THE CHEMICAL SAFETY AUDIT PROGRAM:
          FY 1991 STATUS REPORT
                      Prepared for:

           Chemical Emergency Preparedness and Prevention Office
                U.S. Environmental Protection Agency
                     Washington, B.C.
                      Prepared by:
                     ICF Incorporated
                     November 1991

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THE CHEMICAL SAFETY AUDIT PROGRAM:
          FY 1991 STATUS REPORT
                      Prepared fon

           Chemical Emergency Preparedness and Prevention Office
                U.S. Environmental Protection Agency
                     Washington, D.C.
                      Prepared by:
                     ICF Incorporated
                     November 1991

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                                   TABLE OF CONTENTS


EXECUTIVE SUMMARY	  i

1.0     CHEMICAL SAFETY AUDIT PROGRAM: HISTORY AND FUTURE	1

       1.1     CSA Program Background 	1
       1.2     CSA Database 	4
       1.3     CSA Training Workshop	5
       1.4     State CSA Programs	6
       1.5     Clean Air Act Amendments 	7

2.0     OVERVIEW OF CSA PROGRAM RESULTS	9

       2.1     Chemical Safety Audits and Reports Completed 	9
       2.2     Chemical Safety Audits by SIC Code	9
       2.3     Chemical Safety Audits by Hazardous Substance	9
       2.4     CSA Training Workshops	  13

3.0     ANALYSIS OF CSA PROFILE RESULTS  	'	  17

       3.1     Facility Background Information	  17
       3.2     Chemical Hazards	  19
       3.3     Process Information for Hazardous Chemicals	20
       3.4     Chemical Accident Prevention	t	29
       3.5     Accidental Release/Incident Investigation  	39
       3.6     Facility Emergency Preparedness and Planning Activities	41
       3.7     Community and Facility Emergency Response Planning Activities	49
       3.8     Public Alert and Notification Procedures	52

4.0     STATUS OF CSA PROGRAM IMPLEMENTATION 	55

       4.1     Regional Implementation  	55
       4.2     Regional Activities	56

APPENDICES

Appendix A:   Outline of the Chemical Safety Audit Protocol
Appendix B:   List of Chemical Safety Audits
Appendix C:   Hazardous Substances Examined in Chemical Safety Audits
Appendix D:   Chemical Safety Audit Report Profiles

EXHIBITS

Exhibit 1:      Status Summary of the Chemical Safety Audit Program
Exhibit 2:      Summary of Chemical Safety Audits  and Final Reports Completed by Region
Exhibit 3:      Breakdown of Audited Facilities by SIC Code
Exhibit 4:      Chemical Safety Audit Workshop Attendees by Affiliation, FY 89 through FY 91
Exhibit 5:      Chemical Safety Audit Workshop Attendees by Affiliation
Exhibit 6:      Chemical Safety Audit Workshops: Number of Persons Trained by EPA Region

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                                     EXECUTIVE SUMMARY

        This report provides a comprehensive overview of the status of the U.S. Environmental Protection
Agency's Chemical Safety Audit (CSA) program since its inception in FY 89, and a discussion of the
future direction of the program.

        The 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 visit facilities handling hazardous substances to gather information on safety practices
               and technologies;

              To heighten awareness of the need for, and promote, chemical safety among facilities
               handling  hazardous substances, as well as in communities where chemicals are located;

              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.

        The CSA program is not a compliance or regulatory program; however, EPA does have legal
authority for entering a facility and conducting a  chemical safety audit under CERCLA sections 104(b) and
104(e), as amended by SARA. The auditing team consists of EPA employees and other designated
representatives, including contractors, part-time EPA employees from the American Association of Retired
Persons (AARP), and representatives of State Emergency Response Commissions (SERCs) and Local
Emergency Planning Committees (LEPCs). The  audit consists  of interviews with facility personnel and an
on-site review  of various aspects of facility operations related to the prevention of accidental chemical
releases. Observations and conclusions from the audit are detailed in a report prepared by the audit team.
The audit report, which is available to the public, identifies and characterizes both problematic and
successful chemical process safety management practices, as well as technologies for preventing and
mitigating chemical releases.

        This status report is intended to provide  EPA headquarters and regional management with a
better understanding of the  audit program purpose and goals, the type of information being generated and
its uses, and how the program is being implemented both in headquarters and the regions.  The following
four topics are the focus of this report  program background,  program results, analysis of audit report
information, and regional implementation  status. In addition, this report addresses the impact that
implementation of the Clean Air Act Amendments of 1990 can be expected to have on the CSA program
and the future course of the program. The chapter on CSA report analysis is based upon standardized
profiles or summaries developed from the  80 final audit reports received by EPA headquarters as of
August 31, 1991; Appendix D contains 48 report  profiles which were not included in the FY 1990 CSA
Status Report.  This Executive Summary summarizes  key findings of the program results, analysis, and
implementation status chapters.

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        Program Results

        The audit program results, further documented in Chapter 2, are based on the number of audits
conducted and reports completed in each region, along with a summary of the audits by the facility's
Standard Industrial Classification (SIC) code and by the hazardous substances examined during the audit.
An overview of training workshop participation is also included.

        For FY 89 and FY 90, each region was assigned a target of conducting 4 audits per year under
EPA's tracking and evaluation system; in FY 91, the total target for all ten regions remained at forty, but
the regions were assigned individual targets based on the nature of their programs.  The regions conducted
32 audits in FY 89, 39 audits in FY 90, and 52 audits during FY 91, for a total of 123 audits.  As of
September 30, 1991, the regions  had submitted 101 final audit reports to EPA headquarters, of which 80
were examined  for this status report. Exhibits 1 and 2 in Chapter 2 provide a complete summary of the
number of audits and reports completed. Overall, there was a noticeable increase in the number of audits
conducted and audit reports completed in FY 91.

        To realize the goals of the CSA program to collect and disseminate information on chemical
process  safety issues and to improve program coordination, the Chemical Emergency Preparedness and
Prevention Office (CEPPO) is assembling a computerized database to provide  EPA regions and
headquarters with information gathered  from final chemical safety audit reports, organized in a uniform
format consistent with the CSA protocol. Although the database will not be directly available to the
public and industry, it will be used to develop guidance and technical assistance documents that will be
distributed to individuals and organizations involved in chemical accident prevention. Each regional CEPP
coordinator will be receiving a copy of the initial version of the database, containing information from at
least 40 CSA reports, on two or  three diskettes that can then be downloaded to a hard disk drive.

        CEPPO has designed a four-day chemical safety audit workshop that provides potential audit team
members with the training to conduct an audit. During FY 89 to FY 91, a total of 10 workshops were
conducted in Regions 3 through  10. A total of 336 individuals have attended the  10 workshops, including
137 individuals who attended the four workshops held in FY 91. One notable trend in the CSA program
has been increased state and local involvement, evidenced by the fact that the percentage of state and local
government attendance at  the CSA workshops has grown substantially.

        A related trend in the CSA program has been the interest of some states in developing their own
ability to conduct chemical safety audits, or to develop their own CSA program to support chemical
accident prevention initiatives at the state and local level. This interest has been fostered by the states'
emergency preparedness responsibilities  under Title III and other related state legislation.  The regional
CEPP offices have been actively  supporting state and local involvement in the CSA program, including
developing state CSA programs.  The most notable examples of this trend are in the states of Colorado
and Nevada.

        Program Analysis

        Chapter 3 characterizes the notable and problematic safety practices identified from the report
profiles developed from the 80 final audit reports. The analysis summarizes and evaluates the types of
observations and recommendations presented in the audit reports according to the CSA protocol, the
outline which provides the structure of the audits and the audit reports. The following general categories
of actions recommended for the  audited facilities have been identified and will serve as a baseline for
further analysis of the CSA database as information from additional audits  becomes available:

              Improvements in facility security measures to restrict access to areas containing hazardous
               substances;

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               Improvement of labeling and color-coding for storage areas, storage containers, and
               process and on-site transfer equipment;

               Improvements in safety procedures during shipping and receiving operations involving
               hazardous substances;

               Expansion of both process and environmental monitoring systems;

               Increased support for chemical process safety programs by facility and corporate
               management.

               Development of process-specific standard operating procedure manuals and distribution to
               all appropriate employees;

               Increased availability of chemical hazard and process safety information to employees and
               other on-site personnel;

               Establishment of formal preventive maintenance programs, including regular inspection
               and testing of equipment and instruments;

               Development of facility procedures for conducting regular hazard evaluations of process
               units where hazardous substances are present;

               Refinement or installation of secondary containment measures;

               Expansion of incident investigation policy to include  all releases, spills, and near-miss
               incidents;

               Refinement of facility contingency plans and establishment of schedules for regular
               reviews and exercising of such plans;

               Increased availability of emergency equipment and emergency response training for
               employees;

               Improvements of on-site emergency alarm and communication systems;

               Increased coordination with community planning activities; and

               Development of procedures for notifying the public during an emergency.

        Regional Implementation Status

        Chapter 4 addresses the status of the CSA program and program implementation issues that have
been identified by headquarters and the regions during FY 89 and FY 90.  Program status is presented
based upon a review of the number of audits conducted  and reports completed and the quality of report
contents.

        In general, a review of the numbers of audits conducted from FY 89 through FY 91 indicates that
the regional offices have been attempting to commit resources for CSA program implementation.  In the
past, problems have occurred that have prevented some  regional offices from accomplishing the  targeted
number of audits every year, such as the loss of trained personnel and canceled or postponed audits.
During FY 91, there has been an increase across all the  regions in the number of audits conducted. In

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                                                IV
addition, following up on a concern identified in the FY1990 Status Report, the time required to finalize
audit reports has been reduced significantly. As of September 30,1991, final reports had been submitted
for a significant majority of the audits conducted in FY 91, although a number of audit reports remain
outstanding from FY 89 and FY 90.

        A related area of concern in the program has been the lack of consistency in audit report format
from region to region.  Consistency across audit reports and timeliness of report preparation facilitate
analyzing conclusions and recommendations, identifying successful and problematic practices and
technologies, and sharing information.  To address these concerns, CEPPO is considering revisions to the
CSA training materials, including developing a CSA report preparation module and advanced CSA
training courses. Headquarters will coordinate these activities and other program implementation issues
with the Regional Chemical Safety Audit Committee chaired by Region 6.

        Most regional offices actively seek LEPC and SERC participation in audits, but several  of the
regional offices have also been actively involved in the development of CSA expertise at the state and local
level. Region 4 held an EPA-sponsored CSA workshop in Charleston, SC, in FY 91 that was attended by
over 30 state and local officials, and plans to conduct its own chemical safety audit workshop in  FY 92 at
the request of the North Carolina SERC.  Region 8 is currently assisting the Colorado SERC in providing
a series of CSA workshops to LEPC members throughout the state. Region 9 is providing assistance to
Nevada in developing its own chemical safety audit program, which will include audits conducted under the
authority of a new state law on chemical accident prevention.

        Conclusion

        In summary, EPA views the CSA program as a cornerstone in the Chemical Accident Prevention
program and as a continuing means of focusing chemical accident prevention initiatives.  Current benefits
from the CSA program include the following:

              CSA training workshops and audit participation provides EPA, SERCs, LEPCs, and other
               federal agencies with a better understanding of chemical process safety management and
               facility practices to prevent and mitigate chemical releases; and

              Jointly conducted audits and training are sponsoring cooperation and coordination on
               chemical safety programs among federal,  state, and local government agencies.

        In the next few years, the influence of the Clean Air Act Amendments of 1990 and the
development of independent state chemical safety audit programs will further expand the potential
contribution of the CSA program to chemical accident prevention.  Future activities under the CSA
program include:

              Dissemination of information from CSA  reports as part of guidance to promote a greater
               awareness among facilities and  state and  local officials of chemical process safety
               management, and an understanding of effective prevention and preparedness techniques.

              Use of CSA training workshops to prepare EPA regional, as well as state and local
               personnel for their responsibilities under the Clean Air Act, particularly in understanding
               risk management programs and providing technical assistance to covered facilities; and

              Use of the CSA database to help EPA identify problematic and successful industry
               practices related to preventing chemical accidents for the development of the "reasonable
               regulations"  under the Clean Air  Act.

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1.0     CHEMICAL SAFETY AUDIT PROGRAM:  HISTORY AND FUTURE

        This report is intended to provide U.S. Environmental Protection Agency (EPA) headquarters and
regional management and other program offices with a better understanding of the Chemical Safety Audit
(CSA) program.  The CSA program is part of a broad EPA initiative designed to accomplish four chemical
accident prevention goals:

               Visit facilities handling hazardous substances to learn and understand problematic and
               successful practices and technologies for preventing and mitigating releases;

               Heighten awareness of the need for and promote chemical safety among chemical
               producers, distributors, and users, as well as in communities where chemicals are located;

               Build cooperation among authorized parties by coordinating joint 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.

        This report focuses on the information being generated by the CSA program and its current and
intended uses, as well as how the program is being implemented at headquarters and in the regional
offices.  The remainder of this chapter describes the key features of the CSA program, including its history,
scope, and purpose, and other key CSA activities - developing the CSA report database, conducting
regional training workshops, and supporting state and local government involvement in the CSA program.
In addition, the last section of this chapter will discuss the potential influences of the Clean Air Act
Amendments of 1990 on the CSA program.  Chapter 2 provides a statistical overview of the results of
CSA program activities and achievements.  Chapter 3 analyzes the successful and problematic practices and
techniques identified in final CSA reports.  To identify these industry trends, the analysis examined the 80
final CSA reports submitted to EPA's Chemical Emergency Preparedness and  Prevention Office  (CEPPO)
as of August 31,  1991.  Finally, Chapter 4 provides an overview of regional activities in implementing the
CSA program.

        Of the 123 audits conducted as of September 30, 1991, 80 final audit reports have been completed
by regional personnel (see Appendix B); the data from the 43 additional audits have not been considered
for the purposes of this analysis because the final audit reports were not completed by August 31, 1991.
To compile information for this report, the final audit reports  have been summarized in standardized
profiles consistent with the CSA protocol.  Copies of the latest profiles (those completed after the
publication of the FY1990 Status Report) are enclosed as Appendix D of this report. The profiles provide
a summary of audit observations, and include the conclusions and recommendations made by the audit
team. The profiles also contain other information, such as facility name, location, primary processes and
product(s); the hazardous substances examined for the audit; and the name, affiliation, role, and expertise
of each audit team member.

        1.1     CSA Program Background

        History

        Following the 1984 release of methyl  isocyanate in Bhopal, India, and  subsequent incidents in the
United States, 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.  EPA established the Chemical
Emergency Preparedness Program to help states and communities plan for chemical emergencies. Many of
the features of this voluntary program were incorporated into Title III of the Superfund Amendments and

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Reauthorization Act of 1986 (SARA Title III), which established a chemical emergency preparedness
infrastructure within each state, territory, and Indian land.

        Recognizing accident prevention as the next step after instituting local emergency preparedness
efforts, EPA created the Chemical Accident Prevention (CAP) program in  1986.  The CAP program seeks
to identify causes of accidental releases of hazardous substances and the means to prevent them from
occurring, to promote accident prevention in industry, and to share information with the community,
industry, and other groups (e.g., academia, professional organizations, trade associations, labor, and
environmental groups).

        Many of these key concerns were identified in the Congressionally  mandated SARA Title III
section 305(b) study, Review of Emergency Systems.  This study reviewed technologies, techniques, and
practices for preventing, detecting, and monitoring releases of extremely hazardous substances, and for
alerting the public to such releases.  As part of the information gathering efforts to prepare this  study, the
CAP program conducted a number of audits of facilities to evaluate, first-hand, their chemical process
safety management practices.  As one method of acquiring additional information and encouraging
awareness of accident  prevention at facilities, the study recommended that EPA continue the program of
facility audits, thus inaugurating the CSA program.

        Authority

        While the CSA program is not a compliance or regulatory program, EPA does have legal
authorities for entering a facility and conducting a chemical safety audit.  The  primary authority for  EPA
and its designated representatives to enter a facility and review its records and operations is provided by
CERCLA sections  104(b) and  104(e), as amended by SARA.  The audits are intended to be non-
confrontational and positive, so that information on safety practices, techniques, and technologies can be
identified and shared between EPA and the facility. If serious problems are discovered during the audit,
however, EPA has a variety of legal authorities to use in response to them.

        Audit Team

        An EPA audit team consists primarily of EPA employees and other designated representatives,
including contractors and members of the American Association of Retired Persons (AARP).  Other
federal, state, and local government personnel, particularly representatives of State Emergency Response
Commissions (SERCs) and Local Emergency Planning Committees (LEPCs) established under SARA
Title III, are encouraged to participate in audits as team members or as observers. The audit team can
vary in size depending on the scope of the audit and the expertise of individual team members.  Although
states and local governments must use their own authorities for audit participation, the CSA program
encourages the  involvement of LEPC and SERC members.

        Audit Selection

        In selecting a  facility for a chemical safety audit, the EPA regional  office may consider a  number
of factors, including but not limited to the hazardous substances used, the facility's releases history, the
facility's proximity to a sensitive population or high population density, its accident prevention technology,
or the industry's concentration in the area. The regional office may want to review information sources
such as federal, state, and local release notification reports and follow-up reports; On-Scene Coordinator
(OSC) reports;  Regional Response Centers; Accidental Release Information Program (ARIP) reports;
Emergency Response Notification System (ERNS); and other sources.  Currently, most facilities selected
have been identified through ARIP reports.

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        At present, there are no formal procedures an EPA regional office must follow when selecting a
facility for an audit, provided the following two important requirements are met:

              Under CERCLA, EPA may enter a facility only if a release of a CERCLA hazardous
               substance, pollutant, or contaminant has occurred at the facility, or there is "reason to
               believe" that a threat of such a release exists; and

              The Office of the Regional Counsel and the SERC must be consulted to identify any legal
               actions currently being pursued or anticipated against the audited facility.  Although not
               compliance-oriented, a chemical safety audit conducted at a facility where legal action is
               on-going or anticipated may interrupt or otherwise have an impact on the settlement
               process.  It is also suggested that other regional program offices be consulted.

EPA can, of course, enter a facility and conduct an audit at the invitation or with the voluntary consent of
the facility's management.

        Audit Process

        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:

              Process characteristics;

              Emergency planning and preparedness activities;

              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 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 is conducted  in accordance with the Guidance Manual for EPA Chemical Safety Audit
Team Members, which contains  mandatory procedures, as well as recommended actions 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 should be sent to the facility prior
to the audit.  The guidance manual also contains an audit protocol (see Appendix A), a detailed outline
that directs the scope and content of the audit and provides a structure for preparing the audit report.
The protocol is designed  to provide CSA teams with an organized and detailed format for conducting an
audit  and preparing a comprehensive report.  By following the protocol in preparing CSA reports, regional
staff will ensure continuity and consistency in report preparation.

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        EPA sets individual targets for the number of audits (and audit reports) to be completed each year
by each region. A total of forty audits and audit reports is targeted annually, with each region responsible
for three to six audits.  CEPPO uses the Strategic Targeted Activities for Results System, or STARS, to
track the regions' progress toward these goals, although STARS does not involve a review of the focus and
contents of the audit reports.

        1.2     CSA Database

        To realize the goals of the CSA program to collect and disseminate information on chemical
process safety issues and to improve program coordination, CEPPO is assembling a computerized database
to provide EPA regions and headquarters with information gathered from final chemical safety audit
reports, organized in a  uniform format consistent with the CSA protocol.  The information contained in
the database will be useful to  EPA regions for a variety of purposes, such as identifying field experts and
comparing processes at different facilities for the same chemicals. Although the database will not be
directly available to the public and industry, it will be used to develop guidance and technical assistance
documents that will be distributed to individuals and organizations involved in chemical accident
prevention.

        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 database will assist CEPPO in identifying successful and problematic techniques or practices used to
manage process safety at facilities handling hazardous substances. CEPPO will also be able to use the
database to assess the implementation of the CSA program in terms of number of audits conducted.

        The CSA database will  make it possible to quickly examine audit information about specific
facilities. For example, the database user could easily examine and compare audit observations and
recommendations for facilities that use similar chemicals, that manufacture similar products, or that are
located in the same region.  Users can search the database for different types of information, such as
chemical names, SIC codes, processes, and process safety practice or technique, or a combination of fields.
For example, a user could search the database to identify the type of containment systems  present at
chemical manufacturing facilities (SIC code 28) that use chlorine. EPA regional and headquarters
personnel may also use the database to:

              Identify field  experts for auditing advice, or even possible participation in  an audit;

              Identify facilities with similar processes or practices to support an ongoing audit;

              Compare successful or problematic safety practices  among similar facilities;

              Identify previous recommendations for  a similar process safety practice or technique;

              Compare safety equipment among similar facilities;

              Assemble information on a specific  chemical safety process management practice; and

              Determine the number of audits conducted, the number of audit reports completed, and
               the general areas of information contained in the reports.

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        Each regional CEPP coordinator will be receiving a copy of the initial version of the database
containing information from at least 40 CSA reports, on two or three diskettes that can then be
downloaded to a hard disk drive. As additional chemical safety audit reports are completed, profiles will
be developed and entered into the database. The database will updated annually and new diskettes will be
provided to the regions.

        1.3     CSA Training Workshop

        In order 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, EPA has designed the Chemical
Safety Audit program workshops.  The workshops are presented to a combination of regional, AARP,
contractor, and state and local government personnel who are or will be  involved in conducting chemical
safety audits. EPA is evaluating the need for a refresher workshop to discuss more advanced issues  related
to conducting audits  for personnel already familiar with the CSA program.

        The topics addressed during the current four-day workshop include:

              EPA's Chemical Accident Prevention program;

              Chemical process safety management

    /         Guidance Manual for EPA Chemical Safety Audit Team Members;

              Chemical safety audit protocol;

              Chemical and process hazards;

              Hazards evaluation and application;

              Process safety systems and practices;

           .   Incident investigation; and

              Conducting interviews.

A series of sequential group exercises are held during the workshop  to provide  participants with the
opportunity to apply theoretical knowledge in  scenarios that simulate all  phases of conducting a chemical
safety audit, including interviewing facility personnel.

        Following a pilot workshop held in FT 88, EPA conducted three CSA workshops in both FY 89
and FY 90.  In FY 91, four workshops were held throughout the country ~ San Diego, California;
Charleston, South Carolina; Denver, Colorado; and Chicago, Illinois. A total of 336 regional, AARP,
contractor, state and local government,  and other federal agency personnel have attended these ten
workshops.  For FY 92, a workshop is scheduled in the Washington, D.C., area for November 4-7, 1991;
future workshops  are planned on an as-needed basis.

        One significant trend in FY 91  has been the increased participation  of state and local government
in the CSA training workshops.  For example, the South Carolina SERC, in order to build state auditing
expertise, requested that Region 4 conduct a CSA training workshop in Charleston in 1991, rather than in
Atlanta where it was originally planned  to be held.  South Carolina sent over 30 state and local
government employees to this workshop, which had largest attendance of the FY 91 workshops.

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        EPA Region 9 decided to follow the four-day San Diego CSA workshop (January 7-10, 1991) with
a one-day workshop on implementation issues related to California's Risk Management and Prevention
Program (RMPP). This was done as a result of the interest expressed by the California SERC and local
officials within California who wanted to discuss ways to better implement California's RMPP using the
knowledge gained from the CSA workshop. Like EPA's CSA program, California's RMPP is designed to
minimize or prevent  accidental releases.  Many workshop attendees believed the information from the
CSA workshop would be useful in reviewing facilities' risk management plans.

        1.4     State CSA Programs

        Another significant trend in the CSA program has been the interest of some states in developing
their ability to conduct chemical safety audits or to develop their own CSA program to support chemical
accident prevention initiatives at the state and local levels.  This interest has been fostered by the states'
emergency preparedness responsibilities under Title HI and other related state legislation. Regional CEPP
offices have been actively supporting state and local involvement in the CSA program, including
developing state CSA programs.  The most notable examples of this trend are in the states of Colorado
and Nevada.

        Colorado

        Colorado decided to develop its own CSA workshop to train potential state and local audit team
members and expand awareness of chemical process safety management issues and practices within the
state.  Region 8, with support from CEPPO, assisted the Colorado SERC in designing, organizing,  and
delivering a series of workshops to train LEPC members from  across the state. The first workshop was
held in Pueblo on September 4-5, 1991, a second is scheduled for November 22-24, 1991, in Durango, and
additional workshops are planned.  The workshops were specifically designed to provide Colorado's LEPCs
with the tools and knowledge to conduct effective audits, to understand the concepts of chemical process
safety management, and to enable them to participate in audits conducted by EPA.

        Nevada

        Nevada recently enacted a law (S.B. 641, June 15, 1991) governing the handling of hazardous
chemicals that is designed to prevent catastrophic releases from occurring.  If a facility has a chemical
accident, near-miss, or poses a "catastrophic threat" to public health and safety, the governor can appoint a
committee to inspect the facility. The committee will review the facility's compliance with fire codes,
regulations, standards and safety orders of the division of occupational safety and health of the department
of industry, and any other state and federal regulations and standards; the effectiveness of these agencies in
the enforcement of their respective rules and regulations; and the adequacy of emergency response  plans
adopted for the area  in which the facility is located.  The committee may also review and make
recommendations to the reviewing authority regarding permits to construct, substantially alter,  or operate
a facility that has been the subject of the committee's review and evaluation.

        EPA Region 9, with support from CEPPO, is providing assistance to Nevada in developing its own
chemical safety audit program, which will conduct audits under the authority of the new law. A Nevada
CSA manual, based on the Guidance Manual for EPA Chemical Safety Audit Team Members, is being
developed to serve as the guide for the program and  will be supported by a series of training workshops  to
be conducted later in FY 92.

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        As more and more SERCs and LEPCs look for ways to better prepare for, or prevent, chemical
accidents, interest in the CSA program increases.  In Chapter 4, more information is available on regional
efforts to promote the CSA programs at the state and local levels. The results are encouraging; as an
example, Region 4 conducted its own CSA workshop in Greensboro, North Carolina, at the request of the
SERC on October 22, 1991.

        1.5      Clean Air Act Amendments

        Probably the most important influence on the future of the CSA program is the passage of the
Clean Air Act (CAA) Amendments of 1990. The chemical accident prevention provisions, found in
section 112(r) of CAA, require EPA to develop several regulations, including a  list of regulated substances,
and the requirements for development of reasonable regulations, including risk management plans and a
system for auditing these plans.  In addition to the regulatory requirements, EPA is  also required to
provide technical guidance in accordance with section 112(1)(3) of CAA to state and local agencies.

        Section  112(r) requires the development of a list of at least 100 substances which are known to
cause or may be anticipated to cause death, injury, or serious adverse effects to human health or the
environment.  The list will also include specific thresholds for each chemical.

        Facilities handling a listed substance at or above the threshold will be required to prepare a risk
management plan (RMP) as well as comply with other applicable reasonable regulations. The RMP must
contain a hazards analysis, an accident prevention program, and an emergency response plan.  EPA is also
required to develop an auditing system for reviewing the RMPs from regulated facilities. The auditing
responsibilities will be delegated to the state and local agencies who are authorized to implement section
        Section 112(r)(7)(ii) requires EPA to publish reasonable regulations for the .prevention and
detection of accidental releases of regulated substances. The regulations shall, as appropriate, recognize
differences in size, operations, process, class, and categories of facilities and the voluntary action of
facilities to prevent and respond  to accidental releases.

        There are several important areas in which the CSA program can support the implementation of
CAA.  The CSA training workshops have and will continue to play an important role by providing state
and local agencies with the expertise to conduct reviews of chemical process safety management practices.
The workshops can also provide  state and local officials with a basis for understanding the use of the RMP
information to  support local chemical  preparedness and prevention efforts.  For example, the activities of
the States of Nevada and Colorado in  developing the tools and knowledge to conduct effective chemical
safety audits will enhance their states'  ability to review RMPs under the CAA  The information which has
been collected under the CSA program may also be used in the regulatory development phase of
implementing section 112(r).  EPA may also use the CSA database as a means of identifying areas which
need to be addressed by reasonable regulations.

        When discussing the future of the CSA program, it is necessary to look at the two parts of the
program structure -- providing training to state and local agencies on how to perform a chemical safety
audit and actually performing chemical safety audits at facilities.  Although the role of the CSA program
in the implementation of the  CAA is still being  considered, EPA envisions several options for the
direction of the CSA program. First, the CSA program in its current non-regulatory format may continue
to operate as a technical guidance program.  This guidance from the  federal level could be provided in
accordance with section 112(1) (3) to state and local agencies.  In addition, section 507 of CAA provides
assistance for small business that may have difficulty complying with the requirements of the Act. States
are, therefore, required to establish small business technical and environmental compliance assistance

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                                                 8

programs.  In support of these programs, the CSA training workshops can be adapted to assist states and
local agencies in reviewing RMPs.

        Second, the CSA program may also evolve into the federal compliance arm of the accidental
release provisions of CAA, with audits focusing only on the review of the RMPs and the facilities that are
subject to section 112(r).  Finally, EPA may also combine these approaches,  with the Chemical Safety
Audit program  remaining a technical assistance tool for state and local agencies while adapting the audit
procedures to also establish an  RMP auditing system.

        While the relationship  between the  CSA program and the CAA has  not been decided, the
requirements in various sections in the statute indicate that EPA is obligated to provide technical
assistance to states and local agencies, set up an auditing  system for state and local agencies to evaluate
facilities and RMPs, and require facilities to modify their RMPs periodically. Section 112(1)(3) requires
EPA to provide technical assistance to states and  local agencies.

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2.0     OVERVIEW OF CSA PROGRAM RESULTS

        As of September 31,1991, EPA regional offices have conducted a total of 123 chemicals safety
audits.  This chapter provides an overall summary of the achievements of the Chemical Safety Audit
program focusing on the following subjects:

               The number of chemical safety audits and audit reports completed in each fiscal year;

              A breakdown of the audited facilities by Standard Industrial Classification (SIC) code;

               The number of hazardous substances examined by the audit team and indicates  those
               substances that appeared most frequently in the audit reports; and

               The ten chemical safety audit training workshops conducted by the EPA for the regions.

        2.1     Chemical Safety Audits and Reports Completed

        As of September 30, 1991, a total of 101 audit reports for the 123 chemical safety audits
conducted have been finalized.

        For FY 89 and  FY 90, each EPA region was assigned a target of conducting four audits each year
under the Agency's tracking and evaluation system, Strategic Targeted Activities for Results System
(STARS).  Beginning in FY 91, the STARS measure was expanded to include both the fulfillment of an
on-site facility visit and  the subsequent audit report. In addition, specific STARS targets were set for each
region to better reflect regional priorities and capabilities.

        Exhibit 1 provides totals for the number of chemical safety audits that the regional offices
conducted during each fiscal year.  The number of reports completed by each regional office is also
included. The chart indicates that 32 chemical safety audits were completed in FY 89.  In FY 90, an
additional 39 chemical safety audits were completed. Fifty-two chemical safety audits were completed in
FY 91.  Exhibit 2 provides a summary of the chemical safety audits and final reports completed by region.

        2.2     Chemical Safety Audits by  SIC Code

        The majority of the regional offices conducted their chemical safety audits at chemical
manufacturing facilities  (SIC code 28).  Exhibit 3 provides a breakdown by SIC code of the type of
facilities at which chemical safety audits were conducted; note that some facilities are categorized in more
than one SIC code, so that the total is more than 80.  Forty-one of the 80 facilities at which chemical
safety audits were performed were chemical manufacturing facilities.  Most of these were further classified
under SIC codes 281, 282, or 287.  Seven audits  involved facilities in the petroleum refining industry (SIC
code 29).  Five of the audits involved facilities in the fabrication metal products category (SIC code 34)
and five other facilities were classified as electronics manufacturers (SIC code 36). The remaining facilities
audited  were classified in a variety of other SIC codes.

        2.3     Chemical Safety Audits by Hazardous Substance

        A total of 157 hazardous substances were examined by audit team members at the 80 audited
facilities. Appendix C of this report provides a complete listing of the hazardous substances examined
during the audits.  The five most commonly examined hazardous substances were sulfuric acid  (38 audits),
chlorine (31), sodium hydroxide (27), hydrochloric acid (21), and ammonia (18).  On average, four
hazardous substances were examined at each audited facility.

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                      Exhibit 1
     Summary of Chemical Safety Audits and
        Final Reports by Year and Region
                   FY 89 Through 91
Region
1
2
3
4
5
6
7
8
9
10
FY89
4
2
4
5
3
4
0
3
4
3
FY90
4
4
4
5
5
5
0
4
4
4
FY91
3
2
4
15
3
5
4
6
4
6
Total Audits
11
8
12
25
11
14
4
13
12
13
Number of Final Reports
11
5
11
19
4
14
3
13
11
10
Total     32      39      52        123           101

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30
                                Exhibit 2
             Summary of Chemical Safety Audits and
                Final Reports Completed by Region
                            FY 89 Through 91
25
20
15
10
 0
                                5      6
                               EPA Regions
         8
10
             Number of Chemical
             Safety Audits Completed
Number of Chemical Safety Audit
Final Reports Completed

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                              Exhibit 3
            Breakdown of Audited Facilities
                        by SIC Code*
                         FY 89 Through 91
 All Other SIC Codes
 25 Audits,
 30.5%
     SIC Code 36:
     5 Audits,
     6.1%
                                                           SIC Code 28:
                                                           41 Audits,
                                                           50.0%
            SIC Code 34:
            5 Audits,
            6.1%
SIC Code 29:
6 Audits,
7.3%
*This analysis is based on the 80 completed audit reports. Several of the
facilities are classified under more than one SIC Code. This is reflected in the Exhibit.

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                                                13

        2.4     CSA Training Workshops

        As of the close of FY 91, CEPPO has conducted a total of 10 CSA workshops in eight of the ten
EPA regions. Although workshops were not held in Regions 1 and 2, representatives from these regions
did participate at workshops in neighboring regions.  In FY 90 and 91, the host regions were co-sponsors
of the CSA workshops and provided valuable assistance in organizing and conducting the workshops. In
addition, hosting the workshop in cities near the locations of the regional office allowed other EPA
program offices, and other federal agencies 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.  In FY 91, workshops were conducted in Denver, San
Diego, Charleston, SC,  and Chicago.  Exhibit 4 provides a break-down of attendees by affiliation.  A total
of 336 individuals have  attended the ten workshops, including 112 regional personnel, 30 AARPs, 78
contractor personnel (primarily technical assistance team members), 83 state and local officials, 10
representatives from other federal agencies, and 23 others (e.g., EPA HQ personnel).  Exhibit 5 compares
the percentage of attendees by affiliation between FY 89-FY 90 and FY 91; indicating the growing
involvement of state and local personnel in the CSA program.

        Exhibit 6 is a breakdown by region of the number of audit team members who have received
training. State and local officials, HQ personnel, HQ contractors, and other federal agency representatives
are not  included in these figures. The largest  number of personnel attending a workshop were from
Region  4 (64), Region 3 (30), and Region 6 (25).

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                                     Exhibit 4
              Chemical Safety Audit Workshop Attendees
                                 by Affiliation
                                  FY 89 Through 91
                                 Other Federal Agencies
                           Other*    3 o%
                           7.0%
                   AARP
                   9.0%
            TAT/Other
            Contractors
            23.0%
EPA Regional
Personnel
33.0%
                                                State & Local
                                                Officials
                                                25.0%
Other includes personnel from EPA HQ and EPA HQ contractors.

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                                           Exhibit 5
                 Chemical Safety Audit Workshop Attendees
                                     by Affiliation
              FY 89 Through FY 90
     TAT/Other
     Contractors
     22.7%
  State & Local
  Officials
  20.2%
EPA Regional
Personnel
36.4%
                               Other
                               5.1%
                   AARP    Other
                   11.6%    Federal Agencies
                          4.0%
                                  FY91
TAT/Other
Contractors
23.9%
               State & Local
               Officials
               31.2%
EPA Regional
Personnel
29.0%
                                      AARP
                                      5.1%
                             Other
                             9.4%
                          Other
                          Federal Agencies
                          1.4%
* Other includes personnel from EPA HQ and EPA HQ contractors.

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                          Exhibit 6
         Chemical Safety Audit Workshops
   Number of Persons Trained by EPA Region
                     FY 89 through FY 91
70
60
50
40
30
20
10
 0
                      456
                        EPA Regions
8
10
* Totals include EPA Regional personnel, AARPS, TAT and other contractor
personnel, but do not include state and local officials, EPA HQ personnel,
EPA HQ contractors, and other Federal agency offcials who received training.

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3.0     ANALYSIS OF CSA PROFILE RESULTS

        This chapter highlights the major trends and issues from EPA's chemical safety audits, based on
report profiles developed from the 80 final CSA reports received by EPA headquarters as of August 31,
1991, as well as from conversations with EPA regional staff. 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.  An outline of the CSA protocol can be found in Appendix A The  following
eight major  elements of the CSA protocol are examined in this section of the report:

              Facility background information;

              Chemical hazards;

              Process information for hazardous chemicals;

              Chemical accident prevention;

              Accidental release/incident investigation;

              Facility emergency preparedness and planning;

              Community and facility emergency response planning; and

              Public alert and notification procedures.

        This chapter provides an overview of the principal trends identified in the conclusions and
recommendations relating to the eight CSA protocol elements listed above.  CSA report conclusions
highlight chemical process safety practices observed at  the facility; they reflect the audit team's perception
of the facility's understanding of and commitment  to chemical process safety management,  but are not
judgments of adequacy or inadequacy of the practices observed by the team.  CSA report recommendations
address options that the facility may consider implementing to enhance facility knowledge of and practices
in chemical  process safety management.  These recommendations are based solely on areas observed
during the audit and are not required or mandatory actions to be taken  by the facility.

        Each section of this chapter will be introduced by an overview of the key features of the
corresponding protocol element, explaining the purpose for its inclusion in the CSA protocol and its
relevance to chemical process safety management.  The introduction will be followed by a discussion of
unique and successful facility practices which support chemical process safety. The sections will conclude
with a discussion of trends in the concerns and recommendations  in the CSA reports, and provide
examples for these issues.

        3.1     Facility Background Information

        This section of the report addresses the recommendations and conclusions made in the chemical
safety audit  reports regarding general facility information.  This section of the protocol is concerned with
the facility site and surrounding area, and includes the  following:

              Comprehensive facility profile and history;

              Description of site topography and meteorological conditions;

              Transportation access;

                                                 17

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                                                 18

              Special and sensitive populations and environments in the surrounding area;

              Community demographics; and

              Identified vulnerable zones that provide information on the potential risks facility
               activities pose to the community.

        Many of the final audit reports contained conclusions involving facility background information.
The issues stressed in the conclusions fell into four general categories.  Many of the conclusions focused
on either old or outdated equipment and/or the  installation of safer equipment. Some of the conclusions
referred to the growth or decline of the facility in terms of size, staffing requirements, or productivity.
Other conclusions identified transportation concerns or topographical limitations which  present a potential
risk to the vicinity around the plant during operations.  The remainder of the conclusions focused on site
access.  Below are a couple of examples of successful practices for this element of the protocol:

              A chemical manufacturing facility replaced windows with explosion proof glass designed to
               drop out to minimize flying glass in the event of an explosion.

              A payload processing facility designed security measures based on DOD and ATF
               explosive siting criteria. The facility's perimeter access is  restricted by a chain link fence
               topped with barbed wire. Access through the main entrance gate is controlled 24 hours a
               day in order to regulate visitor traffic through conventional sign in procedures.  An
               additional badge exchange guard station limits access to the entire hazardous work area
               during potentially risky operations.

        Concerns about  facility background information tended to focus on hazards posed by the
geographical and meteorological conditions at the  facility's location and limited site access in emergency
situations.  A number of audited  facilities located in active seismic zones, or in areas where normal
meteorological conditions increase the risk of a chemical accident, lacked measures for reducing or
mitigating the threat posed by earthquakes, hurricanes, or volcanic activity.  In addition, several reports
referred to a lack of sufficient access and evacuation routes, limiting entrance to facilities by response
crews in case of an emergency and departure from facilities for employees and at-risk populations
attempting to evacuate the immediate area.  The following is an example of these concerns:

              Railroad tracks were frequently blocked at an agricultural products facility.  Since there is
               only one other vehicle access entry to the facility, it would be  difficult for responders to
               take action in the event of an emergency.  The audit team recommended that the facility
               insure that the railway entrance is kept clear.

        Recommendations within the chemical audit reports  relating to general background information
focused primarily on security issues and facility access. A few audit reports made recommendations based
on  facility background information. These recommendations focused on improving security measures by
improving or expanding  fencing along the perimeter of the facilities, having a third party conduct a security
evaluation of the plant, or modifying facility access procedures. For example, certain facilities needed
additional fencing, dikes, containments, and warning signs around hazardous areas such as sulfur pits or
ammonia storage tanks.  General site access and gate  control and guarded entry, as well  as visitor safety
were issues addressed in a number of other reports.

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                                                 19

        3.2      Chemical Hazards

        This section of the report addresses the conclusions and recommendations made in the chemical
safety audit  reports regarding chemical hazards, as well as how the facility identifies and understands the
risks posed by hazardous substances at the facility.  This section also examines the methods by which the
facility communicates these hazards to its employees in the form of training, available information, policy,
and safety procedures. There are two parts to this element of the protocol:

               Overview of Hazards for Chemical(s)  Being Audited -- covers the dangers  posed by
                hazardous chemicals that the audit team examined at the facility.  This part does not
                include detailed information, such as Material Data Safety Sheets (MSDSs), which may be
                included as attachments to the report, if necessary.

               Facility Management of Chemical Hazard Data  encompasses the facility's policies and
                practices regarding the hazards it perceives at the facility, the documentation of those
                hazards, the availability of that documentation, and mechanisms for updating the
                information and monitoring potential toxic effects on the work force.

        The facility's understanding of its chemical hazards can indicate the extent to which it examines its
processes for potential accidents, and is important to the facility's  emergency planning efforts.  The
management of chemical hazard data, such as MSDSs, also demonstrates the facility's commitment to
employee safety and training; a facility that ensures that its employees are trained in chemical hazards has
demonstrated a significant dedication to safety. Examples of facilities that have successful practices in
chemical hazard information include the following:

               A metal plating facility converts all MSDSs received from manufacturers into a standard
                format; this makes it much easier for  employees to understand.  They are updated
                annually or when new information is received.

               A pesticide plant maintains an thorough hazard review report for every chemical on the
                premises. Each report includes a description of the equipment used in the process,
                associated chemical hazards, a decision tree path,  moderate hazards, minor hazards,
                investigations and findings, equipment design parameters, instrument control, SOPs,
                possible malfunctions, and an electrical  check list.

               A circuit board producer requires all employees to pass an English exam to ensure that
                personnel can read and understand operation procedures and MSDSs.

               A semiconductor plant maintains a computerized  employee health tracking system that
                logs health surveillance, risk, environmental, accident, and injury data for analysis and
                statistical review.

        The most significant issues in chemical hazard recommendations are the facility's awareness of
hazards associated with chemicals used, stored, and produced at the facility; the availability of information
on those hazards - usually in the form of MSDSs  to all  plant employees; updating of existing MSDSs;
employee training about chemical hazards; and health  monitoring and medical surveillance  programs.
Several audit reports commented  on facility practices concerning chemical hazards.  The following are five
examples illustrative of the issues:

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                                                 20

              At a lighting equipment plant, although MSDSs exist in certain areas, employees who do
               not understand English are not able to read or comprehend the chemical information.
               Because most of the employees are Spanish-speaking, the MSDSs should be translated
               into Spanish.

              A tool manufacturing facility did not display chemical hazard information in risk areas.
               The plant should post required protective clothing requirements for handling hazardous
               chemicals at the  storage and handling locations.

              Personnel at a chemical storage facility were not aware  of the potential for fire conditions
               to create large quantities of toxic gas such as hydrogen  chloride which could affect workers
               and off-site personnel.

              An audit report from a wood preserving plant recommended that the facility reinstate its
               medical  surveillance program, including on-going health monitoring and urinalysis testing,
               in order to  expand the cross-section of workers in an industrial hygiene study and
               statistically  increase the validity of the results.

              At a chemical facility, the audit team noted that employees drank coffee, ate, and smoked
               in areas  where those activities presented a hazard  to operations.  The facility should
               establish eating, drinking, and smoking practices for process, maintenance, and control
               areas.

        3.3     Process  Information for Hazardous Chemicals

        The sixth element of the  CSA protocol is process information for hazardous chemicals, which
reviews operational and storage procedures within the facility.  There are three sub-elements:

              Storage  and Handling  which examines facility storage systems, shipping and  receiving,
               and material transfer involving hazardous substances;

              Process  Description  which evaluates the process steps, equipment, system backups, and
               monitoring  procedures; and

              Process  Hazards  - which determines significant process hazards at the  facility.

        Storage and Handling

        This section addresses facility storage, shipping  and receiving, and on-  site transfer involving
hazardous substances.  Examining storage and handling  procedures and  process operations can reveal a
facility's overall safety  practices and its comprehension of process hazards.  Chemical safety audits examine
storage and  handling practices in  order to identify facility awareness of potential hazards, as well as  to
recommend  alternative practices to those facilities which need storage and handling improvement.

        Storage Systems

        Examining storage systems is an essential part of reviewing facility operations.  Chemical safety
audits review storage methods to  assess  the safety and efficiency of storage procedures.  Capacity,  location,
identification, maintenance and housekeeping are examined to better understand routine storage
procedures and operations.  Many of the chemical safety audit reports noted exceptional storage
procedures at the audited facilities. The following are some examples of successful storage methods and
procedures:

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                                                 21

              At a lighting equipment manufacturing facility, all chemicals are segregated into two
               storage areas: the caustic/cyanide storage area and the acid storage area.  The two areas
               have wire screen walls, dikes, and are kept locked.

              At an alkalies and chlorine facility, cell line capacity contains provisions for cell downtime
               for anode replacement and normal maintenance.  Spare pumps and valves for all critical
               products and utilities are available. There are also back-up process and storage tanks on
               site to allow for maintenance.

              At an agricultural chemicals plant, surface runoff paths have been identified and holding
               ponds are in place to control surface runoff from a spill or fire incident.  One tank  farm is
               adjacent to an emergency runoff pit, to which all materials can be diverted in the event of
               an emergency.

              At a facility manufacturing agricultural chemicals, storage of methyl isocynate (MIC) is
               minimized to decrease the chances of a disastrous release. In addition, the above ground
               MIC storage tank is covered by a steel cable mat to prevent projectiles from damaging
               these tanks in the event of another nearby explosion.

              At a facility that manufactures bromide-based products, the reduction in size of bromine
               storage tanks has minimized the risk of a large release; the maximum quantity that could
               be released is lessened and consequently more easily contained.

              At an industrial organic chemicals  facility, toluenediamine is stored in an insulated,  steam
               heated tank under nitrogen to prevent moisture from contaminating the chemical.

              At a fertilizer manufacturing facility, ammonia storage tanks are covered with glass foam
               insulation to maintain the ammonia in liquid form.  Vapors are collected, liquified,  and
               recycled back into the storage tanks.

              At a chemical manufacturing facility, hydrogen cyanide storage capacity has been reduced
               from over 100,000 gallons to a present capacity of 60,000 gallons, divided equally among
               two storage tanks.  When this new system was constructed, the facility installed new
               piping, pumps, and  tank monitoring instrumentation.

              A bleach manufacturing facility has instituted a waste minimization program where
               products which do not meet specification are recycled back into the process.  This
               eliminates storage and disposal of  refuse material.

        EPA audit teams expressed  a variety of concerns regarding storage practices and procedures.
Many facilities should consider monitoring tanks for corrosion and maintenance needs on a scheduled
basis. Observations and corrective action should be recorded  in a log book.  Common concerns included
improper placement of storage area drains, storage tank exposure to the elements, and lack of pressure
valve release units in storage tanks.  Poor identification of hazardous materials, unrecorded quantities of
chemical ingredients and product yields, leaky storage tanks, and grouping of incompatible materials are
some other examples of improper chemical safety procedures.  Such operations unnecessarily contribute to
the risk of an accidental release. Many of these procedures can be easily corrected  to lessen this threat of
hazards.  Some of the more typical concerns are as  follows:

              At a petroleum products storage terminal and asphalt refinery, various combustible
               materials and ignition sources were found within the main tank farm. In addition, the
               storage tanks in the terminal and the refinery were constructed before the current NFPA

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                                  22

guidelines were established, so many of the tanks were spaced closer than these guidelines
recommended.  The audit team believes these factors increase the probability or severity
of a fire spreading throughout the tank farm. The facility should segregate combustible
materials and should reduce the number of containers stored in any one location within
the warehouse.

A sodium hydroxide tank was located near sulfuric acid tanks at  a facility that produces
electricity.  The tanks should be relocated because of the possibility of tank rupture which
could occur if the acid and the base are inadvertently mixed.

At a petroleum refining facility,  process flow lines, pipelines, and equipment are not
routinely labeled and numerous  pipe lines are not insulated.  Although some flow
directions are indicated, the  lack of uniformity could cause confusion during operations,
maintenance or an emergency.  These current housekeeping practices create safety hazards
and should be reevaluated. At the same petroleum facility, contents of the storage tanks
are not apparent by labeling. Process flow lines, storage tanks, and equipment should
receive permanent labeling.

At a facility that produces liquid chlorine and caustic soda, the sulfuric acid storage tank
is elevated and could cause an uncontrollable hazardous release should a rupture occur.
The facility should consider grounding the tank of sulfuric acid.

At a facility that specializes in the production of metal products, storage tanks were old,
corroded, deteriorated and are not coated.  The foundations and supports of the tanks are
deteriorated and the tank bottoms cannot be inspected.  The storage area for flammable
chemicals should be upgraded and moved to an approved  area of the plant.

At a polymer manufacturing facility, at least one operating area had small quantities of
flammables, acids, and caustic stored next to each other on the floor.  Incompatible
materials such as these should be separated by greater distances.

At a facility that produces cyclic organic crudes and intermediates, and organic dyes and
pigments, ground cables were not used to guard against static buildup and lightning rods
are not present to dissipate lightning strikes.  Ground cables and lighting rods should be
placed on and near all of its storage tanks to prevent a release due to lightning.

At a facility which produces monochloroiodine, chlorine cylinders contained chemicals
other than chlorine and had no feature to prevent them from falling over.  Since the caps
of these cylinders are  removed, the cylinders should be chained or otherwise prevented
from tipping.

At a facility that produces intermediates for Pharmaceuticals, dyestuff,  and pesticides, large
numbers of one-ton phosgene and chlorine gas storage cylinders  are stored  in  an open
storage area and are manually handled with hoists and transport equipment.  These
cylinders should be stored in a dry area away from excess heat or danger of fire and
protected from accumulation of snow and ice.

At a jewelry manufacturing facility, there was no capability for detecting wind  direction
near ammonia storage tanks. The facility should install wind socks in order to detect wind
patterns.

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                                                 23

              At a facility that produces surfactant polyol, warehouse personnel were not fully aware of
               what chemicals were in storage, or the location of these materials in the warehouse. A
               diagram of warehoused materials was not maintained for identifying even the location and
               quantity of any hazardous and/or extremely hazardous substances. A diagram should be
               developed and maintained showing the location of any hazardous or extremely hazardous
               substances and their amounts.

        Shipping and Receiving

        Methods of loading and unloading materials indicate a level of facility responsibility for handling
process hazards. This sub-section addresses shipping and receiving procedures for hazardous substances
examined during the audit, including methods of transportation, responsible personnel, and training
programs.  Schedules and  quantities of shipments are noted but depend on site-specific information such
as the capacity of storage units, the size of the facility, and the quantities of chemicals needed for
processing.  Most shipping and receiving is handled by truck, rail, and sometimes barge. Hazardous
materials are usually loaded into railroad tank cars by facility employees and into tanker trucks by truck
drivers.  Hazardous liquids and gases are often transported to and from the facility by pipeline.  The
following examples of notable success in shipping and receiving practices were mentioned in the audit
reports:

              At a facility producing chemicals for use in paper products manufacturing,  formal transfer
               procedures are followed in the transfer of all liquid chemicals entering the  facility.  The
               material is verified by shipping papers.  The proper valve hook up is checked and the
               receiving  tank is checked for sufficient volume. The connecting valve is unlocked by a
               supervisor and the transfer is documented.

              At an agricultural products storage facility, a written standard operating procedure for
               shipping and receiving covers accurate inventory, receiver accountability, and
               responsibilities during the unloading process.

              At a facility manufacturing bromide-based products, facility shipping stations are  equipped
               with scrubbers to control bromine vapor from escaping into the atmosphere.

        Concerns about a number of different shipping and receiving practices were addressed in  the audit
reports.  Location in proximity to sensitive areas, security, recording schedules, quantities of shipments,
designated  responsibility, and storage in receiving areas were  all areas of concern. Many of the facilities
need to improve their control of shipping  and  receiving to prevent releases during material transfer
operations.  Shipping and receiving are  not always supervised by  trained and experienced personnel and
loading and unloading areas are  not provided with appropriate hazard information.  Some of the more
specific areas of concern are as follows:

              At a facility that produces industrial organic chemicals, the hazardous materials rail  car
               unloading area is in close proximity to a river and the rail cars are not always secured
               prior to a materials transfer operation.  A diked pad with a collection sump should be
               installed to minimize the impact  from a catastrophic rail car failure or release during bulk
               unloading operations.  Wheel  chocks must be used to prevent movement of hazardous
               materials  rail cars during unloading operations.

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               At a copper and sulfuric acid production facility, nighttime operations are potentially
                hazardous because of poor visibility, access, and communications. Loading of sulfuric acid
                into tanker trucks is accomplished by the truck drivers, who may or may not have had
                specialized training in the handling of the chemical. Acid loading should be limited to
                daylight hours and an  operator should be required to supervise loading procedures.

               At a facility that produces circuit boards, sections of the shipping and receiving area are
                used for storage of empty drums, waste, and containers of chemicals waiting for off-site
                recycling.  There is no inventory or management system for this area; some drums were
                mislabeled and drums of different classifications were mixed together. These drums
                should be clearly dated and labeled, and should be shipped off-site for treatment, storage,
                or disposal within 90 days.

               At an electric utility, the  only way for anyone to know when unloading is completed is to
                listen for the sound of air venting from the relief valves on the truck tank.  An audible
                alarm system should be installed to alert personnel when tanker unloading is completed.

               At a sanitary services facility, both cyanide and acid solutions are present in the truck bay,
                and hoses used  to unload these materials from the trucks into storage tanks are
                interchanged. It was recommended that specific hoses be dedicated for each activity.

        Material Transfer

        Methods and procedures for transferring hazardous materials throughout a facility can significantly
influence its safety practices and its potential for chemical accidents. The chemical safety audit evaluated
on-site material transfers by determining the status of pipes, valves, pumps, valves, color-coding and
labeling. Methods of transferring materials  from storage areas to different stages of chemical processing
were reviewed.  Initial transfer occurs as hazardous materials are moved from  receiving stations to storage
and process areas.  Cylinders and drums of dry hazardous materials are often transferred by forklift or
dolly. Hazardous  liquids and gases are often pumped from trucks and rail cars by hoses that lead to the
storage  systems. A few of the more notable findings are:

               At a plastics facility, buildings in which phosgene or chlorine  are used are under negative
                pressure.  Air from these buildings and nitrogen used in the  piping system are passed
                through scrubbers. Chlorine pipes are painted green, and phosgene pipes are painted red
                for identification.  In high hazard areas at the facility, pipes are double-piped, space
                between pipe walls is swept with nitrogen, and the nitrogen is analyzed for contaminants.

               A chemical manufacturer has replaced jacketed pipes with stainless steel pipes containing
                heat traces to improve leak detection, and uses easily identifiable markings and placards
                on buildings, tanks, and pipes.

               At a petroleum refinery, all critical pumps have steam-driven  backup pumps available for
                use if the primary pump goes down or the electricity fails.

        The condition of equipment, coding and  material of pipes, and housing of transfer system affect
the safety of material transfer  operations.  Many facilities should  review routing, supports, materials, and
connections to tanks and equipment.  In addition, deficiencies in  coding and identification of hazardous
materials pipes, tanks, and vessels were identified at many of the  audited facilities.  Some of the specific
concerns were as follows:

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              A petroleum products facility has a checklist, but no formal written procedures to be used
               during transfer operations.  The facility should also document transfer operations.

              At a petroleum products facility, piping systems within the process units and between
               storage areas are not protected from potential damage by trucks, especially the crude oil
               pipelines which run along major refinery thoroughfares.  The facility should install a rail
               guard or florescent tape to protect piping near the vehicle loading and unloading area.

              At a facility that produces bleach, piping was made out of mild steel schedule 40, which
               may be corroded by chlorine byproducts.  This  facility should assess the compatibility of
               construction materials and process conditions.

              The unloading nozzles for the sulfuric acid tank is identical to that of sodium hydroxide at
               a facility that manufactures  printed circuit boards. The proximity is a major hazard
               because the chemicals could be unloaded  into the wrong tanks.  The piping and the filter
               at the storage tank is inadequately supported and fastened.  The ground level location of
               the piping and wiring is a hazard because personnel could trip.  Measures should be taken
               to prevent tripping over wire and unloading into incorrect tanks.

              A facility that produces chlorine and caustic  soda provides a site plan and paints some
               tanks and piping yellow. The facility should  consider developing a documented color-code
               system for all  piping carrying  hazardous materials. This would be very helpful to local
               emergency personnel responding to an incident at the facility.

        Process Description

        A key element in understanding the causes of past and  possible future chemical releases is an
investigation of facility process steps and procedures.  Without a critical investigation  of the chemical
processes and the mechanisms for controlling these processes, it is impossible to effectively identify the
source of potential  chemical releases. Chemical safety audits examine several aspects of facility chemical
processes, including:

              Process steps which could be improved to decrease the chance of a release;

              Process equipment which may be substandard or which could be upgraded to improve
               efficiency and reduce the likelihood of system failure;

              Systems with or in need of backups or automatic shutdowns;

              Methods of monitoring process parameters; and

              Devices for environmental monitoring.

        Overview of Processing Steps and Operating Procedures

        An examination of the basic process steps and operating procedures can reveal critical procedures
and parameters, deviations from which could lead to unwanted releases. This sub-section of the audit
addresses processing steps and operating procedures for the hazardous substances examined during the
audit.  A common problem among facilities seemed to be the availability of up-to-date process and
instrumentation diagrams.  It was recommended that these facilities update and distribute these diagrams
to assist training, maintenance, and safety efforts. Other recommendations focused on process
modifications and standardization of equipment.  The following are illustrative recommendations:

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              At a payload processing facility, changes in recent years in payload processing operations,
               prompted the audit team to recommend that the facility consider evaluating the feasibility
               and safety of modifying the sequence of processing operations dealing with this process to
               minimize the possibility of releases.

              The audit team suggested that a refinery should update process schematics and diagrams
               and convert them to computer drawing files, because the diagrams were last reviewed in
               1951 and did not indicate the extensive modifications that have been made in the
               intervening years.

              At an ammonia manufacturing facility, the audit team suggested that the pill tower should
               be replaced with another process that emits less paniculate and vapor, or they should
               install appropriate emission control devices.

        Process Equipment

        Process equipment is another important aspect of chemical processes which should be examined.
In the audit program, this area covers capacity and design  conditions, flow rates, construction material, and
chemical use rates.  In the audit reports, most comments were simply proposals for replacing equipment,
like valves and flanges, in order to make the process  more resistant to upset.  Some specific concerns and
recommendations were:

              At a plating facility, an audit team suggested that the facility should study the possibility
               of eliminating all but the most vital flange systems in the hydrogen  cyanide process and
               replacing the jointed flanges with welded seams.

              At a food manufacturing facility, an audit team suggested that, to prevent corrosive
               failure,  threaded drain couplings in the sulfuric acid storage tank should be replaced  with
               flanged connections, because they are less susceptible to corrosion.

              In light of  an aluminum release  incident, the audit team suggested that a sulfuric acid
               producer should continue their replacement of vinyl-shelled pools with steel tanks.

        Some recent audits, however, seem to be focusing on process rate modifications. Even the best
equipment  is prone to upset when operated at rates beyond design specifications.  Although this may be
obvious, many processes are modified over time, making it difficult to determine original designed flow
rates. One specific recommendation appears below:

              The audit team suggested that an ammonia production facility should review historical
               records to  see if a correlation between process throughput and frequency or magnitude of
               ammonia releases exists.  If a correlation exist, they should either reduce throughput  to
               the point that no statistically significant increase in frequency or magnitude of accidental
               ammonia releases is anticipated, or comprehensively re-evaluate the process design for
               compatibility with the  desired rate, and modify or replace unit processes as required.  If
               the correlation cannot be identified, they should reduce throughput to design levels.

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       Backups and Redundancies

       An indication of a facility's ability to handle process upsets and system shocks is the existence of
system backups and redundancies.  Backups, automatic shutdowns, and the ability to detect and
compensate for disabled control equipment are important methods for preventing accidental releases.  The
audits contained many examples of facilities with effective backups and redundant equipment.  Especially
in recent audits, comments focussed on positive aspects of facility backups. The following are some
examples:

               At a chemical facility, standby equipment is rotated once a week, ensuring that the backup
                equipment is well  maintained and ready for emergency use.

               At a chemical manufacturer, computer controlled processes are easily changed to manual
                operation for emergency shutdown. Also at this facility, reactors that have critical
                isotherms can be quenched by redundant techniques. Such techniques include gravity-fed  .
                water baths  to cool the reactor  in the event of a temperature excursion, or nitrogen purge
                systems used to provide backup reactor agitation in the event  of a mixer failure.

               A plastics facility has a computer-operated console with three sections and a backup
                station for each section.  If the  primary console fails, the operator can immediately switch
                to a back-up station and maintain control of the process.

               At a petroleum refinery, all instrumentation in the alkylation unit is in duplicate,
                including hydrogen fluoride (HF) level indicators and wiring.  Instruments are backed up
                with batteries with a half hour power supply.  During a power outage, shutdown is
                automatic, and HF can be moved back to the holding tanks.

       The presence of backups is unimportant, however, if the backup equipment is not well maintained
or if it does not address critical equipment. At most facilities, some backup features existed; however,
many times these backups did not address critical process equipment. Another common problem at
facilities was the lack of adequate backup for electric and other utilities.  In the event of a power failure,
many facilities had no means of maintaining process operation or even adequate lighting.  The following
are some of the specific observations:

               At a chemical manufacturing facility, there was no backup for a chemical detection unit,
                and the audit team recommended that the facility use several chemical-specific portable
                personnel monitors as backups.  These units would also provide redundance for the
                automatic monitoring system.

               At a facility that burns liquid hazardous waste, the audit team noted there was no
                automatic backup  to the process temperature control system.  A significant decrease in the
                temperature would create incomplete destruction of the wastes and thus releasing toxic
                vapors directly to the environment via stacks.

       Process Parameter Monitoring

        Many chemical processes must maintain very stringent parameters in order to function safely and
efficiently.  For this reason, chemical safety audits look at the  methods of parameter monitoring as a
means of early detection of accidental releases or process upsets which could result in a release.  In
general, there were only a few facilities with well-integrated  parameter monitoring systems with  audio and
visual alarms  Among those  facilities with formal monitoring procedures, the following are examples of
exceptional practices:

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               All operating units at a chemical facility have centralized control rooms where critical
               process parameters are monitored and recorded continuously.  Critical systems are
               connected to audio-visual alarms which are activated when parameters exceed safe levels.
               There are periodic inspections and preventive maintenance to minimize breakdowns.

               At a metal manufacturer, flow monitoring of certain waste streams has  been instituted
               using a data acquisition network.  The system tracks flows in the sewer  and monitors the
               balance between the influent and the effluent.  The monitoring unit samples materials  that
               are transferred to the sewers on a sporadic basis.

               At another chemical  manufacturer, each main plant section has its own central control
               room, using both digital and analog instrumentation.  All  significant process parameters
               are monitored in the control rooms, and alarms are provided for critical process functions
               and equipment.

        Recommendations in the area of process parameter monitoring addressed many issues. Among
these were a number of recommendations to improve temperature and pressure monitoring as an easy and
effective way to improve early detection of system malfunctions  or releases. Also, many reports addressed
improvements in control room instrumentation, modernization of monitoring equipment, and increased
number of parameters monitored. Among these recommendations were the following:

               At a chlorine production facility, the audit team went as far as saying that the process
               monitoring and control systems should be completely overhauled.  More automation and
               continuous monitoring should be emphasized, especially in the high hazard areas such  as
               chlorine handling. One control room with centralized digital displays and remote
               corrective action would be ideal.

               At an ammonia production facility, an audit team found that although the  facility has a
               number of alarms and safety shutoffs, it has no routine monitoring capability for  the
               presence of hazardous chemicals.  The facility should  consider such monitoring
               particularly for hydrogen sulfide, and for ammonia at  one  or two points in  the ammonia
               unloading and handling area.

               At a chemical facility, the audit team suggested that additional temperature probes and
               recorders should be installed in the reactors in  order to develop temperature profiles for
               enhanced control and to serve as a backup in the event of a malfunction in the primary
               temperature sensor.

               For its own information, the audit team suggested that a hazardous waste burner should
               install  continuous recorder devices on all meters that  show temperature or pH of the
               waste.

        In several recent audits, corrosion monitoring practices  appeared to be of concern in both tanks
and piping. Corrosion  is a problem which is often not easy to detect until a release is imminent.  Also,
there appears to be an  increased  focus on the need for level alarms. Level alarms are a primary means of
early warning of a potential release. These level alarms should  be both audible and visible  to ensure
acknowledgement of a situation.  Specific examples appear below:

               At a chlorine manufacturer, the audit team suggested  that an adequate corrosion
               monitoring program should be adopted.  Electronic instrumentation for measuring piping
               and vessel wall thickness and integrity should be utilized.

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              The audit team suggested that an electronics firm should install high level alarms on the
               sodium hydroxide tanks to ensure that the tanks do not overflow while being refilled.

        Environmental Monitoring

        The importance of effective environmental monitors cannot be overemphasized. In the event of a
release, these monitors can provide information on the area and severity of the release leading to its
effective mitigation.  This sub-section of the report includes discussion of the types of equipment used to
conduct the monitoring and its placement in process and storage areas or on the facility perimeter. Over
half of the audit reports contained numerous recommendations and comments relating to the improvement
or installation of environmental monitoring equipment indicating the importance of this issue. The most
prevalent recommendations among the audit reports was the installation of equipment for monitoring
levels of hazardous substances, for monitoring worker environment, and for monitoring perimeter chemical
concentrations. A common issue in recent audits is the recommendation for meteorological monitoring.
Especially during an air release, knowledge of wind and weather patterns can be critical in determining the
spread of a release.  Despite the need for improvement in most facilities, the following are examples of
successful environmental monitoring programs:

              A chemical manufacturer uses the Systematic Approach for Emergency Response
               (SAFER) system for environmental monitoring.  Sensors transmit exposure information
               on chlorine to the SAFER system. An additional warning system is sounded at the main
               gate when  the concentration at the sensor reaches a certain level.

              A plastics manufacturer has both perimeter air monitoring stations and ground water well
               monitoring stations.

              At an electronics manufacturer, an on-site environmental analytical laboratory was
               established to conduct analysis relating to water arid wastewater, hazardous and non-
               hazardous  waste, waste minimization, environmental contaminants, and pollution
               abatement materials for all their facilities. During an emergency, the lab can conduct
               contaminant and concentration level analysis.  On-site equipment includes mercury vapor
               detectors, CO analyzers, halide detectors, oxygen  meters, aerosol dust monitors, and a
               variety of other monitoring and detecting devices.

        Process Hazards

        Once the entire process at a facility has been examined, the overall system can be evaluated to
identify processes or areas which present the most significant hazards.  This determination can be helpful
to a facility in focusing resources to  eliminate these hazards first.  Audit team concerns related to this
subject were referenced in the conclusion section of the report, and were specific to individual facilities.

        3.4    Chemical Accident Prevention

        The seventh element of the  CSA protocol is chemical accident prevention, a description of the
facility mechanisms for implementing and maintaining safe process systems.  There are five sub-elements
within chemical accident prevention:

              Management Activities -- health and safety initiatives  and internal auditing practices
               developed  by facility and corporate management;

              Process Operation and Maintenance - facility standard operating procedures, employee
               training practices, and equipment and instrument maintenance policy;

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              Hazard Evaluation and Modeling - facility hazard evaluation techniques and all-media
               accidental release modeling;

              Release Prevention Systems -- facility activities and systems designed to prevent the
               occurrence of or reduce the severity of an accidental chemical release; and

              Mitigation Systems - facility systems designed to mitigate the health and safety risk posed
               by an accidental chemical release.

        Management Activities

        Corporate and facility management play an integral role in ensuring a coherent and consistent
approach to chemical safety and health issues at a facility. Without a firm management commitment to
chemical process safety, even the best training programs and operating procedures become outdated, and
facility safety can gradually deteriorate. Chemical safety audits examine and evaluate the commitment of
management to chemical process safety through the existence and  contents of policy and goals statements,
general operating guidelines,  and safety manuals; the availability of corporate financial and technical
support on facility health and safety issues; and the development of an internal audit program to evaluate
individual facilities or operating units.

        Corporate Role

        By setting an example in its commitment to chemical process safety, corporate management will
provide the basis for the development of greater safety consciousness at individual facilities. Several
chemical safety audit reports  commented on corporate management practices that support the goal  of
improving facility chemical process safety.  The following is an example:

              Corporate management for a chemical warehouse has been active in the Mid-West
               Agricultural  Chemicals Association's (MACA) efforts to develop standards for storage
               structures, to minimize potential public exposures, to evaluate mitigation systems, and to
               examine health and safety issues.  They  have also  established a peer review program in
               which managers evaluate each other's facilities, training, and preparedness programs.

              Management at the corporate and facility level at an agricultural chemicals facility have
               established plant safety committees, standards review boards and personnel, hazard
               evaluation decision tree scenarios, training courses, corporate audits, incident investigation
               teams, and accountability criteria  for managers.

              Corporate policy for an oil refinery provides reimbursement to employees for training
               expenses up  to 90% for job-oriented courses and  100% for job-mandated courses.

              The corporate laboratory at a photographic equipment manufacturer performs chemical
               compatibility studies, design studies for  new chemicals and equipment, laboratory testing
               of exposure to new chemical compounds, and develops chemical handling and safety
               procedures as well as basic physical property data.

        There were several concerns raised by the chemical safety  audit teams with respect to corporate
management practices.  These concerns focused primarily on the commitment of corporate management to
an overall safety policy, in light of the provision of financial and personnel resources to individual facilities
for safety programs and the development of standard corporate health and safety policies.  The following is
an example of these concerns and recommendations:

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              A fertilizer manufacturing facility had no standard safety policy.  The audit team
               recommended that a corporate safety doctrine be developed that includes safety
               procedures covering all employees and all aspects of the workplace.

        Facility Role

        Facility management must establish its commitment to chemical process safety in order to create a
safe and healthy workplace. Many chemical safety audit reports commented on facility management
practices that support the goal of improving facility chemical process safety. A number of the audited
facilities had adopted the Dupont Safety Training Observation Program (STOP), under which unsafe
procedures observed by fellow employees are brought to the employee's attention for discussion and
modification. The following are some other notable examples:

              A chlorine manufacturer has an unsafe condition report procedure to allow employees to
               identify potential problem areas. Management response to the report is required within a
               specified time frame, and reports and follow-up actions are tracked on a computer.

              Employees at an oil refinery 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 and is a source of pride for plant employees.

              Managers at a pesticide  packaging facility develop an annual safety, health, and
               environmental plan to outline activities for the following year, such as conducting
               HAZOP reviews for various process units, investigating wastewater treatment options,
               investigating better  release prevention systems for unloading stations; and  conducting a
               review of fire protection for the warehouse production room.

              A photographic equipment manufacturer is working toward certification under the
               International Standards for Organization 9000 quality management system endorsed by the
               European Community. The standard is basically a common sense document setting down
               the minimum requirements for a quality assurance system that demonstrates to customers
               that a business is committed to quality.  Internal audits are conducted to evaluate
               compliance with the standard.

        There were a variety of concerns raised by the chemical safety audit teams with respect to facility
management practices.  These concerns primarily focused on the responsibilities of health,  safety, and
environmental management personnel; the development of facility health and safety policies; the regularity
and attendance at scheduled safety meetings; safety incentive programs for employees; and  the membership
of facility safety committees. In addition, a number of audit reports addressed security measures to restrict
access to hazardous substance process and storage areas.  Several illustrative concerns and
recommendations made were:

              At a fertilizer manufacturer, the safety director also serves  as the traffic manager and the
               security manager, and as a result devotes less than half of his time to safety issues.  The
               audit team recommended that the facility should consider hiring a full-time health and
               safety manager.

              The safety and environmental departments at a pesticide manufacturer share certain
               duties. The audit team recommended that there should be more formal communication
               and cooperation between the departments to meet their common responsibilities.

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              An oil refinery conducts safety meetings for its management employees.  The audit team
               recommended that the facility should involve operations and shift employees more directly
               in the facility's safety meetings, even if on a rotating basis.

              The new ownership at an electronics manufacturing facility did not maintain the pre-
               existing system of internal audits, safety goals and objectives, safety meetings, and formal
               training and maintenance recordkeeping. The audit team recommended that these
               elements of the former safety program be reinstituted.

        Audit Activities

        A regular schedule of audits will not only improve specific process unit conditions, but will also
support a consistent approach to health and safety issues throughout the facility.  Several chemical safety
audit reports commented on auditing practices that support  the goal of improving facility chemical process
safety.  The following are some examples:

              A chemical manufacturer conducts a comprehensive audit of its facilities every 18 months
               that generates a list of action items to be addressed by facility management.

              At a carbon black manufacturer, a plant safety team, consisting of two management and
               three hourly employees, conduct monthly internal audits. Important results are then
               discussed at monthly safety meetings, attended by all employees.

              A plastics manufacturer developed an annual internal auditing program to assess
               industrial and chemical process safety, industrial hygiene, environmental protection, and
               other issues.  The program also includes a planning and  tracking system for evaluating the
               facility's achievement of health and safety goals.

        There were a few concerns raised by the chemical safety audit teams with respect to internal audit
activities. These concerns focused on the lack of a comprehensive, regular internal auditing program to
evaluate the effectiveness of training, maintenance, and other health and  safety programs.  Specifically, the
audit team commented on the lack of a regular audit schedule, insufficient coverage of all units handling
hazardous substances, and the absence of formal facility procedures for implementing audit
recommendations.   The following is an  example of these concerns:

              An oil refinery has no formal procedures for follow-up on internal audit findings and
               recommendations by management; thus, internal  audit results may not be followed up on
               and implementation of any recommendations may never  occur. The audit team
               recommended that the refinery should establish a tracking system to ensure that action is
               taken on audit findings and recommendations.

        Process Operation  and Maintenance

        Standard Operating Procedures

        The existence of standard procedures for normal and emergency  operations provides a basis for
coherent, safe  facility operations by supporting safety in day-to-day activities as well as operator training
programs.  Standard operating procedures (SOPs) provide an outline for  routine and emergency
operations, as  well as process start-ups and  shutdowns, and should be immediately available in the
appropriate process areas.  A chemical safety audit examines the breadth  of operations covered by SOPs,
the regularity with which SOPs are reviewed and revised, and access to and familiarity with SOPs by
operators and  supervisors.

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        Several chemical safety audit reports commented on standard operating procedure policies that
support the goal of improving facility chemical process safety.  The following are some examples:

              Before filling operations begin each day at a chlorine manufacturing facility, every
               connector, valve, and flange is checked for chlorine leaks with aqueous ammonia.

              A lighting equipment manufacturer has developed concise task instruction lists written to
               fit the non-technical educational background of the general production staff.

              An agricultural chemical manufacturer has prepared extensive documentation on
               operating procedures, including detailed plant startup and shutdown procedures, operating
               procedures, and technical operating profiles to assist the technical staff in daily operation.
               The facility has a complete set of engineering  documentation consisting of detailed
               mechanical, process, and instrumentation drawings,  specific equipment, and general
               equipment specifications. In addition, there are operator training manuals ~ covering all
               plant operation and integrating job definitions, roles, emergency response instructions, and
               training information -- which are used as operator's reference manuals.

              A pesticide packaging facility has comprehensive and detailed job analysis guides for all
               raw material unloading, process operations, and storage and shipping operations, in the
               respective process areas. The guides, which include lists of required safety gear and
               cautions for the specific tasks, are used for training purposes and are routinely evaluated.

        There were a variety of concerns raised by the chemical safety audit teams with respect to standard
operating procedures.  These concerns focused primarily on ensuring the availability of SOP manuals in
each process area, using checklists, process records, and operating logs to track daily activities, and
coordinating SOPs with training, hazard evaluation, and emergency planning programs. In addition,
several audit reports indicated that current SOPs do not necessarily  reflect recent plant modifications or
are not  located in appropriate areas of the plant.  The following is an illustrative example of these
concerns and recommendations:

              A chemical facility had no log books, SOPs, emergency notification  and fire procedures,
               safety manuals, or other information. The audit team recommended that the facility
               should use log books to support communication between supervisors and operators.

        Training Practices
                             j
        Training of supervisory and operations personnel provides the most immediate opportunity to
increase awareness of chemical health and safety issues, as well as  working to ensure the competence of
employees in performing their responsibilities. Although training can be conducted  in a classroom or on-
the-job  setting, a  training program is most effective when it involves learning evaluation (tests) as well as
regular  refresher training. Chemical safety audits  review the type and content of employee training
programs, the existence of refresher training, and provisions for evaluating the effectiveness of the training.
Several  chemical safety audit reports commented on training practices that support the goal of improving
facility chemical process safety. The following are some examples:

              A chemical manufacturer has instituted a comprehensive training program for
               maintenance employees requiring a passing grade on a written test and four practical tests
               before a  new employee is admitted to the department.  Advancement depends upon
               results from further tests.

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              An oil refinery employs a contractor safety coordinator to oversee contractor personnel
               training by reviewing scheduled training programs and testing contractor employee
               knowledge.  In addition, managers are given extensive training in hazard evaluation and
               accident prevention.

              A pesticide packaging facility conducts cross-training of plant personnel on all process
               activities to produce a more comprehensive understanding among employees of all specific
               process tasks.

              Employees at a semiconductor facility are required to complete 40 hours of "relevant job
               training and education"  each year according to corporate policy.  Managers are responsible
               for setting employee training requirements, and the training and human resource
               department provides support in setting up and evaluating training courses. Worker safety
               and hazardous materials waste handling are among the courses offered. Training is
               tracked on computer and can be accessed by employee name, course number, or
               department.

        There were a variety of concerns raised by the chemical safety audit teams with respect to training
practices. These concerns primarily focused on specific areas that employee safety training should
encompass and the type of training that  should be made available to specific groups of employees, as well
as the coordination of training with other health  and safety programs.  Specifically, the audit reports
recommended that safety training for facility contractor, management, and maintenance employees should
be expanded.  Several audit teams also suggested the use of simulation exercises as a regular part of the
facility training program, the institution  of a formal knowledge testing program, and the creation of safety
awareness programs for facility visitors such as tour groups, equipment vendors, and delivery personnel.
Two specific concerns and recommendations were:

              There is no formal classroom training, only on-the-job training, at a plastics facility.  The
               audit team recommended that a  formal classroom training program should be established
               to educate operators about hazardous materials, process design, and safety systems.

              A bleach manufacturer did not control  or track contractor training.  The audit team
               recommended that the facility should oversee contractor training  to increase contractor
               familiarity with safety procedures and to improve the capacity of contract employees to
               respond in an emergency situation.

        Equipment Maintenance

        Maintenance of chemical process equipment falls into two categories:  predictive or preventive
maintenance, which is performed to avoid equipment failure or breakdown, and emergency maintenance,
which is performed in response to equipment failure. While the latter is an essential element of any
facility maintenance program, systems of predictive or preventive maintenance are essential to effective
chemical process safety. Key maintenance issues  in a chemical safety audit are the written and informal
maintenance procedures at a facility, such as testing and inspection practices, equipment history records,
and maintenance scheduling systems. Several chemical safety audit reports commented on equipment
maintenance programs  that support the goal of improving facility chemical process safety.  The following
are some examples:

              The predictive maintenance program at a metal refinery includes  ultrasonic thickness
               testing, vibration analysis, and infrared video imaging to identify deteriorating equipment.

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               A chemical manufacturer inspects all safety valves and rupture discs on a rotating basis
               each month, and has created a computer database to track maintenance records and
               identify continuing trouble spots.

               Another chemical manufacturer uses a computer software to track and monitor preventive
               maintenance, generate work schedules, track equipment history, issue work orders,
               maintain spare parts control, and do cost reporting.

               Maintenance staff at a third chemical manufacturer are involved in a program to
               continually test new materials and products that will help to increase the operating life
               and safety of equipment at the facility.

               An oil refinery uses a conventional work-order system for maintenance tasks,
               discriminating between normal, emergency, and preventive tasks.  A system is  in place
               establishing preventive maintenance cycles, and subsequent planning and scheduling of
               that maintenance work.  Check lists and  maintenance records and histories are kept on
               equipment and check sheets are used for common, repetitive maintenance work.

        There were a variety of concerns raised by the chemical safety audit teams with respect to
equipment maintenance. These concerns primarily addressed facilities without formal maintenance
procedures or informal "as-needed/ breakdown" maintenance procedures.  Many recommendations focused
on conducting regular equipment inspections and instituting formal preventive maintenance programs.  In
addition, a number of audit teams suggested that the facility should institute a more formal maintenance
record system and examine historical maintenance records to identify problematic equipment.  A few of
the more specific concerns and recommendations were:

               The maintenance policy at a  chemical manufacturer was to  repair equipment when it fails.
               The audit  team recommended that the program should be upgraded to include routine
               replacement of critical parts based on the history of failure, rather than on observation of
               actual failure.

               Another chemical manufacturer did not consistently follow lock-out and tag-out
               procedures for out-of-service equipment. The audit team recommended that the  lock-out
               and tag-out programs need to be formalized so that non-functional equipment is  properly
               marked.

               While a third chemical manufacturer was installing a computerized maintenance
               management system to replace a system of  handwritten records, the audit team
               recommended that the facility should review the preventive maintenance schedule and the
               history of  unscheduled maintenance for each unit process and modify the preventive
               maintenance schedule accordingly.

        Instrument Maintenance

        As with equipment maintenance, maintenance of instruments can be separated into two categories
- predictive/preventive and emergency maintenance; once again, programs of predictive or preventive
maintenance are key ingredients to a comprehensive chemical process safety management system.
Similarly, key instrument maintenance issues in a chemical safety audit are the written and informal
maintenance procedures at a facility, such as testing and inspection practices, instrument history records,
and maintenance scheduling systems.  A few of the chemical safety audit reports commented on instrument
maintenance programs that support the goal of improving facility chemical process safety. For example:

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               A chemical manufacturer has its own instrument maintenance technicians, who are trained
               at classes conducted by the instrument manufacturers and vendors.

        There were a few concerns raised by the chemical safety audit teams with respect to instrument
maintenance.  These concerns focused on the absence of regular preventive maintenance for instruments.
In addition, some audit teams suggested that the facility should institute a more formal instrument
maintenance record system and examine historical maintenance records to identify problematic
instrumentation.  The following is an example of these concerns:

               An audit team concluded that the preventive maintenance for instruments at an oil
               refinery is less effective due to a complex work order system, a possible shortage of
               instrument technicians, the scheduling of instrument system inspections every three years,
               and the numerous additional responsibilities of the instrument reliability engineer. The
               audit team recommended that the instrument  maintenance program be redesigned.

        Hazard Evaluation and Modeling

        The development of a facility hazard evaluation and modeling program, particularly in conjunction
with community planning efforts, supports both  emergency preparedness and accident prevention
initiatives. Hazard evaluation and modeling can direct attention to the areas in most need of improvement
by providing a thorough analysis of the potential causes and consequences of accidents at the facility. A
chemical safety audit examines whether a formal hazard evaluation and modeling program is in place, who
participates in the process, and how the results are utilized by the facility to improve safety. Several
chemical safety audit reports commented on hazard evaluation and modeling programs that support the
goal of improving a facility's chemical process safety.  The following are some examples:

               An oil refinery has organized a  team of personnel, including personnel from the
               engineering, operations, maintenance, and safety departments as well as management, to
               evaluate hazards, discuss safety  issues, and consider changes to the facility's design,
               construction, and standard operating procedures.

               A chemical manufacturer routinely performs HAZOP studies to evaluate process safety
               hazards for capital additions and process modifications, as well as on a scheduled basis
               and after accidents or near-misses. They also  use the CHARM software package for
               dispersion modeling -- occasionally for real-time  response data, but more often to run
               worst-case release scenarios for emergency planning purposes.

               Another chemical manufacturer has participated  in a voluntary initiative with twelve
               nearby facilities to perform dispersion modeling analysis of ground-level concentrations
               from emissions, considering each facility individually and then cumulatively.

               Hazards at an oil refinery have  been evaluated in three separate studies; several types of
               air models were used to estimate contaminant plume characteristics as part of these
               hazard studies.  Gaussian models were applied for normal operating conditions.  Two
               dispersion models, the "Hazardous Atmospheric Release Model" and the  "Industrial
               Source Complex" model were used to predict surface concentrations during upset
               conditions.

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        Hazard Evaluation

        There were several concerns raised by the chemical safety audit teams with respect to hazard
evaluation practices. These concerns primarily focused on the development and regular updating of hazard
evaluations for specific process areas. Several of the audit teams were also concerned about the lack of
facility experience in conducting hazard evaluations.  A few of the more specific concerns and
recommendations were:

              Employees at a fertilizer manufacturer do not have any understanding of hazard analysis
               techniques, and the facility has no protocols for identifying specific hazards, the areas at
               risk from a release, or the effects of exposure in the event of a release.

              Due to potential contamination of groundwater and soil, a chemical  manufacturer should
               review and evaluate  the plant-wide sewer and drainage system.

              A metal refinery has no comprehensive risk management program based on hazard and
               operability (HAZOP) studies and hazards analysis.  The audit team recommended that the
               facility should conduct a HAZOP study to systematically identify hazards or operability
               problems for the facility, including hazards which may result in or be affected by an
               uncontrolled acid release.

        Modeling

        There were several concerns raised by the chemical safety audit teams with respect to modeling
practices. These concerns primarily focused on the absence of any release modeling program at the facility
to identify vulnerable areas within the surrounding community or the failure of the facility to provide the
community with modeling information  that had been developed. The following is an  example of these
concerns:

              A metal manufacturer has not conducted modeling  for evaluation of  the consequences of
               releases  of sulfuric acid or other hazardous chemicals present at the facility.

        Release Prevention Systems

        There are a variety of often unrelated facility practices which can be identified as  release
prevention systems -- the means by which  the facility seeks to reduce the likelihood and/or severity of
accidental releases of hazardous chemicals. Chemical safety audits should review the  types of systems in
place, design modifications, installation of new equipment, and changes in the type and quantity of
hazardous substances as potential methods of release prevention.  Several chemical safety audit reports
commented on release prevention systems and equipment that support the goal of improving facility
chemical process safety.  The following are some examples:

              The floor of the hazardous materials processing area at a payload processing facility is  .
               covered with vinyl tiles, impregnated with graphite,  and bonded to the concrete with
               conductive mastic. This floor construction dissipates static electricity to the building
               grounding grids, thus reducing the threat of an electrostatic discharge igniting flammable
               liquid propellants.

              An oil refinery redesigned its processes to replace chlorine with bromine, which is
               significantly less toxic, and to use gaseous, rather than liquid ammonia to reduce  high
               pressure hazards.

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              Another refinery replaced chlorinated solvents with hydrocarbon solvents to reduce the
               hazards of its cleaning operations, and intends to replace the hydrocarbon solvents with
               steam cleaning apparatus to further reduce its chemical hazards.

              The ventilation system in the reactor room at a hazardous waste processing facility is shut
               down in the event of a release to prevent the escape of nitric oxide or other contaminants.
               This procedure allows all of the potentially contaminated air to be processed by a
               scrubber system.

        There were a variety of concerns raised by the chemical safety audit teams with respect to release
prevention.  These concerns primarily focused on a wide variety of specific systems and equipment that
could be installed in individual  process areas to reduce the potential for significant releases.  The following
are illustrative examples of these concerns and recommendations:

              An audit team  visiting a chlorine manufacturer recommended that the facility should
               consider installing an electrical isolation  valve at the chlorine tanks to stop the chlorine
               flow in case of a failure in the piping system or the bulk loading rack.

              An audit team  visiting a water treatment facility recommended that utility management
               should continue to evaluate the use of alternate chemicals (i.e., sodium hypochlorite) that
               may be safer than using chlorine.

        Mitigation Systems

        There are a variety of practices which can be grouped together as release mitigation systems -- the
means by which a facility seeks  to reduce the impact or the severity of the impact of a hazardous chemical
release.  The principal methods of mitigating accidents include systems to deploy foam, water, or other
chemicals, as well as containment devices (e.g., dikes or curbs) to halt or slow the spread of a release.
Several chemical safety audit reports commented on release mitigation systems and  equipment that support
the goal of improving facility chemical process safety.  The following are some examples:

              A payload processing facility has installed a  computer-controlled fire suppression system
               requiring two events for activation. First, the smoke and heat detectors must open the
               sprinkler water valve; then there must be enough heat to melt the fusible link in  the
               sprinkler head. This prevents a false alarm from resulting in damage to sensitive payloads.

              A plastics manufacturer installed a new storm drainage system to control  the flow of
               liquid wastes toward the storm water drains.  A culvert routes these wastes to several
               waste water holding tanks for treatment.

              An oil refinery uses cone roofs on its major oil tanks to reduce evaporation, and
               surrounds these tanks with earthen dikes or retaining walls.  There is also a large ditch
               that is designed to prevent spills escaping containment from reaching a nearby river.

              All storage tanks at a metal refinery are contained in concrete dikes that are designed to
               hold more than the maximum contents of the tank to prevent overflow.

              The flammable storage area at a chemical warehouse has a separate, 18,000-gallon
               flammable liquid recovery system that removes released flammables from  the building via
               a floor drain to an exterior storage tank.  The emergency tank is situated  in a bermed
               swail so that any overflow from the tank  will be contained.

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        There were a variety of concerns raised by the chemical safety audit teams with respect to release
mitigation.  These concerns primarily focused on installation and maintenance of diking and other
containment systems and water sprays and other suppressant systems.  Many of the reports identifying
problematic containment practices were concerned with  the segregation of incompatible chemicals and the
effectiveness of existing systems. A few of the more specific concerns and recommendations were:

               A chemical manufacturer has storage tanks and unloading areas that lack secondary
                containment. Spill containment dikes should be installed on a priority basis for all
                chemical storage tanks in light of the proximity of the nearby wetlands and river.

               At a chlorine manufacturing facility, containment dikes were old, breached, or appeared to
                be of inadequate capacity to control a catastrophic release. The audit team recommended
                that the containment systems be improved.

               A lighting equipment manufacturer has several process involving incompatible compounds
                surrounded by a single containment system. The audit team  recommended that  separate
                diking and sump systems should be constructed to segregate the individual process units
                and any potential spills of incompatible substances.

               Due to the limited emergency response accessibility of the ammonia tanks at a jewelry
                manufacturer, the audit team recommended that a water deluge system should be installed
                to knock down released vapors, and that the facility should evaluate the disposition of any
                contaminated run-off.

               A number of problematic containment practices were examined at a petroleum storage
                terminal, including insufficient containment capacity; deteriorated earthen dikes; large
                storage tanks adjacent to their containment dikes;  dikes and berms compromised in
                numerous  places to allow passage of piping; tank farms not separately bermed; and the
                limited capacity of a pair of oil/water separators, which control outflow into a nearby
                waterway.

        3.5     Accidental Release/Incident Investigation

        This element of the CSA protocol addresses the history of accidental releases and incidents and
the resulting facility responses. In order to prevent future accidents, facility's should investigate their
training and work practices to identify the causes of accidents and assess the need for improvements in
equipment and operating procedures. Guidelines should be developed for documenting releases  of
hazardous substances, including fires and explosions.   Management must be knowledgeable of the accident
history of the facility so that trends among accidents can be identified and corrective action can be  taken
as necessary. There are two sub-elements of accidental release/incident investigation:

               History of Accidental Releases/Incidents, describing the types of releases that have
                occurred at the facility in the past and how the facility responded; and

               Facility Investigation Procedures, describing a facility's investigation policies, including:
                types of releases investigated, personnel responsible for conducting investigations, and
                corrective actions resulting from investigations.

        The audits show that most  facilities  represented have a standard procedure for investigating
releases. The audit teams noted, however, that several of these facilities normally do not investigate "near
misses."  The auditors suggested that facilities investigate releases of all sizes as well as "near misses" in
order to identify problems  in operating procedures and equipment  that could result  in larger or more

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damaging releases in the future.  Part of the investigation procedure should involve a review of training
practices in order to identify ways that accident prevention training could be improved.  In addition, the
audit teams stressed that facilities should identify "follow-up" procedures for ensuring that appropriate
corrective actions are taken after a chemical incident.

        Several chemical safety audits describe successful investigating and reporting procedures that
indicate management's goal to preventing future incidents.  For example:

              A chemical facility investigates unidentifiable plant emissions. In the past, the facility has
               made process and mechanical changes in response to these investigations to reduce the
               likelihood of a reoccurrence.

              The environmental department at an agricultural chemicals manufacturer tracks all
               releases, even  if they are below the reportable quantity.

              The policy of another chemical company is to report accidental releases and "near misses"
               to the Corporate Safety Officer.  Reports are then reviewed by corporate headquarters
               and recommendations are sent back to the facility.

              At an oil refinery, the system of release investigation includes an evaluation and review of
               current training and work practices to identify the causes and factors involved in the
               release.  After investigations, findings are reported to management, safety committees, and
               facility trainers.

              Another chemical manufacturer compiles the information generated from incident reports
               and uses it to  prepare corporate safety policy and design and operation modifications.
               The company also disseminates the information to other Hercules facilities that use
               similar processes or system designs.

              The policy of a metal refinery is to conduct a full "post mortem" investigation for any
               significant spill to determine the true causes of the spill, the clean up costs involved, and
               to implement preventive procedures.

        In some  cases, the audits reflect concerns about facilities that do not have standard procedures for
investigating and reporting releases or for investigating "near misses."  The audit teams mentioned, in some
cases, that facilities need to incorporate conclusions  from accident investigations into their training
programs.  It was also noted that some facilities lack "follow-up" procedures to ensure that corrective
actions have been taken.  For example:

              A plastics manufacturing facility had no written procedures for investigating chemical
               incidents, sharing information about causes and prevention of spills with other parts of the
               facility, or conducting follow-up investigations.

              At a petroleum refinery, the audit team observed that incident files did not provide
               evidence of in-depth investigations of "near misses" or reportable releases.

              At a pulp products manufacturing facility, the audit team recommended that the facility
               draft an SOP with guidelines for conducting investigations of incidents, releases, and near
               misses to elicit maximum information for future accident prevention training.

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              At an organic chemicals manufacturing facility, the audit team observed that investigation
               techniques did not fully assess system reliability, corrective technology, or the probability
               of a  recurring incident.

        3.6     Facility Emergency Preparedness and Planning Activities

        This element of the CSA protocol focuses on facility emergency preparedness and planning
activities including actions taken by plants to prepare for emergency incidents involving hazardous
substances. The protocol lists nine sub-elements of facility emergency preparedness and planning:

              Facility Emergency Response Plan -- facility emergency plans and procedures including
               schedules for updates and key areas covered;

              Emergency Response Exercises and Simulations  description of types of drills, frequency
               of occurrence, and use of findings;

              Fire, Evacuation, and Rescue Corridors - condition of fire and rescue corridors and detail
               and location of facility and community maps;

              Emergency Equipment Provisions -- provisions used to maintain, test, and locate
               equipment in the facility, and train personnel on  its use;

              Emergency Response Chain of Authority -- chain of command describing the designation
               of control during an emergency;

              Emergency Response Management Procedures -- management's role in response incidents;

              Emergency Communication Network within the Facility -- communication(s) systems and
               backups including testing and training procedures;

              Emergency Response Personnel Training Requirements -- type and frequency of
               emergency response training available; and

              Follow-up Release Procedures - clean-up and review of response with involved parties.

        Facility Emergency Response Plan

        Comprehensive facility emergency planning is the crucial  element for effective and rapid response
to accidents.  An all-inclusive response plan, followed by well-trained facility personnel and local
responders, can protect both facility employees and the surrounding community from a worsening release
situation. It is the effective plan that minimizes the consequences of a release. Several audit reports cited
a number of effective planning techniques, including the following:

              A chemical production plant developed a contingency plan which covers responses by two
               designated facility emergency  response teams.to any emergencies  that may occur.

              One hardware manufacturer revises its contingency plan annually, and distributes the plan
               to facility management personnel as well as the LEPC, the local fire department, the local
               hazmat unit, and the local hospital.

              To develop a preparedness, prevention, and contingency plan, a plastics plant hired a
               planning consultant to add expertise to the drafting process.

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        There were a variety of concerns with respect to facility emergency response plans.  The primary
concern of audit team members was that many of the facilities audited had emergency plans that lacked
key elements including site and area maps, evacuation routes, lists of chemicals in use at the facility,
information on possible plume dispersion pathways, and other elements.  This lack of comprehensiveness
sometimes stemmed from a failure to recognize the potential hazards at a particular facility.  Several audit
teams suggested that facilities with incomplete plans conduct a careful hazard evaluation to determine all
potential trouble areas that need to be addressed by the plan.  Several facilities relied on multiple
incomplete documents  for their emergency plans.  To avoid any possible confusion, audit teams
recommended that critical elements of each of these plans be reflected in a single, comprehensive
emergency response plan. Use of computer modeling to determine off-site vulnerability was also cited as
an effective  tool for enhancement of response planning. Audit teams recommended that emergency plans
cover all degrees of response from the smallest of  spills to uncontrollable or catastrophic releases.

        There were several other concerns about emergency response planning.  Regulatory requirements,
including CERCLA and SARA reporting procedures and corresponding phone numbers, are another
crucial element not often included in the emergency plans.  Audit teams noted that a number of facilities
listed phone numbers that had not been updated or were incorrect.  A comprehensive plan should not also
be a confusing one; audit teams recommended that facilities take  care in crafting their plans to be concise
and easy to  understand and to implement.  Emergency plans need to be revised regularly to prevent even
the most comprehensive of plans from becoming outdated.  Plans need to be updated to reflect changing
process conditions,  equipment, personnel, and procedures, and to be integrated with the community and
appropriate local and state responders.  Several recommendations were made to facilities to establish a
schedule for updating their existing emergency response plans. A few of the more specific concerns and
recommendations were:

               An audit team recommended that a payload processing facility develop written guidelines
                for sequencing and timing of emergency response activities following an "uncontrollable"
                spill including a definition of initiating incidents, proper mitigation and evacuation
                procedures, and steps and requirements for plant re-entry.

               An audit team suggested that the  contingency plan at a swimming pool chemical company
                be  reviewed and rewritten with more emphasis toward those persons who are going to
                have to read, understand, and place into operation its mandates. For instance, an
                employee or a professional industrial writer could prepare a draft which the response
                employees can exercise to evaluate its  effectiveness as a planning and response tool.

        Emergency Response Exercises and Simulations

        Emergency response exercises and simulations  are an integral part of a facility's emergency
preparedness and planning. Conducting drills, from table-top exercises to the most elaborate of accident
scenarios, is an integral way of ensuring that an emergency response plan is realistic, effective, and
understandable. If  a facility gets into the habit of  drilling different aspects of their response plans  at
regular intervals each year, the employees will become  increasingly familiar with correct emergency
response procedures.  Exercises are most helpful when the conditions vary from drill to drill so that
employees learn appropriate procedures for each accident scenario.  A number of audit reports highlighted
facilities' programs  to regularly conduct emergency response exercises.  The following are some examples:

               Emergency squads at an agricultural chemical manufacturer  conduct monthly drills on
                selected subjects.   Each year, the plant conducts two drills with community involvement.

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              At a bleach manufacturing facility, emergency drills are held quarterly, including table-top,
               walk through, and planned simulations. Drills are held during day shift working hours as
               well as weekends and nights.

              A petroleum refinery has four emergency response teams which each conduct four
               exercises annually.  At least one exercise from each team is conducted on a plant-wide
               level, the goal of which is to involve the local response community in a plant-wide
               exercise.

              Following emergency response exercises at an ammonia and urea production plant, reports
               are prepared by the participants, analyzed by the safety and environmental staff, and
               discussed at the next safety meeting.

        Most of the concerns with respect to emergency response exercises and simulations had to do with
the frequency of drills. A facility could have the most comprehensive of emergency plans, but unless the
facility conducts regular drills, the plan may not be followed properly.  In many cases, either drills were not
conducted on a routine basis or simply not at all. Several  CSA reports recommended that facilities
develop an exercise schedule in order  to make drills a routine part of plant operations. Another concern
was in lack of attempts by facilities  to vary the types of exercises conducted.  In addition to facility-wide
drills, table-top exercises were suggested as well as exercises that highlight hazards to the surrounding
community. Audit teams also noted that mutual emergency response aid agreements between facilities had
often not been exercised. There were additional concerns that facilities failed to  record the lessons learned
during an exercise in order to correct  mistakes in response  procedures prior to an actual emergency.
Because of this concern, audit teams suggested that facilities document formal critiques of their
drills/exercises to improve response procedures.  A few of the more specific concerns and
recommendations were:

              A chlorine and alkali production plant has a comprehensive "Plant Emergency and RCRA
               Contingency Plan" that addresses issues such as alert procedures, emergency shutdown
               procedures, media responsibility, MSDS listings, and evacuation  procedures, but has not
               been routinely exercised.

              An agricultural chemicals manufacturer had conducted annual exercises and set a goal to
               have quarterly exercises, but had not planned to vary the accident scenarios for each
               exercise. To promote the development of a flexible response capability, the audit team
               suggested that the facility consider holding several different types of exercises on a
               rotating basis annually.

        Fire. Evacuation, and Rescue Corridors

        Well-marked fire, rescue, and evacuation pathways  accomplish several things. First, these
pathways and corresponding facility and community maps can aid responders in identifying appropriate
rescue procedures.  Concise evacuation plans also help to protect and account for all employees during an
evacuation.  A number of audit reports focused on the adequacy of fire, evacuation, and rescue corridors.
The following are some examples:

              Measures have been taken at a bleach manufacturing facility to familiarize fire/police
               department personnel with the plant layout, principal hazards, and fire protection
               facilities.

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              There are ten major defined egress routes in one petroleum refinery, each marked with
               distinctively colored signs leading to specified off-site staging areas.  Large evacuation
               maps are posted throughout the plant.

        There were a variety of concerns with respect  to facility fire, evacuation, and rescue corridors.
Some audit teams observed that evacuation plans lacked detailed facility and community maps, and
evacuation procedures, in some cases, were not posted in highly visible locations. An absence of maps and
posted procedures not only makes fire and rescue operations exceedingly difficult, especially for off-site
emergency responders unfamiliar with the layout of the plant, but also can cause a breakdown in the
evacuation of personnel from the building and surrounding area. Facility employees should be able to
evacuate through multiple escape routes to predesignated meeting areas at a minimum safe distance. To
aid in employee accountability after an evacuation, several audit teams suggested using a per-building head
count system.  In addition, audit teams were concerned that facilities did not train personnel in flexible
evacuation procedures to suit changing situations or threats during an emergency.  Audit teams suggested
that facilities be aware of, and plans account for, any unique topographical or meteorological conditions
that may hinder evacuation routes in a particular area. A few of the more specific concerns and
recommendations were:

              A detergent manufacturer had a single door as the only available escape route from the
               building.  Improved ventilation and additional escape routes were needed.

              A plastics plant was advised to develop additional evacuation plans for imminent danger
               situations.  The primary concern of such a plan would be immediate evacuation of all
               personnel, to a minimum safe distance, by the most expedient means possible.

              One audit team determined that the confined and dark conditions in a food products
               manufacturing plant could hinder efficient evacuation of operators in the  event of a
               release.  The audit  team  recommended that the facility upgrade the area by improving
               lighting.

        Emergency  Equipment Provisions

        Having equipment available immediately to mitigate an  emergency situation is essential to stem
the consequences of a release. If facilities were to depend on off-site response equipment alone, an easily
controlled release could lead to a catastrophic accident.  Effective response equipment, used by trained
personnel, can prevent such consequences through timely containment and mitigation of the situation.  A
number of audit reports indicated the presence of proper emergency equipment at some of the facilities.
The following  are some examples:

              A twenty-company  cooperative, spearheaded by a specific petroleum refinery, purchased
               and stocked a semi-trailer with spill response equipment to more effectively respond to
               spills in a nearby river.

              The Safety Department at an agricultural chemical manufacturer performs monthly
               inspections and maintains written records on all safety equipment. Once  a year, a private
               contractor is brought in to check this  equipment.

        There were a variety of concerns with respect  to facility emergency response equipment. In a
number of cases, facilities had some form of personal protective equipment (PPE) and emergency response
equipment, but did  not strategically locate this equipment throughout the facility, particularly in areas
vulnerable to releases. In some cases, audit teams suggested location of such equipment in predesignated
and well stocked spill control cabinets or "disaster packs."  In several cases, eyewash stations were not

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easily accessible.  Suggestions were made that facilities acquire additional equipment, including cartridges
for acid vapors, neoprene boots, backup PPE, five minute escape masks, and other equipment.
Maintenance and regular testing of personal protective equipment to avoid deterioration had not been
performed at some facilities.  Improvements could also be made on fire fighting capability, perhaps by
establishing a fire brigade.  Procedures for such a brigade should be outlined, including a description of
the transfer of responsibility for fighting a  fire from facility response teams to local fire department
personnel.  A few of the more specific concerns and recommendations were:

              At a waste water treatment plant, workers wear ordinary clothing and do not have access
               to totally encapsulated suits to protect themselves from exposure to chlorine. The audit
               recommended that the facility make personal protective equipment available throughout
               the facility.

              At a chemical manufacturing facility, firefighting water pumps were supplied by city water
               rather than river water.  In order to avoid any possible stoppage of water to the pumps
               due to a failure in the city water supply, the facility should install a pumping system to
               enable equipment to pump water from a nearby river to fight a major fire.

              An audit team recommended that a pesticide production plant provide sufficient numbers
               of level A hazardous materials suits so that two emergency responders have an additional
               two man backup.

        Emergency Response Chain of Authority

        Establishment of a chain of command can streamline a large-scale response by ensuring that all
responders receive authorized assignments in order to maximize safety.  By specifying personnel in charge
of response situations, facility management can avoid  confusion and implement emergency procedures
immediately. A number of the facilities  audited had a formal emergency response chain of authority in
place.  The following are some examples:

              During emergencies at a pesticide production facility, the shift supervisor for the half of
               the plant involved in the incident serves as the on-scene coordinator.  The other shift
               supervisor becomes the  emergency coordinator and also serves as the replacement for the
               on-scene coordinator if  he/she is unable to serve in that capacity.

              In case of an emergency at a plant that manufactures chlorine and alkalis, the control
               room operator and the shift supervisor make the decision to shut-down operations.  In the
               event of a leak, the area operator and his assigned backup have responsibility for bringing
               the situation under control.

        Audit team members found that a number of facilities did not identify an emergency response
chain of authority or even an individual  responsible in case of emergency.  Some facilities did not
document a chain of authority because they assumed personnel  knew whom to contact during an
emergency.  In addition, several facilities that identified responsible personnel did not ensure that they
could be reached  after normal working hours. Audit team members recommended that facilities establish
a formal chain of authority, and identify backup personnel, available during all shifts to manage
responders.  A few of the more specific concerns and  recommendations were:

              A fertilizer plant has outlined its emergency planning in broad terms and has no formal
               chain of command for combatting fires, explosions, or releases. The  facility should require
               all shifts to have several personnel designated to initiate notification  procedures in case of
               emergencies.

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              One pesticide warehouse facility does not state in its spill response plan who is
               responsible for differentiating between minor and reportable releases, or for assuring that
               evacuation of the area and product identification are accomplished.

              The chain of authority at a hardware manufacturer was unclear. The plant manager acts
               as emergency coordinator, but it was unclear who reports releases to the coordinator.

        Emergency Response Management Procedures

        Facility management not only needs to identify those in charge during an emergency, but also
should establish formal procedures for management to follow. These procedures should be included in
facility SOPs and emergency response plans.  By indicating the procedures management will take in case of
an accident, a facility can ensure decisiveness in the initial stages of a response action.  The following are a
couple of examples of an effective emergency management  procedures  in place at a facility:

              If an emergency occurs during daylight hours at a certain chlorine and alkali production
               facility, procedures call for the plant manager and the  safety manager to converge on the
               central security station in order to coordinate emergency operations.  In the event of a
               night or weekend emergency, all management would report to the central security station
               or (in case the central station is jeopardized by a hazardous release) to a predetermined
               backup location.

              At one petroleum refining facility, the shift supervisor is responsible for emergency
               response, including notification of the security department, the response team, and other
               operating personnel. The shift supervisor  is also responsible for categorizing emergencies
               into one of three classes, depending on the nature of the response required.

        There were a variety of concerns with respect to facility emergency response management
procedures.  One concern was that facilities need to evaluate the feasibility of a centralized emergency
control center.  Other concerns include a  recommendation  that facilities address safety shoe and contact
lens policies, and that safety glasses be required for employees in certain areas of the plant. An illustrative
example of these concerns follows:

              An audit team noted that an automobile air bag propellant manufacturer had not
               formalized its emergency management procedures, and recommended that the facility
               include such procedures in its standard operating procedures.

        Emergency Communication Network within the Facility

        To keep emergency response personnel abreast of changing conditions, a communication network
is essential.  The ability to communicate the nature of an accident quickly to facility personnel and to off-
site responders helps to determine the initial success of a response operation.  Color-coded signals as well
as various audible alarms are this  first means of informative communication.  Constant contact during a
response action and following an incident ensures  that everyone involved remains informed as to the
nature and severity of the accident. Various backup systems, not including phone service, ensure that a
loss of electricity or other problem does not result in a breakdown in communication.  Several CSA
reports cited several effective means of emergency communication, including the following:

              A chemical manufacturer has two distinct color-coded  alarm systems.  One system  is
               dedicated to fire incidents, and notifies the local fire department; the other system is for
               incidents and emergencies under the plant's supervision, and notifies the facility's four-
               member emergency service team.

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                                                47

               The alarm system at a payload processing facility is automatically sent to the guardhouse
               at the front gate via computer link for various parameters and systems at use in the plant.
               The alarm panel indications displayed to the guard allow prompt identification of
               potential problems and notification of appropriate personnel.

               An ammonia and urea production plant has an emergency fire phone  call-up system tied
               into a conference call circuit,  which immediately rings emergency phones located in all the
               control rooms and various supervisor's offices.

        There were a number of concerns about the emergency communication networks within facilities.
Most of the concerns centered on the need for improvement of communication and alarm systems.  In
some cases, word-of-mouth was the sole means of communication between operators.  The audit teams
recommended installation of additional alarm  systems or improvement of existing systems.  Frequent
testing of such systems was also cited as a concern.  Several suggestions were made to  facilities to evaluate
and update telephone and radio systems. A few of  the more specific concerns and recommendations were:

               At a lighting equipment production plant, an audit team made a number of
               recommendations concerning  emergency communication. Because the facility operates 40
               hours per week, the facility should  consider placing a lock box system  containing
               emergency information outside the building or surrounding fence. The team also
               recommended that the facility install a visual alarm system (i.e., flashing lights) to
               supplement the existing audible alarms due to the noise level inherent to the machinery
               used.

               At an industrial chemical manufacturing plant,  the audit team recommended that the 
               facility upgrade its alarm system to communicate the specific nature and location of an
               emergency to personnel. Such a measure would speed containment  operations when  the
               alarm sounds.

               Plant emergencies at a paper  manufacturing plant are indicated by a series of complicated
               whistle signals to alert the entire complex or by telephone to  alert a specific  person or
               group. Half of the workers questioned could not consistently and accurately interpret the
               alarm signals.  The audit team suggested that the facility simplify their alarm and
               communications systems to eliminate employee identification  and interpretation problems.

        Emergency Response Personnel Training Requirements

        Extensive training of response personnel and familiarization with equipment and procedures can
aid in streamlining an actual response incident, and in avoiding  injury due to ignorance of proper
procedures. Facilities should ensure that experienced and certified personnel conduct response training at
regular intervals, and offer refresher courses to keep procedures fresh in the minds of responders.  Several
CSA reports focused on commendable emergency response personnel training practices, including the
following:

               Visitors to one agricultural chemical manufacturer first report to a reception area where
               the visitor must view a ten minute video of certain facility safety rules.

               At a bromide-based chemical  production facility, fire brigade staff are  sent to a university
               fire academy for training. The facility also holds joint training programs with the local
               hospital to review various types of medical problems such as bromine  chemical burns and
               inhalation.

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                                                 48

              One manufacturer of semiconductor materials requires the following courses for members
               of the facility hazmat response team:  hazardous materials training, confined space and
               rope rescue training, coordination with police and fire departments, hazardous materials
               exercises, emergency care attendant training, fire brigade training, first responder training,
               and more.

        There were a variety of concerns about emergency response personnel training requirements.
These concerns primarily focused on the need for facilities to  improve existing training for response
personnel.  Specific emergency response training is needed if response teams are to be effective. In
particular, some audit teams were concerned that facilities did not train response personnel on the proper
use of emergency response equipment, including PPEs. Incorrect use of such equipment during an actual
emergency could result in potential injury to response personnel.  A number of audit team suggested that
facility emergency responders be trained in basic first aid and  CPR techniques.  Another concern of audit
personnel was that facilities with two or more distinct processes had not cross-trained employees on
emergency response procedures for each process.  Confusion among facility personnel and waiting for
trained, off-site responders could  cause response delays.  Audit team recommended emergency response
personnel be made familiar with all operations.  A few of the  more specific concerns and recommendations
were:

              With recent cutback in operations and personnel at one manufacturer of printed  circuit
               boards, the facility  lost members of its emergency response team.  Although these
               positions have been filled and new emergency response personnel briefed on their duties,
               not all personnel had sufficiently trained.

              Safety and process  training courses alone will not help an employee to help mitigate a
               release.  One plastics plant offered training in most areas but not in emergency response
               procedures.  During an accident in 1988, the workers did not know how to respond
               properly.

              Formalized  training is needed for the response team at a refrigeration facility to
               familiarize them with personal protection equipment, emergency response procedures, and
               to ensure compliance with worker protection  standards.

        Follow-up Release Procedures

        A response action does not end with release containment and mitigation of the cause of the
accident. Clean-up need to be conducted by licensed personnel from the facility or private contractors.
The facility should also review the accomplishments and problems of the response action, and update
response procedures accordingly.  One report focused on existing follow-up release procedures:

              Response plans at an aggregate mining and production facility include provisions for
               containing and cleaning up hazardous materials releases.

        Audit team members were concerned that a few facilities did not retain records of recovery
operations, and failed to specify contractors responsible for clean-up. An audit team also expressed
concern that a facility did not review its  response actions following an incident.  A couple of illustrative
examples of these concerns follows:

              A pesticides warehouse  lists contractors for recovery and disposal for large spill situations,
               but does not indicate if the contractor has either a license or the necessary training for
               recovery operations. The audit team recommended that the facility document such
               licensing and training.

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                                                49

               One audit team noted that a facility that manufactured propellants used in automobile air
                bags lacked formal procedures for release follow-up and  investigation of chemical releases.
                A recommendation was made to include such procedures within a formal response plan.

        3.7      Community and Facility Emergency Response Planning Activities

        The tenth element of the CSA protocol is community and facility emergency response planning
activities, a description of a facility's outreach efforts and activities associated with SARA Title III. There
are two sub-elements of community and facility emergency response planning activities:

               Facility Planning and Outreach Activities with the Community-awareness and
                participation in LEPC and CAER activities, as well as open houses, joint training, and
                educational programs;

               Local/Community Emergency Response Planning-plan status, degree of coordination with
                community in plan preparation, exercise and response procedures, and facility role in non-
                facility-related community responses.

        Facility Planning and Outreach Activities with the Community

        Facility planning and outreach activities with the community are  essential elements of effective
emergency response. Facility outreach efforts give local emergency responders a better understanding of
facility activities, which increases local emergency responders' effectiveness in the event of an incident.
Moreover, outreach campaigns make the public more aware of a facility's operations, its potential hazards,
and its safety practices.  As public awareness and community/facility interaction increase, so does the
likelihood of a coordinated community emergency plan that identifies each facility's hazards, as well as its
response capabilities and/or needs.

        Several chemical safety audit reports commented on facility planning and outreach activities that
support the goal of improving community and facility coordination on emergency response planning.
Many facilities have worked with LEPCs and participated in the Community Awareness and Emergency
Response (CAER) program.  In a few cases, facilities have contacted and coordinated emergency response
procedures with the area hospitals that would be  providing emergency medical treatment in the event of an
accident. Some facilities have instituted joint training with local responders, while others publish
community newsletters which provide information on plant activities and  safety issues. Auditors also
commented on facilities that hosted open houses, distributed information brochures to the surrounding
community, and regularly scheduled tours for visitors. In addition, auditors noted that a few facilities
provided their local fire departments with plant tours and  information on chemicals stored.  The following
are some illustrative examples:

               An industrial organic and  inorganic chemical manufacturing company not only sponsors
                the local volunteer fire department, but many of its employees are volunteers  as well.

               A pesticide production plant is actively involved in the community through the LEPC.
                Three of its representatives served on LEPC steering and public information
                subcommittees, and the  plant participates in the CAER program even though it is not a
                member of the Chemical Manufacturers Association.

               A petroleum refinery plans to send two local fire fighters to an annual, university-
                sponsored fire school.

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                                                50

               A semiconductor manufacturer has purchased CAMEO software for the local fire
               department and has equipped the fire trucks with Macintosh computers.

               One chemical manufacturer conducts an annual training program for the local volunteer
               fire department.  This company also has contractors come to the plant to train fire
               departments, hazardous materials teams, and emergency management directors and
               personnel from the surrounding cities and counties.

               A concrete block and brick manufacturer and a chemical manufacturer have provided the
               local fire department with chemical foam, a foam cannon, a new fire truck, and an
               asbestos fire suit that will enable responders to approach extremely hot fires.

        While many facilities have taken steps to increase community/facility interaction, the chemical
safety audit teams did report a variety of concerns.  Some facilities appeared to have little contact with
local emergency responders. Chemical safety auditors suggested that facilities send representatives to
LEPC meetings and increase the level of community/facility interaction through sponsoring community-
oriented events such as open houses.  In addition, some auditor reports recommended that facilities invite
outside  agencies to on-site visits so that these groups will be familiar with the facilities  layouts and
operations. Additionally, auditors noted a few instances where facilities did not have any community
outreach programs and made no references in its emergency plan concerning the documentation and
reporting of spills to state and federal agencies. At certain facilities, the personnel responsible for
ensuring compliance with SARA Title III reporting requirements were not listed in the facility's SOPs.
More specifically, chemical safety auditors noted the following concerns:

               At a soap and detergent manufacturer, audit team members only met with staff level
               personnel.  Management did not appear to be interested in the audit or in their
               responsibilities under SARA Title III.  The audit team encouraged management to make
               every effort to obtain a comprehensive knowledge of their responsibilities under SARA
               Title III and suggested that the facility interact with their SERC and LEPC
               representatives.

               Audit team members noted that a chemical manufacturing facility failed to resubmit its
               section 312 chemical inventory forms. Furthermore, the same facility did not notify the
               SERC and LEPC that extremely hazardous substances were being handled in amounts that
               exceeded their  threshold planning  quantities as  required under section  302.

               At an electricity-generating plant, the audit team recommended that the facility make
               their CHEMSAFE database available to the SERC, LEPC, local fire departments, and
               emergency management agencies since sharing information will help these groups in
               planning and response activities.

        Local/Community Emergency Response Planning

        Without well-coordinated  local/community response planning, even the best employee training
programs and operating procedures cannot assure effective, rapid emergency responses. Facilities  must do
more than simply develop their own emergency response plans  - these plans should be communicated to
and integrated with the appropriate local emergency responders.  Ideally, emergency plans will  be designed
in conjunction with local  officials.  Furthermore, simulated drills and exercises should be conducted
regularly with the responders from the community  to ensure that emergency procedures are functioning
properly. Neither facilities nor their surrounding communities can afford to let emergency response
procedures become outdated.

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        The following are examples of facility programs designed to facilitate a coordinated
facility/community emergency response:

              A soap and detergent manufacturer distributed its emergency plan to and arranged for
               response assistance with local fire, police, and health departments, as well as the local
               hospital and two emergency medical providers.

              An oil refinery conducted a full-scale simulation exercise in concert with its  CAER group,
               the LEPC, and the local mutual aid association. An annual community response drill is
               planned by individuals representing both the community and industry.

              A pesticide warehouse facility consulted with both fire department inspectors and
               hazardous materials specialists on their structural and systems designs.  Furthermore, in
               response to the most  recent evaluation, the facility has revised and coordinated its
               emergency response plans with state and local fire department hazardous materials team
               and codes inspection personnel.

              An industrial organic chemical manufacturer has worked with outside agencies in
               conducting simulated  highway and rail transportation accidents involving hazardous
               materials.  These exercises were  put to use when the facility's hazardous materials team
               assisted local authorities with a recent railway incident in which several chemicals were
               spilled two miles away from the  plant.

              A petroleum refinery  has formally agreed to assist local officials with developing
               neighborhood evacuation plans.

        However, a significant number of facilities were identified as needing to coordinate emergency
response plans with LEPCs, fire and police departments, and area hospitals.  For certain facilities with
emergency plans already in place, the audit team recommended that plans either be revised or coordinated
with local emergency responders. Furthermore, chemical safety audit team members indicated that more
facilities need to conduct regular emergency exercises with local emergency responders.  In several cases,
the audit team recommended a more rigorous analysis of the exercise results to assure that emergency
plans are functioning properly.  Some  facilities were identified as having significant chemical hazards  and
were encouraged to assist  LEPCs in conducting vulnerability, risk assessment, and BLEVE analyses.   In
many instances, audit teams recommended that facilities periodically reevaluate emergency plans to assure
the immediate notification of the appropriate local authorities in the event of an incident. The following
are two illustrative concerns identified in the audit reports:

              Audit team members  suggested that a pesticide and agricultural chemicals manufacturing
               plant expand its existing modelling efforts and share the results with the LEPC.  In
               addition, auditors recommended that a hazard analysis be completed to improve in-plant
               risk analysis.

              At a pesticide warehouse facility, the audit team noted that there were  no provisions in
               the spill emergency plan for releasing information  to either state or federal agencies  and
               that the facility's plans were vague in establishing specific responsibilities for ensuring that
               reporting requirement were met.

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        3.8     Public Alert and Notification Procedures

        The purpose of this element of the protocol is to identify unique procedures that a facility has
employed to alert the public when an accident occurs at a facility and to identify problems that facilities
may be having in establishing public alert and notification procedures. This information should also
indicate facility commitment to safety in the community. The following sub-elements of the protocol will
be addressed:

              Procedures for Public Notification of Releases, including alarm systems, communication
               networks, and back-up systems;

              Schedule of Testing for Procedures, including frequency of tests and number and type of
               individuals notified;

              History of Notification Procedures and Evaluation, including the type of incident, the
               timeliness of public notification, and the number of individuals notified and methods of
               public and private emergency notification;

              Community and Facility Contacts, including alternate contacts and telephone number
               updates; and

              Facility and Media Interaction, including direct communication links and the history of
               past interaction.

        Several facilities have incorporated some uniquely comprehensive or effective methods  for public
alert and notification.  Designating media contacts and establishing procedures for communicating
effectively and quickly with the media during and after an emergency is one way many facilities  plan to
notify the public of an emergency.  Other facilities coordinate with fire and police personnel who go door
to door to notify nearby residents in the event of an emergency. In addition, many facilities made good
efforts to coordinate public  alert and notification planning with Local Emergency Planning Committees
(LEPCs). The following examples illustrate innovative or particularly effective procedures that  have been
developed by various facilities:

              Emergency procedures at a chemical manufacturer require that updates be made every
               fifteen minutes to the local emergency communications center.

              An oil refinery has established procedures that provide for public notification to  be made
               over the radio, by telephone, and broadcast over the city's emergency broadcast system.  In
               addition, the facility set up a telephone hotline to make information about a release
               accessible to the public.

              Another chemical manufacturer issues all employees wallet cards with listings of  plant  and
               community emergency telephone numbers to notify in the event of an emergency.

              Another oil refinery has developed computer software to direct the emergency  coordinator
               to notify the appropriate state and local agencies.

              A third chemical manufacturer has installed an automatic-dial emergency dial notification
               system for notifying nearby residents of an emergency situation.

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              A fertilizer manufacturer has access to a public warning system operated through local
               radio stations, equipped with back-up electrical generators if primary power supplies are
               disrupted, as well as high-powered voice and siren systems;  in addition, the facility's
               release prevention, control, and countermeasures plan outlines steps that should be taken
               by the incident commander should evacuating some part of the surrounding community be
               necessary.

              A third oil refinery is part of a two-way radio system between 21 industrial and six state,
               local, and private parties; the system is tested daily and provides notification of upsets as
               well as actual releases.

              A metal refinery works with the local fire department and sheriffs office to alert nearby
               residents of an incident through a command conference phone system that all residents
               have access to through their residential telephones; in addition, the fire department can
               telephone all residents simultaneously to notify them  of an incident.

              A water treatment facility keeps a two-way hand-held radio tuned to the local fire
               department's frequency in the facility's control room;  in addition, plans are in place to
               initiate emergency broadcasts through a 24-hour local radio station as well as  sending fax
               transmissions to local radio and television stations; the emergency broadcast system is
               tested weekly.

        The reports  examined for this analysis also indicated that many facilities do not  have adequate
public alert and notification procedures in place.  And, a few facilities rely strictly on federal, state, and
local government agencies and entities such as the local fire or police  departments to alert the public of a
release, rather than developing additional alert and notification procedures for their own facility.  In
general, therefore, it was recommended  that some kind of public alert and notification procedures be
established for those facilities that do not have such procedures and especially for those that are located in
communities or areas that have no public alert mechanisms.  The following are some examples:

              A facility at which synthetic resins are manufactured has designated a chain-of-command
               and  a list of agencies to contact in the event of an accident, but has no specific procedures
               for public notification.

              A release that occurred at an electronics facility revealed a lack of coordination between
               the facility and public information and response activities and public concern was
               expressed over  getting information about the release of an extremely hazardous substance .
               before it reached its reportable quantity.

              During a release incident that occurred at an oil refinery, no initial notification was made
               either by siren or through direct phone calls.

              At another facility where pulp and paper products are manufactured,  the LEPC and
               SERC expressed concern, prior to the audit, about the tardiness exhibited by the facility in
               notifying the public about a release that had occurred.

        Another problem evident at some facilities is that the equipment or methods that would be used
to alert the public could be made more effective.  Several facilities rely solely on the 911 system but do not
have a warning siren, horn, or some other kind of audible warning system.  A few facilities have audible
alarm systems that are only manually operated and no provisions have been made for an emergency
occurring after  hours.  In addition, back-up equipment is needed at many facilities to supplement an
equipment failure and response procedures for nearby residents should be published.  For example:

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              Residents who live nearby a facility at which intermediate chemicals for use in bleach
               products are manufactured reported being able to hear the warning siren or horn, but
               because they were never informed of proper response procedures, they do not know what
               to do when they hear it.

        In general, it was recommended that some kind of public alert and notification procedures should
be established for those facilities that do not have them. Other suggestions included improving media
relations by designating a media spokesperson at the facility and a local media contact to notify concerning
an emergency, making public address systems such as sirens or horns more audible and less confusing,
ensuring that nearby residents know what to do if they hear a warning siren or horn, and regularly
conducting tests of warning systems to ensure their effectiveness.  Comprehensive lists of the appropriate
response personnel, agencies, and industrial neighbors to contact during an emergency should also be
made readily available and posted outside facility buildings for easy access after-hours.  Finally, it was often
recommended that appropriate facility personnel meet with local fire and police officials and other
emergency response personnel to define individual responsibilities as well as to communicate and
coordinate with LEPCs and SERCs and meet with nearby residents.  The following are illustrative
examples of these concerns and recommendations:

              Testing procedures used by a facility at which gasoline is produced are confusing because
               the loudspeakers for the warning siren lack clarity; this sometimes indicates that an actual
               emergency is taking place when the system is only being tested.

              For one facility at which a release has already occurred while no public notification
               systems were in place, it was recommended that a vulnerability zone be designated around
               the facility and that nearby residents be informed of the parameters of this zone.

              For another facility, it was recommended that formal procedures be established for
               relaying information from the incident scene to the media liaison in order to mitigate the
               spread of rumors and to ensure that accurate, current information about an incident is
               provided.

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4.0
STATUS OF CSA PROGRAM IMPLEMENTATION
        This chapter focuses on the status of the CSA program as well as region-specific information
about unique CSA implementation and outreach activities. The progress of the program at the regional
level is measured by the number of audits performed and completed audit reports, as well as training and
workshop participation.  Overall, there was a noticeable increase in the number of audits conducted and
audit reports completed in FY 91 over FY 89 and FY 90.

        4.1     Regional Implementation

        The following chart shows the status of the Chemical Safety Audit program from FY 89 through
FY 91.  The columns indicate the number of audits conducted by each region, the number of final audit
reports received by CEPPO from each region as of September 30, 1991, and the number of EPA regional,
AARP, and TAT personnel who have attended the CSA training workshops, respectively.

                          CHART  OF REGIONAL CSA ACHIEVEMENTS
REGION
AUDITS
REPORTS
TRAINING
1
11
11
7
2
8
5
20
3
12
11
30
4
25
19
64
5
11
4
19
6
14
14
25
7
4
3
9
8
13
13
21
9
12
11
15
10
13
10
11
        For FY 89 and FY 90, EPA set identical CSA targets for each regional office.  Each regional
office was to complete four audits in both FY 89 and FY 90. The Strategic Targeted Activities for Results
System (STARS) is used to track the regions' progress toward these targets.  In FY 89, only five of the
regions accomplished their goal, although a total of 32 audits were conducted nationally. All but one of
the regions conducted at least four audits in FY 90, and Region 4, Region 5, and Region 6 surpassed their
targets.  Only Region 7 did not conduct any audits  in either FY 89 or FY 90; Region 7 did conduct four
audits in FY 91.

        For FY 91, EPA changed its method for tracking chemical safety audits, making the targets
region-specific and requiring regions to conduct an  audit and finalize the audit report.  EPA set individual
targets for the number of audits and audit reports to be completed by each region to better reflect regional
priorities and capabilities. For the ten regions, a total of 40 audits was targeted for FY 91, with each
region required to complete from three to six audits.  Six regional offices achieved or exceeded their
individual targets; Region 4 conducted audits and submitted audit reports for twelve facilities during FY
91. Regions 2, 5, 9, and 10 did not reach their targets during FY 91; in each case the Region conducted
enough audits, but has not yet submitted the final audit reports to headquarters.

        The FY 1990 Status Report identified a number of concerns arising from the chemical safety audit
reports completed by the regions.  In the last year,  there has been an overall improvement in the report
preparation process, as a result of increased input from state and local officials participating in audits and
the dramatic increase in the percentage of audit reports completed for the audits conducted this year.  In
addition, as documented in Chapter 3, the reports are identifying a number of unique and successful
facility safety practices, as well as documenting various trends in more problematic areas.
                                               55

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date:
                                                56

        Nevertheless, there remain several outstanding concerns about the audit reports completed to
               First, many audit reports contain recommendations for the facility without providing any
               documentation of why the recommendation was made.  In doing so, the audit team makes
               it more difficult for headquarters to identify problematic chemical process safety issues,
               and for the facility, LEPCs, and SERCs to understand and address the specific concerns of
               the audit team.  As an example, one audit team recommended that the facility should
               label and/or color-code all of its storage tanks and process piping, but the report did not
               indicate whether the facility has any existing labeling or color-coding policy or whether
               this policy is followed for some but not all tanks and piping at the facility. This type of
               supporting information should be included in either the body of the report or the
               conclusions section.

               In a related concern, many of the audit reports comment on facility practices which appear
               to be unsafe or improper, and yet the reports do not provide a recommendation to the
               facility on this topic, or explain why such a recommendation was not made.  Once  again,
               this makes it more difficult for headquarters to identify problematic chemical process
               safety issues, and for the  facility, LEPCs,  and  SERCs to understand and address the
               specific concerns of the audit team.

               In addition, some regional offices have been attaching a separate technical assistance team
               report on the audit, discussing issues and practices that are not addressed in the body of
               the report.  This creates an opportunity for conflicting statements to appear in the report,
               and as a result, headquarters  recommends that all audit team members work together to
               develop a single report.

               Some of the regional offices have displayed a  tendency to incorrectly focus their attention
               on the accident(s) or release(s) that resulted in the facility's selection, rather than to
               conduct a review of the facility's safety practices for  the hazardous substances present.

               Some of the regional offices have also been including an excessive amount of information
               in attachments to their reports. This documentation should only be included in the final
               report if it provides information on unique facility safety practices.

               In addition, many of the reports reference industry-specific, technical terminology or
               acronyms  which would be unfamiliar to the general reader. Audit teams should remember
               that the reports are available to the public, and define all such terms used in the audit
               report.

               Finally, while adherence to the structure  of the CSA protocol, designed to simplify  the
               identification of important chemical process safety issues and practices by EPA, has been
               improving, a number of audit teams continue  to describe safety practices in unrelated
               sections of the report. As an example, in one audit  report a discussion of a facility's
               emergency planning coordination with  the community  (element 10 of the protocol) was
               improperly located in the section on chemical accident  prevention (element  7 of the
               protocol).

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        4.2     Regional Activities

        This section reviews the principal accomplishments of the CSA program at the regional level and
identifies notable successes in implementation. These accomplishments focus on publicizing the CSA
program, using the CSA program to enhance Title III activities, and supporting the development of state
CSA programs or capabilities.  Publicizing CSA program activities has helped increase state and local
interest and participation. Most regional offices actively seek LEPC and SERC participation in audits.  To
foster this participation, many regions have encouraged  state and local officials to attend EPA's CSA
workshops. The following is a list of CSA-related activities initiated by the regional offices which go
beyond their necessary CSA program responsibilities:

              Region 4 is planning to encourage other program offices within the regional office to
               require companies to conduct chemical safety audits as part of their enforcement
               settlements. The regional CEPP staff will provide technical assistance in oversight of such
               settlements. At the request of the South Carolina SERC, Region 4 held an EPA-
               sponsored CSA workshop in Charleston in FY 91, rather than in Atlanta as originally
               planned; over 30 state and local officials attended. Region 4  also plans to supplement
               their CSA efforts by conducting its own chemical safety audit workshop in FY 92 at the
               request of the North Carolina SERC.  As resources will allow, Region 4 will present this
               workshop in other states.  Region 4 also issues press releases whenever its CSA team
               conducts an audit or issues a final audit report.

              Region 5 initiated an audit component  to its enforcement settlements.  When one facility
               could not afford the large penalty it was assessed due to a release, Region 5 approved a
               reduced payment schedule and required the company to perform chemical safety audits  for
               all three of its facilities.

              Region 6 made a presentation on the CSA program at the Region 6 SERC conference.
               The Region hopes to receive more facility referrals from local and state officials to
               simplify the facility selection process. Under the auspices  of the Integrated Border
               Environment Plan with Mexico, the Region will be conducting two chemical safety audits
               at maquiladora ("across the border") facilities. Region 6 is also considering incorporating
               chemical safety audits into Title III enforcement settlements.  As part  of the settlement,
               the facility would be required to conduct an audit and submit an audit report to the
               Region using the CSA protocol as a guide.  One regional  CSA team member would
               participate in the audit as an observer and to provide assistance, if necessary.

              Region 8 is currently assisting the Colorado SERC in providing a series of CSA
               workshops to LEPC members throughout the state. They have also visited the Colorado
               Chamber of Commerce, LEPCs, and SERCs throughout the Region to request state and
               local participation on CSA audit teams. Additionally, Region 8 generates a questionnaire
               asking the audited facility if recommendations from the CSA report have been
               implemented six and twelve months after the audit.  The regional contact noted an 80-85
               percent response rate by facilities in implementing audit recommendations.  Region 8 also
               publishes a newsletter which advertises  the CSA program and the new provisions of the
               Clean Air Act in order to increase state and local interest.

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Region 9, with support from CEPPO, is providing assistance to Nevada in developing its
own chemical safety audit program, which will conduct audits under the authority of a new
state accident prevention law.  The new law mandates an inspection of a facility that has a
chemical accident or near miss, or poses a threat to public health and safety.  Region 9 is
also involved with pre-audit introductory meetings with local fire and police department
personnel, county and regional planners, and other members of LEPCs. The purpose of
these meetings is to introduce the community to the CSA program and to assess the level
of interaction between responders and the audited facility.  In FY  91, at the request of
officials from San Diego County and the State of California, a CSA workshop was held in
San Diego.  A one-day workshop on the implementation of California's Risk  Management
Plan Program followed the CSA workshop.

Region 10 is acting as a referral center for facilities to contact with questions concerning
safety practices.  For example, when a facility contacts  the region with questions about a
particular element of the CSA protocol, Region 10 will refer it to  another facility which
has been successful in the relevant areas of the protocol. Region 10 provides another
referral service concerning audit expectations. After initial audit notification, a facility can
prepare itself by contacting previously audited facilities. Also, Region  10 targets areas
where LEPCs are no longer active and  uses the  CSA process to  recommend that the
LEPCs become more involved in emergency response exercises with the audited facility
within the next six months. Region 10 is also coordinating with states  in the  region in
developing state CSA programs.

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                APPENDIX A




OUTLINE OF THE CHEMICAL SAFETY AUDIT PROTOCOL

-------
                                        APPENDIX A

                   OUTLINE OF THE CHEMICAL SAFETY AUDIT PROTOCOL


1.0     INTRODUCTION

2.0     SUMMARY OF FINDINGS/CONCLUSIONS

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 CHEMICALS

       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 Steps 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 Monitoring

       6.3     Process Hazards

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7.0     CHEMICAL ACCIDENT PREVENTION

       7.1     Management Activities

              7.1.1 Corporate Role in Facility Process Safety
                            Management
              7.1.2 Facility Role in Process Safety Management
              7.1.3 Audit Activities and Procedures

       7.2     Process Operation and Maintenance

              7.2.1 Standard Operating Procedures
              7.2.2 Training Practices
              7.2.3 Equipment Maintenance Procedures
              7.2.4 Instrument Maintenance

       7.3     Hazard Evaluation and  Modeling

              7.3.1 Hazard Evaluation
              7.3.2 Modeling

       7.4     Release Prevention Systems

       7.5     Mitigation Systems

8.0     ACCIDENT RELEASE INCIDENT INVESTIGATION

       8.1     History of Accidental Releases/Incidents
       8.2     Facility Investigation 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
       9.4     Emergency Equipment Provisions
       9.5     Emergency Response Chain of Authority
       9.6     Emergency Response Management Procedures
       9.7     Emergency Communication Network within the Facility
       9.8     Emergency Response Personnel Training Requirements
       9.9     Follow-up Release Procedures

10.0   COMMUNITY AND FACILITY EMERGENCY RESPONSE PLANNING ACTIVITIES

       10.1    Facility Planning and Outreach Activities with Community
       10.2    Local/Community Emergency Response Planning

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11.0    PUBLIC ALERT AND NOTIFICATION PROCEDURES

       11.1    Procedures for Public Notification of Releases
       11.2    Schedule for Testing Procedures
       11.3    History of Notification Procedures and Evaluation
       11.4    Community and Facility Contacts
       11.5    Facility and Media Interaction

12.0    CONCLUSIONS

13.0    RECOMMENDATIONS

       APPENDICES

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         APPENDIX B




LIST OF CHEMICAL SAFETY AUDITS

-------
                                         APPENDIX B

                              LIST OF CHEMICAL SAFETY AUDITS
                                    as of September 30,1991
REGION
DATE OF AUDIT

03/22/89
04/10-14/89
08/03/89
08/07-11/89
11/29/89
03/20/90
06/20-21/90
09/12-13/90
12/17-18/90
05/13-14/91
07/24-25/91

08/21-24/89
09/11/89
01/09-10/90
01/11-12/90
07/31 - 08/01/90
09/10-11/90
03/11-13/91
06/03-05/91
08/05-07/91

07/30-08/03/89
08/14-16/89
09/11-12/89
09/25-26/89
01/31 & 02/02/90
02/12-16/90
03/26-28/90
08/20-22/90
01/07-10/91
04/15-16/91
04/23-25/91
05/21-23/91
REPORT STATUS  NAME OF FACILITY
                                       X1
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X-D2
                                       X-D

                                       X

                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X-D
                                       X-D
                   Polysar, Inc., Indian Orchard, MA
                   W.R. Grace, Nashua, NH
                   Fall River Treatment Plant, Fall River, MA
                   Upjohn Co., North Haven, CT
                   Bradford Soap Works, W. Warwick, RI
                   Jones Chemicals, Merrimac, NH
                   Monet Crystal Brands, Pawtucket, RI
                   LCP Chemicals, Orrington, ME
                   Hercules, Inc., Chicopee, MA
                   Pacific Anchor, Cumberland, RI
                   Rising Paper Co., Housatonic, MA

                   BASF, Rensselaer, NY
                   Xerox Corporation, Webster, NY
                   Du Pont Agrichemicals, Manati, PR
                   Bacardi Rum, San Juan, PR
                   Goodyear, Niagara Falls, NY
                   BASF, Washington, NJ
                   C.P. Chemicals, Sewaren, NJ
                   3M/O-Cel-O, Tonawanda, NY
                   Schenectady Chemicals, Schenectady, NY

                   Rhone-Poulenc, Charleston, WV
                   LCP Chemicals, Inc., Moundsville, WV
                   Purolite Co., Philadelphia, PA
                   Carl Falkenstein, Inc., Philadelphia, PA
                   Automata, Sterling, VA
                   Mobay Chemical, New Martinsville, WV
                   Olin Chemical, Charleston, WV
                   Occidental Chemicals, Delaware City, DE
                   Rohm & Haas, Bristol, PA
                   Anzon Lead, Philadelphia, PA
                   DuPont Textile Fibers, Waynesboro, VA
                   SCM Chemicals, Baltimore, MD
    1 An "X" indicates that the final report has been received and a profile has been completed.

    2An "X-D" indicates that the final report for this audit was received by EPA Headquarters after August
31, 1991, and the results are not included in the 1991 Chemical Safety Audit Program Status Report.

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REGION     DATE OF AUDIT
REPORT STATUS  NAME OF FACILITY
             03/20-24/89                X
             05/01-05/89                X
             07/11/89 & 08/03-04/89      X-D
             07/18-20/89                X-D
             08/17/89 & 09/11-15/89
             02/12-13/90                X
             02/26-03/02/90              X-D
             04/04-05/90                X
             05/08-11/90
             09/11-13/90
             10/26/90                   X
             11/29/90                   X
             12/4-5/90                  X
             12/4-5/90                  X
             12/12/90                   X
             01/07-10/91                X-D
             01/22-25/91                X-D
             01/30-31/91                X
             02/20-21/91                X
             02/25-26/91                X
             03/04-08/91
             03/18-22/91
             03/27/91                   X
             04/02/91                   X-D
             08/26-30/91

             07/25-28/89                X
             08/08-11/89                X
             09/15/89
             03/05/90
             03/26-30/90
             04/14-18/90                X
             06/11-15/90
             07/16-19/90
             03/18-20/91
             05/20-22/91
             08/12-14/91                X-D

             06/13/89                   X
             08/30-31/89                X
             08/15-16/89                X
             09/12-13/89                X
             10/16-17/89                X
             11/06-07/89                X
             11/14/89                   X
             01/17-18/90                X
             04/17-19/90                X
             03/05-06/91                X
             03/20-22/91                X-D
             05/01-03/91                X
             07/09-11/91                X-D
             08/27-29/91                X-D
                   Royster Phosphate, Piney Point, FL
                   Olin Corporation, Charleston, TN
                   Armco Steel, Ashland, KY
                   Kerr McGee, Hamilton, MS
                   Texas Gulf, Aurora, NC
                   Photocircuits, Atlanta, Peachtree City, GA
                   Kemira, Inc., Savannah, GA
                   Astrotech, Titusville, FL
                   Cardinal Chemical Co., Columbia, SC
                   Tennessee Chemical Co., Copper Hill, TN
                   Kason Industries, Newnan, GA
                   C & S Chemical Company, Austell, GA
                   Carolina Solite, Norwood, NC
                   Oldover Corporation, Albemarle, NC
                   Tull Chemical Company, Oxford, AL
                   Peridot Chemical Company, Augusta, GA
                   Aqua Tech/Groce Labs, Duncan, SC
                   Virtex Chemicals, Bristol, TN
                   Water Treatment Plant, Cape Coral, FL
                   Canal Pumping Station, Cape Coral, FL
                   Kentucky American Water, Lexington, KY
                   Drexel Chemical Co.,  Tunica County, MS
                   Columbia Organics, Camden, SC
                   Armstrong Glass, Atlanta, GA
                   B. F. Goodrich, Calvert City, KY

                   Koppers, Cicero, IL
                   Best Foods, Chicago,  IL
                   Shell Oil, Wood River, IL
                   Eli Lilly, Clinton, IN
                   Anderson Development, Adrian, MI
                   General Electric Plastics, Mt. Vernon, IN
                   Tremco, Inc., Cleveland, OH
                   Flexel, Inc., Covington, IN
                   Detroit Edison, River Rouge, MI
                   Nalco Chemical Company, IL
                   SCM Chemicals, Astabula, OH

                   Western Extrusion, Carrollton, TX
                   Great Lakes Chemical Co., El Dorado, AR
                   Farmland Industries, Enid, OK
                   Fermenta ASC Corporation, Houston, TX
                   Chief Supply, Haskell, OK
                   Phillips Petroleum, Pasadena, TX
                   Texas Instruments, Dallas, TX
                   Exxon Refinery, Baton Rouge, LA
                   Olin Chemicals, Lake Charles, LA
                   Sid  Richardson Carbon Co., Borger, TX
                   ARCO Chemical, Channelview, TX
                   Citgo Refinery, Lake Charles, LA
                   International Paper, Pine Bluff, AR
                   Agricultural Minerals, Catoosa, OK

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REGION

7
10
DATE OF AUDIT

10/25/90
11/20/90
05/01/91
07/31/91

05/02-04/89
06/13-15/89
08/15-17/89
03/27/90
05/15-17/90
06/26-29/90
08/27-31/90
11/01/90
02/06-07/91
02/19-21-91
04/30-05/03/91
05/29-31/91
09/29-30/91

05/12-13/89
07/25-27/89
08/16-17/89
09/07-08/89
04/17-20/90
06/19-22/90
07/17-20/90
09/10-16/90
04/09-12/91
07/16-19/91
08/20/91
08/21-23/91

07/27/89
08-10/893
09/12-15/89
03/19-23/90
04/23-27/90
05/14-18/90
09/24-28/90
01/08/91
01/15-18/91
03/18-22/91
04/22-26/91
07/24-26/91
08/05-09/91
REPORT STATUS  NAME OF FACILITY
    X
    X
    X-D
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X-D

                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X
                                       X-D
                                       X-D
    X
    X
    X
    X
    X-D
    X
    X
    X-D
    X
    X-D
ICI Americas, Omaha, NE
Jacobson Warehouse, Des Moines, LA.
ABB Power Transformers, St. Louis, MO
Hydrozo, Inc., Lincoln, NE

Phillips Refinery, West Bountiful, 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
Western Zirconium,  Ogden, UT
Jemm Plating, Co., Denver, CO
SAS Circuits, Littleton,  CO
Kodak-Colorado Division, Windsor, CO
Col. Falls Aluminum, Columbia Falls, MT
Syncom Techologies, Mitchell, SD
LaRoche Industries,  Inc., Orem, UT

Nunes Cooling Inc., Salinas, CA
Unocal Chemical,  Brea, CA
Eticam of Nevada, Fernley, NV
Coronado Generator, St. Johns, AZ
Ultramar, Inc., Wilmington, CA
Magma Copper, Inc., San Manuel, AZ
Pioneer Chlor Alkalai, Henderson, NV
Dole Packaged Foods, Honolulu, HI
Motorola, Phoenix, AZ
Dow Chemicals, Pittsburg, CA
Pioneer Chlor Alkalai, Henderson, NV
Timet Corporation, Henderson, NV

All Pure Chemical Company,  Kalama, WA
ITT Rayonier, Port Angeles, WA
McWhorter Northwest, Portland, OR
BP Oil Company, Ferndale, WA
FMC Corporation, Pocatello,  ID
Neste Resins, Springield, OR
Unocal Chemicals, Kenai, AK
Occidental Chemicals, Tacoma, WA
Chevron USA, Richmond Beach, WA
James River Corporation, Clatskanie, OR
Potlatch Corporation, Lewiston, ID
Great Western Chemical Co.,  Nampa, ID
Boise Cascade Mill, Wallula, WA
     The audit at ITT Rayonier consisted of three separate visits during a three month period.

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                     APPENDIX C




HAZARDOUS SUBSTANCES EXAMINED IN CHEMICAL SAFETY AUDITS

-------
                                         APPENDIX C
Acetic Acid:
    64-19-7
HAZARDOUS SUBSTANCES EXAMINED IN CHEMICAL SAFETY AUDITS
             (including Chemical Abstract Service Numbers)

                       Best Foods, Region 5
Acetone:
    67-64-1
                       Carolina Solite, Region 4
                       General Electric Plastics, Region 5
                       Western Forge, Region 8
Adipic Acid:
    124-04-9
                       Hercules Chemicals, Region 1
Aluminum Sulfate:
    10043-01-3
                       C & S Chemicals, Region 4
Ammonia:
    7664-41-7
                       Hercules Chemicals, Region 1
                       Monet, Region 1
                       Original Bradford Soap Works, Region 1
                       Upjohn, Region 1
                       W.R. Grace, Region 1
                       Olin, Region 3
                       Royster Phosphates, Region 4
                       Best Foods, Region 5
                       Citgo Refinery, Region 6
                       Farmland Industries, Region 6
                       Fermenta ASC, Region 6
                       Chevron, Region 8
                       Western Zirconium, Region 8
                       Dole Packaged Food, Region 9
                       Nunes Cooling, Region 9
                       Unocal Chemicals, Region 9
                       ITT Rayonier, Region 10
                       Unocal Chemicals, Region 10
Ammonium Hydroxide:
    1336-21-6
                       Jones Chemical, Region 1
                       Automata, Region 3
                       Carl Falkenstein, Region 3
                       SAS Circuits, Region 8
Antimony:
    7440-36-0
                       Monet, Region 1
Arsenic Trioxide:
    1327-53-3
                       Fermenta ASC, Region 6

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Benzene:
    71-43-2
Upjohn, Region 1
Exxon Refinery, Region 6
Amoco Refinery, Region 8
Bromine:
    7726-95-6
Purolite, Region 3
Great Lakes Chemical, Region 6
1,3-Butadiene:
    106-99-0
Phillips 66 Houston, Region 6
Butyl Acetate:
    123-86-4
Western Forge, Region 8
Cadmium:
    7440-43-9
Monet, Region 1
Carbaryl:
    63-25-2
Jacobson Warehouse, Region 7
Carbon Tetrachloride:
    56-23-5
Oxychem, Region 3
Chlorine:
    7782-50-5
Fall River Waste Treatment, Region 1
Jones Chemical, Region 1
LCP Chemicals, Region 1
Bacardi Rum, Region 2
Du Pont Agrichemicals, Region 2
LCP Chemicals, Region 3
Mobay, Region 3
Olin, Region 3
Oxychem, Region 3
Cape Coral Pumping Station, Region 4
Cape Coral Water Treatment, Region 4
Columbia Organic Chemicals, Region 4
Olin, Region 4
Photocircuits, Region 4
Best Foods, Region 5
Citgo Refinery, Region 6
Farmland Industries, Region 6
Fermenta ASC, Region 6
Great Lakes Chemical, Region 6
Olin, Region 6
Phillips 66, Region 6
Sid Richardson Carbon, Region 6
Chevron, Region 8
Columbia Falls Aluminum, Region 8

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Chlorine (cont'd):
Phillips 66, Region 8
Western Zirconium, Region 8
Coronado Generating Station, Region 9
Dole Packaged Food, Region 9
Pioneer Chlor Alkali, Region 9
All Pure Chemical, Region 10
BP Oil, Region  10
ITT Rayonier, Region 10
Chloroform:
    67-66-3
Rhone-Poulenc, Region 3
Chromic Acid:
    11115-74-5
Kason Industries, Region 4
Phillips 66, Region 8
Copper Cyanide:
    544-92-3
Carl Falkenstein, Region 3
Kason Industries, Region 4
Creosote:
    8001-58-9
Koppers, Region 5
Koppers, Region 8
Cumene Hydroperoxide:
    80-15-9
General Electric Plastics, Region 5
Cyclohexane:
    110-82-7
Phillips 66, Region 6
Cyclohexanone:
    108-94-1
Syncom Technologies, Region 8
o-Dichlorobenzene:
    95-50-1
Mobay, Region 3
Dinitrotoluene (mixed isomers):
    25321-14-6
Mobay, Region 6
Epichlorohydrin:
    106-89-8
Hercules Chemicals, Region 1
Ethyl Acrylate:
    140-88-5
Rohm & Haas, Region 3
McWhorter, Region 10

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Ethylene Dichloride:
    107-06-2
BASF (NY), Region 2
Kodak, Region 8
Ethylene Oxide:
    75-21-8
BASF (NJ), Region 2
Ferric Chloride:
    7705-08-0
Jones Chemical, Region 1
Chevron, Region 10
Formaldehyde:
    50-00-0
Hercules Chemicals, Region 1
Farmland Industries, Region 6
Neste Resins, Region 10
Formic Acid:
    64-18-6
Hercules Chemicals, Region 1
Hydrazine:
    302-01-2
Astrotech, Region 4
Virtex Chemical, Region 4
Hydrochloric Acid:
    7647-01-0
Jones Chemical, Region 1
LCP Chemicals, Region 1
Monet, Region 1
Original Bradford Soap Works, Region 1
Upjohn, Region 1
BASF (NY), Region 2
Automata, Region 3
Carl Falkenstein, Region 3
LCP Chemicals, Region 3
Mobay, Region 3
Purolite, Region 3
Rhone-Poulenc, Region 3
Olin, Region 4
Photocircuits, Region 4
Fermenta ASC, Region 6
Phillips 66, Region 8
Western Extrusion, Region 6
JEMM Plating, Region 8
SAS Circuits, Region  8
Western Forge, Region 8
Pioneer Chlor Alkali, Region 9
Chevron, Region 10
Hydrogen Cyanide:
    74-90-8
W.R. Grace, Region 1

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Hydrogen Fluoride:
    7664-39-3
Columbia Falls Aluminum, Region
Phillips 66, Region 8
Motorola, Region  9
Ultramar, Region 9
BP Oil, Region 10
Hydrogen Peroxide:
    7722-84-1
Olin, Region 3
ITT Rayonier, Region 10
Hydrogen Sulfide:
    7783-06-4
Royster Phosphates, Region 4
Citgo Refinery, Region 6
Sid Richardson Carbon, Region 6
Amoco Production, Region 8
Amoco Refinery, Region 8
Hydroquinone:
    123-31-9
Du Pont Agrichemicals, Region 2
Rohm & Haas, Region 3
Lead:
    7439-92-1
Monet, Region 1
Maleic Anhydride:
    108-31-6
McWhorter, Region 10
Mercury:
    7439-97-6
LCP Chemicals, Region 1
LCP Chemicals, Region 3
Oxychem, Region 3
Olin, Region 4
Methanol:
    67-56-1
Du Pont Agrichemicals, Region 2
Mobay, Region 3
Tull Chemicals, Region 4
General Electric Plastics, Region 5
Fermenta ASC, Region 6
Neste Resins, Region 10
Methomyl:
    16752-77-5
Jacobson Warehouse, Region 7
Methyl Chloride:
    74-87-3
Fermenta ASC, Region 6

-------
Methylene Chloride:
    75-09-2
Chief Supply, Region 6
Great Lakes Chemical, Region 6
SAS Circuits, Region 8
Western Forge, Region 8
Methyl Ethyl Ketone:
    78-93-3
Carolina Solite, Region 4
SAS Circuits, Region 8
Syncom Technologies, Region 8
Western Forge, Region 8
Methyl Isobutyl Ketone
    108-10-1
Western Zirconium, Region 8
Methyl Isocyanate:
    624-83-9
Rhone-Poulenc, Region 3
Methyl Methacrylate
    80-62-6
Rohm & Haas, Region 3
Monomethylamine:
    74-89-5
Rhone-Poulenc, Region 3
Monomethyl Hydrazine:
    60-34-4
Astrotech, Region 4
Naphthalene:
    91-20-3
Koppers, Region 5
Exxon Refinery, Region 6
Nickel:
    7440-02-0
Monet, Region 1
Nickel Chloride:
    7718-54-9
Monet, Region 1
Kason Industries, Region 4
Nickel Sultate:
    7786-81-4
Monet, Region 1
Kason Industries, Region 4

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Nitric Acid:
    7697-37-2
Jones Chemical, Region 1
Bacardi Rum, Region 2
Automata, Region 3
Mobay, Region 3
Kason Industries, Region 4
Western Extrusion, Region 6
JEMM Plating, Region 8
Kodak, Region 8
Western Forge, Region 8
Nitric Oxide:
    10102-43-9
Eticam, Region 9
Nitrogen Dioxide:
    10102-44-0
Mobay, Region 3
Eticam, Region 9
Perchloroethylene:
    127-18-4

Phenol:
    108-95-2
Western Forge, Region 8
General Electric Plastics, Region 5
Neste Resins, Region 10
bis-Phenol:
    4418-66-0
General Electric Plastics, Region 5
Phosgene:
    75-44-5
Upjohn, Region 1
Mobay, Region 3
Rhone-Poulenc, Region 3
General Electric Plastics, Region 5
Great Lakes Chemical, Region 6
Olin, Region 6
Phosphine:
    7803-51-2
Jacobson Warehouse, Region 7
Phosphoric Acid:
    7664-38-2
Royster Phosphates, Region 4
Western Extrusion, Region 6
Chevron, Region 8
Kodak, Region 8
Phosphorus Pentoxide:
    1314-56-3
Columbia Organic Chemicals, Region 4

-------
Phosphorus Trichloride:
    7719-12-2
W.R. Grace, Region 1
Phthalic Anhydride:
    85-44-9
Koppers, Region 5
Potassium Cyanide:
    151-50-8
Monet, Region 1
Kason Industries, Region 4
JEMM Plating, Region 8
Potassium Hydroxide:
    1310-58-3
Carl Falkenstein, Region 3
Oxychem, Region 3
Kason Industries, Region 4
Propylene Oxide:
    75-56-9
BASF (NJ), Region 2
Sodium Azide:
    26628-22-8
Virtex Chemical, Region 4
Sodium Cyanide:
    143-33-9
W.R. Grace, Region 1
Carl Falkenstein, Region 3
Columbia Organic Chemicals, Region 4
JEMM Plating, Region 8
Sodium Fluoroacetate:
    62-74-8
Tull Chemicals, Region 4
Sodium Hydroxide:
    1310-73-2
Fall River Waste Treatment, Region 1
Hercules Chemicals, Region 1
Jones Chemical, Region 1
LCP Chemicals, Region 1
Monet, Region 1
Original Bradford Soap Works, Region 1
Bacardi Rum, Region 2
Du Pont Agrichemicals, Region 2
Automata, Region 3
Carl  Falkenstein, Region 3
LCP Chemicals, Region 3
Olin, Region 3
Oxychem, Region 3
Purolite, Region  3
Cape Coral Water Treatment, Region 4
Kason Industries, Region 4
Olin, Region 4

-------
Sodium Hydroxide (cont'd):
 Photocircuits, Region 4
 Tull Chemicals, Region 4
 Virtex Chemical, Region 4
 Best Foods, Region 5
 Koppers, Region 5
 Exxon Refinery, Region 6
 Fermenta ASC, Region 6
 Great Lakes Chemical, Region 6
 Olin, Region 6
 Kodak, Region 8
 Phillips 66, Region 8
 Dole Packaged Food, Region 9
 Pioneer Chlor Alkali, Region 9
 All Pure Chemical, Region  10
 ITT Rayonier, Region 10
Sodium Hypochlorite:
    10022-70-5
 Jones Chemical, Region 1
 LCP Chemicals, Region 1
 Du Pont Agrichemicals, Region 2
 LCP Chemicals, Region 3
 Fermenta ASC, Region 6
 All Pure Chemical, Region 10
Sodium Nitrite:
    7632-00-0
 Virtex Chemical, Region 4
Styrene:
    100-42-5
 Polysar, Region 1
 Purolite, Region 3
. Phillips 66, Region 6
Sulfur Dioxide:
    7446-09-5
 Jones Chemical, Region 1
 Olin, Region 4
 Royster Phosphates, Region 4
 Great Lakes Chemical, Region 6
 Amoco Production, Region 8
 Chevron, Region 8
 Ultramar, Region 9
 BP Oil, Region 10
 ITT Rayonier, Region 10

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Sulfuric Acid:
    7664-93-9
Hercules Chemicals, Region 1
Jones Chemical, Region 1
LCP Chemicals, Region 1
Monet, Region 1
Upjohn, Region 1
Bacardi Rum, Region 2
BASF (NY), Region 2
Du Pont Agrichemicals, Region 2
Automata, Region 3
LCP Chemicals, Region 3
Mobay, Region 3
Olin, Region 3
Oxychem, Region 3
Purolite, Region 3
C & S Chemicals, Region 4
Cape Coral Water Treatment, Region 4
Kason Industries, Region 4
Olin, Region 4
Photocircuits, Region 4
Royster Phosphates, Region 4
Virtex Chemical, Region 4
Best Foods, Region 5
Koppers, Region 5
Citgo Refinery, Region 6
Exxon Refinery, Region 6
Great Lakes Chemical, Region 6
Sid Richardson Carbon, Region 6
Western Extrusion, Region 6
Chevron, Region 8
JEMM Plating, Region 8
Kodak, Region 8
Koppers, Region 8
Phillips 66, Region 8
SAS Circuits, Region 8
Western Forge,  Region 8
Coronado  Generating Station, Region 9
Dole Packaged Food, Region 9
Magma Copper, Region 9
Pioneer Chlor Alkali, Region 9
ITT Rayonier, Region 10
Sulfuric Acid (Fuming):
    8014-95-7
Bacardi Rum, Region 2
BASF (NY), Region 2
Sulfur Trioxide:
    7446-11-9
Royster Phosphates, Region 4
Toluene:
    108-88-3
BASF (NY), Region 2
Du Pont Agrichemicals, Region 2
Carolina Solite, Region 4
General Electric Plastics, Region 5
Western Forge, Region 8

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Toluenediamine:
    25376-45-8
Mobay, Region 3
Toluene Diisocyanate:
    91-08-7
Mobay, Region 3
Olin, Region 6
Syncom Technologies, Region 8
1,1,1-Trichloroethane:
    71-55-6
Chief Supply, Region 6
SAS Circuits, Region 8
Vanadium Pentoxide:
    1314-62-1
Royster Phosphates, Region 4
XyJene (mixed isomers):
    1330-20-7
Du Pont Agrichemicals, Region 2
Carolina Solite, Region 4
Fermenta ASC, Region 6
Syncom Technologies, Region 8
Western Forge, Region 8
o-Xylene:
    95-47-6
Koppers, Region 5
Exxon Refinery, Region 6
Zinc Cyanide:
    557-21-1
Carl Falkenstein, Region 3

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