I *
THE CHEMICAL SAFETY AUDIT PROGRAM:
A STATUS REPORT
Prepared for
Chemical Emergency Preparedness and Prevention Office
U.S. Environmental Protection Agency
Washington, D.C.
2?
CO
CM
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Prepared by:
ICF Incorporated
December 1990
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TABLE OF CONTENTS
EXECUTIVE SUMMARY ,
1.0 BACKGROUND OF CHEMICAL SAFETY AUDIT PROGRAM I
1.1 CSA Program Authority 1
1.2 Audit Team Composition 2
1.3 Facility Selection 2
1.4 Audit Scope 3
1.5 CSA Training Workshop 4
1.6 CSA Database 4
2.0 OVERVIEW OF CSA PROGRAM RESULTS 7
2.1 Chemical Safety Audits, and Reports Completed 7
2.2 Chemical Safety Audits hy SIC Code 7
2.3 Chemical Safety Audits by Hazardous Substance 7
2.4 CSA Training Workshops 12
3.0 ANALYSIS OF CSA PROFILE RESULTS 15
3.1 Facility Background Information 15
3.2 Chemical Hazards 19
3.3 Process Information 19
3.4 Chemical Accident Prevention 22
3.5 Accidental Release/Incident Investigation 15
3.6 Facility Emergency Preparedness and Planning Activities 25
3.7 Community and Facility Emergency Response Planning Activities 2S
3.8 Public Aleri and Notification Procedures 30
4.0 STATUS OF CSA PROGRAM IMPLEMENTATION 31
APPENDICES
Appendix A:
Appendix B:
Appendix C:
List of Chemical Safety Audits
Hazardous Substances Examined in Chemical Safely Audits
Chemical Safety Audit Report Profiles
EXHIBITS
Exhibit I: Outline of the Chemical Safetv Audit Protocol
FIGURES
Figure 1:
Figure 2:
Figure 3:
Figure 4:
Figure 5.
Status Summary of the Chemical Safety Audit Program
Summary of Chemical Safety Audits and Final Reports Completed hy Region
Breakdown of Audited Facilities by SIC Code
Chemical Safety Audit Workshop Training by Affiliation for FT 89 and FY 90
Chemical Safety Audit Workshop Training by EPA Region
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EXECUTIVE SUMMARY
This document is a report to senior management on the status of the U.S. Environmental
Protection Agency's Chemical Safety Audit program since its official beginning in FT 89.
The Chemical Safety Audit (CSA) program evolved from the 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 them from occurring, to promote industry initiatives in these areas, and to share
the results with the community, industry, and other interested groups. The CSA program was established
as part of this broad initiative. The purpose of the CSA program is to heighten awareness of the need for
chemical safety by visiting facilities handling hazardous substances: to build cooperation among facilities,
EPA, and other authorized parties by conducting joint audits: and to establish a national database for the
assembly and distribution of chemical process safety management information obtained from the facility
audits.
This report is intended to provide EPA Headquarters and Regional management and other
program offices with a better understanding of the audit program goals and purpose, the type of
information being generated and its uses, and how the program is being implemented both in
Headquarters and the Regions.
The report contains four major sections which cover the following topics: audit program
background, results, analysis, and implementation status. The audit program results and analysis sections
are based upon 32 final audit reports and standardized profiles or summaries on these completed audit
reports. Appendix C contains these profile reports. The following discussion summarizes key findings of
the program results, analysis, and implementation status sections.
FINDINGS PROGRAM RESULTS
Audit program results (Section 2.0) are based upon the number of audits conducted and reports
completed in each Region, along with a characterization of the audits by Standard Industrial Classification
(SIC) code and by the hazardous substances reviewed. A summary of training workshop participation is
a bo included.
For FY 89 and FY 90, each Region was assigned a target of conducting 4 audits per year under
the Agency's tracking and evaluation system. In FY 89, 33 audits were conducted, for which 22 final audit
reports have been prepared. The Regional audit teams conducted a total-of 39 audits in FY 90, for which
10 final audit reports have been prepared. A total of 72 chemical safety audits were conducted during FY
39 anjd FY 90. In FY 91 and beyond, the Agency's tracking measure for chemical safety audits will be
considered fulfilled based upon completion of the audit report and its submission to Headquarters.
For FY 89 and FY 90. Regions I, III, IV, VI, IX, and X each met the target of 4 audits per year.
In addition. Region IV exceeded the target by one audit in each fiscal year. During FY 89, Regions V and
VIII conducted 3 audits and in FY 90, they both met the target measure. Region V also exceeded the
target by one audit in FY 90. Region II performed 2 audits in FY 89 and 4 audits in FY 90. Region VII
did not conduct any audits in either fiscal year.
As previously indicated, 32 final audit reports have been completed as of June 30, 1990. Twenty-
two reports on the 33 audits conducted in FY 89 have been prepared. As of June 30. 1990, 29 audits have
been conducted in FY 90, for which 10 final audit reports have been received. The following table
summarizes Regional preparation of audit reports for FY 89 and FY 90.
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REGION
I
II
III
IV
V
VI
VII
VIII
IX
X
Total
NUMBER OF
AUDITS CONDUCTED
Pi' 89 FY 90
4
5
3
4
0
3
4
4
33
4
4
4
5
5
5
0
4
4
4
39
NUMBER OF
REPORTS COMPLETED
(As of June 30. 1990"!
5
0
7
0
5
Of the 32 chemical safely audits for which final reports arc available. 19 categorized the facilities
as manufacturers of chemical and allied products (SIC code 28). Three of ihe audits involved facilities in
the fabricating mcul products category (SIC code 34). The remaining reports were audits of facilities
within other SIC codes. Only 3 of the audits involved non-manufacturing operations.
A total of 104 hazardous substances were examined by audii teams based upon a review of the 32
completed reports and 13 incomplete profiles. On average, the audits examined approximately 6
hazardous substances at each laciliiy. The five most commonly examined hazardous substances were
c acid 1 16 audits), sodium hydroxide (14), chlorine (14), hydrochloric acid (12). and ammonia (10;
A four-day chemical safety audit workshop provides audit team members with training to conduct
an audit. During FY 39 and FY 90, a total of 6 workshops were conducted in Regions III. IV, VI. VII. IX.
and X. Each Region is given the opportunity to host a workshop in order to facilitate attendance by other
Regional media program personnel, regional personnel from Occupational Safety and Health
Administration and Federal Emergency Management Agency offices, and State Emergency Response
Commission (SERC) and Local Emergency Planning Committee (LEPC) members. A louil of 199
individuals attended the 6 workshops, including 72 EPA Regional personnel. 23 American Association ui'
Retired Persons (AARP) members, 46 contractors (primarily Technical Assistance Team members), 40
state and local officials, and 18 others.
FIND INGS PROGRAM ANALYSIS
Section 3.0 characterizes trends identified from the 32 audit profiles developed from the audit
reports. The analysis summarizes and compares the types of recommendations and/or conclusions
presented in the 32 audit reports. The following types of actions recommended for the audited facilities
have been idem i lied and will serve as a baseline for further analysis of the Chemical Safety Audit database
as additional information becomes available.
Expansion of both process and environmental monitoring systems;
Development of process-specific standard operation procedure manuals:
Regular inspection of equipment and testing of instruments:
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Development of facility procedures for regular hazard evaluations;
Refinement or installation of secondary containment measures;
Improvement of labeling/color-coding of storage areas/containers and process and on-site
transfer equipment;
Establishment of schedules for regular reviews and exercising of facility contingency plans;
Increased accessibility and availability of emergency equipment;
Improvements of on-site emergency alarm systems;
Increased coordination with community on planning activities; and
* Development of emergency procedures for public notification.
FINDINGS/IMPLEMENTATION STATUS
Section 4.0 addresses the status of the CSA program and issues that have been identified by
Headquarters and the Regions during FY 89 and FT 90 related to program implementation. Program
status is presented based upon a review of the number of audits conducted and reports completed and (he
qualify of report contents.
In general, a review of the numbers of audits conducted for FY 89 and FY 90 indicate ihai ihe
majority ol Regions have been attempting to commit resources for program implementation. Problems
have occurred in some Regions that have prevented them from accomplishing the 4 audits each year.
including loss of trained personnel and canceled or postponed audits (e.g.. Hurricane Hugo). One area of
concern, however, is associated with the workshop training and conduct of the chemical safety audits. The
CSA program is designed to enhance EPA expertise in the chemical process safety management area. The
Regions arc encouraged to take full advantage of this opportunity to enhance staff skills. The recent past
indicates a trend toward the training of fewer Agency staff and more AARP and TAT personnel. Skills
learned in the training and information gathered through audits will assist the Agency in the
implementation of the Accidental Release Provisions of the Clean Au Act Amendments of 1990.
Other areas of concern in the program to date have been the lack of final audit reports and the
lack of consistency in audit report format from Region to Region and within Regions. Consistency across
audit reports and timeliness of report preparation facilitate analysts of conclusions and recommendations
and assist Headquarters in effectively identifying successful and problematic practices and technologies and
sharing of information with stakeholders.
To address these concerns, the Chemical Emergency Preparedness and Prevention Office is
planning revisions in the CSA protocol and training materials. Headquarters will coordinate these
activities and other program implementation issues with the Regional Chemical Safety Audit Committee
chaired by Region VI.
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CONCLUSION
In summary. EPA envisions the CSA program as a foundation for future activities of the Chemical
Accident Prevention program and as u continuing means of focusing chemical accident prevention
initiatives. The Chemical Safety Audit program is already serving as a stepping stone to the achievement
of many of the goals of the Chemical Accident Prevention program:
* Information gathering in the chemical safety audits helps to identify chemical accident
prevention technologies;
CSA program provides EPA. SERCs, and LEPCs, and other federal agencies with a better
understanding of the causes of chemical releases;
Dissemination of information from the CSA final reports will promote a greater
awareness by facilities of chemical process safety management, and an understanding of
effective prevention and preparedness techniques;
The CSA database will help EPA in identifying problematic ariK in industry where more
attention is needed by private- and public-sector groups with a stake in preventing
chemical accidents; and
The CSA program will sponsor cooperation and coordination of chemical safety programs
with other Federal. State, and local government agencies through joint audits and training.
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1.0 BACKGROUND OF CHEMICAL SAFETY AUDIT PROGRAM
The Chemical Safety Audit (CSA) program is part of a broad initiative 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 audits
where appropriate; and
Establish a national database for the assembly and distribution of chemical safety
information obtained from facility audits and from other sources.
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) passed 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 intentions 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 the results with the community, industry, and other groups (e.g.,
jcademia. 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. As part of the information gathering efforts to prepare this study,
EPA personnel conducted a number of facility site visits to evaluate chemical process safety management
practices. The study covers technologies, techniques, and practices for preventing, detecting, and
monitoring releases of extremely hazardous substances, and Tor alerting the public to such releases. One
of the key recommendations resulting from the study was the continuation and expansion of CAP
activities, including on-site facility visits.
As a follow-up to this national prevention study, EPA has undertaken cooperative initiatives with
other 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
develop and share information on release prevention technology and practices, and to enhance the state of
practice in the chemical process safety arena.
l.l CSA 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 10 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 10
the public health or welfare or to the environment.
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CERCLA sections I04{b) and I04(e>, as amended by SARA of 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 there are no such
arrangements. States, as well as local governments, must use their own authorities for audit participation.
As a matter of EPA policy, if entering pursuant to CERCLA. all facilities that will receive an
audit must have experienced a release of a hazardous substance, pollutant, or contaminant, or there must
be "reason to believe" that there exists a threat of such a release. The audits are intended to be non-
confrontational and positive, such that information on safety practices, techniques, and technologies can be
identified and shared between EPA and the facility. The CSA program encourages the participation of,
and provides benefits to, the Local Emergency Planning Committees (LEPCs) and State Emergency
Response Commissions (SERCs) established under SARA Title III.
It should he noted that the CSA program is not a compliance or inspection program. However, if
serious problems are discovered during the audit, EPA has a variety of legal authorities to use in response
to them. 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.
1.2
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) enrollees. Other Federal.
Siaie. and local government personnel, particularly SERC and LEPC representatives, are encouraged to
participate in audits as team members or as observers. The audit team can vary in size, depending upon
the level of detail of the audit (e.g., number of chemicals and/or processes under review; national
significance). Ai a minimum, however, there must be two technical experts on a team.
Field activities for EPA employees are subject to the training requirements embodied in EPA
Order 1440.2. Health and Safety Requirements for Employees Engaged in Field Activities. Prior to
participation in an audit, all EPA team members, which include EPA employees, contractors, and AARP
enrolleci. must complete training in occupational safety and health procedures as specified in the
Occupational Safety and Health Administration's regulations (29 CFR 1910.120) and under EPA Order
1440.2. and .should attend an EPA Chemical Safety Audit Training Course. In addition, participation in
annual medico 1 monitoring is required.
1.3 Facility Selection
At present, there are no established procedures for selecting a facility for an audit. Each EPA
Region has flexibility in identifying facilities. A variety of options to use in selecting a facility can be
considered;
Previous release history of the facility:
SERC and/or LEPC referral;
Proximity to sensitive population(s);
Public sensitivity;
Opportunity for sharing new technology:
* Population density; and
Concentration of mdusirv in the area,
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Information sources thai can be used in determining some of ihese options include Federal. State, and
local release notification reports and follow-up reports. On-Scene Coordinator (OSC) reports. Regional
Response Centers. Accidental Release Information Program (ARIP), Emergency Response Notification
System (ERNS), and other sources.
Although there is considerable flexibility in facility selection, there are two important
requirements:
A release of a CERCLA hazardous substance, pollutant, or contaminant must have
occurred, or there must be "reason to believe" that a threat of such a release exists at the
facility: and
The Office of the Regional Counsel and the SERC of the State where the audited facility
is located must be consulted to identify any legal actions currently being pursued or
anticipated. It is advised that Regional media programs also be consulted.
To date, the majority of all facilities selected have been identified through ARIP reports. The
ARIP program was initiated in 1986 and collects information through a questionnaire, completed by
facility representatives, that is then entered into a computerized database. The questionnaire includes
information about the facility, the circumstances of the releases such as the occurrence of death/injury, the
need for evacuation, the environmental effects, the methods for clean-up, and the methods implemented
and planned ID prevent further releases.
1,4 Audit Scope
Tht audit consists ot 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:
Process characteristics;
Hazard evaluation and release detection techniques;
Training of operators and emergency response personnel;
Management structure (corporate and local);
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 the Chemical
Emergency Preparedness and Prevention Office (CEPPO). This guidance contains recommended actions,
as wefl 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
tJu: manual n transmitted to the audited facility prior to the audit.
The guidance also contains an audit protocol which provides a detailed topic outline to direct the
scope and content of the audit and a structure for preparation of the audit report. The purpose of ihe
uudii protocol is 10:
Provide detailed guidance on the types of information (hat should be reviewed during the
audit and discussed in the report;
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Ensure continuity m report preparation; and
* Provide an organized and detailed report format for easy access to specific lessons learned
on chemical process safety management practices.
1.5 CSA Training Workshop
The purpose of the Chemical Safety Audit program workshop is to provide guidance on the
procedural and technical aspects of conducting an audit and to promote a better understanding of the
objectives of the CSA program to Regional, AARP, contractor, and State and local government trainees.
The workshop addresses recommended actions and mandatory procedures for conducting chemical safety
audits. Other topics addressed during the four-day workshop include:
EPA's Chemical Accident Prevention Program:
Chemical Safety Audit Guidance Manual;
Chemical Safety Audit Protocol;
Chemical and Process Hazards;
Hazards Evaluation and Application:
Process Safety;
Incident Investigation: and
Computer Modeling tor Planning i Response.
Group exercises are held throughout the workshop 10 provide participants with the opportunity to nppK
theoretical knowledge in scenarios that simulate realistic industry conditions.
Following a pilot workshop held in FY 88 outside of Washington. D.C.. CEPPO conducted 3 CSA
workshops in FY 89. In FY 90, another 3 CSA workshops were held. A lotal of 199 Regional, AARP.
contractor, and state and local government personnel have attended these last 6 workshops. The following
CSA workshops have been planned for FY 91: Denver (Region VIM). San Diego (Region IX), and
Chicago (Region V). A fourth workshop is planned for Region IV. hut a location has not yet been
determined.
1.6
CSA Database
A computerized database is being developed that will provide Regions and Headquarters
information gathered from final chemical safety audit reports, organized in a uniform format consistent
with the CSA protocol. The information contained tn the database will be useful to the Regions for a
variety of purposes, such as identifying field experts and comparing processes at different facilities for the
same chemical.
Through manipulation of the data, CEPPO will be able to use the database to assemble and
distribute information on chemical process safety management and chemical accident prevention issues.
The CSA database will assist CEPPO in identifying successful and problematic chemical process safety
management practices and technologies at the audited facilities. CEPPO will also be able to use the
datable 10 assess the implementation of the program in terms of the number of audits conducted, the
number of reports completed, and the depth of information contained in the reports.
To compile information for inclusion in the database, final audit reports were summarized in
Mundardized profiles consistent with the CSA protocol. Copies of ihesc profiles are enclosed as Appendix
C 10 this report. The profiles provide a summary of ihc audii observations and include the conclusions
and recommendations made by the audit team. The profiles also contain historical material, such as
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facility name, location. primary processes and product(s), hazardous substances examined for ihe audit, and
name. utle. and expertise of each audit team member.
Ol the 62 audits conducted as of June 30. 1990, 32 audit reports have been completed by Regional
personnel. Althouch 10 additional audits have been conducted since June 30, 1990. the data from these
audits have not bee'n considered for the purposes of this analysis. Preliminary review of the 32 audit
reports reveals a number of trends in the actions recommended for the audited facilities. For example, a
sianiiicant number of the audit reports recommend that audited facilities expand both process and
environmental monitoring systems, conduct regular inspection and testing of equipment and instruments.
and develop or improve procedures for emergency notification of the public. These and other trends are
anher discussed in section 3.0 of this report.
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2.0 OVERVIEW OF THE CSA PROGRAM RESULTS
As of June 30, 1990. EPA Regional Offices have conducted a toial of 62 chemical safety audits.
The 32 completed audit reports were reviewed for this analysis. The following four sections provide an
overall and Region-by-Region summary of the Chemical Safety Audit program implementation. Section
2.1 indicates the number of chemical safety audits and audit reports completed in each fiscal year. Section
2.2 provides a breakdown of the audited facilities by Standard Industrial Classification (SIC) Code.
Section 2.3 indicates the number of hazardous substances examined by the audit teams and identifies those
substances that appeared most frequently in the audit reports. Section 2.4 discusses the 6 chemical safety
audit training workshops conducted by EPA for the Regions.
2.1 Chemical Safety Audits and Reports Completed
For FY 89 and FY 90, each EPA Region was assigned a target of conducting 4 audits each year
under the Agency's tracking and evaluation system. The Agency tracking measure for FY 89 and FY 90
was fulfilled upon completion of an on-site facility visit and did not include completion of a subsequent
audit report. In FY 91 and beyond, the tracking measure for chemical safety audits will be based on
completion of the audit report.
Figure 1 provides totals for the number of chemical safety audits thai the Regional offices
conducted during each fiscal year. The number of reports completed by each Regional office is also
included. The chart indicates that 33 chemical safety audits were completed in FY 89. Twenty-two of the
33 audits from FY 89 have final audit reports available. As of June 30, 1990. the Regional Office audit
teams conducted a total of 29 audits in FY 90, for which U) final audit reports have been received. Figure
2 provide^ a Regional comparison of the number of chemical safety audits and final reports completed.
2.2 Chemical Safety Audits by SIC Code
Most Regional Offices conducted the majority of their chemical safety audits at chemical
manufacturing facilities. For example, of ihe 7 facilities audited by Region VI for which final audit reports
are available. 5 of the facilities were chemical manufacturers.
Figure 3 provides a breakdown by SIC code of the types of facilities at which chemical safety
audits were conducted. Of the 32 chemical safety audits for which final audit reports are available, 19
categorized the audited facilities as manufacturers of chemical and allied products (SIC code 28). Three of
the audits involved facilities in the fabricated metal products category (SIC code 34). The remaining 10
reports were audits of facilities within other SIC codes. Only 3 of the audits involved non-manufacturing
operations.
2.3 Chemical Safety Audits by Hazardous Substance
A total of 104 hazardous substances were examined by audit teams in the 45 chemical safety audits
- 32 completed audit reports and 13 incomplete profiles ~ for which this information is available. On
average, the audits examined approximately 6 hazardous substances at each facility. Appendix B of this
report provides a complete listing of the hazardous substances examined during these 45 audits. The 5
most commonly examined hazardous substances were sull'uric acid (16 audits), sodium hydroxide (14),
chlorine H4), hydrochloric acid (12), and ammonia (10).
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r- 5*
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Figure 3
Breakdown of Audited Facilities
by SIC Code*
Other SIC Codes
10 Audits
(31+%)
SIC Code 34:
Fabricated
Metal Products
3 Audits
(9+%)
SIC Code 28:
Chemicals and
Allied Products
19 Audits
(59+%)
This figure only includes the 32 audits for which final audit reports are available.
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Figure 4
Chemical Safety Audit
Workshop Training
by Affiliation for
FY 89 and FY 90
State and
Local Officials
(20%)
AARP Personnel
(12%)
EPA Regional
Personnel
TAT and
Other
Contractors
(23%)
Other Personnel*
'Other Personnel includes EPA HO personnel, other federal agency officials,
and EPA HQ contractor personnel.
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2.4 CSA Training Workshops
As of the close of the FY 90. CEPPO has conducted 7 CSA training workshops for Regions across
the country. With the exception of the pilot CSA workshop held in Bethesda. Maryland, all of the
workshops were held in cities in which a Regional Office is located. In FY 90. the host Regions were co-
sponsors of the CSA workshops and provided valuable assistance in organizing and conducting the
workshops. In addition, hosting workshops in (he cities in which the Regional Office is located allowed
other EPA program offices, other Federal agencies, and SERCs and LEPCs to attend.
EPA conducted workshops in Atlanta, Dallas, and San Francisco in FY 89. In FY 90, workshops
were held in Philadelphia, Seattle, and Kansas City. Figure 4 reflects the number of audit team personnel
that have been trained in the workshops. A total of 199 individuals attended the six workshops, including
72 Regional personnel. 23 AARPs. 46 contractor personnel (primarily technical assistance team members).
40 state and local officials, and 18 others (e.g.. EPA HQ and other federal officials).
Figure 5 is a breakdown by Region of the number of audit team members who have received
training. State and local officials are not included in these totals. The largest number of personnel
attending the workshops were from Region IV (35), Region VI (22), and Region III (16).
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Figure 5
Chemical Safety Audit Workshop
Training by EPA Region*
35-r
30 4
254
20 4
154
104
54
II
IV V VI VII VIII IX X
EPA REGION
'Totals include EPA Regional personnel, AARPs, and TAT and contractor
personnel, but do not include state and local officials, EPA HQ personnel,
EPA HQ contractors, and other federal agency officials who received training.
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3.0 ANALYSIS OF CSA PROFILE RESULTS
The following section highlights the major trends and identifies the major issues from the chemical
safety audit reports, based on profiles developed from the 32 final audit reports, conversations with EPA
Regional staff, and other sources. The CSA protocol, which was designed to serve as an outline for
conducting audits and a structure for preparation of audit reports, provides the format for this analysis.
The followinc eichi major elements of the protocol are examined in this section of the report:
Facility Background Information:
Chemical Hazards;
Process Hazard Information;
Chemical Accident Prevention:
Accidental Release/Incident Investigation;
Facility Emergency Preparedness and Planning;
Community and Facility Emergency Response Planning; and
Public Alert and Notification Procedures.
As pan of the introduction to each of these eight elements of the protocol, each section of the report
defines the purpose and types ol information examined during an audit related to chemical process safety
mamigcmem for a particular section of the protocol. An analysis summarizing and comparing ihe types ol
recommendations and/or conclusions presented in the audit reports follows.
The audit report protocol also includes two final sections: conclusions and recommendations.
The conclusions section highlights chemical process safety practices observed at the facility. These
practices reflect the facility's understanding of and commitment to chemical process safety management,
but do not represent any judgments of adequacy or inadequacy of the practices observed by the team. The
recommendations section addresses options that the facility may consider implementing to enhance facility
knowledge of and practices in process safety management. The recommendations are solely based on areas
observed during the audit and are not required or mandatory actions to he taken by the facility. Exhibit I
on the following pages provides an outline of the CSA protocol.
3.1 Futility Background Information
This section of (he report addresses the recommendations made in the chemical safety audit
reports regarding general facility information (section 4.0 of the CSA protocol). This section of the
protocol is concerned with the facility site and the surrounding area. A comprehensive facility profile and
history, a description of site topography and meteorological conditions, transportation access, special and
sensitive populations and environments in the surrounding area, community demographics, and identified
vulnerable zones provide information on the potential risks facility activities pose to the community.
Of the 32 CSA reports examined for this analysis. 3 reports contained a total of 4
rccommcndanons regarding general facility inlormation. all of which related to plant security.
Three audit reports recommended improving plant security measures by improving or
expanding fencing along the perimeter of the facility, having a third party conduct a
security evaluation of the plum, or modifying facility access procedures.
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EXHIBIT 1
OUTLINE OF THE CHEMICAL SAFETY AUDIT PROTOCOL
1.0 INTRODUCTION
2.0 EXECUTIVE SUMMARY: SUMMARY OF CONCLUSIONS/RECOMMENDATIONS
3.0 BACKGROUND
3.1 GENERAL FACILITY AND AUDIT INFORMATION
3.2 PURPOSE OF THE AUDIT AND FACILITY SELECTION PROCESS
3.3 AUDIT METHODOLOGY
4.0 FACILITY BACKGROUND INFORMATION
4.1 SITE AND SURROUNDING AREA DESCRIPTION
4.1.1 Facility Profile
4.1.2 Site Topography and Meteorological Conditions
4.1.3 Site Access
4.1.4 Special/Sensitive Populations and Environments
4.1.5 Regional Demographics
4.1.6 Identification of Vulnerable Zones
5.0 CHEMICAL HAZARDS
5.1 OVERVIEW OF HAZARDS FOR CHEMICAL(S) BEING AUDITED
5.2 FACILITY MANAGEMENT OF CHEMICAL HAZARD DATA
6.0 PROCESS INFORMATION FOR HAZARDOUS CHEMICAL I. II, III, etc.
6.1 STORAGE AND HANDLING
6.1.1 Storage Systems
6.1.2 Shipping/Receiving
6.1.3 Material Transfer
6.2 PROCESS DESCRIPTION
6.2.1 Overview of Processing Sieps and Operating
Procedures
6.2.2 General Description of Process Equipment
Capacity
6.2.3 Back-ups and Redundancy
6.2.4 Process Parameter Monitoring
6.2.5 Environmental Montioring
63 PROCESS HAZARDS
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7.0 CHEMICAL ACCIDENT PREVENTION
-.1 MANAGEMENT ACTIVITIES
7.1.1 Corporate Role in Facility Process Safety
Management
"1.2 Facility Role in Process Safety Management
7.1.3 Audit Activities and Procedures
:.: PROCESS OPERATION AND MAINTENANCE
7.2.1 Standard Operating Procedures
7.2.2 Training Practices
".2.3 Equipment Maintenance Procedures
T.2.4 Instrument Maintenance
-.3 HAZARD EVALUATION AND MODELING
~..vl Hazard Evaluation
7.3.2 Modeling
-.4 RELEASE PREVENTION SYSTEMS
".5 MITIGATION SYSTEMS
8.0 ACCIDENT RELEASE INCIDENT INVESTIGATION
8.1 HISTORY OF ACCIDENTAL RELEASES/INCIDENTS
S 2 FACILITY PROCEDURES
9.0 FACILITY EMERGENCY PREPAREDNESS AND PLANNING ACTIVITIES
9.1 FACILITY EMERGENCY RESPONSE PLAN
9.2 EMERGENCY RESPONSE EXERCISES AND SIMULATIONS
9.3 FIRE, EVACUATION, AND RESCUE CORRIDORS
94 EMERGENCY EQUIPMENT PROVISIONS
9.5 EMERGENCY RESPONSE CHAIN OF AUTHORITY
96 EMERGENCY RESPONSE MANAGEMENT PROCEDURES
97 EMERGENCY COMMUNICATION NETWORK WITHIN THE FACILITY
9.8 EMERGENCY RESPONSE PERSONNEL TRAINING REQUIREMENTS
9.9 MONITORING STATIONS FOR CHEMICAL RELEASES
9 10 FOLLOW-UP RELEASE PROCEDURES/INVESTIGATION
10.0 COMMUNITY AND FACILITY EMERGENCY RESPONSE PLANNING ACTIVITIES
10.1 FACILITY PLANNING AND OUTREACH ACTIVITIES WITH COMMUNITY
10.2 LOCAL/COMMUNITY EMERGENCY RESPONSE PLAN
10.3 COMMUNITY RESPONSE STRUCTURE AND PROCEDURES
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11.0 PUBLIC .ALERT .AND NOTIFICATION PROCEDURES
11.1 PROCEDURES FOR PUBLIC NOTIFICATION OF RELEASES
11.2 SCHEDULE OF TESTING FOR PROCEDURES
11.3 HISTORY OF NOTIFICATION PROCEDURES AND EVALUATION
11.4 COMMUNITY AND FACILITY CONTACTS
11.5 FACILITY AND MEDIA INTERACTION
12.0 CONCLUSIONS
l.VO RECOMMENDATIONS
APPENDICES
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3.2 Chemical Hazards
This section of the report addresses the recommendations made in the chemical safety audit
reports regarding chemical hazards (section 5.0 of the CSA protocol). This section of the protocol is
concerned with an overview of how the facility perceives the hazards posed by the hazardous substances
examined durinsi the audh and a review of facility management of data describing and communicating
ihese hazards. Detailing the existing chemical hazards and describinc how the facility identifies,
documents, and develops this information focuses on the potential hazards as well as the facility's
understanding of these hazards.
Of the 32 CSA reports examined for this analysis, 5 reports contained a total of 3
recommendations regarding chemical hazards, all of which related to facility management of hazard
communication.
Four audii reports recommended improving the availability of Material Safety Data Sheets
(MSDSs) 10 plant employees. This included updating exisiing MSDSs and translating
MSDSs into Spanish for non-English-speaking workers.
Three audit reports recommended safer eating, drinking, and smoking practices for the
facility. This included restricting eating, drinking, and smoking in process areas and
repairing existing lunchroom facilities,
3.3 Process Information
This section of the report addresses the following subsections of the CSA protocol: facility
stoMuc. slnppma and receiving, on-site transfer, and process operations involving hazardous substances. It
includes a review h\ the iiudit team of the equipment, practices, and personnel involved in these process
operations, as well as the specific process hazards identified by the facility. The review of facility
operations involving hazardous substances can reveal facility practices and techniques for managing process
hazards, as well as reveal the facility's understanding of process hazards.
A number of ihe audit teams provided conclusions in their reports that addressed successful
chemical process safety management practices and technologies established or conducted by the audited
facilities in the process information element of the protocol. The following are some examples:
By utilizing smaller bromine storage tanks, the company has reduced the potential severity
of an accident; the maximum quantity that could be released or spilled is lessened and
consequently more easily contained.
The above ground MiC storage tank area is covered by a steel cable mat to prevent
projectiles from damaging these tanks if there is an explosion in another, nearby area ot
the plant.
Flow detectors have been installed 10 detect abnormally high flow in the MIC or phosgene
flare lino. The detectors trigger alarms that automatically increase fuel delivery' to the
Hare. An infrared scanner monitors the flame continuously and will automatically re-
ignitc the flare.
A control hoard allows the operator to monitor a number of process systems concurrently.
while physical displays ai the vessels allow an on-location operator to have instantaneous
knowledge about ihe status of the process.
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Critical operating parameters (COP) have been established to ensure that a process unit
will be immediately shut down it" any COP reaches abnormal levels. These actions are
automatically or manually initialed ;md can only be countermanded by department head
authorization. Any unit operator can initiate emergency shutdown procedures without
obtaining prior authorization.
In addition, the audit teams also provided recommendations in the audit reports for improving the
facilities' chemical process safety management practices regarding process information (section 6.0 of the
CSA protocol). Of the 32 CSA reports examined lor this analysis. 30 reports contained over 100
recommendations regarding process information. The recommendations address the following subsection*
of the CSA protocol:
Storage and Handling (subsection 6.1): and
Process Description (subsection 6.2).
The remainder of this section of the report will discuss the recommendations made in ihe CSA
reports that discuss process information. This analysis will identify recommendations addressing each
subsection specified in the process information section of the CSA protocol, and will attempt to identify
trends in these recommendations.
Storage ami Handling
Storage Systems. This section addresses the facility storage systems for hazardous substances
examined during an audit, including the types of containers, their characteristics, and on-sitc location, as
well as placardmc. maintenance, and housekeeping of storage areas. Fourteen audit reports contained a
total of 27 recommendations regarding storage systems.
Five audit reports recommended improving measures for protection of storage vessels
from the elements. This included grounding tanks to prevent lightning strikes and
constructing storage structures to block excessive sunlight and precipitation, which cause
storage equipment to deteriorate.
Five audit reports recommended corrections in drum placement. This included
eliminating storage of drums in precariously high stacks and clearing drums from access
corridors.
Four audit reports recommended the segregation of incompatible substances within
storage areas by placing drums in separate areas or realigning secondary containment
measures.
Four audit reports recommended labelling drums and storage areas to improve
identification of hazardous substances.
Three audit reports recommended relocation of storage containers to improve leak
detection.
Shipping and Receiving. This section addresses facility shipping and receiving practices for
hazardous substances examined during the audit, including methods of off-site transportation, shipment
scheduling, and responsible personnel. Eight audit reports contained a total of 1? recommendations on
shipping and receiving procedures and equipment for loading and unloading operations.
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Six of the audit reports recommended improving safety procedures for railcar unloading
operations. These included securing railcars before operations commence and increasing
the number of operators present during unloading and loading of railcars.
Material Transfer. This section addresses facility operations involving the on-site transfer of
hazardous substances examined during the audit, including use of equipment, coding of pipes, and housing
of transfer systems. Eight audit reports contained a iota) of 12 recommendations On material transfer
operations.
All S audit reports recommended the expansion or introduction of labeling or color-
coding of pipes, tanks, drums, and other equipment used for the transfer and storage of
hazardous substances. Many indicated that labeling and color-coding would aid first
responders in an emergency situation.
Process Description
Overview. This section addresses the facility processing steps and operating procedures for the
processes involving the hazardous substances examined during the audit. Nine audit reports contained a
total of 13 recommendations regarding specific features of the facility's process operations.
Three of the audit reports recommended improvements in ventilation systems. This
included installation of fans, and vents, in process and laboratory areas.
Three of the audit reports recommended improving the availability of process, piping, and
instrument diagrams. This included developing updated diagrams to reflect recent process
changes and providing these diagrams to maintenance workers 10 improve their familiarity
with ihe equipment that they maintain.
Other recommendations suggested replacing or otherwise improving specific process
equipment. This included replacing drain couplings with more durable couplings,
installing locks on valves, and standardizing the heat exchange capacity of similar-sized
reactors.
One audit report recommended that the facility consider the feasibility and safely of
modifying the sequence of processing operations.
Back-Ups and Redundancies. This section addresses the existence of backup and redundant
systems for process and other equipment, including how these systems are initiated and how they function.
Four audit reports contained a total of 5 recommendations relating to the development of emergency'
power systems.
All 4 audit reports recommended that a backup power system be established for process
or release mitigation equipment to reduce the risk of a power failure initiating a release.
The other recommendation suggested the facility conduct a study to determine what
critical process equipment would require a backup power supply.
Process Monitoring. This section addresses the monitoring of process parameters for operations
mvoKine hazardou> substances, including ihe performance history of the facility, the parameters that have
been established, and facility response procedures for unsafe parameter levels. Nine audit reports
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contained a total of 10 recommendations relaiina to the improvement or installation of process monitoring
equipment.
Six of the audit reports recommended improvement in control room instrumentation and
displays, such as centralization and modernization of process control operations.
Six of the audit reports recommended expanding or establishing process temperature and
pressure monitoring to improve early detection of potential release incidents.
Environmental Monitoring. This section addresses the systems for monitoring levels of hazardous
substances outside immediate process areas, including types of equipment and their placement in process
and storace areas or on the facility perimeter. Eighteen audit reports contained a total of 28
recommendations relating to the improvement r installation of environmental monitoring equipmeni.
Eighteen audit reports recommended installing equipment for monitoring levels of
hazardous substances. This included permanent concentration monitoring station ai the
plant perimeter and in specific process and storage areas, as well as personal monitoring
equipmeni in the event of possible exposure.
Two audit reports recommended installing on-site equipment for meteorological
monitoring to assist in the response to a release.
3.4 Chemical Accident Prevention
This section of the chemical safely audit protocol describes mechanisms for implementing and
maintaining safe process systems. Five subsections of the protocol are examined by chemical safely audit
teams to determine steps that the facilities have taken in regard to chemical accident prevention.
Management directives are reviewed to identify goals and implemented activities that present the facility's
perspective and commitment to safe management of process hazards. Process and operation systems such
as standard operating procedures, training practices, and equipmeni and instrument maintenance are
reviewed to identify routine safety practices at the facility. The methods and frequency of hazard
evaluation and the uses and types of models for tracking releases were reviewed in order to determine how
facilities address hazards that they have identified. Finally, facility activities related to preventing a release
and post-release mitigation systems were reviewed.
A number of audit teams provided conclusions that addressed successful chemical process safety
management practices and technologies established or conducted by the audited facilities in the chemical
accident prevention section of the protocol. The following are some examples:
The facility has an ongoing program linking safety training to the progression and
promotion of operators.
Upper management personnel attended a hazardous materials spill prevention and control
course and. subsequently, sent middle managers (shift supervisors) to similar courses
Employees who have had no accidents over a period of three years are allowed to join a
club called the 'Armadillo Club," which gives certain off-duty benefits to workers.
Membership in this club is a source of pnde for plant employees, and is a strong incentive
for them to follow all safety practices.
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The t'acility has developed a >hirt pocket-sized booklet for all employees and contractor^
to provide easy reference u; all \vork and salety rules. In addition, employees are issued
wallet cards with u listing of plant and community emergency telephone numbers.
The maintenance department has instituted a comprehensive training program for its
employees. A written test and lour practical tests are given to new employees before they
are admitted to the maintenance department. Advancement within the department is
contingent on results from continued tests.
The company includes all contractors in its training courses designed for new employees.
including chemical handling, basic process parameters, start up/shut down procedures,
maintenance procedures, emergency communications, and use of respiratory protection
devices.
The facility has organized a team of personnel, including personnel from the engineering.
operations, maintenance, and safety departments as well as management, to evaluate
hazards. The team meets monthly to discuss safety issues and to consider possible changes
to the facility's design, construction, and standard operating procedures.
As a result of the chemical safety audit, the facility has segregated us acid storage tanks
from its caustic storage tank through diking of the storage area. This will prevent the
accidental mixing of these hazardous substances during an incident and the creation oi
increased hazards.
In case of an emergency, the chlorine flow can be cut off and the chlorine remaining in
the system can be vented 10 neuiralizers and environmental vent scrubber (EV'Si rather
than released to air The EVS was installed to reduce the number of releases at the
facility, and is specifically designed and periodically upgraded to anticipate a major release
of chlorine based on the capacity of the relief valves and rupture discs.
In addition, the audit teams also provided recommendations in the audit reports for improving the
tacilmes' chemical process safety management practices regarding chemical accident prevention (section T.D
ot the CSA protocol). Of the 32 CSA reports examined for this analysis, 30 reports included
recommendations concerning chemical accident preveniion. These recommendations addressed the
following subsections of the protocol:
Management Activities (subsection 7.1)
Process Operation and Maintenance (subjection 7.2)
Hazard Evaluation and Modeling (subsection 7.3)
Release Prevention Systems (subsection 7.4)
Mitigation Systems (subsection 7.5)
Management Activities
The Regional audit team members made a total ot 15 recommendations concerning activities on
the pun of the management of the corporation and the facility. These comments broadly addressed the
commitment of the corporation and the facility to the safety policy. For example, a Region VI audit team
recommended that an audited company sponsor and develop a safety audit to review safety procedures and
practices throughout the facility.
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Process Operation and Maintenance
This subsection of the protocol is divided into four topics - standard operating procedures.
training practices, equipment maintenance, and instrument maintenance -- and generated the most
recommendalions on chemical accident prevention. A total of 62 suggestions were made on process
operation and maintenance.
Fourteen recommendations addressed standard operating procedures. Ten of those
recommendations indicated that the facility should develop and maintain manuals for each
area of operation so operators are familiarized with all aspects of a particular process.
Two recommendations suggested the use of operating logs as a means of communication
between supervisors and operators. One recommended safer procedures during the
removal and replacement of chlorine cylinders. One recommenda lion suggested that
checklists be developed to track routine process activities.
Twemy-one recommendaiions addressed employee training. Fourteen recommendations
addressed specific areas that employee safety training should encompass. Four
recommended actions that the facilities incorporate emergency simulation exercises as a
regular part of the safely training program. Three recommendaiions addressed the control
and tracking of contractor training.
* Twenty-five audit reports included recommendaiions on equipment maintenance.
Thirteen recommendations suggested thai the facilities conduct regular inspections of
equipment and update maintenance procedures. Twelve of the recommendaiions
suggested the facility institute a structured preventative maintenance program, verify that
work has been completed, identify trends, and ensure regular maintenance.
* Two audit reports addressed instrument maintenance in their recommendaiions. One
audit report suggested that the facility regularly test the wastewater treatment alarm
system. The second recommendation concerned instrument service contracts.
Hazard Evaluation and Modeling
Nineteen recommendations made by the Regional audit teams concerned hazard
evaluation. Seventeen recommendations suggested that the facilities develop or regularly
update methods of hazard evaluation in specific areas. One audit report recommended
that management should provide hazard analysis training.
None of the audii reports included recommendaiions on hazard modeling.
Release Preftntion Systems
The Regional audit team members listed 11 recommendations concerning facility activities related
to preventing a release. These recommendations included specific suggestions as to types of systems ihai
should be installed in certain process areas. For example, one audit report recommended thai un
automatic shutoff system should be installed on pumps to prevent an overflow from occurring.
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Mitigation Systems
Twenty-one audit reports included recommendations regarding mitigation systems. These
recommendations generally suggested the installation and regular maintenance ot diking and drainage
systems at the facility. For example, a Region I audit report recommended that storage tanks that contain
caustic materials should be diked in order to prevent uncontrolled spills.
3.5 Accidental Release/Incident Investigation
This section of the report addresses the recommendations made in the chemical safety audit
reports regarding release.'incident investigation (section 8.0 of the CSA protocol). Section $.0 of the
protocol describes facility activities for identifying the underlying causes of unplanned incidents, such as
fires, explosions, and release of hazardous substances, and for preventing similar incidents from occurring
in the luture. Potential facility activities include the development of standard operating procedures and
other guidelines for the investigation of incidents and the development and implementation of
recommendation^ based on the investigation to prevent future accidents.
Of the 32 CSA reports examined Tor this analysis. 8 reports included a total of 9 recommendations
regarding incident invesugation.
Four audit reports recommended the development of a formal investigation policy for
accidental release, including standard procedures, incident report preparation, and
re-^ponsmle staff.
Four audit reports recommended expanding the scope of existing release investigation
programs from actual incidents to near-misses and small-scale releases, particularly those
which do not require reporting under environmental regulations.
J.6 Facility (Emergency Preparedness and Planning Activities
This section of the report addresses the recommendations made in the chemical safety audit
reports regarding on-site facility emergency preparedness and planning activities (section 9.0 of the CSA
protocol). Facility emergency preparedness and planning activities include actions taken by plants 10
prepare tor emergency incidents involving hazardous substances. Such activities include, but are not
limned 10. preparing and exercising on-site emergency response plans, ensuring the availability of the
proper emergency response equipment, and determining and installing the appropriate emergency
communication network wuhm the facility. These planning activities help to ensure that a facility will be
prepared for an emergency incident and help the facility to identify potential problem areas.
A number of the audit teams provided conclusions in their reports that addressed successful
chemical process safety management practices and technologies established or conducted by the audited
tacilities in the facility emergency preparedness and planning section of the protocol. The following are
surne examples:
Tu remove liquid bromine from the skin in the event of employee exposure, barrels oi
Hypo solution -- water, sodium carbonate, and sodium thiosulfaie are located
throughout the facility because water is not an effective wash against bromine.
The plani has two distinct color-coded alarm systems. One system is dedicated to fire
incidents, and notifies the fire department; the other system is for plant incidents and
emergencies, and notifies the facility's four-member Emergency Service Team
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In addition, the audit teams also provided recommendations in the audit reports for improving the
facilities' chemical process safety management practices regarding facility emergency- preparedness and
planning (section 9.0 of the CSA protocol). Of the 32 CSA reports examined for this analysis, 26 reports
included recommendations regarding facility emergency preparedness and planning. These
recommendations addressed the following subsections of the CSA protocol:
Facility Emergency Response Plan (subsection 9.1);
Emergency Response Exercises and Simulations (subsection 9.2);
Fire, Evacuation, and Rescue Corridors (subsection 9.3);
Emergency Equipment Provisions (subsection 9.4);
Emergency Response Management Procedures (subsection 9.6);
Emergency Communication Network within the Facility (subsection 9.7); and
Emergency Response Personnel Training Requirements (subsection 9.8).
The remainder of this section discusses the recommendations made in the CSA reports that address facility
emergency preparedness and planning activities.
Facility Emergency Response Plan
This section addresses recommendations concerning facility emergency response plans, including
how and when the plans are updated, and by whom. The following are recommendations and illustrative
examples of the recommendations that were made in the audit reports:
* Seventeen of the audit reports recommended that the facilities revise their emergency
response plans. Five of the audit reports recommended that the emergency response plan
contain a list of potential hazardous substances, detail CERCLA and SARA reporting
procedures, and list the telephone numbers for reporting releases. One audit report
recommended thai the plan contain alternate contacts and detail evacuation routes and
location of equipment on the maps. Another report recommended thai the plan include
maps to the nearest hospital, detailed site maps, and a list of scheduled simulations.
Finally, one report recommended that the plan be written for those persons who have to
read, understand, and place into operation the mandates of the plan.
Four audit reports recommended that facilities establish a program for emergency
procedures at the facility.
Three of the audit reports suggested that facilities establish a schedule for updating their
emergency response plans. In one audit report, the audit team specifically recommended
that the facility assign a detailed schedule for plan revisions, review, and updates.
One audit report recommended that the facility identify persons responsible for updating
the plan.
One audit report recommended that the facility use dispersion models for plan
development
Emergency Response Exercises and Simulations
This section addresses emergency response exercises and simulations, including the types.
frequency, groups involved, and the uses or findings. A number ot the audit reports addressed the
frequency of the emergency response exercises and simulations. The following are recommendations and
illustrative examples of the recommendations thai were made m the audit reports:
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* Four audit reports recommended that the facilities develop an exercise schedule \o
routinely exercise their update emergency response plans.
. Three audit reports recommended thai the facility conduct emergency response exercises
or simulations. One audit report specifically suggested that the facility develop "table top"
exercises; another report recommended that the facility consider holding terrorist, civil
disorder, and natural hazards exercises.
Two audit reports recommended tha: the facility use formal critiques of drills/exercises so
that mistakes could be corrected and response procedures improved.
Fire, Evacuation, and Rescue Corridors
This section addresses fire, evacuation, and rescue corridors, including maps and
designations/symhols. The following are recommendations and illustrative examples of the
recommendations that were made in the audit reports:
Three audit reports recommended that the revisions be made to the evacuation plans.
including more detailed facility and community maps.
Two audit reports recommended that the facility address the confined and dark conditions
that could hinder evacuation ol operators or emergency response in the event ol a release.
One audit report recommended that the facilities revise their evacuation procedures. One
audn report suggested that the facility consider training personnel in flexible evacuation
procedures depending on wind direction, for example. The report fount! that the present.
indexible evacuation procedures were inappropriate and unduly lime consuming
One audit report recommended that the facility improve ventilation and provide
additional escape rouies.
One audit report recommended that the evacuation plan be posted in visible locations.
Emergency Response Equipment
A number of the audit reports address the type of emergency response equipment, the location,
and the maintenance policies of the equipment. The following are recommendations and illustrative
examples of ihe recommendations thai were made in the audit reports:
Eight audit reports recommended that emergency response equipment be strategically
located. Four of these audits recommended that personnel protective equipment (PPE)
be easily accessible or located in areas vulnerable to releases. Three audit reports
addressed the installation and location of eye wash stations.
» Five audit reports recommended that the facility acquire additional emergency equipment.
including cartridges for acid vapors, neoprene boots, backup PPE, five minute escape
masks, a water gun with a fog nozzle, and a pumping system to pump water from a river
to fight a major fire.
Three audit repom recommended that PPE be carefully maintained and regularly tested.
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Two audit reports recommended that the fire tightinc capability be improved, perhaps
through the eMahtishmcru of a tire brigade.
Emergency Response Management Procedures
Three audit reports made recommendations on emergency response management procedures One
audit report recommended that the facility evaluate the feasibility of a centralized emergency conirol
center. One audit report recommended that the facility address safety shoe and contact lens policy; the
other audit report suggested thai the use of safety glasses in the wood processing areas be required.
Emergency Communication fretwork within the Facility
A number of the audii reports made recommendations on emergency communication within the
facility. Most comments suggested ways in which the alarm system could be improved. The following arc
recommendations and illustrative examples of the recommendations that were made in the audit reports:
Six audit reports suggested thai the facility install additional alarm systems or upgrade
existing systems. For example, 2 audit reports recommended upgrading or installing a new
system that would communicate the nature of the emergency and perhaps e\en the
location of the emergency.
» Two audit reports recommended that the facility evaluate and update their
communications system, including the telephone system, and the radio network
» One audit report recommended that the facility establish clear cut procedures lor updating
personnel on the status of an emergency incident.
One audit report recommended that the facility insure detailed and accurate testing of all
alarm systems and strict compliance with safety procedures.
Emergency Response Personnel Training Requirements
Five audit reports addressed emergency response training requirements: one of the audit reports
recommended that such a training program be established and the other 4 audit reports recommended
improvements in the existing training programs.
3.7 Community and Facility Emergency Response Planning Activities
This section addresses the recommendations made by the chemical safety audit teams regarding
community and facility emergency preparedness and planning activities. Such activities include outreach
efforts by facilities and activities associated with SARA Title III. These activities also include the
development of emergency response plans by facilities in coordination with the community and
involvement by facilities in community emergency response planning and response activities. Community
and facility emergency response planning activities require coordination between the facility and the
community, these arc not just activities taken on behalf of facilities to prepare tor emergency incident.
A number of the audit tcitms provided conclusions in their reports that address successful
chemical process safety management practices and technologies established or conducted by the audited
facilities in ihc community and lacility emergency response planning element of the protocol. The
following are some examples:
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The environmental and safety departments arc actively involved tn the community'* Uxu;
Emergency Planning Committee (LEPC.i, The facility has three regular representatives on
the LEPC that have served on the steering and public information subcommittees.
The plant participates in the Community Awareness and Emergency Response (CAER)
program even though it is not a member of the Chemical Manufacturer's Association.
The facility holds joint training programs with the local hospital 10 review medical
problems such as bromine chemical burns and inhalation.
In addition, the audit teams also provided recommendations in the audit reports for improving the
facilities' chemical process safety management practices regarding community and facility emergency
response planning (section 10.0 of the CSA protocol). Of the 32 CSA reports examined for this a
U reports included recommendations regarding community and facility emergency preparedness and
planning These recommendations addressed the following three subsections of the CSA protocol:
Facility Planning and Outreach Activities with the Community (subsection 10,1 of the
CSA protocol):
Local/Community Emergency Response Plan (subsection 1U.2); and
Community Response Structure ;md Procedures (subsection 10.3).
Facility Planning and Outreach Activities with ilie Community
One audit report recommended that facility staff be trained in CERCLA and SARA notification
procedures.
Local:Communify Emergency Response Plan
A number 01 the audit reports recommended that the facilities work more closely with the
community, and specifically wuh the LEPC. The autlit reports also recommended that emergency response
exercises be conducted in coordination with the community. The following are illustrative examples of the
recommendations that were made in the audit reports:
Four audit reports recommended that ihe facility ensure that it is represented on the
LEPC and that the faciluy regularly aiicnd LEPC meetings or strengthen its relationship
with the LEPC
Two audit reports recommended that the facility assist itoe LEPC. One audit report
recommended that the facility share its modeling programs with local response personnel
One audit report recommended that the facility develop a plan with the assistance of the
LEPC. tire and police departments, and local hospitals. One audit report recommended
that the plan address community interaction.
One audit report recommended that nil management personnel know how their plan
coordinates wuh the LEPC plan.
Community Response Struclurt and Procedures
A number of the audii reports recommended that the facility improve their involvement and rok
in community emergency response efforts. The following recommendations were made tn the audit
reports:
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* Eight audit reports recommended that the facility include local emergency responders
and/or public officials in emergency response exercises. Two audit reports recommended
that the facility develop exercises in coordination with the LEPC.
Five audit reports recommended that the facility provide emergency responders with
facility information to assist in emergency response; for example, [he facility could store
MSDSs outside the facility 10 alert emergency responders prior to entry tn an emergency.
Three audit reports recommended that the facility work more closely with local
responders.
Two audit reports recommended that the facility address the training of local emergency-
response personnel. One audit report suggested that the facility consider establishing such
training, the other recommended that this training be continued.
One audit report recommended that the facility establish written mutual aid agreements
with the fire department and the hazmat team.
One audit report recommended that ihe facility work with the local community to
construct additional access roads to ensure efficient evacuation.
* One audit report recommended that better perimeter control be established and that la*
enforcement officials coordinate with other agencies with traffic control responsibilities
3.8 Public Alert and Notification Procedures
The purpose ol this section of the protocol is to identify unique procedures that the facility has
employed to alert the public when an accident occurs at the facility. This information should also indicate
facility commitment to safety in the community. Of the 32 CSA reports examined tor this analysis, 12
reports included recommendations concerning public alert and notification procedures. The following
subjections of the protocol were examined during the chemical safety audits reviewed for this analysis:
Procedures for Public Notification of Releases (subsection 11.1);
Schedule or Testing for Procedures (subsection 11.2).
The following subsections were not addressed in these reports:
History of Notification Procedures and Evaluation (subsection 11.3);
Facility and Media Interaction (subsection 11.4); and
Community and Facility Contacts (subsection 11.5).
Procedures for Public Notification of Releases
A. total of 10 recommendations were made concerning public alert and notification procedures.
The>e comments suggested that the facilities should establish some means to communicate emergency
conditions to the public.
Schedule of Testing for Procedures
Two recommendations made specific reference to existing public alarm systems. One suggested
that the facility test the alarm system to ensure it is in working order. The other recommended that the
emergency alarm signals for the facility and the community should match in order to avoid confusion
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M
4.0 STATUS OF CSA PROGRAM IMPLEMENTATION
This section addresses the status 01 the CSA program and issues that have been identified by
CEPPO and the Regional offices during FY S9 and FY 9U related to program implementation. Program
status is beins presented based upon a review of the number of audits performed and reports completed.
and the quality of report contents. Section 2.0 of this report presented data on the status of the number
of audits conducted in each Region and of the types and quantities of personnel trained to perform audits.
A review of the numbers indicated that the majority of the Reeions have been successfully committing
resources to implementing this program. The following is a brief synopsis of each Region's CSA program
activities during FY 89 and FY 90:
Region i has conducted S audits and completed 5 audit reports. A total of 6 potential
audit team members have been trained; no workshops have been held or are scheduled to
be heJd in the upcoming year.
Region 11 has conducted 6 audits and completed no audit reports. A total of 14 potential
audit team members have been trained: no workshops have been held or are scheduled '.o
be held in the upcoming year.
Region 111 has conducted S audits and completed 7 audit reports. A total of 16 potential
audit team members have been trained; a workshop was held in Philadelphia in FY 90.
Region IV has conducted 10 audits and completed 2 audit reports. A total of 35 potential
audit team members have been trained: a workshop was held in Atlanta in FY 39. and
another is planned to be held in Region IV in the upcoming year.
Region V has conducted 3 audits and completed 2 audit reports. A total of 12 poienn.il
audit team members have been trained; a workshop is scheduled to be held in Chicago in
the upcoming year.
Region VI has conducted 9 audits and completed 7 audit reports. A total of 22 potential
audit team members have been trained; a workshop was held in Dallas in FY 39.
Region VII has conducted no audits and completed no audit reports. A total of 4
potential audit team members have been trained: a workshop was held in Kansas City in
FY90.
Region VHI has conducted 7 audits and completed 5 audit reports. A total of 10
potential audit team members have been trained; a workshop is scheduled to be held in
Denver in the upcoming year.
Region IX has conducted 8 audits and completed 2 audit reports. A total of 11 potential
audit team members have been trained; a workshop was held in San Francisco in FY $9
and another workshop is scheduled to be held in San Diego in the upcoming year
Region X has conducted 8 audits and completed 2 audit reports. A total of 11 potential
audit team members have been trained: a workshop was held in Seattle in FY 90
The pnmarv area of concern in the procram to dnte. however, has been the lack ol completed
final audit reports (i.e.. 32 reports completed out of 72 audits performed during FY 89 and FY W).
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Concerning audit report completion, the lack of final audit reports seriously affects the usefulness
of the CSA program in identifying and disseminating information on successful and problematic chemical
process safety management practices and technologies. One reason, cited by many Regions, for the delays
in preparing a final audit report has been the audited facility's review of the draft report. This review is
required to ensure that no confidential business information is included in the final audit report thai is
available to the general public. CEPPO is reviewing this issue and will provide Regions with further
guidance on reducing the time for this review process.
Although CEPPO has reorganized and revised the audit protocol from its initial format, the
essential elements that should be addressed in a chemical safety audit have noi changed since the start of
the program. A review of the reports, however, has indicated inconsistent use and attention to the
protocol, and insufficient coverage of some audit protocol elements. Many audit reports, for example, do
not address accidental release incident investigation. It is difficult to determine from the audit reports if
the audii team did not address this element oi the protocol or if the facility did not have procedures for
investigating accidental release incidents. Furthermore, many audit reports did not sufficiently address
public alert and notification procedures.
An important lesson learned has been derived from the development of the chemical safety auUu
profiles. A large degree of inconsistency from Region to Region, and even within Regions, in the formnt
and contents of the final CSA reports has been identified. To address the inconsistency, CEPPO is
planning substantial revisions in the CSA protocol and training materials in preparation for FY 91 audits.
A module on audit report preparation and writing will be developed for future CSA workshops to improve
the consistency of all CSA reports. Consistency across audit reports will help to facilitate analysis of
conclusions, and recommendations and will assist CEPPO in effectively identifying successful and
problematic practices and technologies and sharing of information with stakeholders. CEPPO will
coordinate these activities as well as identify and resolve other CSA program implementation issues with
ihe Regional Chemical Safety Audit Committee chaired by Region VI.
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APPENDIX A
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APPENDIX A
LIST OF CHEMICAL SAFETY AUDITS
REGION
!I
II!
IV
CSA REPORT
AVAILABILITY
X1
X
X
X
X
DATE OF AUDIT
03/22.89
04/10-14/89
08/03/89
OS/09-10/89
11/30/89
03/20/90
06/20-21/90
09/12-13/902
08/71-24/89 P3
09/11/89
01.W90 P
01/11/90 P
07/31 - 08/01/90 P
09/10-11/90 1'
07/31-08/03/89 X
08'14-16/89 X
09/11-12/89 X
09--25-26/89 X
01,31 & 02'02-03/90 X
02/12-16/90 X
03-76-28/90 X
08/20-22/90
03/20-24/89 X
051)1-03/89 P
07/11/89 A 08/03-04/89 P
07/18-20/89 P
08/17/89 & 09/11-15/89 P
02/12-13/90 P
02/26-03/02/90 P
04/02-06/90 X
05/08-11/90 P
09/IM3/90
NAME OF FACILITY
Polysar. Inc., Springfield. MA
W.R. Grace. Nashua. NH
Fall River Treaiment Plant. Fall Ri%'er. MA
Upjohn Co., North Haven. CT
Original Bradford Soap Works. W.
Warwick, RI
Jones Chemicals. Merrimac. NH
Monet. Crystal Brands. Pawiucket. RI
LCP Chemicals, Orrington, ME
BASF, Rensselaer. NY
Xerox Corporation, Webster. NY
Du Pont Agrichemicals, Manati. PR
Bacardi Rum, San Juan. PR
Goodyoir Tire and Rubber Co., Niagara
Tails," NY
BASF, Washington, NJ
Rhone-Poulenc A.G. Co., Institute Plant.
Charleston. WV
LCP Chemicals. Inc., Moundsville, WV
Purolite Co.. Philadelphia. PA
Carl Falkenstein. Inc.. Philadelphia. PA
Automata. Sterling. VA
Mobay Chemical. New Martinsviile. wv
Olin Chemical, Charleston. WV
Occidental Chemicals, Delaware City, DE
Royster Phosphate, Piney Point. FL
Olin Corporation, Charleston. TN
ARMCO Steel, Ashland. KY
Kerr McCee. Hamilton, Monroe County.
MS
Texas Guif. Aurora. NC
Photocircuiis. Atlanta. Peachtree Citv. GA
Kemira. Inc., Savannah. GA
Astrotech, Titusville, FL
Cardinal Chemical Company
Tennessee Chemical Co,, Copper Hill. TN
! An "X" indicates that the final report has been received from the Region.
: Audits thai were- conducted after June 30. 1990. are indicated by bold text and arc noi considered tor
purposes of ihis report
' A "P" indicates that although no final report has been received from the Region, a draft protile ha>
been developed based on information provided by the Region.
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REGION
V
VI
vu
VIII
IX
DATE OF \UDIT
07 28/89
08.' 11/89
09.' 15,89
03;05;90
03/26-30/90
04.14-17,90
06.11-1590
07/16-19/90
05/13/89
OS/29/89
08/14/89
09'll/89
10/15-18/89
11/05-07/89
11.' 14/89
01/16-19/90
04.46-19/90
NONE
05/09-12/89
06.13-16/89
- 16/89
05 15-17/90
06-26-29/yu
08/28-31/90
06/12-13/89
07.-75-27/89
08.09- 1Q/S9
09/07-03/S9
04/14-20/90
06/19-22/90
07/09-19/90
W/10-L6/90
CSA REPORT
AVAILABILITY
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
NAME OF FACILITY
Koppers. Siickney. IL
Best Foods. Chicago, IL
Shell Oil. Wood River, IL
Eli Lilly, Clinton, IN
Anderson Development, Adrian, MI
General Electric Plastics. Mt. V'ernon. IN
Tremco. Inc.. Cleveland, OH
Flexcl, Inc., Covington, IN
Western Extrusion, Carroilton. TX
Great Lakes Chemical Company, El
Dorado, AR
Farmland Industries, Enid, OK
Fermenta ASC Corporation, Palqumme, LA
Chief Supply, Haskell. OK
Phillips Petroleum, Pasadena, TX
Texas Instruments, Dallas, TX
Exxon Refinery, Baton Rouge. LA
Olin Chemicals. Lake Charles, LA
Phillips Refinery. Woods Cross. UT
Chevron Chemical, Rock Springs. WY
Western Forge. Colorado Springs, CO
Koppers Industries. Denver. CO
Amoco Production Company, Powell. WY
Amoco Casper Refinery, Casper. WY
Westinghouse Electric Corporation/Western
Zirconium, Ogden, UT
Nunes Cooling Inc., Salinas. CA
Unocal Chemical, Brea. CA
Eticam of Nevada, Fernley, NV
Coronauo Generating Station. Si. Johns.
AZ
Ultramar, Inc., Wilmington, CA
Magma Copper, Inc., San Manuel. AZ
Pioneer Ch.lor Alkalai, Henderson, NV
Dote Packaged Foods, Honolulu, HI
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CSA REPORT
REGION DATE OF AUDIT AVAILABILITY NAME OF FACILITY
.V 07:27,89 X All Pure Chemical Company. Kalama, NVA
08/15.89 ITT Rayonier Pulp Plant. Port Angeles, WA
0912,89 X McWhorter Northwest. Portland. OR
09:26/89 ITT Rayonier Pulp Plant, Port Angeles. WA
03/19/90 P BP Oil Company, Bellingham, WA
04-90 P FMC Corporaiion, Pocatello, ID
05/90 P Neste, Springield, OR
09/24/90 Un
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APPENDIX U
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APPENDIX B
Hazardous Substances Examined In Chemical Safety Audits
(AS of 6,30/901
Acetic Acid:
Best Foods. Renion V
Acetone:
Western Force. Recion Vjll
Activated Catalyst--
Phillips 66 Houston. Region VI
Ammonia:
W.R. Grace. Region 1
Upjohn, Region i
Original Bradford Soap Works. Region I
Olin, Region III
Roysier Phosphates. Region IV
Best Foods. Region V
Fermenta ASC. Recion VI
Farmland Industries. Region VI
Chevron. Recion VIII
Nunes Cooling. Region IX
Ammonium Hvdroxidt:
Curl Falkensiein. Region III
Automata, Recion III
Arsenic Trioxide:
Fermenta ASC. Recion VI
Kenzetie:
Upjohn, Region I
Bromine:
Great Lakes Chemical, Region VI
1.3-kiutadiene:
Phillips 66 Houston, Region VI
Univl Acetate:
Western Force. Recion VIII
Curium Monoxide:
Mobay, Region III
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Chlorine:
Fall River Waste Treatment. Region 1
Bacardi Rum. Region I!
Mobay. Region III
Olin, Region III
LCP Chemicals. Region III
Best Foods, Region V
Phillips 66 Houston, Region VI
Farmland Industries, Region VI
Fermenta ASC, Region VI
Great Lakes Chemical. Region VI
Chevron, Region VIII
Phillips 66 Co Woods Cross, Region VIII
AJ1 Pure Chemical, Region X
BP Oil Company, Region X
Chloroform:
Rhone-Poulenc, Region III
Chlornthalonil:
Fermenta ASC. Recion VI
Chromic Acid:
Phillips 66 Woods Cross. Region VIII
Copper Cyanide:
Carl Falkcnstein. Region III
Creosote:
Ftoppers. Region V
Koppers. Region VIII
Cresvlic Acid:
Phillips 66 Woods Cross. Region VIII
Cvunuric Acid:
Olin, Region III
Cvcluhexane:
Phillips 66 Houston, Region VI
D001 Wastes:
Chief Supply, Region VI
Diammonium Phosphate:
Chevron. Region VIII
De FiKimer 91J-HL:
Chevron. Region VIII
Diethvlzinc:
Phillips 66 Houston, Region VI
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Diesel Fuel:
Ti. Recuin
Dinitrotoluene:
Moh;i\. Region VI
Divinvl Benzene 55 (DVB):
Puroliie Corp, Region III
Ethvl Acrvlate:
McAVhorter. Reeion X
Kthvlene:
Phillips 66 Houston. Region VI
Ethviene Dichloride:
BASF. Corp.. Region 11 (NY)
FIXM-F005 Solvents:
Chic! Supply, Region VI
Fluoroboric Acid:
Auiomaia. Region III
FIv \sh:
Chief Supply, Reaion V!
Formaidehvde Snluiioii:
Farmland Indusincs, Region VI
Ncsic Corporation. Region X
Hexene-1:
Phillips 66 Houston. Region VI
iivdrazines:
Astroicch. Region IV
Ilvdrochloric Acid:
Original Bradford Soap Works. Region 1
Upjohn. Region I
BASF. Corp". Region II (NY)
Car! Falkenstcin, Region III
Mobay. Region III
Rhone-Poulenc. Region III
Automata. Region III
LCP Chemicals. Region III
Fermema ASC. Region VI
Western Extrusions, Region VI
Phillip* 66 Wood* Cross. Region VIII
Western Forge. Region VIII
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Hydrogen:
Hydrogen Cyanide:
Hydrogen Fluoride:
Mohay. Region III
LCP Chemicals, Region lil
Besi Foods. Region V
Phillips 66 Houston. Region VI
W.R. Grace. Region I
Phillips 66 Woods Cross. Region VIII
BP Oil Company. Region X
Hydrogen Peroxide:
Hydrogen Sulfide:
Olin, Recion III
Royster Phosphates. Region IV
Amoco Production, Region VIII
ll,P04:
Kobulane:
BASF. Corp.. Region II (NY)
Phillips 66 Houston. Region VI
Isooanates:
Du Pont Agrichemicals. Region II
Isnphlhalonitrile:
Fermenia ASC. Retzion VI
Mult it Anhvdride:
McWhortcr, Region X
Mercurv
LCP Chemicals. Reuion 111
Methane:
Amoco Production, Region VIII-
Methanol:
Du Pont Agrichemicals. Region II
Mobay. Region III
Fermenu ASC. Re«ion VI
Melhtl Chloride:
Fermenta ASC. Region VI
Methvl Isocvanate:
Rhone-Poulenc. Remon III
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Meihvlene Chloride:
Methvl Ethvl Ketone:
Mineral Spirits:
Monoammonium Phosphate:
Vlonomelhylamine:
Mono Sudium Methvl Arsenate:
Naphthalene:
Nitric Acid:
Nitric Oxide:
Nitrogen:
Nitrogen Dioxide:
Nitrogen Tetroxide:
Nopco 8050 Defoumer:
Ordnance:
Orthodichlorohenzene:
Great Lakes Chemical. Region VI
Chief Supply. Region V!
Western Forge. Region VIII
Western Force, Reaion VIII
Chief Supply, Region VI
Chevron. Region VIII
Rhone-Poulenc, Reeion III
Fermenta ASC. Recion VI
Koppers. Region V
Bacardi Rum, Recion II
Mobay. Recion III
Automata. Region III
Western Extrusions, Recion V'l
Western Forge. Recion VIII
Eticam. Region IX
Phillips 66 Houston, Region VI
Mobay, Region 111
Eucam. Region IX
Asirotech, Region IV
Chevron, Region VIII
Astroiech, Region IV
Mobay. Region III
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Perchloroethylene:
\Vesiern Force. Recion \'III
Phosgene:
L'ptohn, Region I
Mobay. Region III
Rhone-Poulenc, Recion II
Great Lakes Chemical, Recion VI
Phosphoric Acid:
Roysier Phosphates, Region IV
Western Extrusions. Region V'l
Chevron. Reaion VIII
Phosphorous:
FMC Corporation, Recion X
Phosphorous Trichloride:
W.R. Grace, Recion I
Phthulic Anhvdride:
Koppers. Recion V
Polyethylene/Polypropylene:
Phillips 66 Houston. Region VI
Polvolefln Catiilvst:
Phillips 66 Houston. Recion VI
Potassium Hydroxide:
Girl Falkenstein. Region III
Propylene Dichloride:
Purolitc Corp. Region III
Slum Oil:
Koppers. Region VIII
Sodium Chloride:
Automata. Region III
Sodium Chlorite:
Automata, Region III
Sodium Cvanide:
W.R. Grace. Region I
Carl Falkenstein. Recion III
Sodium DkhloriMSOcvynurate:
Olin. Region III
Stxlium Dkhroniatc:
Phillips 66 Housion. Reuion VI
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I)
Sodium Hvdroxide:
Original Bradford Soap Works. Region
Fall River Waste Treatment, Region I
Du Pont Agrichemicals. Region ll
Bacardi Rum. Region II
Carl Falkenstein. Region III
Automata, Region III
Olin. Region III
LCP Chemicals, Region III
Best Foods, Region V
Koppers, Region V
Fermenta ASC. Region VI
Great Lakes Chemical, Region VI
Phillips 66 Woods Cross. Region VIII
AJ1 Pure Chemical. Region X
Sodium Hypochlorite:
LCP Chemicals, Region III
Fermenia ASC. Region VI
All Pure Chemical. Resion X
Sodium Persulfale:
Automata, Region III
Solid 1'ropellant:
Astrotech, Region IV
Stadis 450:
Phillips 66 Houston. Region IV
Stvrene:
Polysar. Region I (Styrene Monomer)
Puroliie Corp., Region III
Phillips 66 Houston, Region VI
Sulfur:
Chevron, Region VIII
Amoco Production. Region VIII
Sulfur Dioxide:
Roystcr Phosphates. Region IV .
Great Lakes Chemical, Region VI
Chevron. Region VIII
Amoco Production. Region VIII
BP Oil Company, Region X
Sulfur I riovide:
Royster Phosphates. Region IV
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Sulfuric Acid:
T-butyl-peroyacetate:
Tercphthalic Acid:
L'pjohn. Region 1
Bacardi Rum, Region U
Puroiiic Corp.. Region HI
Moha\. Region III
Automata. Region III
Olin. Region III
LCP Chemicals, Region III
Roystcr Phosphates, Region IV
Best Foods, Region V
Koppers, Region V
Western Extrusion. Region VI
Great Lakes Chemical. Region VI
Western Forge, Region VIII
Phillips 66 Woods Cross, Region VIII
Koppers. Region VIII
Chevron. Region VIII
Polvbar. Riicion I
Fcrmenta ASC. Region VI
Toluene:
Du Pont Agrichemieals. Region II
BASF. Corp.. Region II (NY)
Western Forge. Region VIII
Toluenediamine:
Toluene Diisocvanate:
Mobiiv. Region III
Mobay. Region III
l.L.l-Trichloroethane:
Chiel Supply, Region VI
Trichioroisocyanuric Acid:
Olin. Region III
Urea:
Olin, Region III
Farmland Industries, Region VI
Vanadium Pentoxide:
Roystcr Phosphates. Region IV
Wolmanac (CCA):
Koppers, Region VIII
Xvlene:
Du Pont Aunchemicals, Region II
Koppers. Region V
Fcrmenta ASC. Region VI
Western Force. Rceion V11I
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