
Other Protective domino or Equipment
respirator with escape SCBA and a fully encapsulating, chemical resistant suit
WorK/Hygienic Practices
-------
Material Safety Data Sheet
May be used to comply with
OSHA's Hazard Communication Standard,
29 CFR 1910.1200. Standard must be
consulted for specific requirements.
U.S. Department of Labor
Occupational Safety and Health Administration
(Non-Mandatory Form)
Form Approved
OMB No. 1218-0072
IDENTITY (As Used on LaD& and Ust)
Ammonium Carbamace
Note: Blank spaces are not permitted. H any item is not apcxicacte or no
information is available, tne space must Oe masked to maica'e mat
Section
Manufacturer s Name
Address (Number. Street.
Facility X
Dry, Slate, ana ZIP Coael
One Industry Street
Pacific Town, WA 99999
Emergency Telephone Number
(206) 555-6666
Telephone Number lor Information
(206) 555-5555
Date Prepared
February 28, 1990
Signature of Preparer (optional)
Section II Hazardous Ingredients/Identity Information
Hazardous Components (Specific Chemical Identity; Common Name(s)) OSHA PEL
ACGIH TLV
Other bmits
Recommended
/optional)
Ammonium Carbamate (CH^N',,0,,)
TWA 25ppm
IDLH SOOppm
(limits as ammonia)
STEL 35ppm
Section
Physical/Chemical Characteristics
Boiling Point
Sublimates at 60° C
Vapor Pressure (mm Hg.)
Vapor Density (AIR - 1)
Specific Gravity (H2O -
1)
Melting Point
Evaporation Rate
(Butyl Acetate - 1)
Solubility in Water
Verv soluble in water and ammonium hydroxide, slightly soluble in alcohol
Appearance and Odor
White, crystalline, rhombic powder; ammonia odor
Section IV Fire and Explosion Hazard Data
Rash
Point
(Method
Used)
FlammaJDle
Limits
LEL
UEL
Extinguishing Media
Special Fire Fighting Procedures
For small fires, applv drv chemical. C02, Halon. water spray, or standard foan. For
large fires, apply water spray, fog, or standard foam.
Unusual Fire and Explosion Haza/ws
Evolves irritating fumes when heated
Fire may produce irritating or poisonous fumes
(Reproduce locally)
OSHA 174. Sect, 1985
-------
Section V Reactivity Data
Stability
UnstaDie
Stable
Conditions 10 Avao
Verv
volati le
Incompatibility (Materials to Avoid)
Hazardous Decomposition or Byproducts
Decomposes in air to evolve ammonia
Hazaroous
Polymerization
. May Occur
Will Not Occur
Conditions to Avoid
Section VI Health Hazard Data
Routes) of Entry:
Inhalation?
Skin?
ingestion?
Healtn Hazards (Acute ana Chronic)
Contact may cause burns to skin and eyes
Eye and respiratory tract irritant
Carcmogeniciry:
NTP?
IARC Monographs?
OSHA Regulated?
Signs and Symptoms ot Exposure
Medical Conditions
Generally Aggravatec by exposure
Emergency and Firsi Aid Procedures
In case of contact, immediately flush eyes with running water for at
least 15 minutes. Wash skin with soap and water. Isolate contaminated clothing.
Section VII Precautions for Safe Handling and Use
Steps to Be Taken in Case Malarial is Released or Spilled
Stop leak if possible without risk. For small, dry spills, place material into clean, dry
container and cover. For small spills, take up with absorbent material and place into
covered container. For large spills, dike far ahead of liquid spill for later disposal.
Waste Disposal Method
Precautions to Be Taken in Handling and Stonng
Other Precautions
Keep unneccessary people away, isolate hazard area, and deny entry.
Section VIII Control Measures
Respiratory Protection (Spec/ty Type)
Self-contained breathing apparatus (SCBA) and structural firefighter's protective clothing
Ventilation
Local Exhaust
Mechanical (General)
Special
Other
Protective Gloves
Eve Protection
Other Protective Cloihing or Eoupmeni
Work/I-lygiemc Practices
Page 2
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Material Safety Data Sheet
May be usea to comply with
OSHA's Hazard Communication Standard.
29 CFR 1910.1200. Standard must be
consulted tor specific requirements.
U.S. Department of Labor
Occupational Safety and Health Administration
(Non-Mandatory Form)
Form Approved
OMB No 1218-0072
IDENTITY (As Used on Laoel ana List)
CARBON DIOXIDE
Wore BlanK spaces are not permitted. It any item is not app//caO/e. or no
information is available, tne soace must oe marked to indica'e ing!
Section I
Manufacturer s Name
Address (Number. Street.
Facility X
City. State, ana ZIP Code)
One Industry Street
Pacific Town, WA 99999
Emergency Telepnone Number
(206) 555
Telephone Number tor Information
:.'206) 555
Date Prepared
February
-6666
-5555
28, 1990
Signature ot Preparer (optional)
Section II Hazardous Ingredients/Identity Information
Hazardous Components (Specific Chemical Identity: Common Name(s)) OSHA PEL
ACGIH TLV
Other Limits
Recommended
°'o loottonai'
Carbon Dioxide (CO )
5,000 ppm TWA 5,000ppm IDLH SO.OOOppm
STEL 30.000DDm
Section III Physical/Chemical Characteristics
Boiling Point
Sublimates
Vapor Pressure (mm Hg.)
44061 @ 70°F
Vapor Density (AIR - 1)
1.53
Specific Gravity (HjO
Solid:
Metting Point
1.56 (? -79°C
-79°C
Evaporation Rate
(Butyl Acetate - 1)
Solubility in Water
0.14 7. solubility in water
Appearance and Odor
Colorless, odorless gas
Section IV Fire and
Explosion Hazard Data
Flash Point (Method Used)
Flammable Limns
LEL
UEL
Exlinguisning Media
Special Fire Fighting Procedures
Not flammable
Container may explode in heat of fire -- move container or cool with v;ater from the sice
Unusual Fire and Exptoston Haza/os
Several bulk materials burn in carbon dioxide
(Rep'oouce locally!
OSHA 174. Sert. 1966
-------
Section V Reactivity Data
Siacxiiiy
Unstaoie
Staoie
Cononions to Avoid
Incomoatibiiity (Materials to Avoid)
acrvlaldehvde. metal acetvlides. sodium peroxide, and chemically active metals -- sodium.
Hazardous Decomposition or Byproaucts
potassium, and hot titanium
Hazardous
Polymerization
May Occur
Will Not Occur
Conoitions to Avoid
Section VI Health Hazard Data
Route(S) ol Entry:
Inhalation?
Skin?
ingestion?
Healtn Hazards (Acute and Chronic)
An asphyxiant, vapors may cause dizziness or suffocation
Contact with liquid may cause frostbite
Carcinogenic try:
NTP?
IARC Monographs?
OSHA Regulated?
Signs and Symptoms of Exposure
Meaica! Conditions
Generally Aggravated by Exposure
Emergency and First Aid Proceoures
Move victim to fresh air and call for emergency medical care; if not.
breathing, give artificial respiration; if breathing is difficult, give oxygen.
Section VII Precautions for Safe Handling and Use
Steps to Be Taken in Case Material Is Released or Spilled
Stop leak if possible without risk -- do not touch
spilled material.
Waste Disposal Metnod
Precautions to Be Taken in Handling and Storing
Other Precautions
Keep unnecessary people away, isolate hazard area, and deny entry. Stay upwinc
out of low areas, and ventilate closed' spaces before entering.
Section VIII Control Measures
Respiratory Protection (Specify Type)
Self-contained breathing apparatus (SCBA) and structural firefighter's protective clothing
Ventilation
Local Exhaust
Mechanical /General)
Protective Gloves
Special
Other
Eye Protection
Other Protective Clotnmg or Equipment
'Aork/Mvoienic Practices
PBQC 2
frU.L. Gov*r
-------
Material Safety Data Sheet
May be used to comply with
OSHA's Hazard Communication Standard.
29 CFR 1910.1200. Standard must be
consulted for specific requirements.
U.S. Department of Labor
Occupational Safety and Health Administration
(Non-Mandatory Form)
Form Approved
OMB No. 1218-0072
IDENTITY (As Used on Laoel ana List)
UREA
Note: Blank spaces am noi permmed. // any item is not applicable, or no
information is available, ine space must be marked to inoica'e that.
Section
Manufacturer s Name
Address (Number. Street.
Facility X
City. State, and ZIP Code)
One Industry Street
Pacific Town, WA 99999
Emergency Telephone Number
Telepnone Number for Information
(206)
555-6666
555-5555
Date Prepared February 28, 1990
Signature of Preparer (optional)
Section II Hazardous Ingredients/Identity Information
Hazardous Components (Specific Chemical Identity; Common Name(s)) OSHA PEL
ACGIH TLV
Other Limits
Recommend eo
lopnonan
Urea (CH,N 0)
Section ill Physical/Chemical Characteristics
Boiling Point
De composts
Vapor Pressure (mm Hg.)
Vapor Density (AIR « 1)
Specific Gravity (HzO - 1)
Solid: 1.34. (2 20°C
Melting Point
133°C
Evaporation Rate
(Butyl Acetate - 1)
Solubility in Water
Soluble in water, alcohol, and benzene; slightly soluble in ether
Appearance and Odor
White, tetragonal, needles or prism crystals; almost odorless with saline taste
Section IV Fire and
Explosion Hazard Data
Flash Point (Method Used)
Flammable Limits
LEL
UEL
Extinguishing Media
Special Fire Fighting Procedures
Not flammable
Unusual Fire and Explosion Hazaros
(Reproduce locally)
OSHA 174. Sect. 1985
-------
Section V Reactivity Data
Stability
Unstaoie
StaDie
Conditions to Avoid
incompatibility (Materials to Avoicfi . . . u j u ui JI-L i_ i
Reacts explosively with sodium nypochlorite and calcium hypochlorit*
Hazardous Decomposition or SyprOCuCiS
Toxic decomposition products
Hazaraous
Polymerization
May Occur
Conditions to Avoid
Will Not Occur
Section VI Health Hazard Data
Routets) of Entry:
Inhalation?
Skin?
subcutaneous and intravenous
Ingestion? yes
Healtn Hazards lAcute ana Chronic)
skin irritant
Caronogeniciry:
NTP?
IARC Monographs?
OSHA Regulated?
Signs and Symptoms ol Exposure
Meoical Conditions
Generally Aggravated by Exposure
Emergency ano First Aid Procedures
Section VII Precautions for Safe Handling and Use
Steps to Be Taxen in Case Material Is Released or Spilled
Wasie Dispose! Memod
Precautions to Be Taken in Handling and Storing
Other Precautions
Section VIII Control Measures
Respiratory Protection iSpec/ty Type)
Ventilation
Local Exhaust
Mecnanical (General;
Protective Gloves
Special
Other
Eye Protection
Other Protective Clothing 0" Equipment
WortoHygienic Practices
tru.S. a.r.r
-------
Exercise 2Process Systems, Operations, and Maintenance Interviews
and Interviewing Techniques
This exercise covers interviewing selected facility personnel and completing the following sections
of the audit report: Section 6 - Process Information and Section 7 - Chemical Accident Prevention.
The exercise begins with members selected from each audit team interviewing Facility X operating
and maintenance staff, including a maintenance foreman, an operations foreman, the operator who
was on duty at the time of the ammonia release, and the fire brigade commander.
Interviewing procedure:
1. Interviews with each Facility X employee will be conducted in front of the entire
class.
2. Each Facility X employee will be interviewed by representative(s) from each team.
3. To ensure maximum fairness during the exercise, interviews will be conducted in
rounds. Each audit team will be allowed three questions plus one follow-up question
per round. The rounds will continue until there are no further questions for the
employee.
Upon completion of questioning, a short critique will be conducted. The critique will focus on
interviewing technique strengths and weaknesses displayed during the interviews.
Short follow-up interviews will be allowed. These interviews will be conducted in the presence of
all workshop participants.
Tasks to be accomplished:
1. Perform Facility X employee interviews with the operations foreman, the fire brigade
commander, the maintenance foreman, and the operator on duty at the time of the
ammonia release.
Possible interview topics include, but are not limited to:
Facility standard operating procedures
Response activities relating to the ammonia release
Maintenance philosophy and procedures
Specific maintenance activities relating to the ammonia release
Emergency response procedures, etc., needed to complete the chemical safety
audit report.
2. Reassemble the team and evaluate the information obtained from the facility overview
and the interviews. Reinterview facility employees as needed.
3. Complete Section 6 - Process Information and Section 7 - Chemical Accident
Prevention of the audit report.
7/93 37 Exercise 2
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TIPS FOR CONDUCTING AN EFFECTIVE INTERVIEW
SETTING THE CLIMATE
1. Decide where to conduct the interviewTalking about safety issues with federal officials
can be threatening and create defensiveness in some plant managers or employees.
Therefore, the physical setting for the meeting is an important consideration. Several options
that can alleviate some tension for the interviewee include:
Conduct the interview in an informal setting in an office
Conduct the interview in a conference room
Conduct the interview outside the plant
Conduct the interview on the plant floor in a convenient location for the employee.
Try to determine where the interviewee will be most relaxed and undistracted.
2. Establish the proper tonePrepare for each interview by writing down an opening
statement that breaks the ice and sets a comfortable, positive tone for the meeting. A relaxed
and open atmosphere will significantly improve the quality of the discussion.
3. Clarify why you are meetingMake a clear statement at the beginning of the interview
about why you are meeting and what you hope to accomplish.
4. Monitor nonverbal cuesIn addition to setting an appropriate tone for the interview, you
should reflect this tone physically. It is hard to sound relaxed, open, and supportive if your
body position is conveying that you are uptight and uncomfortable. During the first moments
of the interview, monitor the way you are sitting, your voice, and your body language and
relax as needed.
GETTING DOWN TO BUSINESS
1. Ask effective questionsQuestions are the basic vehicle for obtaining information during
an interview. There are several types of questions you can use.
Open questions invite the interviewee to express his or her opinion about an issue
(e.g., "What is involved in your plant's HAZOP analysis?"). Open questions begin
with phrases such as What do you know about. . ., Describe for me the way. . ., and
How would you. . . Open questions are used to ask people to describe, explain, or
expand on a topic.
Closed questions ask the interviewee to state where he or she stands on an issue
(e.g., "Which database system would you use?"). Closed sentences begin with do,
which, where, or who and ask the interviewee to make a choice or state a preference.
7/93 39 Interviewing Tips
-------
Leading questions suggest the answer the interviewer expects to receive. This type
of question should be avoided.
Mirror questions repeat or reflect information you have already received for which
you desire confirmation or clarification. They begin with Let me see if I
understand..., Can you tell me what you meant by..., and In other words...
Loaded questions use words that may trigger defensive or emotional responses. This
type of question should also be avoided.
2. Listen activelyAn essential ingredient of a successful interview is to listen actively to the
interviewee's point of view. To listen actively, you must concentrate on what the other
person is saying, rather than catching the "gist" of what is said. To ensure that you are
listening accurately, periodically summarize what the other person has said. You can use
phrases beginning with So what you are saying is..., or Your concern is that..., or
summarize the topic in your own words.
3. Seek clarificationThere will be times during the interview when you think you know what
the interviewee has in mind, but you may not be certain. When in doubt, don't assume you
understand. Ask a question or summarize what the individual has said so you will be certain
you understand their intent. Questions such as How would you do that? or So what you are
suggesting is... may provide the necessary clarification.
4. Handle disagreementsDuring the interview, you may disagree with the interviewee. If
this happens, be direct and explain why you disagree with them. Use an example to illustrate
your point. After you have given your explanation, ask the interviewee if he or she
understands your point of view. Don't let a disagreement prevent you from obtaining the
information you need.
CONCLUDING THE INTERVIEW
1. Summarize the discussionTo ensure that both you and the interviewee have the same
understanding of the topics you have discussed, wrap up the conversation by recapping the
key issues and findings of the interview and asking for any final comments.
2. Decide on follow-upAs the interview concludes, determine whether specific follow-up
steps are needed (e.g., obtaining additional information or consulting other employees).
Next, determine who is going to be responsible for the action, the time frame for the action,
and the expected results.
3. Obtain commitmentOnce the need for follow-up is established, decide (with your
interviewee) on the most appropriate format (e.g., telephone call, meeting, or other) and
establish a time for completion.
Interviewing Tips 40 7/93
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KEY FACILITY PERSONNEL AND FEATURES
PLANT AND CORPORATE PERSONNEL
When conducting an interview, you will meet and interact with several industry personnel, each with
different information or concerns related to your visit. The following personnel positions may be
represented at a facility you visit:
The plant managerThe most important person at the site. The plant manager is
responsible for the workday safety and well-being of the plant's employees and for
the impact of operations on the surrounding community. He or she is also
responsible for the viability of the business and plant site. The plant manager will
likely attend both the kickoff and the exit meetings with your team. These meetings
will include his or her staff and may also include personnel from corporate staff.
Legal counselA company lawyer can reasonably be expected to get involved in the
site visit portion of the audit. The lawyer could be a member of the plant manager's
staff, in which case he or she would handle a range of issues, such as taxes and
licenses, workers compensation, environmental permits and compliance, and customer
legal issues. This lawyer could, however, be from corporate headquarters, and in
a large company he or she would handle a narrower range of issues, primarily
dealing with safety and environment. With respect to your visit, the company lawyer
will be interested in the maintenance of confidentiality and in the legal standing of
your requests for information.
Operations staffIt is highly likely that you will meet other engineers, foremen,
operators, and technicians while touring the plant operating areas. Middle managers
and, perhaps, junior staff will participate in your visit because of their day-to-day
involvement with the plant's operation from a people, process, and equipment
perspective. These people may be asked by your tour guides to discuss or
demonstrate particular aspects of the operation for which they have a hands-on role.
For example, you may see a demonstration of an alarm system, or the operation of
an important process control instrument may be explained.
Corporate staffPersonnel representing a parent corporate entity will likely be
present during your visit. Corporate involvement will depend on corporate
management policy and the amount of public awareness and media attention focused
on the facility. Corporate level staff that may be present could include managers
active in developing both corporate and public safety policy, as well as engineers and
scientists who provide company-wide expertise ranging from new process design to
audits and troubleshooting.
7/93 41 Interviewing Tips
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PLANT SOURCES AND SURVEY-RELATED INFORMATION
An important task for the team will be to determine who, among all those you meet, can best provide
the information you seek. All of the people you will come into contact with will have, at least in
part, a functional health and safety focus to their jobs. This focus can range from site or process
specific to worldwide (including government affairs). Based on the major areas of inquiry reflected
in the audit protocol, the following company staff will likely be the most helpful:
Desired Information Personnel to Contact
Facility information Plant manager, safety personnel
Hazard assessments Safety personnel, technical staff
Prevention, monitoring, and mitigation Technical staff, safety personnel
Manufacturing
Release monitoring and detection Manufacturing and safety personnel,
environmental staff
Modeling Safety personnel, technical staff, corporate
technology
Public alert Safety personnel, public relations
Understanding the roles and responsibilities of these company employees, their interests, and how
they relate to one another will help you communicate effectively and get your job accomplished.
Remember:
Know your sources. Because you will be gathering information during your
interactions with many different plant personnel, it is important to establish where in
the organization they fit and what their overall function is relative to the information
they are providing.
Knowledge of personnel and responsibilities can greatly enhance your team's position. For example:
You can garner a measure of respect from your hosts, which can translate into
acceptance
You can learn much from the way they interact, which will facilitate your inquiry.
A precautionary note: It is important to work with the appropriate plant personnel. If the plant does
not have a clear understanding of your mission, you may meet many people who are not well
matched to your needs.
Interviewing Tips 42 7/93
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PLANT FEATURES OF PARTICULAR INTEREST
As part of your audit, you will be shown many areas of the plant and see many items relating to your
objective. You should be able to request to see those items you feel are important to your
understanding of the situation. Places you may enter or items you may see could include the
following:
Office of the plant safety officerWall chart tracking systems and plant layouts
organized to emphasize safety considerations
Plant emergency command centerDedicated internal and external communications
equipment, key contacts and instructions on how to reach them, health and safety and
emergency procedure information for all plant chemicals and anticipated situations,
and backup power to the center and the life support equipment/systems for command
personnel
Process areasBatch or continuously operated equipment such as reaction vessels;
separation equipment; storage vessels; heat exchangers; pumps, piping, and valves;
monitoring and control instrumentation; relief systems; and equipment for handling
raw materials, products, and wastestreams
Safety equipment in process areasCommunications systems, safety barriers and
markings, safety showers, and personal protective equipment
Process control roomsMonitoring and control instrumentation, process records and
logs, communications systems, process diagrams, operating instructions and
procedures, emergency instructions and procedures, log in/log out books, and safety
equipment
Fire and emergency medical systemsVehicles, control equipment, supplies,
personnel to respond to plant emergencies, records and logs, communications
systems, process diagrams, operating instructions and procedures, and emergency
instructions and procedures.
7/93 43 Interviewing Tips
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Exercise 3Safety, Training, and Emergency Response Planning
Interviews
In this exercise, members selected from each team will interview Facility X management staff and
complete Section 8 - Accidental Release/Incident Investigation, Section 9 - Facility Emergency
Preparedness and Planning, Section 10 - Community and Facility Emergency Response Planning,
and Section 11 - Public Alert and Notification Procedures. The management staff to be interviewed
include the facility manager (who also overviews training), the safety supervisor, and a process
engineer (who handles both hazards evaluation and emergency response planning). The interviews
will be conducted separately by individual team members in various locations.
Tasks to be accomplished:
1. Perform Facility X management staff interviews.
Possible interview topics include, but are not limited to:
Safety and accident investigation procedures and records
Incident investigation findings for the ammonia leak
Staff and management training needs and availability
Hazards evaluation techniques
Emergency response planning
2. Reassemble the team and evaluate the information obtained during the interviews.
Reinterview Facility X management staff as needed.
3. Complete Section 8 - Accidental Release/Incident Investigation, Section 9 - Facility
Emergency Preparedness and Planning, Section 10 - Community and Facility
Emergency Response Planning, and Section 11 - Public Alert and Notification
Procedures.
7/93 45 Exercise 3
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Exercise 4Audit Report Preparation and Presentation
In this exercise, each audit team will finish preparing a chemical safety audit report for Facility X.
They will present their report orally to the rest of the participants. Limited reinterviews of various
Facility X personnel will be allowed during this exercise.
Tasks to be accomplished:
1. Complete Section 2 - Summary of Findings/Conclusions, Section 12 - Conclusions,
and Section 13 Recommendations.
2. Complete any other section that was not finished earlier.
3. Prepare the team's oral audit report presentation.
7/93 47 Exercise 4
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CHEMICAL SAFETY AUDIT PROGRAM WORKSHOP
GROUP EXERCISE
CHEMICAL SAFETY AUDIT REPORT
WORKSHEET
1.0 Introduction (includes an introduction to both the chemical safety audit program AND the
facility audit)
1.1 Chemical Safety Audit Program:
1.2 Facility X - Pacific Town, Washington, Audit:
7/93 1 Audit Report Worksheet
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2.0 Summary of Findings/Conclusions (includes a BRIEF description of the major findings
and conclusions of the audit)
Audit Report Worksheet 2 7/93
-------
3.0 Background (includes general facility and audit information, purpose of the audit and the
facility selection process, and audit methodology)
3.1 General Facility and Audit Information
7/93 3 Audit Report Worksheet
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3.2 Purpose of the Audit and Facility Selection Process
Audit Report Worksheet 4 7/93
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3.3 Audit Methodology
7/93 5 Audit Report Worksheet
-------
4.0 Facility Background Information (Includes information about the location, size, and
general layout of the facility. Also includes information about sensitive populations in the
area and a brief description of climatic and topological conditions.)
Audit Report Worksheet 6 7/93
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5.0 Chemical Hazards (includes all chemical hazards that are covered in the scope of the audit;
MAY include material safety data sheets)
7/93 7 Audit Report Worksheet
-------
5.0 Chemical Hazards (continued)
Audit Report Worksheet 8 7/93
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6.0 Process Information (includes storage information, a process description, and process
hazards)
6.1 Storage Information
7/93 9 Audit Report Worksheet
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6.2 Process Description
Audit Report Worksheet 10 7/93
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6.3 Process Hazards
7/93 11 Audit Report Worksheet
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7.0 Chemical Accident Prevention (includes management activities, process operation and
maintenance, hazard evaluation and modeling, release prevention systems, and release
mitigation systems)
7.1 management Activities
Audit Report Worksheet 12 7/93
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7.1 Management Activities (continued)
7/93 13 Audit Report Worksheet
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7.2 Process Operation and Maintenance
Audit Report Worksheet 14 7/93
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7.2 Process Operation and Maintenance (continued)
7/93 15 Audit Report Worksheet
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7.3 Hazard Evaluation and Modeling
Audit Report Worksheet 16 7/93
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7.4 Release Prevention Systems
7/93 17 Audit Report Worksheet
-------
7.5 Release Mitigation Systems
Audit Report Worksheet 18 7/93
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10.0 Community and Facility Emergency Response Planning Activities
7/93 21 Audit Report Worksheet
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11.0 Public Alert and Notification Procedures
Audit Report Worksheet 22 7/93
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8.0 Accidental Release/Incident Investigation
7/93 19 Audit Report Worksheet
-------
9.0 Facility Emergency Preparedness and Planning Activities
Audit Report Worksheet 20 7/93
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12.0 Conclusions
7/93 23 Audit Report Worksheet
-------
12.0 Conclusions (continued)
Audit Report Worksheet 24 7/93
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13.0 Recommendations
7/93 25 Audit Report Worksheet
-------
13.0 Recommendations (continued)
Audit Report Worksheet 26 7/93
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CHEMICAL SAFETY AUDIT
FACILITY X
PACIFIC TOWN, WASHINGTON
(FEBRUARY 5 - FEBRUARY 8, 1990)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 11
MAY 1990
-------
REPORT DISCLAIMER
The contents of this report reflect information concerning Facility X obtained during a U.S.
Environmental Protection Agency Chemical Safety Audit and from records provided by Facility X. The
audit was conducted from February 5, 1990, through February 8, 1990, and the observations as presented
in this report provide a snapshot of conditions existing at the facility during the audit time frame. They do
not represent planned or anticipated changes proposed or on-going at the facility. The recommendations
and other report observations contained in this report are not mandatory actions that the facility must
implement. In addition, EPA makes no assurances that if implemented, the recommendations and other
report observations contained in this report will prevent future chemical accidents, equipment failures,
unsafe management practices, or provide protection from a future enforcement action under any applicable
law or regulation.
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TABLE OF CONTENTS
Page
1.0 INTRODUCTION I
1.1 Chemical Safety Audit Program
1.2 Facility X -- Pacific Town, Washington Audit
2.0 SUMMARY OF FINDINGS/CONCLUSIONS 2
3.0 BACKGROUND 2
3.1 General Facility and Audit Information
3.2 Purpose of the Audit and Facility Selection Process
3.2 Audit Methodology
4.0 FACILITY BACKGROUND INFORMATION 3
5.0 CHEMICAL HAZARDS 6
6.0 PROCESS INFORMATION FOR AMMONIA 6
6.1 Storage and Handling
6.2 Process Description
6.3 Process Hazards
7.0 CHEMICAL ACCIDENT PREVENTION 9
7.1 Management Activities
7.2 Process Operation and Maintenance
7.3 Hazard Evaluation and Modeling
7.4 Release Prevention Systems
7.5 Release Mitigation Systems
8.0 ACCIDENTAL RELEASE/INCIDENT INVESTIGATION 10
9.0 FACILITY EMERGENCY PREPAREDNESS AND PLANNING ACTIVITIES 11
10.0 COMMUNITY AND .FACILITY EMERGENCY RESPONSE PLANNING ACTIVITIES . 11
11.0 PUBLIC ALERT AND NOTIFICATION PROCEDURES 12
12.0 CONCLUSIONS 12
13.0 RECOMMENDATIONS 13
Appendix A - Audit Team 15
Appendix B - MSDS Sheet for Ammonia 16
Figure 1 - Facility X 4
Figure 2 - Communities Around Facility X 5
Figure 3 - Urea Manufacturing Process 8
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1.0 INTRODUCTION
1.1 Chemical Safety Audit Program
The Chemical Safety Audit (CSA) program has evolved from efforts of the U.S. Environmental
Protection Agency (EPA) under the Chemical Accident Prevention (CAP) program. The primary
objectives of the CAP program are to identify the causes of accidental releases of hazardous substances
and the means to prevent such releases from occurring, to promote industry initiatives in these areas, and
to share activities with the community.
The Chemical Safety Audit program is part of this broad initiative, and has been designed to
accomplish the following chemical accident prevention goals:
Heighten awareness of the need for chemical safety among chemical producers,
distributors, and users, as well as in communities where chemicals are located;
Visit facilities handling hazardous substances to learn and understand problematic and
successful practices and technologies for preventing and mitigating releases.
Build cooperation among authorized parties by coordinating joint accidental release
investigations where appropriate.
Establish a national database for the assembly and distribution of chemical safety
information obtained from facility investigations and from other sources;
The audit consists of interviews with facility personnel, and on-site review of various aspects of
facility operations related to the prevention of accidental chemical releases. CERCLA Sections 104(b) and
104(e), as amended by SARA, provide authorities for entering a facility and accessing information.
Specific topics addressed in the audit include:
Process characteristics:
Hazard evaluation and release detection techniques;
Training of operators and emergency response personnel;
Management structure (corporate and facility);
o Preventive maintenance and inspection programs; and
Community notification mechanisms and techniques.
L2 Facility X -- Pacific Town, Washington, Audit
This report contains observations, conclusions, and recommendations from an audit conducted at
Facility X, a urea manufacturing plant in Pacific Town, Washington, from February 5 through February 8,
1990. The facility was selected for an audit because of a series of releases of ammonia from the urea
production unit, the last one of approximately 500 pounds. This report identifies and characterizes the
strengths of specific chemical process safety management program areas to allow the elements that are
particularly effective to be recognized. Copies of this report have been provided to the facility's corporate
management so that weak and strong program areas may be recognized.
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2.0 SUMMARY OF FINDINGS/CONCLUSIONS
Based upon a limited review of the chemical process safety management practices related
specifically to the handling of ammonia, the audit team has reached the following conclusions:
Facility X management is actively sponsoring and providing training for emergency
response, maintenance, and operations; has reduced the ammonia operating inventory; and
has documented operating and maintenance procedures, checklists, standard safety rules,
and procedures for all tasks and operations.
Facility activities related to preventing ammonia leaks include use of an excess flow valve
and earthquake protection measures.
Facility X has not conducted a hazard evaluation for 5 years due to budget limitations.
Corporate policy calls for evaluations to be performed annually. The facility performs
maintenance on an "as needed" basis and has extensive records on equipment inspection,
testing, and replacement.
The facility has evaluated an ammonia perimeter monitoring system and elected not to
install such a system. However, the facility is currently investigating the use of ammonia
monitors at certain potential release points.
The facility management conducts incident investigations for all deviations from standard
conditions and identifies problems in the investigation reports. However, there is no
systematic follow-up to correct those problems.
The facility did not notify the LEPC of its ammonia releases.
The fire brigade, responsible for handling all emergency situations, does not meet
regularly and has not conducted a drill in nearly 15 months. The emergency response
plan does not include the names of personnel responsible for relieving employees who
leave a job to respond to an emergency.
3.0 BACKGROUND
3.1 GeneralFacility and Audit Information
Facility X is owned by Urea Manufacturing, Inc., the parent company. Facility X operates at the
following address:
Facility X
1 Industry St.
Pacific Town, WA 99999
The facility has five buildings and is located north of Interstate Highway 1 and west of County Highway.
The facility produces .urea in a multi-step process based on the reaction of ammonia with carbon dioxide.
The urea is bagged and sold for nitrogenous fertilizer. 'The audit was conducted from February 5 through
February 8, 1990, by a team of Regional representatives from the U.S. Environmental Protection Agency
(EPA). EPA was assisted by representatives from the Occupational Safety and Health Administration
(OSHA), the State Emergency Response Commission (SERC), and the Local Emergency Planning
Committee (LEPC). The names of the team members, their affiliation, their responsibilities in the audit,
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and their expertise are provided in Appendix A.
3.2 Purpose of the Audit and Facility Selection Process
The purpose of the audit was to examine the facility's chemical process safety management
practices associated with ammonia. The facility was selected for an audit based on an analysis of chemical
use in the region, referral from the SERC. and the facility's release history. Region 11 identified ammonia
and chlorine as the two chemicals used in the highest volume in the region. Based on the facility's release
history, the SERC requested through the Regional Office that a chemical safety audit be conducted.
There was a series of accidental releases of ammonia occurring over the past year, the last one of
approximately 500 pounds.
3.3 Audit Methodology
The audit centered around the process areas related to the use of ammonia in the urea
manufacturing process. Because of time and resource constraints, the audit team did not review the
production of ammonia from natural gas in the ammonia/carbon dioxide unit. The audit addressed
ammonia hazards, chemical accident prevention, process operation and maintenance, hazard evaluation and
modeling, release prevention systems, accidental release incident investigation, facility emergency
preparedness and planning, and community and facility emergency response planning activities. However,
the audit is limited in that it does not attempt to make comparisons or otherwise distinguish between the
safety systems used only for urea manufacturing processes and those used for other chemical processes at
the facility.
4.0 FACILITY BACKGROUND INFORMATION
Facility X is located approximately 100 miles west of Seattle on the Pacific coast in an area known
as Pacific Town. This facility is located north of Interstate Highway 1 and west of County Highway.
Figures 1 and 2 are maps of the area provided to the audit team by the facility. The facility is bounded on
the north side by the railroad tracks. There are five buildings on the property; the urea unit, the ammonia
and carbon dioxide production unit; the urea storage warehouse, the stearn plant, and offices. There is
also a tank farm and a parking lot.- The facility can be accessed from either the main gate off the
Interstate Highway or from the railroad spur. Hazardous and extremely hazardous substances are
transported both by highway and rail. The facility is 20 years old and employs 110 persons.
The facility occupies 100 acres in a relatively sparse area approximately 2.5 miles from the nearest
community shopping mall. An elementary school is within three miles and a lake, critical to the town's
water supply, is within 3.5 miles of the plant. The shopping mall, the school, and the lake are considered
by the facility to be sensitive populations and environments for a major ammonia release. Both the
County Highway and the Interstate Highway are heavily travelled routes.
Pacific Town experiences the heavy spring rains and high humidity associated with a Northwest
Pacific coastal city. Other relevant weather data include an average temperature of 53°F, average relative
humidity 73 percent, and mean wind speed of 7.9 miles per hour from east-southeast direction. The
facility is situated near a flood plain and minor flooding often occurs in the area during the spring months.
The coastal area also is susceptible to earth tremors from nearby earthquake prone zones. In April 1965,
before this facility was built, an earthquake with an epicenter in Puget Sound-Tacoma caused extensive
building and property damage to the coastal region. In a response to this potential for damage, the facility
owners designed and constructed the chemical process buildings with lateral bracing and strong
connections to guard against the dangerous horizontal motions which can be caused by an earthquake.
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The design capacity for the urea plant is 500 tons per day. Currently, it operates at 70 percent
capacity. Within the last year, the facility had seven ammonia releases, which were reported to the
National Response Center (NRC) and have been documented in internal incident investigation reports.
5.0 CHEMICAL HAZARDS
According to the facility safety supervisor, ammonia, if released accidentally, has the greatest
possibility of producing adverse off-site impacts. Ammonia is produced in the ammonia/carbon dioxide
unit from natural gas and then pumped into the urea production unit via a surge tank. If allowed to
escape to the air, ammonia becomes a colorless toxic gas with an extremely pungent odor. In the worst
case scenario anticipated by the facility, a catastrophic failure of the transfer piping would release liquid
ammonia which would rapidly evaporate and form a toxic cloud. The gas is nonflammable; however, under
certain conditions, it may pose an explosion hazard. The Material Safety Data Sheets (MSDS), which
includes the National Institute of Occupational Safety and Health (NIOSH) Immediately Dangerous to
Life and Health (IDLH) levels for ammonia is provided in Appendix B. In the ammonia production and
urea reactor areas, large bright signs display graphically the hazards of ammonia.
A mini-library of reference materials is kept in each process operations control room. The library
includes information on the hazards associated with chemicals used in all of the processes and includes
MSDSs, accidental investigation reports, the Merck Index, a folder describing worker rights and
responsibilities under OSHA regulations, a document summarizing SARA Title III Community Right-to-
Know provisions, and about one dozen books on chemical toxicity, hazard analyses, and basic facility
design. Employees are encouraged to visit the mini-library, however, most employees interviewed were not
aware of the extent to which these resources existed.
6.0 PROCESS INFORMATION FOR AMMONIA
6.1 Storage and Handling
Storage Systems
There are no dedicated storage systems for hazardous chemicals at Facility X. Ammonia and
carbon dioxide production is set at levels sufficient to maintain urea operations.
Shipping and Receiving
Natural gas is delivered to the ammonia\carbon dioxide unit by pipeline from a nearby well in
sufficient quantity to maintain a continuous production process. The finished product is transferred to the
urea warehouse in the northeast corner of the facility for storage before shipment off-site by railcar.
Material Transfer
Ammonia is produced on-site by Facility X in the ammonia/carbon dioxide production unit
building. After the ammonia is generated, purified, and compressed, it is transferred via welded, flangeless
pipes to the urea reactor building using electrically grounded equipment to prevent dangerous static
electricity sparks. The pump is equipped with a double mechanical seal and seal purge to guard against
seal failures and leaks, and an excess flow valve is connected to the transfer piping to prevent accidental
releases if a rupture occurs in the piping.
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6.2 Process Description
Overview of Processing Steps
Ammonia is reacted with carbon dioxide to produce urea. The two reactants are produced in the
ammonia/carbon dioxide unit through a process of steam reforming of natural gas (methane). The natural
gas reacts with steam over a catalyst to form carbon dioxide and hydrogen gas. The carbon dioxide is
removed and the hydrogen is further reacted with a nitrogen source under elevated temperature and
pressure to produce ammonia.
The process flow diagram of the reaction of ammonia and carbon dioxide to produce urea is
shown in Figure 3. Ammonia is pumped through the surge tank, heated and vaporized, compressed, and
fed to the urea reactor. The reaction with carbon dioxide is exothermic (releases heat) and is controlled at
3515 psia and 365°F. Crude urea leaving the reactor passes through a series of decomposers and pressure
reduction valves to separate excess ammonia and carbon dioxide, which are recycled. The urea is purified.
crystallized, dried, prilled, and coated to make a final product.
Details of Ammonia Flow in the Urea Production Process
Ammonia from the ammonia/carbon dioxide unit is pumped with high-pressure pumps through
welded (non-flanged to prevent leaks) piping and a surge tank. The pumps are equipped with double
mechanical seals and purges to prevent seal leaks. If a leak occurs, standard operating procedures call for
operators to switch to standby pumps and immediately shut down the leaking pump. The surge tank is
designed to provide consistent flow and pressure to the ammonia heater and compressors. The surge tank
is equipped with level controls and high-level and -pressure alarms. The tank is also equipped with a relief
valve that vents to the atmosphere should pressure get too high.
Ammonia flows next to a gas-fired heater to vaporize the ammonia for feed to compressors and to
the reactor. Fuel flow to the heater is interlocked with the ammonia exit temperature control. When exit
temperatures get too high for any reason, a high temperature alarm sounds and an interlock cuts off fuel
to the heater. The ammonia vapor from the heater is compressed and fed to the reactor. The compressor
is equipped with special seais to prohibit leaks and is checked for leaks during operation several times a
day.
Ammonia, carbon dioxide, and recycled ammonium carbamate react exothermically to form urea.
The temperature in the urea reactor can be controlled using the flow of reactants. Pressure is controlled
by a pressure control valve on the high pressure decomposer and separator. High reactor pressure causes
an alarm to sound and if the pressure reaches a certain level in the reactor, the high pressure relief valve is
interlocked open to vent pressure to the atmosphere. All ammonia piping in these systems is welded to
prevent flange leaks.
Ammonia Release Detection
According to facility operators, the primary methods for detection of leaks are by visual
observation and ammonia odor. Operators make routine patrols to check for leaks. In addition, operators
also use portable gas monitors for ammonia detection. The ammonia monitors are used typically after a
release has been identified to measure ammonia concentration and to verify the source of the leak. They
are not used regularly or stationed around the process. The facility examined the feasibility of purchasing
a perimeter monitoring system to measure the presence of several gases including ammonia. The facility
decided not to install this system because of the high cost of maintaining it. The facility is investigating
installation of a monitor on a few selected locations, such as the compressor, for early detection of leaks
For releases to water, the facility uses continuous nitrogen analyzers to provide quick detection of
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ammonia in wastewater. Daily and weekly composite sampler provide analysis of the wastewaier to aid in
determining the sources of accidental releases.
6.3 Process Hazards
The high temperature and pressure levels in the urea production process present an increased
potential for an accidental release.
7.0 CHEMICAL ACCIDENT PREVENTION
7.1 Management Activities
A corporate safety person (a Vice President) is responsible for 22 plants located at various
locations within the United States. All environmental regulatory compliance, safety, and health issues are
the responsibility of the corporate safety person. At the plant, the safety/loss prevention supervisor has
the primary responsibility for safety, health, and the environment. He maintains records of all incident
investigations, including accidental releases, and prepares a report for the plant manager within 30 days of
each incident that provides the full details of the investigation along with recommendations for
improvements of safety. Also, he supervises the employee suggestion program to encourage safety-related
suggestions accompanied by monetary rewards. In addition, he maintains records of personnel who have
attended training programs at the facility. Training programs include courses on employee safety,
emergency response, and equipment operation certification. Facility X is an active participant in the
Chemical Manufacturers Association's Community Awareness and Emergency Response (CAER) program
and is a member of the Industry Mutual Aid Association, a group of local industries that combine
resources to address emergency responses to catastrophic chemical releases. The facility is in regular
communication with the corporate safety office and formal meetings are scheduled monthly.
7.2 Process Operation and Maintenance
Management has coordinated the development of training courses on emergency response,
maintenance, and operations. Classes include employee safety, chemical hazards, emergency response,
certification of operators on equipment, employee retesting, equipment replacement, completing release
investigation forms, and an on-the-job buddy system program for new hires.
All operators in charge of the urea process, including the area in which the ammonia release
occurred, are given a one-week, four-part training course covering (1) process operation, (2) process
hazards, (3) problem solving, and (4) emergency procedures. Part one informs the operator about the
reactions in the process and the steps in startup, operation, and shutdown of the urea unit. Operators are
provided with routine operations checklists to follow as standard operating procedures. These have been
developed and revised by both the process design engineers and the operators. Part two on process
hazards is covered in lecture format and part three on problem solving is conducted in a discussion format.
Emergency procedures, the final part, is addressed in actual simulation tests on the urea unit. The goal of
the course is to familiarize and educate the operators about the process and proper procedures so that
supervisory involvement can be minimized. As a result of the latest ammonia accident, the facility
management is designing a mini-course for urea operators to review and strengthen their knowledge and
skills in problem solving and in following emergency procedures.
Equipment maintenance at,this plant is performed on an "as needed" basis. However, the plant
conducts regular instrument and equipment inspections and testing, bi-annually during scheduled
shutdowns, daily for the nitrogen analyser, every 1-3 years for relief valves, and every 1.5 years for excess
flow devices, transfer hoses, automatic shutdowns, pressure gages, and flow indicators. Records of all
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equipment inspection, testing, and replacement are kept in the maintenance department office and the
process control room. The units in the manufacturing of urea typically operate about 16 hours a day and
are left idle overnight. Full shutdown for repair of the units in the urea process occurs every 13 to 16
months.
7.3 Hazard Evaluation and Modeling
Corporate policy requires that cause-consequence analysis or HAZOP evaluations be conducted
annually. Facility X has not performed such an evaluation for 5 years because of budget limitations. The
facility has worked with the LEPC and used EPA's Technical Guidance for Hazards Analysis to perform
screening modeling of ammonia releases. This led to inventory reductions as mentioned above. The
facility has not conducted any Other modeling techniques for evaluation of the consequences of releases
other than catastrophic vessel failure.
7.4 Release Prevention Systems
The relief valve on the ammonia surge tank is designed to reduce the potential for a catastrophic
release. Also, the urea reactor vessel was recently replaced with a titanium-lined reactor because of its
improved protection against corrosion.
7.5 Release Mitigation Systems
Should a release occur at Facility X, the ammonia plant is equipped with a water spray system to
help lock down ammonia vapors and reduce their spread. When examined, the spray nozzels were
corroded and did not appear to be in good working condition. The spray system was not activated in the
last reported release, and the last date of use was unknown.
8.0 ACCIDENTAL RELEASE/INCIDENT INVESTIGATION
Facility X has had seven releases of ammonia over the past year. All were from the urea unit and
above the reportable quantity (100 pounds) for ammonia. The last release involved 500 pounds. Three of
the releases occurred because of seal failures on pumps, three occurred on the ammonia compressor seals,
and one occurred on the pressure relief valve on the urea reactor. The releases ranged from 150 pounds
to 500 pounds.
The last reported release occurred from the relief valve on the urea reactor. The urea process was
"upset" by fluctuations in the carbon dioxide feed and possible blockage in lines from the reactor.
Operators were unable to manually slow down the pressure and feed oscillations in the system. At 10%
above normal reactor pressure, the relief valve on the urea reactor lifted, as designed, to protect the
integrity of the vessel by relieving pressure to the air. The valve did not reseat, as it should have as
pressure reduced, and efforts by the field operator to cause the valve to reseat were unsuccessful.
Consequently, the operators shut down the system and emptied the remaining ammonia from the reactor
back to the surge tank. All of the efforts to stop the leak, all of the safety precautions, and all of the
communication between responders followed documented emergency response procedures.
Upon later inspection, the main seat spring in the valve was found to be corroded, causing the
valve to stick open. The facility followed up on the incident by contacting the valve vendor and concluding
that the valve failure was "rare and unusual". No documentation exists on why the process became upset,
why operators could not stop feed oscillations, and if other causes of high pressure in the urea reactor
were identified (e.g., blockage in lines). However, in interviews with various plant personnel, it is unclear
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if the pressure surges in the reactor are the result of operator error or blockage in the process lines to and
from the reactor.
For accidents reported to the NRC, facility policy requires completion of an Accidental Release
Report. The report usually is assembled by an operator/maintenance staff with the assistance of the plant
safety supervisor. Training is offered to properly teach how to write such a release report.
Recommendations from the report are discussed with the plant manager and worthwhile changes are
addressed in a follow-up memorandum by the safety supervisor and distributed to the appropriate facility
staff. According to the plant safety supervisor, all of the accident reports are annually reviewed to identify
common problems and a comprehensive investigation is conducted for each identified problem, such as
equipment failure.
9.0 FACILITY EMERGENCY PREPAREDNESS AND PLANNING ACTIVITIES
As an active participant in the local CAER program, emergency response plans at the facility are
revised and updated every six months. The plan covers the facility's release response and reporting
procedures, emergency equipment provisions, and evacuation routes. In the event of an emergency,
Facility X currently has a fire brigade for responding to facility emergencies, including responding to
ammonia releases. Equipment for response to ammonia releases includes Level A and B suits and
respirators, hand-held ammonia monitors, two-way radios, and an ammonia leak repair tool kit. The fire
brigade staff at the facility had received training at the State University Fire Academy to learn better fire
fighting, search, and rescue techniques. The fire brigade consists of six operators, all volunteers, and is
headed by two shift supervisors who are on duty at the facility during the typical 12 hours daily operations.
Facility X has only one main gate, making fire and evacuation corridors very limited should a full
facility evacuation become necessary. Evacuation instructions were posted inside each building. These
instructions were clear and corridors were well marked and accessible.
The operators have designated personnel to replace them on a process line if an incident occurs
and the fire brigade is activated. However, most operators did not know who their replacement was, and
replacements were not listed in the response plan.
The shift supervisors have several other responsibilities besides being the head of the fire brigade.
They are responsible primarily for ensuring the proper operation of the process including monitoring
operator performance, coordinating operations and maintenance duties, and other management duties.
According to some of the fire brigade members, they are so busy with their management tasks, the fire
brigade rarely meets to discuss operational issues or conduct drills. During the non-operational hours, the
shift supervisors are on-call with a beeper. If an emergency occurs during non-operational hours and the
shift supervisor is unavailable, the night watch staff is instructed to call the designated backup staff and the
on-call emergency response representative from a nearby chemical facility.
In-plant emergency radios, which are tested every shift, are used to alert all facility staff of an
emergency situation. The facility does not maintain a separate, specialized HazMat team, medical
personnel, or decontamination equipment.
10.0 COMMUNITY AND FACILITY EMERGENCY RESPONSE PLANNING ACTIVITIES
The management of Facility X has coordinated emergency efforts primarily with the Industry
Mutual Aid Association. These include monthly meetings to discuss common hazards, pooling resources,
and conducting simulation exercises. In these meetings, facility responsibilities have been designated and
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formalized in a mutual aid agreement.
As an active participant in the local CAER program, the facility has established a relationship
with the LEPC in planning for chemical releases. According to the SERC and LEPC, facility management
has provided all information required under Title III. Also, the management has given facility tours to
LEPC members and other local emergency response personnel. The facility plans to improve its accidental
release notification procedures with the community, including possible use of short-wave radios to notify
the LEPC and other local emergency response personnel. Also, the facility plans to hold a joint training
program with the Pacific Town hospital to review various types of medical problems such as chemical
burns and inhalation.
11.0 PUBLIC ALERT AND NOTIFICATION PROCEDURES
The facility follows CAER's public notification procedures outlined in the "Community-Industry
Emergency Notification System". Plant policy is for the operations supervisor to make a decision on
notifying the community. Once a decision to notify the local community is made, the procedure calls for
the main gate security guard to contact the local fire department by telephone or radio. The exact wording
of the notification is stated in the facility's emergency response plan. There has been no testing of those
public notification procedures. In addition, the facility has no system for alerting the public of releases.
For each of the seven ammonia releases, the facility notified the NRC and the SERC but did not
notify the LEPC. According to facility procedures, release notification to the LEPC is not necessary
unless the odor of ammonia is detected by hand-held monitors at the fence line and if the release is above
750 pounds. According to SARA Title III, a release need not result in actual exposure to persons off-site
in order to be subject to release reporting requirements.
12.0 CONCLUSIONS
Based upon a review of the chemical process safety management practices related specifically to
the handling of ammonia, the audit team has reached the following conclusions:
The facility has incorporated earthquake protection measures to prevent releases.
c The facility has evaluated perimeter monitoring systems and is in the process of evaluating
specific process monitoring for early leak detection in certain high-leak rate areas.
Operators are trained in the use of, and do use, portable monitors for locating ammonia
leaks.
Facility X management sponsors and provides training on emergency response,
maintenance, and operations.
* The facility's activities related to preventing ammonia leaks include use of an excess flow
valve if a failure occurs downstream.
The facility has documented operating and maintenance procedures, checklists, standard
safety rules, and procedures for all tasks and operations.
Facility X has not conducted a hazard evaluation for 5 years due to budget limitations.
Corporate policy calls for evaluations to be performed annually.
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The facility performs maintenance on an "as needed" basis and has extensive records on
equipment inspection, testing, and replacement. Several releases involved equipment that
failed in service.
The water spray nozzels for the ammonia release suppression system were corroded and
did not appear to be in good working condition.
The facility identified the cause of the ammonia releases as the failure of the relief valve
to reseat after an initial buildup of pressure in the urea reactor, but interviews conducted
with plant personnel indicate that the cause of the pressure surges in the reactor have not
been clearly identified.
The facility management conducts incident investigations for all deviations from standard
conditions and attempts to follow-up on problems identified in the investigation reports.
The fire brigade is composed of volunteer operators and two shift supervisors. The fire
brigade does not meet regularly and has not conducted a drill in nearly 15 months. The
emergency response plan does not include the names of personnel responsible for
relieving employees who leave a job to respond to an emergency. Because no
documentation existed, it was not clear if these personnel have received the health and
safety training required by OSHA for personnel involved in emergency response
operations.
The facility did not notify the LEPC of any of the seven ammonia releases.
13.0 RECOMMENDATIONS
Based upon the audit team's observations and conclusions, audit team recommendations to the
management of Facility X include:
Use of certain monitors and alanns to detect ammonia leaks at locations where leaks
frequently occur, such as seals should be thoroughly investigated by the facility.
o The practice of maintenance "as needed" may be contributing to equipment failure and
resulting releases. The facility should consider establishing a predictive maintenance and
testing program to repair or replace equipmant and to prevent failures and releases from
critical equipment such as relief valves and seals.
The facility's budget priorities should be re-examined to allow for hazard evaluations to be
completed as required by corporate policy. Investigate use of AIChE Guidelines or use
some recently developed resources (like software or contractors) to allow for more timely
and cost effective completion of hazard evaluations.
The facility should clean and'test the spray nozzles for the ammonia release suppression
system.
The facility should continue its investigation to determine if blockage or operator error is
the cause for pressure surges in the reactor.
The facility should consider developing formal follow-up procedures, including time
schedules, to ensure that incident investigation recommendations are evaluated and
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14
implemented, if appropriate.
The facility should evaluate and adjust the workload demands on the shift supervisors
responsible for the fire brigade. They may not have sufficient time to give the attention
needed for maintaining an effective, well-tested fire brigade. While there is plenty of
commitment on the part of the volunteer operators, emergency response training should
be provided, at least to meet the minimum requirements specified by OSHA. In addition,
the emergency response plan should contain the names of all backup personnel for these
volunteer operators.
The facility should re-examine their policy and procedures regarding release notification,
specifically reporting to local authorities as required under SARA Title III section 304
and to focus on fulfilling the spirit of Title III. The ammonia releases were probably
subject to section 304 notification requirements because the releases were above the
reportable quantity for ammonia and the releases had the potential to result in exposure
to persons off-site. Also, the facility should consider reporting all releases, regardless of
quantity, to the LEPC to strengthen and improve relations with the LEPC and the local
communitv.
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16
Appendix B
MSDS SHEET FOR AMMONIA
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Material Safety Data Sheet
May be used to comply witn
OSHA's Hazard Communication Standard,
29 CFR 1910.1200. Standard must be
consulted for specific requirements.
U.S. Department of Labor
Occupational Safety and Health Administration
(Non-Mandatory Form)
Form Approved
OMB No. 1218-0072
IDENTITY (As. Used on iaoel and Ust)
AMMONIA
A/ore: Blank spaces ara not permitted. It any item is not apoiicaDle. or no
information is available, tne soace must oe marked to indicate tnat.
Section I
Manufacturer s Name
Aooress (Number. Street
Facility X
City, State, and ZIP Code)
One Industry Street
Pacific Town, WA 99999
Emergency Telephone Numoer
(206) 555
Telephone Number for Information
(206) 555
Date Prepared
February
-6666
-5555
28, 1990
Signature of Prepa/er (optional)
Section II Hazardous Ingredients/Identity Information
Hazardous Components (Specific Chemical Identity; Common Name(s)) OSHA PEL
ACGIH TLV
Other umits
Recommended
j /optional)
Ammnn i a ( NH )
TWA SOppm TWA 25ppm IDLH SOOppm
STEL 35ppm TPQ SOOlbs
RQ
lOOlbs
Section III Physical/Chemical Characteristics
Boiling Pant
Vapor Pressure (mm hg.)
Vapor Densny (AIR - 1)
-33° C
400 @ -45°C
0.6
Specific Gravity (HjO - 1)
Liquid:
Meftins Pant
0.68 @ -33° C
-78° C
Evaporation Rate
(Butyl Acetate - 1)
Solubility in Water
31g / IQOg @ 25° C
Appearance and Odor
Colorless gas or liquid; sharp, cloving, repellant
Section IV Fire and Explosion Hazard Data
Rash Point (Method Used)
Flammable Limns
LEL
16%
DEL
25%
''0 '
'0^ i re's : dry chemical or carbon dioxide. Large fires: wacer spray, fog, or foam
Wear positive pressure breathing apparatus and full protective cloth
Special Fire Fighting Procedures
Unusual Fire and Exptosion hazards
Mixing of ammonia with several chemicals can cause severe fire
hazards and/or explosions. Ammonia in container may explode in heat of fire
(Reproduce locally)
OSHA 174. Sept. 1985
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Section V Reactivity Data
Sta&lity
unstaole
Staoie yes
Conditions to Avoid
Mixing with other
chemica Is
and water
incomoatiDimy (Ma.lenais to Avoid)
Strong oxidizers, calcium, hypoch lor i te
b leaches ,
gold,
mercury, si
Iver, and ha
1 o g e n s
Hazarnoys Decomnnsiiion or Byproducts
nazaroous
Polymerization
May Occur
Will Not Occur
Yes
Conditions to Avoid
Section VI Health Hazard Data
Routetsl of Entry:
Inhalation?
Yes
Skin?
Yes
Ingestioo''
Yes
neaitn Hazards lAcure ana Chronici
Eye and respiratory tract irritant
Caranogeniary:
IARC Monographs?
OSHA Regulated?
Signs and Symptoms ol Exposure
Medical Conditions
3eneraMy Aggravated oy Exposure
Emergency and First Aid Procedures
Section VII Precautions for Safe Handling and Use
Steps to B« Taken in Case MitenaJ Is Retoased or Spilled
Vencilate area of spill or leak to disperse gas. If in gaseous form stop flow of gas.
If source of leak is a cylinder and cannot be stopped, remove to open air and repair leak
or allow cylinder to empty. If in liquid form allow to vaporize.
Waste Disposal Method
Precautions to Be Taken in Handling and Storing
Other Precautions
, , . . , . . , ,
In case of release or spill, keep unneccessary people away, isolate hazard are
and deny entry. Stay upwind out of low area. Evacuate area endangered by gas.
Section VIII Control Measures
Respiratory Protection CSpecrfy
Positive pressure, pressure-demand, full facepiece SCBA or pressure-demand supplied air
Ventilation
Local Exhaust
Mechanical (Geoera/,1
Protective Gloves
Special
Other
Eye Protection
Other Protective Clothing or cduipment
respirator with escape SCBA and a fu 1 ly-encapsu lating, chemical resistant suit
Worx/HygieniC Practices
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Tent Summary 2?83oo8538
SITE DATA INFORMATION:
Location: LONG BEACH, CALIFORNIA
Building Air Exchanges Per Hour: 0.52 (Sheltered single storied)
Date & Time: Fixed at March 17, 1992 & 1200 hours
CHEMICAL INFORMATION:
Chemical Name: SULFUR DIOXIDE Molecular Weight: 64.07 kg/kmol
TLV-TWA: 2.00 ppm IDLH: 100.00 ppm
Footprint Level of Concern: 0.2 ppm
Boiling Point: 13.96° Fahrenheit
Vapor Pressure at Ambient Temperature: greater than 1 atm
Ambient Saturation Concentration: 1,000,000 ppm or 100.6%
ATMOSPHERIC INFORMATION:(MANUAL INPUT OF DATA)
Wind: 2.5 meters/sec from N No Inversion Height
Stability Class: B Air Temperature: 85.° Fahrenheit
Relative Humidity: 5% Ground Roughness: Urban or forest
Cloud Cover: 1 tenths
SOURCE STRENGTH INFORMATION:
Direct Source: 1 grams/sec Source Height: 0
Release Duration: ALOHA limited the duration to 1 hour
Release Rate:-0.132 pounds/min
Total Amount Released: 7.94 pounds
Note: This chemical may flash boil and/or result in two phase flow.
FOOTPRINT INFORMATION:
Model Run: Heavy Gas
User specified LOC: 0.2 ppm
Max Threat Zone for LOC: 188 yards
Max Threat Zone for IDLH: 11 yards
For more detailed information check the Time Dependent
Cone/Dose information at specific locations.
TIME DEPENDENT INFORMATION:
Concentration/Dose Estimates at the point:
Downwind: 16 yards
Off Centerline: 0 yards
Max Concentration:
Outdoor: 24.1 ppm
Indoor: 9.67 ppm
Max Dose:
Outdoor: 1,420 (ppm,min)
Indoor: 310 (ppm.min)
Note: Indoor graphs are shown with a dotted line.
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Footprint Window
2783008536
Chemical Name: SULFUR DIOXIDE
Model Run: Heavy Gas
Wind: 2.5 meters/sec from N
FOOTPRINT INFORMATION:
Model Run: Heavy Gas
User specified LOG: 0.2 ppm
Max Threat Zone for LOG: 188 yards
Max Threat Zone for IDLH: 11 yards
For more detailed information check the Time Dependent
Cone/Dose information at specific locations.
150
CO
03
^
CO
150
0
100
200
yards
300
400
U.S. GOVERNMENT PRINTING OFFICE: 1993 3 it 1 - 8 3 S / 83079
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