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 ------- 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 ------- 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 ------- 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. ------- 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; ------- Ill • 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 ------- 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. ------- 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 ------- 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. ------- 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. ------- 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. ------- 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. ------- 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. ------- 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 ------- 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. ------- 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. ------- 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 ------- 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 ------- 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. ------- 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). ------- 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. ------- 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. ------- 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. ------- 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 ------- 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. ------- 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: ------- 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: ------- 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 ------- 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. ------- 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. ------- 24 • 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: ------- 25 • 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: ------- 26 • 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. ------- 27 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: ------- 28 • 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. ------- 29 • 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; ------- 30 • 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: ------- 31 • 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. ------- 32 • 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. ------- 33 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. ------- 34 • 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. ------- 35 • 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: ------- 36 • 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. ------- 37 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. ------- 38 • 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. ------- 39 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 ------- 40 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. ------- 41 • 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. ------- 42 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. ------- 43 • 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. ------- 44 • 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 ------- 45 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. ------- 46 • 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. ------- 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. ------- 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. ------- 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. ------- 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. ------- 51 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. ------- 52 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. ------- 53 • 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: ------- 54 • 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. ------- 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 ------- 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). ------- 57 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. ------- 58 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. ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- |