55019911A
THE CHEMICAL SAFETY AUDIT PROGRAM:
           FY 1991 STATUS REPORT
        APPENDIX D: CHEMICAL SAFETY AUDIT REPORT PROFILES
                      Prepared for

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

-------
                                         APPENDIX D

                        CHEMICAL SAFETY AUDIT REPORT PROFILES


Region         Facility and Location                                       Page

1              Jones Chemicals, Merrimac, NH                               1
               Monet Crystal Brands, Pawtucket, RI                          9
               LCP Chemicals, Orrington. ME                               15
               Hercules, Inc., Chicopee, MA                                 25
2              BASF, Rensselaer, NY                                       33
               Du Pont Agrichemicals, Manati, PR                           41
               Bacardi Rum, San Juan, PR                                  47
               Goodyear, Niagara Falls, NY                                  55
               BASF, Washington. NJ                                       63
3              Occidental Chemicals, Delaware City, DE                      73
               Rohm & Haas, Bristol, PA                                   85
4              Olin Corporation, Charleston, TN                             93
               Photocircuits. Atlanta, Peachtree City, GA                     109
               Kason Industries, Newnan, GA                               119
               C & S Chemical Company, Austell, GA                       129
               Carolina Solite, Norwood, NC                               137
               Oldover Corporation. AJbemarle, NC                         149
               Tull Chemical Company, Oxford, AL                         159
               Vinex Chemicals, Bristol, TN                                169
               Water Treatment Plant, Cape Coral, FL                       179
               Canal Pumping Station. Cape Coral, FL                       189
               Columbia Organics, Camden,  SC                             199
5              General Electric Plastics, Mt.  Vernon, IN                      209
6              Exxon Refinery, Baton Rouge, LA                            217
               Olin Chemicals. Lake Charles. LA               .             225
               Sid Richardson Carbon Co., Borger, TX                       235
               Citgo Refinery, Lake Charles, LA                            243
7              ICI Americas, Omaha, NE                            .       255
               Jacobson Warehouse, Des Moines, 1A                         267
8              Amoco Casper Refinery.  Casper.  WY                         281
               Western Zirconium, Ogden. UT                              291
               Jemm Plating, Co., Denver, CO                               301
               SAS Circuits, Littleton, CO                                  309
               Kodak-Colorado Division, Windsor, CO                       317
               Col. Falls Aluminum, Columbia Falls, MT                     327
               Syncom Techologies, Mitchell, SD                            337
9              Unocal Chemical. Brea, CA                                  345
               Coronado Generator, St.  Johns, AZ                           351
               Ultramar, Inc., Wilmington. CA                              359
               Magma Copper, Inc., San Manuel, AZ                        369
               Pioneer Chlor Alkalai, Henderson, NV                        379
               Dole Packaged Foods. Honolulu. HI-                         387
               Motorola, Phoenix, AZ                                      397
 10             ITT Rayonier, Port Angeles. WA                            407
               BP Oil Company, Ferndale. WA                             423
               Neste Resins, Springield, OR                                 435
               Unocal Chemicals. Kcnai. AK                               447
               Chevron USA, Richmond Beach, WA                      .  457

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Jones Chemicals,  Inc.
Facility Location:
Merrimack, Hillsborough  County, New
Hampshire, Region  1
Date(s) Audit Conducted:
March 20, 1990
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
2812 -- Alkalies and chlorine

Located in an industrial zone adjacent to
the Boston & Maine Railroad and west of
the Merrimack River.
Supplier/manufacturer of chemicals for
non-residential swimming pools, municipal
water and sewage treatment, and industrial
users.
Shopping malls, a residential area, and
the Daniel Webster Highway are all within
1/2 mile of the facility.  Within one mile
are several apartment complexes, a grammar
school, junior high school, and high
school, and the F.E. Everett Turnpike, a
major traffic artery.  The population
within a five mile radius is 40,000.
Reason for Facility Selection:
      ARIP Reports:
The audit focused primarily on chlorine
process and storage areas due to four
chlorine releases that occurred at the
facility between October 1986 and February
1990.   One aqueous sodium hydroxide
release occurred in November 1988.

Sodium Hydroxide: 11/04/88 -- ID// 19653
Chlorine':         10/17/86 -- No ID//

-------
Focus of Audit:

      Hazardous Substance(s)
      Examined:                      Chlorine
                                     Nitric  acid
                                     Sulfur  dioxide
                                     Sulfuric  acid
                                     Ammonium  hydroxide
                                     Ferric  chloride
                                     Hydrochloric acid
                                     Sodium  hydroxide
                                     Sodium  hypochlorite

Physical Area(s) Examined
at the Facility:

      Storage and Handling

      •     Storage Systems

            Liquid chlorine is stored  in  ten  90-ton railroad  tank cars.

      •     Shipping /Receiving

            The facility receives chlorine  in 90-ton railroad tank cars and
            has the ability to off-load two cars at a time.  Normally, only
            one car is handled at any  given time.  Boston & Maine Railroad
            personnel are responsible  for all railcar movement.  Jones
            Chemical personnel are responsible for checking stationary cars to
            ensure that wheels are chocked and safety systems are in place.

            The following materials  are repackaged into 15 and 55 gallon drums
            on-site:

                        Nitric acid  (received in 3,000/5,000 gallon bulk
                        containers);

                        Sulfuric acid  (received in 20,000 gallon railroad tank
                        cars);

                        Ferric chloride (received in 3,000 gallon bulk
                        containers);

                        Hydrochloric acid (received in 3,000 gallon bulk
                        containers);

                        Potassium hydroxide (received in 4,000 gallon bulk
                        containers);

                        Sodium hydroxide  (received in 3,000 gallon bulk
                        containers); and

-------
                        Sodium hypochlorite  (produced by reaction of chlorine
                        with diluted sodium  hydroxide).

            In addition to repackaging sodium hypochlorite in 15 and 55 gallon
            drums,  Jones also ships this substance  in tank trucks having 4,500
            to 5,000 gallon capacities.  Sulfur dioxide is received in one-ton
            containers at the facility, and  is not  repackaged.  The facility
            plans to deplete its supply of ammonium hydroxide and will not
            reorder the chemical.

      Process Area(s)

      Jones Chemical employs 19 people and operates on a five day single-shift
      operation.  The facility consists of three buildings: a combined office
      and warehouse, a manufacturing plant,  and a storage shed.   Chlorine
      repackaging into both 150-pound and one-ton steel cylinders takes places
      within the manufacturing plant.   Dry compressed air at approximately 120
      psi is piped into a railroad tank car  containing chlorine forcing the
      liquid chlorine out through two 2-inch pipes  which are routed to five
      fill stations (two stations for filling one-ton steel cylinders and
      three for the 150-pound cylinders).   The three piping systems involved
      in the chlorine repackaging process include a supply line  fo.r the liquid
      chlorine, a blowdown line for evacuating the  chlorine under pressure
      from tank cars, cylinders, or pipes,  and a vacuum line for removal of
      chlorine gas from areas that are not under pressure.

      Sodium hypochlorite is produced through two manufacturing  methods at the
      facility.  In the first method,  liquid chlorine and 50 percent aqueous
      caustic soda are reacted under pressure in a  reactive chamber,  or
      "Powell Machine."  The second method involves recovering chlorine gas or
      liquid from the vacuum or blowdown lines and discharging the  material
      into a 3,500-gallon tank of caustic soda.   This process is controlled by
      manual monitoring of the solution's pH.
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     Personnel are on-site only during normal working hours  leaving the
            plant unattended on nights and weekends.  The facility  is  not
            completely fenced, and does not have a gate to prevent  vehicles
            from entering the property.  For these reasons,  the  plant  and
            outside chemical storage areas, including railcars,  are vulnerable
            to mischief,  vandalism,  or deliberate damage.

      Process Information

      •     Major improvements are needed in the drum storage area.  The area
            lacks proper drainage and is not paved or diked.

-------
•     No lights or other warning indicators are used during  railcar
      unloading operations.

•     The point at which responsibility for emergency response shifts
      from Boston & Maine Railroad personnel to Jones Chemicals
      personnel during chlorine delivery by rail is uncertain.  Boston  &
      Maine Railroad's release contingency plans do not address
      emergencies involving stationary railcars.

•     Personnel involved with connecting-disconnecting operations on the
      chlorine railcar are equipped with gloves, hard hats,  eye
      protection, and full faced cartridge-type escape respirators.

•     The chlorine railcars are not equipped with remote-operated
      emergency shut-off valves.

•     Pipes, valves, and fixed tanks used for transport or storage of
      hazardous chemicals are not sufficient_y color-coded or labeled
      for proper identification of their contents.

•     The facility does not scrub exhaust gases; rather,  contaminated
      air and odors are released directly to the atmosphere.

•     No continuous chlorine monitoring devices are used in  the railroad
      unloading area or other locations where chlorine is used in large
      quantities.

•     Monitoring and leak detection is performed by manual
      instrumentation checks.

Chemical Accident Prevention

•     Personnel from the corporate headquarters perform safety audits at
      the facility; facility personnel also conduct inspections daily,
      weekly, and monthly.  Safety equipment inspections  are  performed
      monthly and transportation inspections are carried out  at least
      once each year.

•     SOPs require that at least two workers remain within visual  range
      and voice-communicating distance during unloading operations.   No
      other form of communication (e.g.,  portable radios)  is  provided.

•     Piping connections to the chlorine railcars are  made in the
      morning and disconnected each evening.   Normally,  there are  three
      people on-site in the morning when the lines  are  connected;  two
      are on the railcar itself and the third remains  inside  the plant
      away from the unloading station.  During lunch break,  the system
      remains charged except valves at the railcar  are  shut off.

•     Empty 150-pound cylinders and one-ton liquid  chlorine containers
      are returned to the Merrimack plant for refilling.   Before the
      repackaging process can be repeated,  the interior of each cylinder

-------
      and container is inspected and cleaned.  If necessary, valves are
      replaced.

•     Jones Chemicals offers a chlorine safety training seminar  for all
      those who work with chlorine at the facility.  This seminar  is
      also available at no cost to outside organizations and companies
      working with chlorine.

•     Prior to each refill of the one-ton liquid chlorine containers,
      one of the fusible pressure release plugs is removed, cleaned, and
      inspected and, if found to be in satisfactory condition, they are
      reinstalled in the cylinder.  One of the plugs is replaced
      regularly on a rotating basis.  The chlorine containers are
      pressure tested every four years.

•     Before filling operations begin each day, every connector,  flange,
      and valve is checked for chlorine leaks with aqueous ammonia.  The
      facility estimates that they find one or two small leaks a week.

•     The installation of expansion chambers on the chlorine lines has
      not been completed.  The expansion chamber was not in service
      during the audit.

•     To prevent overfilling of 150-pound cylinders and one-ton
      containers,  the scale that is used for the measuring process is
      checked every day with standard-weight cylinders.

•     A Safety Committee meets monthly at the facility.   In addition,
      safety meetings are held with plant personnel and company drivers
      at least once a month.

•     One major release resulted from a failure in a concrete
      containment resulting in sodium hydroxide being released to the
      soil.

Accident Release Incident Investigation

•     One fuse plug from a one-ton liquid chlorine container had  not
      been rescrewed tightly.   The plug blew off the container  as it was
      being filled with chlorine causing an accidental  chemical  release.
      Jones Chemical has since assigned additional personnel to verify
      the tightness of the plugs.

•     The 19 percent aqueous caustic soda used in sodium hypochlorite
      production is contained within two vats that can  be  operated as
      separate systems, but are linked by a crossover.   In one  incident,
      an operator pumped all the caustic into one of the vats.  The vat
      overflowed into a floor drain and overwhelmed a sump.  Four to  six
      inches of caustic solution collected on the concrete  floor  of the
      sump building.  The caustic  was contained in a concrete  enclosure,
      and a decision was made to leave the spill  on the  floor until the
      following Monday.  By Monday,  .the caustic solution had drained

                               . 5

-------
      through the floor.  The facility later replaced  the  valve
      connecting the two vats with a new valve of a different  design.
      The operator was disciplined for his actions.

Facility Emergency Preparedness and Planning Activities

•     There are four self-contained breathing apparatus  (SCBA) units  at
      the facility.  Six plant personnel are trained in  emergency
      response operations.  The plant depends on the local  fire
      department for assistance in the event of an accidental  release.
Recommendations:

Process Information

•     The facility should improve the drum storage area by installing a
      drainage system and by paving and diking the area.

•     The plant should install a warning beacon for use during railcar
      unloading operations.

•     Self-Contained Breathing Apparatus (SCBAs) should be made
      available to Jones Chemicals personnel involved with the
      connecting/disconnecting operations on the chlorine railcar.

«     All pipes,  valves, and fixed tanks used for transport or storage
      of hazardous chemicals should be color-coded and clearly labeled
      for proper identification of their contents.

•     The facility may want to install remote-operated emergency shut-
      off valves near the chlorine railcars.

•     The facility should consider scrubbing exhaust gases in the
      neutralization room.

•     Railroad unloading operations and other high chlorine use
      locations in the plant could be continuously monitored by Closed
      Circuit Television (CCTV).   This type of monitoring could also be
      used during the cylinder filling and hypochlorite operations.

•     The facility may want to consider using enhanced neutralization
      monitoring and detection systems (e.g., computerized controls  and
      gas detection systems).

Chemical Accident Prevention

•     While SOPs require workers to remain within visual range and
      voice-communicating distance, Jones Chemicals may want to provide
      portable radios for communication among personnel involved with
      the chlorine railcars.

-------
      •     Jones Chemical should consider pressure checking returned chlorine'
            cylinders with compressed air or inert gas prior to the refilling
            process.

      •     The facility should connect immediately the expansion chambers on
            the chlorine lines.

      •     The facility should pave its containment areas and install proper
            drainage to prevent leakage to the environment during an
            uncontrolled release.

      Accidental Release Incident Investigation

      •     The facility should consider investigating the use of a marker to
            color code the threads on fuse plugs in the chlorine cylinders and
            valves to insure the proper torque and prevent fuse blow out.
            Such color coding would enable personnel to visually see if the
            fuse plug screws are threaded to the proper distance (between 3 &
            8 threads exposed).

      •     The facility should investigate the use of a valve lockout or
            overflow protection in conjunction with the two caustic solution
            vats involved in the 11/4/88 accidental release.

      Facility Emergency Preparedness and Planning Activities

      •     Jones Chemicals should consider installing additional personal
            protection equipment at both the plant and office locations.   For,
            example,  two response teams could be given six SCBAs;  each team
            would be designated for a specific building and would consist of
            two response personnel with one backup.
Audit Team Member Composition:

Name and Title                Ray DiNardo
Affiliation                   EPA Region 1
Area of Responsibility        Team Leader
Expertise                     Environmental Engineer

Name and Title                Ken Ferber
Affiliation                   EPA Region 1
Area of Responsibility        Mechanical Systems
Expertise                     Environmental Engineer

Name and Title                Russell Hemstreet
Affiliation                   EPA Region 1
Area of Responsibility        Chemical Systems
Expertise                     Chemist

-------
Post-Audit Follow-Up Activities:

      By the Facility:

      By the Regional Office:

      Copies of the audit report have been forwarded to the SERC and to the
      LEPC.

      By State and Local Authorities:


Regional Contact:              Ray DiNardo

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Monet, Crystal Brands
Facility Location:
Pawtucket, Rhode Island, Region  1
Date(s) Audit Conducted:

Description of Facility:

      SIC Code(s):


      Location:
      Products manufactured,
      produced, or distributed:

      Proximity to
      sensitive populations:
Reason for Facility Selection:
      ARIP Reports:
Focus of Audit:

      Hazardous Substances(s)
      Examined:
June 20 - 21, 1990
3961 -- costume jewelry and costume
novelties, except precious metal.

The two facilities are located in a light
industrial area of Pawtucket,  separated by
1/2 mile; one on Newell Avenue, and the
other on Mineral Spring Avenue.
Fashion and costume jewelry
There are residences within 1/4 mile of
both facilities, and the Newell facility
is adjacent to a major interstate highway.

The facility was chosen because of two
anhydrous ammonia releases -- 291 pounds
on 05/23/89 and 250 pounds on 09/21/89.

Ammonia;  05/23/89 -- No ID#
          09/21/89 -- ID// 21841
Anhydrous Ammonia
Potassium Cyanide
Sulfuric Acid
Antimony (white metal)
Cadmium (white metal)
Copper Sulfate
Hydrochloric Acid
Lead (white metal)
Nickel
Nickel chloride
Nickel sulfate
Sodium Hydroxide

-------
      Physical Area(s) Examined
      at the Facility:

      Storage and Handling

      •     Storage Systems

            Anhydrous ammonia is stored outside in 500 gallon horizontal  tanks
            at both the Newell and Mineral Spring facilities.  Sulfuric acid,
            1,1,1-trichloroethane, and sodium hydroxide are received and
            stored in 55 gallon drums.  Hydrochloric acid is received and
            stored in 15 gallon carboys.  Potassium cyanide is received and
            stored in 30 gallon drums.  Potassium cyanoaurite is received in 5
            gallon containers and stored in a 60 gallon plating tank used in
            the manufacturing process.  Potassium copper cyanide is received
            in 5 gallon containers and stored in a 20 gallon plating tank used
            in the manufacturing process.

      •     Shipping/Receiving

            All shipments of chemicals are delivered by truck.

      Process Area(s)

      Newell Facility.  Anhydrous ammonia is used for annealing fashioned
      jewelry.  The annealing is done in a continuous,  b->lt-fed elecrvic oven.
      The oven uses a hydrogen-reducing atmosphere to p.  /ent discolo  ;ion.
      Ammonia from the outside ammonia tank is fed to the annealing oven
      through a pipe at regulated pressure.   Prior to startup and shutdown,
      the oven is purged with nitrogen to prevent an explosive  atmosphere.
      During operation, the oven is under positive pressure.

      Mineral Spring Facility.  Anhydrous ammonia is used for annealing in two
      batch ovens.  In addition, it is used as the hydrogen energy source  for
      soldering clips to pins, brazing,  and heating low temperature casting
      pots to prevent discoloration.


Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      Process Information

      •     At the present time, Monet uses a combustion  gas  analyzer to
            conduct ammonia monitoring.   Although this  instrument is useful as
            an indicator of whether an explosion could  occur,  it  is not
            reliable as a concentration indicator.   An  ammonia  detector tube
            would provide a more accurate indication of concentrations  at
            various locations.

                                      10

-------
•     The ammonia tanks at both facilities are situated  in  locations
      that are difficult for fire apparatus and emergency responders  to
      immediately access and commence mitigation activities.

•     During colder seasons, the ammonia is heated by electrically
      heated liquid which recirculates through tubing immersed  in the
      tanks.  During normal operations, pressure in the  tanks is
      maintained between 60 and 90 psi.  At the time of  the audit
      (June),  the pressure in one tank was 110 psi and the  immersion
      heater was on.  The audit team advised Monet of these unusual
      conditions.

•     The ammonia tank at the Mineral Spring facility is surrounded on
      three sides by industrial facilities approximately 3-4 stories
      high.  The only outside access to the ammonia tank is along an
      industrial road or alley, that is frequently restricted or blocked
      due to loading or unloading of trucks to other industrial
      facilities.

•     The facility has no capability for detecting wind direction (e.g.,
      wind socks)  near the ammonia storage tanks at either facility.

Chemical Accident Prevention

•     No formal safety committee exists at the facility.

•     The ammonia tanks are inspected weekly by Monet environmental  or
      maintenance personnel.  A questionnaire is filled out  after each
      inspection and a sulfur stick is used around the tank  and tank
      fittings to detect ammonia leaks.

•     The ammonia tanks at both facilities are owned by the  supplier,
      who is responsible for their maintenance.

•     Safety and loss prevention,  as well  as accident/near miss  review,
      are the responsibility of both engineering and human resources
      departments.  All new chemicals must be reviewed and approved  for
      safety by an internal review board prior to  use  at  any Monet
      facility.

•     A new employee training and review program has been initiated
      within the past few months.   The new program establishes  a minimum
      level of employee training.   A training review is conducted
      annually and prior to employee promotion.  Training records are
      maintained in the human resources department.

Accident Release Incident Investigation

•     The two releases under review required the evacuation  of both
      facilities.   The incident of 09/21/89 involved the  evacuation  of a
      residential area of approximately 1/4 mile around the  Newell
      facility.

                                11

-------
•     The Mineral Spring facility release was the result of a  leaking
      valve.  The valve is a bleed valve which is normally open during
      the filling of the tank.

•     The Newell facility release was the result of a leaking  valve
      gasket at the level gauge.  The tank had been replaced by the
      vendor two weeks prior to the accidental release, and was replaced
      after the incident by the vendor.

•     No formal policy exists at Monet to require incident reports for
      all chemical accidents and near misses.

Facility Emergency Preparedness and Planning Activities

•     The facility emergency plan is in the process of being updated; it
      currently consists of several contingency plans bound together in
      one folder.

•     The facility has no centralized hazardous materials storage area;
      no contingency measures exist in the emergency plans to handle
      storage of hazardous chemicals throughout the facility.

•     Monet has not conducted any drills or chemical accident
      simulations of the contingency plans.

•     At the time of the audit, the Newell facility had 2 air packs and
      2 level B protective suits.  The Mineral Spring facility had 3 air
      packs and 2 level B protective suits.

•     Environmental personnel assigned to the engineering department ire
      responsible for inspecting the air packs and protective  suits each
      week to ensure that they are operational and in good condition.

•     Two Monet personnel are required to respond to chemical
      emergencies at each site.

Community and Facility Emergency Response Planning Activities

•     The facilities engineering manager handles  Title III  requirements
      and is the section 302 facility coordinator.
Recommendations:

Process Information

•     Protective barriers should be installed in front of the Mineral
      Spring facility's ammonia storage tank to eliminate the potential
      for heavy truck traffic to accidentally impact and fracture  the
      tank.
                                12

-------
•     Monet should install a wind sock at both  facilities  at  strategic
      locations in the. vicinity of the ammonia  storage  tanks  to  enable
      emergency responders to detect wind direction.

•     Monet should consider purchasing an ammonia monitoring  device  to
      enable the facility to measure ammonia concentrations during
      accidental release mitigation activities  or process  upsets.

Chemical Accident Prevention

•     Monet should establish and maintain a formal safety  committee  with
      broad representation from management and  hourly workers.

•     Monet should install a water deluge system directly  above  both 500
      gallon ammonia tanks to immediately knock-down vapors in the event
      of an accidental release.  The system design should  reflect
      whether the deluge will be manually or automatically activated.
      The ultimate disposition of any contaminated runoff  must also be
      considered.  The deluge system is being recommended  because of the
      lack of accessibility to the ammonia tamks for emergency
      responders.

Accident Release Incident Investigation

•     Monet should initiate a formal policy requiring incident reports
      for all chemical accidents, near misses,   and safety  investigations
      involving chemical systems.  At a minimum, the report should
      identify what happened and the probable cause of the incident.
      Response, on-scene activities,  containment, cleanup, health
      effects, and prevention measures should also be included.

Facility Emergency Preparedness and Planning Activities

•     At a minimum, two fully equipped emergency responders are'required
      with a third fully equipped member of the team serving as  a backup
      at each site.  A third SCBA apparatus and personal protective
      equipment and training is needed at both Monet locations.  •

•     Monet should conduct periodic drills and chemical accident
      simulations to enable response personnel   to practice proper
      procedures for response and mitigation.   This will allow
      refinement of response procedures and provide for a more efficient
      response.

•     The facility should consolidate all hazardous material contingency
      measures into one easily accessible and readable plan.   The plan.
      should address the entire response and cleanup decision-making
      process, as well as notification, mitigation,  personal protection,
      response actions, facility .shutdown, evacuation,  and restoration.

•     The consolidated response plan should include a hazards  analysis
      and vulnerability zone calculations.

                                13

-------
            The plan should provide contingency measures to handle the current
            practice of storing cyanide and other hazardous chemicals in
            process areas throughout the Mineral Spring facility.
Audit Team Member Composition:

Name and Title                Ray DiNardo
Affiliation                   EPA Region 1
Area of Responsibility        Team Leader
Expertise                     Environmental Engineer

Name and Title                Ken Ferber
Affiliation                   EPA Region 1
Area of Responsibility        Mechanical Systems
Expertise                     Environmental Engineer

Name and Title                Russell Hemstreet
Affiliation                   EPA Region 1
Area of Responsibility        Chemical Systems
Expertise                     Chemist
Follow-up Activities:

      By the facility:

      By the Regional office:

      Copies of the audit report have been forwarded to the SERC and to the
      LEPC.

      By State and local authorities:


Regional Contact:             Ray DiNardo

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
LCP Chemicals
Facility Location:

Date(s) Audit Conducted:

Description of Facility:

      SIC Code(s):




      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
Orrington, Maine, Region  1

September 12 - 13, 1990
2812 -- alkalies and chlorine
2819 -- industrial inorganic chemicals
2879 -- pesticides and agricultural
        chemicals

12 acre site along the Penobscot River,
five miles south-southwest of Bangor, ME
Liquified chlorine gas and sodium
hydroxide and hypochlorite solutions
There are residences within a one-half
mile radius and four schools within a 1.5
mile radius of the facility.
Reason for Facility Selection:
      ARIP Reports:

Focus of Audit:

      Hazardous Substances(s)
      Examined:
The facility was chosen because it
experienced two chlorine gas releases
within a short time frame (15 pounds on
10/04/88 and 300 pounds 12/23/89), and the
facility produces and stores large
quantities of hazardous substances.

10/4/88 and 12/23/89
Chlorine
Hydrochloric Acid
Sodium Hypochlorite
Chloropicrin
Sodium Hydroxide
Hydrogen Gas
Sulfuric Acid
Mercury
Nitromethane •
                                      15

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      Chlorine  is stored in  three  24,000-gallon  chlorine  receiver tanks
      equipped  with dual pressure  relief valves.   The  tanks  are
      pressure-tested every  three  years.  They are located in an
      unbermed  area, and a storm drain  is located  adjacent to the tanks.

      Chloropicrin is stored in two  6,000-gallon tanks  located in an
      unbermed  area on the extreme west side of  the  facility.  The tanks
      are in poor structural condition and are located  at  the top of a
      slope which leads to the Penobscot River.  A storm drain which
      empties into the river is located in close proximity to the tanks.

      Hydrochloric acid is stored  in ten 15,000-gallon  tanks  grouped
      together  in an unbermed area near the north  side  of  the facility.

      Sodium hydroxide is stored in  two 350,000-gallon  tanks  located in
      a bermed  area.  The tanks are  insulated to prevent the  caustic
      .from freezing.  Sodium hypochlorite is stored  in  two 25,000-gallon
      tanks near the chloropicrin  facility and there is a  2,500-gallon
      tank of sodium hypochlorite  in the cell building.

•     Shipping/Receiving

      Chlorine  railcars arrive at  the facility and are moved  to  the
      loading area by the plant's own locomotive.  Each car takes
      approximately six hours to fill.  There is no capture system to
      contain liquid spilled in the  loading shed.  Normally,  ten  filled
      cars (179,000 to 180,000 pounds each) accumulate on  the  rail
      siding before being removed.   Chloropicrin is loaded onto  30-ton
      railroad  cars in the loading shed.

      Hydrochloric acid is pumped directly to the  loading  shed before
      being loaded into railcars or  trucks.  No means of containing
      spilled material was observed  in the railcar and truck  loading
      areas.  Truck drivers  are required to wait in the lunch room
      during vehicle loading.

      Sodium Hydroxide is loaded into railcars in  the loading shed or
      into trucks at a location near the two tanks.  Sodium hypochlorite
      is  loaded into trucks  near the larger storage tanks; neither the
      tanks nor the loading  area have the ability  to contain
      hypochlorite in the event of a release.
                                 16

-------
Process Area(s)

Chlorine - LCP produces chlorine by the electrolytic  decomposition  of
brine using the mercury cell process.  Chlorine gas is  formed  at  the
positive anode and sodium/mercury amalgam  is  formed at  the  negative
anode.  The chlorine gas formed is contaminated with  water, brine,  and
other materials.  It is cooled, then the gas  goes  through a mist
eliminator, followed by three drying towers,  where chlorine flows
countercurrent to a mist of sulfuric acid, which absorbs the water
vapor.  The gas then goes through a mist eliminator to  remove  residual
sulfuric acid, then through four compressors, two  after-coolers, and two
liquefaction units.   Liquified chlorine is then sent  to one of the
receiver tanks, while unliquified tail gases  are sent to the
hypochlorite reactor.

Chloropicrin - Chloropicrin is formed by contacting sodium  hypochlorite
with nitromethane.   The reaction is instantaneous, and the  Chloropicrin
is readily separated from residual reactants  in a phase separator.
Although the process is continuous, the manufacturing shed  is  not
continuously occupied;  alarms for the process are wired to  the control
room, but the exact nature of the emergency condition is not identified.

Hydrochloric Acid -  Chlorine gas and hydrogen gas are combusted in an
inverted vertical reactor.  Hydrogen chloride gas is contacted with
deionized water to form hydrochloric acid in  the block absorber section
of the acid plant.   Unabsorbed HC1 gas and noncondensable gases pass on
to the tails tower,  which is a packed absorption column.  HC1 gas is
absorbed to form weak acid.   The noncondensable gases pass through a
brine scrubber before being vented from the system.

Sodium Hydroxide -  The amalgam formed at the cathodes of the
electrolytic cells is a solution of sodium in mercury.  The liquid flows
out of the cells into a denuder or decomposer, a vertical cylinder
filled with crushed graphite.  Water flows countercurrent to the
amalgam, reacting with the sodium to form sodium hydroxide,  and fresh
mercury is returned to the cells.   Some of the hydroxide is diluted for
use in sodium hypochlorite manufacturing or in the brine treatment
system; the remainder is stored in tanks.

Sodium Hypochlorite - Sodium hypochlorite is formed by contacting the
sodium hydroxide solution with uncondensed chlorine tail gas,  in  part to
act as a capture system for chlorine.
                                17

-------
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     The plant can be operated by a minimum of  five  people,  including
            one supervisor.  During weekends and holidays,  the minimum  number
            are present; on weekdays, a maintenance  team  is  also  available.   A
            limited number of people are available to  deal  with emergency
            situations.

      •     Access to the plant is by a paved road with an  unattended gate,
            and a gravel road with a locked gate.

      •     The Penobscot River is approximately 100 feet down grade from  the
            chloropicrin process and storage area, and is highly  vulnerable  to
            contamination from an accidental release.

      Chemical Hazards

      •     The facility maintains libraries of MSDSs  in  the administration
            building and the process control room.

      •     The facility provides on-going health monitoring, including
            urinalysis testing, and records are maintained by the safety and
            training supervisor.

      Process Information

      •     Two chlorine detectors, connected to an audible alarm system, are
            located in the cell room.  No other environmental monitoring
            systems were observed; the facility depends on operators to detect
            (through sight, odor, etc.) hydrochloric acid, sodium
            hypochlorite, and chloropicrin releases.

      •     No continuous monitoring of the chlorine system exists to ensure
            acceptable moisture readings and to prevent corrosion.  LCP said
            that such monitoring had been in place previously.

      •     In case of power failure, the plant has a backup generator that is
            tested weekly and a secondary substation.  There are,  however,  no
            procedures to ensure that the backup power will be distributed to
            critical systems to minimize the likelihood of a release.

      •     LCP did not provide assurances that hydrogen levels in the waste
            hydrogen stack, generated as a manufacturing byproduct,  could not
            accumulate near the plant during periods of atmospheric  stagnation
            or inversion; potentially resulting in a fire or explosion
            creating damaging overpressure to chemical systems.
                                      18

-------
•     LCP does not monitor or record explosion  limits  for  oxygen  or
      hydrogen levels.  The facility does not provide  documentation  that
      waste hydrogen in the air from the manufacturing process will  not
      approach the explosive range during normal  or upset  operating
      conditions.

•     Deficiencies in coding and identification of hazardous materials
      pipes, tanks, and vessels were identified in the pipe bridge
      loading areas and in isolated areas throughout the plant.

•     The only computerized control system is for the  electrolytic cells
      to control anode to cathode spacing.  The control room is occupied
      by only one individual, who oversees large volumes of extremely
      hazardous chemicals and complex sequencing of events.

•     The air intake for the control room is vulnerable because it is
      frequently downwind of chemical process and storage areas.

Chemical Accident Prevention

•     The plant has received plaques from CMA and the  Office of the
      Governor in honor of achieving one million man-hours without time
      lost due to an occupational accident.

•     New plant employees are given training which includes procedures
      for working with hazardous chemicals,  use and care of safety
      equipment, emergency procedures,  and plant safety policy.

•     The plant employs a full-time safety and training supervisor,  who
      conducts facility inspections and prepares a safety work report
      that describes potential problem areas.   These observations  are
      discussed with maintenance,  and a schedule for mitigation of the
      problem is established.

•     New and reassigned employees receive on-the-job training from an
      experienced employee and the shift supervisor.   The  supervisor
      reviews the employees'  progress frequently and identifies  those
      areas where additional training is required.

•     Annual training is provided on release reporting, emergency
      procedures,  the DuPont STOP safety program to  eliminate  unsafe
      work practices, hazard communication,  contractor  safety,  and
      specific health and safety issues.

•     Supervisors hold monthly safety meetings for their  employees to
      discuss safety issues and review new safety  policies  and
      procedures.

•     Supervisor training is conducted during the  monthly  supervisor's
      meeting, as well as discussions of recent incidents  and  potential
      impacts of process and procedural changes.
                                19

-------
Maintenance is performed on an as-needed basis,  although  a
preventive maintenance plan is in the process of development.

Release prevention consists primarily of inspecting plant
equipment to detect leaks and other signs of fatigue.

The safety work order system effectively ensures that potentially
hazardous situations are addressed in a timely manner.

Release mitigation systems include a supply of soda ash for  acid
spill neutralization, catch basins to trap/contain spills and
return them to the process where possible, and a supply of process
water to be used during a power outage.

Apart from a chlorine tank leak repair kit, no spill containment
kits, absorbent berms, or similar equipment were  observed.

Consultants conducted safety audits of the facility in 1985 and
1988.

A consultant has performed vulnerability zone calculations and
modelling.

HAZOP studies are also conducted by plant personnel, as well as
informal "What If" discussions during supervisor meetings.

Standard facility hazard identification and release prevention
practices include assessing processes and equipment relative to
industry standard practices;  Chlorine Institute  and CMA
recommendations; and industry and facility experience,  safety
alerts, and incident reports  for similar processes and equipment.

The following observations were made by the audit team in the
chloropicrin manufacturing process:

      There are insufficient  fail-safe systems and operating
      controls for critical parameters in the control room;
      The control room is not continuously attended by an
      operator;
      Rust was present on process vessels and piping;
      The bulk product storage tanks appeared to be in poor
      structural condition, and were not diked;  and
      The bulk chloropicrin tanks are located in close  proximity
      to a storm drain.

The hydrogen gas dump stack is not equipped with water  sprays to
cool the stack in the event of a fire.

While there is a closed-circuit television camera at the  main
entrance, the plant is not fenced around the perimeter  and
unauthorized access is possible from the railroad and adjacent
property.  There are no security guards or check—ints.

                          20

-------
Accidental Release Incident  Investigation

•     On October 4, 1989, a  failure  in  the  compressed  air  system caused
      a chlorine release.  As a follow-up to  the  release,  an  automatic
      valve that could be activated  from the  control room  was installed
      to minimize the duration of a  similar chlorine release.

•     The December 23, 1989, chlorine release was caused by the  exposure
      of the hydrogen gas line and flow meter to  extreme low
      temperatures, resulting in moisture in  the  hydrogen  line
      condensing and freezing.  Steam tracing was added upstream of  the
      flow sensor to prevent condensation from forming in  the  line.

•     The shift supervisor completes a written report on all  accidental
      releases and near-misses.  The report is reviewed by supervisory
      and technical personnel, and corrective actions are  identified.
      Reports are kept in the administration building.

Facility Emergency Preparedness and  Planning Activities

•     All operations personnel and supervisors wear walkie-talkies in
      lieu of audible or visual warning systems.

•     The facility emergency response team  is also the Chlorine
      Institute's regional CHLOREP team.  The team has 12 Level A and 12
      Level B suits, and a variety of chlorine release control kits,
      which can contain gas  from leaking tanks and tank car fill ports.

•     The facility has 16 SCBAs in the plant,  three are dedicated to use
      by the emergency response team and one is in the control room.

•     The response team receives at  least 24 hours of training annually
      in hazmat identification, hazard evaluation, emergency and
      protective equipment and procedures,  and incident review analysis.

•     The emergency response plan is undergoing review and revision;  at
      the time of the audit, notification procedures and the contingency
      plan were completed in draft form.

•     The emergency response plan was last tested in 1987;  the plant
      does not conduct drills.

•     In case of an emergency, 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.

•     Employees are encouraged to take first aid and CPR at company
      expense.  A first-aid station  is equipped at the  plant,  but a
      nurse is at the facility only periodically.
                                21

-------
Community and Facility Emergency Response Planning Activities

•     The plant technical manager is on the Penobscot  County LEPC.

•     Experience in release incidents among local responders is  limited.
      As members of the regional CHLOREP team, LCP response team members
      frequently provide training to local personnel on chlorine
      releases.

•     Outside assistance may be necessary during emergency situations
      for traffic control, evacuations, and technical  assistance since
      operations personnel also serve as response personnel.  The
      facility may need assistance from experts on environmental
      monitoring, cleanup, and other areas not directly related  to plant
      operations.

Public Alert and Notification Procedures

•     Although state and federal authorities were notified of both
      recent releases, the Hampden Civil Preparedness  Department and the
      Orrington Fire Department were not notified after the 12/23/89
      release.

•     The shift supervisor reports release incidents involving large
      quantities to the plant's technical manager, who notifies  the
      appropriate authorities.  The audit team verified that LCP did not
      provide immediate notification of the 12/23/89 release.
Recommendations:

Facility Background Information

•     Because all five personnel are needed for routine operation, LCP
      needs to develop a strategy for immediate operational assistance
      during emergency situations.

Process Information

•     LCP should reinstate continuous hygrometer readings in the
      chlorine system to ensure acceptable moisture readings critical
      for corrosion control and the prevention of equipment failure.

•     LCP should monitor and record explosion limits and oxygen and
      hydrogen levels using continuous monitoring equipment to increase
      process and safety control and to minimize explosion potential.
      The facility should provide documentation to fire and safety
      officials that waste hydrogen in the air from the manufacturing
      process will not approach the explosive range during normal or
      upset operating conditions.
                                22

-------
•     LCP should consider installing continuous monitoring and recording
      devices for chlorine at the unloading areas, tank farm, and other
      chlorine use areas, as well as in the control room.  Existing
      monitors in the cell room need to be improved and upgraded.

•     The plant should determine what utilities should be allocated
      emergency power on a priority basis in the event of a power
      failure.  A power distribution plan and methods for implementing
      the plan should be developed.

•     Identification of hazardous materials pipes, tanks, and vessels
      should be improved to assist potential emergency response efforts.

•     LCP should consider installing computerized controls for the
      chlor-alkali control room to continuously monitor operating
      conditions and set points and automatically alert the operator of
      conditions that deviate from the norm.

Chemical Accident Prevention

•     The procedure for updating process flow diagrams and process
      instrumentation diagrams should be improved.

•     As a follow-up to the audit team's observations, LCP should
      conduct a hazard assessment of the chloropicrin process and
      storage area and implement upgrades on a priority schedule.

•     To reduce the potential for a large chlorine release,  LCP 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 bulk loading rack.  The valve could be activated at the
      loading rack and another remote location.

•     At a minimum, additional camera coverage is needed at  high hazard
      areas throughout the plant.   The cameras should be monitored at
      the control room and one additional location in the  facility.

•     The preventive maintenance program should be upgraded  to include
      routine replacement of critical parts based on a history of
      failure rather than on observation of actual signs of  failure.
      LCP should include routine pipe inspections for hazardous
      materials lines and a program to test pressure relief  devices.

Facility Emergency Preparedness and Planning Activities

•     Alarms, beacons, and audio-visual warning devices are  necessary to
      alert employees of an accidental release.   Alarms should be
      activated locally at the point of release by an employee and
      automatically by a gas detector.   The alarm should be  read at  the
      chlor-alkali control room and the office.
                                23

-------
      Community and Facility Emergency Response Planning Activities

      •     LCP should increase involvement of municipal and regional
            emergency response personnel in actual or near-miss events.

      Public Alert and Notification Procedures

      •     The revised facility contingency plan should establish guidelines
            and procedures for notifying local authorities and the general
            public in the event of a release.  Notification procedures should
            be tested on a priority basis.
Audit Team Member Composition:

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Ray DiNardo
EPA Region 1
Team Leader
Environmental Engineer

Ken Ferber
EPA Region 1
Mechanical Systems
Environmental Engineer

Russell Hemstreet
EPA Region 1
Chemical Systems
Chemist

Gary Riggott
TAT, EPA Region 1
Technical Reviewer
Chemical Engineer
Follow-up Activities:

      By the facility:

      By the Regional office:

      Copies of the audit report have been forwarded to the SERC  and to  the
      LEPC.

      By State and local authorities:
Regional Contact:
Ray DiNardo

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Hercules Chemicals
Facility Location:

Date(s) Audit Conducted:

Description of Facility:

      SIC Code(s):



      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
Reason for Facility Selection:
      ARIP Reports:

Focus of Audit:

      Hazardous Substances(s)
      Examined:
Chicopee, Massachusetts, Region 1

December 17 - 18, 1990
2821 -- plastics materials,
synthetic resins, and non-
vulcanizable elastomers

Mixed commercial/residential area
just outside of Springfield, 30
miles north of Hartford,
Connecticut, and one half-mile east
of the Connecticut River
Kymene, Hercons, Paracols,  and
Defoamers -- chemicals used in paper
and paper product manufacturing
industry
The facility is located in a heavily
populated area with 30,000 people
within a one mile radius.

The facility was chosen because of a
release of 6,000 pound of
concentrated sulfuric acid on
03/09/90, and based on the potential
for other releases.

03/09/90 release of sulfuric acid
Adipic acid'
Aqueous ammonia
Caustic soda
Epichlorohydrin
Formaldehyde
Formic acid
Sulfuric acid
                                      25

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      Most raw materials and products of the Kymene process  are  stored
      in a tank farm adjacent to the process building.  At the  tank
      farm, incompatible materials are physically separated  by  concrete
      berms with locked, closed drains.  The epichlorohydrin tank  is
      located outside in a horizontal position, and a berm contains
      water in the summer months to reduce volatilization of material  in
      case of a tank rupture.  Fuel oil used for space heating  is  the
      only material stored in underground tanks.  Storage of product
      emulsions is located in a covered tank farm attached to the
      emulsion production area.

•     Shipping/Receiving

      Shipments of chemicals to and from the facility are conducted by
      truck or rail.  There are two truck and three rail liquid  loading
      and off-loading locations.

•     Material Transfer

      Formal transfer procedures are adhered to in the transfer of  all
      liquid chemicals entering the facility.  The material  is verified
      by shipping papers.  The proper valve hookup is checked and the
      receiving tank is checked for sufficient volume.  The  connecting
      valve is unlocked by a supervisor and the transfer is  documented.
      In-house liquid transfers are conducted with similar but less
      formal procedures.  Tanks in the tank farm are filled via overhead
      piping and are discharged at ground level locations.

Process Area(s)

Kymene resins are manufactured by batch in two 5,000 and two  3,000
gallon reactors.  Reacting materials are added to the reactor by either
pipe or dry conveyer; liquid chemicals are measured by dedicated scale
tanks or flow meters.  Process reaction temperatures are controlled by
steam heating and water cooling coils in the reactor vessels.  Mixing is
accomplished by an electrically operated agitator or with bubbled
nitrogen as a backup.

Hercons and Paracols are produced in the emulsion process area,  and are
typically made of wax, starch, and water.   Small quantities of hazardous
materials  (e.g., sulfuric acid) are used for product finishing.
Emulsification of the water, wax, and starch is accomplished with a
high-pressure orifice homogenizer.   Blending and product finishing steps
are conducted in one of four tanks.
                                26

-------
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     The facility has a weather station capable of measuring wind  speed
            and direction, but this data  is not recorded or  stored.

      •     The plant normally operates with 3 eight-hour shifts.  The day  and
            second shifts operate with approximately eight operators including
            supervisors, while the night  shift consists of four operators and
            no supervisors.

      Process Information

      •     There are no emergency backup water or electric  utilities to
            maintain plant operations in  the event of service disruption;
            emergency battery-powered lighting is provided.

      •     There are no automatic fail-safe systems to backup the
            computerized central controls.

      •     There are no environmental monitoring systems for organic vapors
            or ammonia.

      •     At least two processes using hazardous chemicals are exothermic
            and temperature critical; presently each reactor has one
            thermocouple.

      •     Computer controlled processes are easily changed to manual
            operation for emergency shutdown, and reactions  that have critical
            isotherms can be quenched by redundant techniques.   Such
            techniques  include gravity-fed water baths available to cool  the
            reactor in  the event of a temperature excursion,  or nitrogen  perch
            systems used to provide back up reactor agitation in the event of
            a mixer failure.

      •     The facility is undergoing a major renovation (anticipated
            completion  in late 1991) that includes installation of a
            computerized central control room,  new monitoring and measurement
            equipment,  tank relocations,  and diking and piping changes.

      Chemical Accident Prevention

      •     Site access is restricted by a surrounding chain link fence.   The
            rail car entrance gate is locked during normal  business
            operations, except for entry or exit of rail  cars,  but the  main
            entrance is open during business hours and is not monitored.

      •     Prior to the sulfuric acid release,  overfill  piping and dead-man
            switches were in place for several chemicals  systems.

                                      27

-------
Management structure is designed to allow direct  contact between
the plant safety and environmental compliance  coordinator  and  the
plant manager.  Both conduct frequent meetings  to discuss  worker
safety and accident prevention issues.

The facility safety and environmental coordinator develops  and
implements in-house safety training programs,  conducts  in-house
safety audits and preliminary reviews of all process design
modification work orders, conducts Title III coordination
activities, and reviews all accidents and near-misses.

Corporate personnel conduct an annual safety loss inspection and
an environmental audit as well as spot safety  inspections.  The
facility also conducts its own periodic safety audits.

Hercules sponsors corporate safety contests with  cash prizes and
awards and publishes periodic safety bulletins.

There are no positive pressure and explosion proofing provisions
included in the design of the control room.   Supplied air is not
available in the control room for operators to perform an orderly
and safe shutdown in the event of an emergency.

Because normal batch operations typically run through personnel
shift changeovers, incoming shift is briefed on current process
information and specific batch characteristics or problems during
the five minute shift overlap.   Formal batch information sheets
are maintained on all facility processes.

Repairs and scheduled maintenance activities are coordinated under
a formal work order system.  Work orders are prioritized for
completion during a weekly meeting;  repairs  or modifications which
affect safety are given top priority.   No formal preventive
maintenance program or instrument calibration program exist at
Hercules.

New salaried employees receive a minimum of  sixteen hours  of
general facility training including videotapes, reference  manuals,
and lectures.  Additional specialized training is provided to
employees working in specific process areas.

Supervisors receive general and process-specific training,  and
some have attended Dupont's STOP training,  a program designed to
reduce accidents by enabling line employees  to stop unsafe  work
practices of their co-workers.   The corporation is currently
considering STOP training for all of its employees.

Hercules has a general, broad-based program  on contractor
orientation concerning chemical hazards at the facility, as well
as process specific training depending on the location and  type of
work to be performed.
                          28

-------
•     Hercules conducts periodic employee training sessions  to maintain
      employee awareness.  The sessions also serve to  formally introduce
      the employees to modifications in safety procedures.   Although
      currently.scheduled on an as needed basis, a more  formal training
      program is scheduled for implementation in the 1991 calendar  year.

•     Corporate personnel have conducted numerous hazard evaluation
      studies for the facility, including HAZOPs and "What If," but the
      audit team did not have access to the study results.

•     Processes using epichlorohydrin and formaldehyde have  been
      evaluated for release hazard potential.  Worst-case releases  have
      been modeled and show no impact to off-site populations and the
      environment according to the facility.  However,  these reports
      were not available for review by the audit team.

•     The truck loading location near the epichlorohydrin storage tank
      includes a spill containment berm, but no other loading.and off-
      loading facilities provide spill containment measures.   If a  large
      spill were to occur during transfer operations, the material would
      most likely flow to storm drains that are directly connected  to
      the city sewer system,  as did the 03/09/90 sulfuric acid spill.

Accidental Release Incident Investigation

•     Hercules compiles the information generated from the incident
      reports and uses them to prepare corporate safety policy and
      design and operation modifications.   They also disseminate  the
      information to other Hercules facilities which use similar
      processes or similar system designs.

•     A release occurred when an operator was charging  sulfuric acid to
      a scale tank.  The operator left the control platform momentarily
      with the charge pump on,  and overcharged 6,000 pounds  of sulfuric
      acid.  The excess acid flowed through the Kymene  production room
      drain directly to the Chicopee sewer system.

•     Subsequent to the 03/09/90 release,  all scale tanks were  fitted
      with overfill piping which returns excess material to  respective
      storage tanks.  In addition,  operator hold-down (dead-man)
      switches have been installed for activation of all scale  tank fill
      pumps and flow meters.

Facility Emergency Preparedness and Planning Activities

•     Hercules has prepared a comprehensive emergency response  plan for
      the facility addressing public notification procedures, chain of
      command structure, health and medical services, evacuation  routes,
      hazardous substance locations and characteristics,  spill  control
      techniques, and spill cleanup resources.
                                29

-------
•     The plan does noc provide hazardous substance air release
      modelling data specific to the facility.

•     Although Hercules has Scott Air Packs, escape respirators, and
      rubber rain suits, this personal protective equipment  is not
      sufficient to provide the level of protection needed to respond  to
      a major release at the facility.

•     The facility does not have any plant-wide alarm system in  the
      event of a chemical release.

Community and Facility Emergency Response Planning Activities

•     Hercules is a member of the Chicopee Manufacturer's Association,
      which regularly conducts chemical emergency preparedness and
      planning activities.  Hercules has also held a public open house.

•     The facility does not have a fire brigade or an emergency response
      team, and relies on the local fire department to respond to both
      hazardous material and fire incidents.  A joint fire
      department/facility drill is being planned for 1991.
Recommendations:

Process Information

•     The facility should consider the installation of chemical
      monitoring and detection systems for safety, emergency egress, and
      fugitive emissions assessment.

•     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.

•     Hercules should conduct an interlock study and incorporate
      appropriate automatic fail-safe systems to the computerized
      central controls, as well as additional monitors and alarms.

Chemical Accident Prevention

•     Security needs to be evaluated and upgraded.  The facility should
      consider television monitoring at the main and rear gates tied
      into a central control room to minimize the possibility of
      unauthorized entry to a hazardous materials area.

•     The control room project should be given a high priority for
      funding and completion since the modernization project will give
      the operators additional tools to prevent process upsets and
      accidental releases.
                                30

-------
      •      The control room designers should consider including provisions
            for positive pressure, and explosion proofing.  In addition, the
            control room should have supplied air available to the operators
            to enable them to perform and orderly and safe shutdown in the
            event of an emergency.

      •      Hercules should establish a formalized preventive maintenance
            program to assure the integrity of critical parts used in
            hazardous materials service.   A formal instrument calibration
            program is recommended for equipment used in the processing of
            hazardous materials.

      •      Hercules needs to implement a more formalized safety training
            program for non-supervisory personnel.

      •      Contractor orientation needs  to be chemical-specific,  explaining
            exposure limits, toxicity and flammability information as well as
            decontamination procedures,  escape respirators,  alarms,  and
            evacuation procedures.

      •      The facility needs to consider developing secondary containment
            areas suitable for treatment  or neutralization of spills prior to
            discharge to the local wastewater treatment plant.

      Facility Emergency Preparedness and Planning Activities

      •      Hercules should assess the adequacy of the existing personal
            protective equipment  on-site,  including the number  of  units,
            location, type,  and maintenance procedures to provide  for  adequate
            protection during emergency operations.

      •      A plant-wide alarm system should be installed to  provide  alert and
            notification in the event of  a chemical release.

      Community and Facility Emergency Response Planning Activities

     • •      Available hazards analysis and risk assessment results should  be
            communicated to the local fire department and LEPC,  including
            dispersion modeling estimates and vulnerability distance
            calculations for hazardous chemicals used and stored.

Audit Team Member Composition:

Name and Title          Ray DiNardo
Affiliation             EPA Region 1
Area of Responsibility  Team Leader
Expertise               Environmental Engineer

Name and Title          Ken Ferber
Affiliation             EPA Region 1
Area of Responsibility -Mechanical Systems
Expertise               Environmental Engineer

                                      31

-------
Name and Title          Russell Hemstreet
Affiliation             EPA Region 1
Area of Responsibility  Chemical Systems
Expertise               Chemist

Name and Title          David Toralinson
Affiliation             TAT, EPA Region 9
Area of Responsibility  Technical Assistance
Expertise               Chemist
Follow-up Activities:

      By the facility:

      By the Regional office:

      Copies of the audit report have been forwarded to the SERC and to ;..e
      LEPC.

      By State and local authorities:


Regional Contact:             Ray DiNardo
                                      32,

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:


Facility Location:
BASF Corporation, Chemicals Division
Rensselaer, New York, Region 2
Date(s) Audit Conducted:
August 21-24, 1989
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
2865 -- dye and pigment manufacturing

The facility is in a mixed use
industrial/commercial area, approximately
10 miles southeast of Albany on the
eastern shore of the Hudson River.
azo (nitrogen-containing) and ultra-violet
sensitive dyes used as chemical
intermediates in the manufacture of
textiles, paper, and sun-screen products
Private residences and schools are within
a quarter-mile of the plant.
Reason for Facility Selection:
      ARIP Reports:
Focus of Audit:

      Hazardous Substance(s)
      Examined:
The facility was chosen because they had
seven accidental releases of hazardous
substances (including toluene)  from April
1987 and July 1988,  and their close
proximity to the Hudson River,  a major
recreational/navigational waterway.

4/13/87 phosphoric acid release,  9/10/87
hydrogen chloride release,  and 11/03/87
toluene release
Hydrochloric acid
Sulfuric acid
Toluene
Ethylene dichloride
Oleum
                                     • 33

-------
      Physical  Area(s)  Examined
      at  the  Facility:

      Storage and Handling

      •     Storage  Systems

           Bulk liquids  are kept in storage tanks.   Small quantities of other
           materials  are stored in the warehouse.

           All raw  materials stored in the warehouse are segregated by the
           type and compatibility of like chemicals.

      •     Shipping/Receiving

           Raw materials arrive in placarded railroad tank cars,  placarded
           tank trucks,  metal or plastic 55 gallon  drums, and dry bags.

           Liquid products  are drummed and solid products are bagged for
           shipment.

      •     Material Transfer

           Gravity  feed  is  used for transferring bulk liquid raw  materials
           into agitated kettles (reactors) and from the reactors into
           further  processing steps.
      Process Area(s)

      The major process areas consist of simple  batch reactors  that use
      gravity-feed for transferring/receiving bulk liquid raw materials  into
      agitated kettles (reactors),  which are  tnen mixed with various other
      solid raw materials.   These reactions produce either a liquid or a solid
      product.  Liquid products are drummed for  shipment,  and solid products
      are transferred  to filter presses  for chemical dewatering,  drying,  and
      bagging for shipment.   The excess  ethylene dichloride that  did not react
      is separated out by the pressure filter and piped to a distillation
      column for recovery.
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     There is currently no seismic- activity  in the  area  of  the
            facility, but a minor local  fault line  is located approximately
            125 miles to the south.
                                      34

-------
Process Information

•     The facility is actively seeking less hazardous  substitutes  for
      its existing chemicals.

•     The color coding of process pipes is incomplete  in many  areas.

•     There are no positive  indicator valves on chemical pipelines.

•     The facility uses ball valves in its material transfer piping.
      Ball valves tend to be more reliable and do not  leak as  readily as
      other valves, such as  gate valves.

•     Process control is centrally located to each production  area,
      providing for visual monitoring of the production line for leaks
      and other upset conditions.

•     BASF has not conducted an internal design study  of the current
      spacing of reactors to determine if there is adequate space for
      workers to move about  safely and for emergency response  personnel
      to function in the event of an incident.

•     Alarm systems for the manufacturing systems, especially  the
      reactor vessels, have  redundant back-ups, e.g.,   audible  alarms
      have flashing red lights.

Chemical Accident Prevention

•     Periodic safety meetings are convened to  discuss safety  issues and
      concerns and new regulations or company policies.

•     The facility has in-place detailed SOPs and step-by-step
      directives for all production and materials handling personnel.
      These SOPs cover all aspects of plant operation  from receipt of
      raw materials to the shipping of final product.

•     Training of new employees in chemical safety and prevention is
      provided, and consists of both formal courses and on-the-job
      training.  Training for both newly hired  and established employees
      is mandatory.  New employees undergo training in basic  safety
      orientation, employee right-to-know information,  hazard
      communication, videotape plant tours,  and manufacturing process
      familiarization.  All employees attend various company-sponsored
      training specific to their jobs,  from janitors to top management.
      However, no training is provided to non-employees who frequent the
      facility, such as tank truck drivers and  other vendors.

•     Preventive maintenance is actively undertaken in some operations.
      However, the current preventive maintenance programs  for  the
      plant's reactors, pipelines, tanks and valves are inadequate.   The
      facility does have a written preventive maintenance  plan, which
      includes provisions for routine replacement of valves and pressure

                                35

-------
      vessels.   The preventive maintenance procedures  specify,  in
      detail,  how maintenance is to be performed.  BASF estimates  that
      25 percent of all facility maintenance is preventive maintenance.
•     Equipment involved in the handling or processing of chemicals  is
      constantly monitored, and replacements/adjustments made
      accordingly, e.g., pumps with linings found to be incompatible
      with materials have been replaced with ones that are compatible.

•     The high temperature alarms on reactor vessels in Building 82, a
      UV production area, are not test-tripped on a regular basis.

•     Release prevention systems are in-place throughout the facility
      including check valves in pipelines, catch basins for chemical
      run-off during spills, and fire suppression and extinguisher  ,
      systems.

•     The facility has an extensive storm water drainage system used
      throughout the grounds.  This drainage system connects directly to
      a holding/aeration pond on the facility grounds.  Releases
      directly to the ground either go into the drainage system or are
      flushed into the system.   The material goes to the holding pond
      for aeration where it is subsequently "metered" into, the sewer and
      then to the POTW.

Accidental Release Investigation

•     The facility had seven previous accidental release incidents.   The
      facility conducted its own release investigation which included a
      management interview of all employees involved,  a review of SOPs.
      and remedial counselling/training as appropriate.   In addition,
      any "lessons learned" are implemented and discussed in detail  at
      the monthly safety meetings.

Facility Emergency Preparedness and Planning Activities

•     The company fire chief is not involved in the  development or the
      review of the facility's SPCC plan.

•     A response team has been formed for minor incidents  such as small
      spills and valve and pipe leaks;  however,  the  team is  not prepared
      to handle major spills and incidents.

•     The facility fire department members are also  members  of the  town
      volunteer fire department, and have received extensive  training.

•     Personnel assembly points and wind socks are on-site.   While
      exercise drills are held periodically,  drills  for major incidents
      have not been conducted.
                                36

-------
      •     There are no floor plans posted in the plant, and  there  is  no  map
            of the plant's exits and alarm boxes.  In addition,  facility
            buildings are not clearly identified.

      •     All essential personnel are required to carry pagers and there is
            also an in-plant public address and emergency signal system.
            Furthermore, all facility vehicles are equipped with two-way
            radios and key plant personnel carry two-way radios.

      •     The facility does not have a meteorological station, an  anemometer
            or a real-time wind direction monitor.

      Community and Facility Emergency Response Planning Activities

      •     BASF participates in a detailed, workable joint response/mutual
            aid program with other facilities in its immediate vicinity.

      Public Alert and Notification

      •     The facility has no public alert system in place.   Notification of
            an emergency is handled by the local police department and local
            fire department upon notification from BASF.
Recommendations:

      Process Information

      •     Additional color coding of process pipes in many areas is
            recommended to distinguish between substances in the pipes.

      •     The use of positive indicator valves in pipelines handling
            chemicals is recommended to prevent misreading of the settings,
            i.e., "open" and "closed."

      •     BASF should initiate an internal design study of the current
            spacing of reactors to determine if there is adequate space  for
            workers to safely move about and for emergency response personnel
            to function in the case of an incident.

      Chemical Accident Prevention

      •     Training should be instituted for non-employees who frequent the
            facility, such as tank truck drivers and other vendors.

      •     BASF needs a better preventive maintenance program for their
            reactors, pipelines, tanks and valves.

      •     High temperature alarms on reactor vessels in Building 82, a UV
            production area, should be test-tripped on a regular basis.
                                      37

-------
      •     BASF should continue its program of waste minimization and
            chemical substitution of less hazardous materials for chemicals  in
            use.

      Facility Emergency Preparedness and Planning Activities

      • -     The facility SPCC plan should be reviewed periodically by the
            company fire chief.

      •     Practice drills should consider more catastrophic scenarios such
            as a major train derailment near BASF chemical storage warehouse.

      •     Floor plans should be posted on each floor in each manufacturing
            area and should clearly indicate the locations of all exits and
            alarm boxes.  Furthermore, facility buildings should be clearly
            numbered for ease of identification for outside first responders,
            fire departments, and other emergency personnel.

      •     The facility should install a meteorological station, to include
            an anemometer and a real-time wind direction monitor.
Audit Team Member Composition:

Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Paul Kahn
US EPA Region 2
Emergency preparedness -  Process
PI. t inspections,  re-lease prevention,  chemicals
processes, and Title III

Angel Rodriguez
US EPA Region 2
Safety and Loss Prevention -  Process
Equipment and preventive  maintenance

Joe Cosentino
US EPA Region 2
Process and release related t--hniques
Water pollution,  monitoring,   astewater
treatment, and chemistry

Charles Fitzsimmons
US EPA Region 2
Process and SPCC
Chemical engineering
                                      38

-------
Follow-up Activities:




      By the Facility:




    •  By the Regional Office:




      By State and local authorities:






Regional Contact:             Ellen Banner
                                      39

-------
40

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:


Facility Location:
Du Pont Agrichemical Caribe, Inc.  (DPACI)
Manati, Puerto Rico, Region 2
Date(s) Audit Conducted:
January 9-10, 1990
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:

      Proximity to
      sensitive populations:
Reason for Facility Selection:
      ARIP Reports:

Focus of Audit:

      Hazardous Substance(s)
      Examined:
2879 -- agricultural chemicals

A suburban, semi-rural area on the north
coast of Puerto Rico.
Pesticides
A new housing subdivision is located one
half-mile from the facility.  A lagoon and
mangrove swamp are within one-half mile of
the facility.

The facility had a 300 gallon xylene
release from an overfilled tank.truck
which was exacerbated by employees hosing-
down the spill with water, resulting in
the release becoming an 81,000 gallon
clean-up.  In addition, isocyanate
compounds used in the manufacturing
process are potentially deadly substances.

None.
Xylene
Sodium hydroxide
Sulfuric acid
Chlorine
Hydroquinone
Toluene
Methanol
Sodium hypochlorite
Isocyanates

-------
Physical Area(s) Examined
at the Facility:

      Storage Systems

      •     Shipping/Receiving
            Incoming hazardous substances arrive by  tank  trucks  (solvents  and
            liquid caustics), special containerized  tanks  (isocyanates),  fiber
            drums (flaked caustic), bags, and pressurized  cylinders.

            Material Transfer

            Raw materials are transferred from storage tanks via pipeline  to
            individual reactor vessels in predetermined amounts, depending on
            the particular product being made.
      Process Area(s)
            The major process areas are coupling and drying  (C&D), and
            formulation and granulation (F&G).   The C&D process involves the
            chemical coupling of an isocyanate compound to a heterocyclic
            compound to form a sulfonylurea-based herbicide.  The F&D process
            involves the centrifugation of the sulfonylurea material to drive-
            off solvent, the drying of the centrifugate,  and the packaging of
            the finished product.

            Once a reaction has been completed, the slurry is dumped into a
            centrifuge where the solid (cake) is separated from the liquid
            (carrier). The wet cake is discharged into a wet cake bin and then
            to a dryer.  Dried material is dumped into bins which feed a
            bagging system for the final product.
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     The geology of the area is karst, irregular limestone in which
            erosion has produced sink holes, fissures, and underground
            streams.  There is some seismic fault activity to the west of the
            facility, but the facility is not actually situated on a fault
            line.

      •     There is no history of flooding, but due to Puerto Rico's location
            in the hurricane zone of the south Atlantic, the island is brushed
            occasionally by hurricanes.  This chemical.safety audit was
            originally scheduled for September 1989, but tragically Hurricane
            Hugo struck Puerto Rico in September and the audit was postponed.

-------
•     The facility was built in 1975, occupies  350  acres  and  employs  210
      people on a 3-shift, 7 day a week basis.

Chemical Hazards

•     Facility management has MSDSs and other health  related
      documentation which fully explain the potential hazards  associated
      with the handling and processing of these chemicals.  This data  is
      available at various locations around the facility,  including
      control rooms, infirmary, Environmental Department,  and  receiving
      areas.

•     The facility maintains an in-depth and very 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, SOP, possible malfunctions, location and plot
     'plan, and an electrical check list.

•     Release prevention systems are in-place throughout  the facility.
      These include check-valves in pipelines, dust collectors, vapor
      sensors, explosion detectors, portable vacuum cleaners for dust
      spills, diking around storage tanks, catch basins for chemical
      run-off during spill incidents, fire suppression systems, and
      redundancy for critical control systems.

Process Information

•     The facility has not color coded all of its pipes.

•     The manufacturing process has remained unchanged for many years,
      and any adverse effects these chemicals may have on processing
      equipment, such as excessive corrosivity or embrittlement,  has
      long been noted and adjustments made accordingly,  e.g.,  pumps with
      linings found to be incompatible with materials have been replaced
      ones that are compatible.

•     Each reactor is automatically monitored by computer for specific
      parameters such as temperature, pressure,  weight,  and processing
      time .

•     Process control is centrally located for each production area.
      Because the processes are fairly simple,, they are somewhat  easy to
      monitor and control.

Chemical Accident Prevention

•     Management's role is one of establishing specific plans  and
      objectives within the overall scheme of the parent  corporation to
      meet corporate objectives.  To this'end, management at  both the
      parent and plant levels have established plant safety committees,

                                43

-------
      standards review boards and personnel, hazard evaluation decision
      tree scenarios,  training courses, corporate audits,  incident
      investigation teams, and accountability criteria  for managers.
      Committees and individuals review operations and  assorted
      chemical/safety hazards as needed, recommendations  to  improve,
      modify,  delete,  or amend these areas are classified by  type, e.g.,
      safety hazard, prioritized and given a date or time frame by which
      the change is to be completed.

•     The facility has written detailed SOPs and step-by-step directives
      for every individual aspect of manufacturing, from  the  receipt of
      all raw materials to the final shipping of product.  These SOP
      manuals are located at strategic areas of the facility.  Personnel
      roles and responsibilities are delineated, and phone numbers of
      key plant and response individuals are included in  the  SOP.

•     Training of new employees in chemical safety and prevention
      consists of both formal courses and on-the-job training (OJT).
      Because the DPACI storage policy increases bulk transportation of
      raw materials into the facility, DPACI has instituted a driver
      training/chemical awareness program for both employees and non-
      employees who frequent the facility and has emphasized educating
      those employees involved in off-loading hazardous substances.

•     The facility preventative maintenance plan is computerized,
      specifies how maintenance is to be performed on a particular piece
      of equipment, and includes a fault tree analysis,  HAZOP analysis,
      and routine replacement of valves and other equipment subject to
      frequent failure due to excessive use.

•     The holding times for the hazardous substances present on-site  is
      relatively short.  To preclude the storage of large quantities  of
      these substances, the facility had decided to use  more frequent
      replenishing rather than building more or larger storage tanks.

•     The bagging operation is conducted inside a clean room which is
      under a slight negative pressure to prevent fugitive dust
      emissions. A dust collector ensures that all process particulate
      will be controlled to air permit levels.

Accident Release Investigation

•     This facility has experienced only one reportable  accidental
      release.  The release involved 300 gallons of xylene from an
      overfilled tank truck.  The DPACI employee who was overseeing the
      filling of the truck left his post for a few minutes.   Upon his
      return he observed the spill occurring.  The initial reaction was
      to hose-down the xylene with large amounts of water, washing  the
      solvent into an adjacent culvert, and from there  into a sink-hole
      about 1,500 feet from the plant.  This action compounded the  spill
      by creating a larger amount of contaminated material (xylene  plus
      thousands of gallons of water, plus groundwater  in the  sink hole).

                                44

-------
      As soon as the release was terminated, clean-up activities  began
      by a contractor who vacuumed the liquid.  Subsequently,  330 cubic
      yards of contaminated soil was excavated and incinerated.   Lessons
      learned from this release resulted in enhanced training  for truck
      unloading operators and revised SOP to more clearly describe  spill
      containment procedures.

•     All chemical accidents are investigated by management and the
      plant safety committee.

Facility Emergency Preparedness and Planning Activities

•     The facility has a fully descriptive SOP for responding  to  any and
      all types of spills or releases that might occur.

•     Because the chemicals rarely change either quantity or type, the
      facility response plan is rarely changed.  Key areas cf  response
      and preparedness do not change often and the occasional  turnover
      of personnel is reflected in the listing of key contacts.

•     The SOP is to be followed in the event of a spill or release, but
      is not tested in regular drills or exercises.   Although  there are
      no practice drills, the local fire department is familiar with the
      facility and has conducted regular fire prevention inspections of
      all areas of the facility.

•     There is very little in the way of actual response hardware  other
      than spill clean-up kits.  DPACI relies on outside response
      capabilities for a major incident,  but is a member of the
      Community Awareness and Emergency Response (CAER)  program and has
      excellent ties to local response organizations.

Community and Facility Emergency Response Planning Activities

•     Notification procedures are in-place  for -warning the local  fire
      department and police department and  to effectuate an evacuation
      if warranted.

•     DPACI does not practice emergency drills with  either the  LEPC or
      local police and fire departments.

Public Alert and Notification Procedures

•     Public notification of a release or other emergency situation such
      as a fire is arranged through the local police  department and
      civil defense office.  There is a provision in  the response  SOP
      for designated facility personnel to  make door-to-door
      notifications in residential areas  directly adjacent to the
      facility.

-------
Recommendations:

      Process Information

      •     Additional color coding of pipes  transporting hazardous materials
            should be undertaken as new pipes are installed, rerouted, or
            replaced.

      Chemical Accident Prevention

      •     DPACI should continue to utilize  its extensive SOP manuals,
            computerized preventative maintenance plans, and policy of routine
            equipment replacement.

      •     DPACI should have its employees attend more hazardous materials
            training courses, with the eventual goal being the formation of
            its own hazmat team to respond to relatively minor incidents such
            as spills and valve and pipe leaks.

      Community and Facility Emergency Response Planning Activities

      •     DPACI should schedule practice drills with local police
            departments, fire departments, and the LEPC on at least an annual
            basis.
Audit Team Member Composition:

Name and Title                Paul Kahn
Affiliation                   USEPA
Area of Responsibility        Team Leader
Expertise                     PID, process flow, ARIP, prevention,  SOPs

Name and Title                Angel Rodriguez
Affiliation                   USEPA
Area of Responsibility        Team Member
Expertise                     Safety, training, SPCC, PM, SOPs
Follow-up Activities:

       By the Facility:

       By the Regional Office:

       By State and  local authorities:


Regional Contact:       Ellen Banner

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Bacardi Rum Incorporated
Facility Location:
San Juan, Puerto Rico, Region 2
Date(s) Audit Conducted:
January 11-12, 1990
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:

      Proximity to
      sensitive populations:
2085 -- distillers and blended liquors

An area of light industry and commercial
businesses, approximately three miles
northwest of the municipality of San Juan.
distilled spirits/151 proof rum
A school is located approximately one mile
south east of the plant.   A housing
development,  a lagoon,  and a mangrove
swamp are within one-half mile of the
plant.
Reason for Facility Selection:
      ARIP Reports:
The facility was chosen because they had a
chlorine release of 150 pounds from a
corroded gas cylinder on January 23,  1988.
In addition, the facility is near a
housing development and thousands of
tourists visit the facility during public
tours.

1/23/88 chlorine release
Focus of Audit:
      Hazardous Substance(s)
      Examined:
Sulfuric Acid
Sodium Hydroxide
Nitric Acid
Chlorine (gas)

-------
Physical Area(s) Examined
at the Facility:

      Storage and Handling

      •     Storage Systems

            All storage tanks are placarded and diked.   Incompatible  chemicals
            are segregated.

      •     Shipping and Receiving

            Incoming hazardous substances, except for chlorine,  arrive  at  the
            facility in tank trucks or 55 gallon drums.  The chlorine gas
            arrives in gas cylinders and are stored  ir.  the cylinders  on-site.
            The holding times for the chemicals is relatively  short.

      •     Material Transfer

            Raw materials are transferred from storage  tanks via pipeline  to
            individual process vessels in predetermined  amounts,  depending on
            the particular product being made.

            All piping and valves are located over a drainage  system, which
            directs liquids to a treatment facility.

      Process Area(s)

      Molasses  is mixed with a yeast/nutrient inoculation and  allowed to
      ferment.  At a certain point in the process, the fermentation is
      clarified, buffered to the desired pH with acid/caustic, distilled in a
      typical distillation column, and pumped to tanks to be aged.  After  a
      specific  period of time, the rum is bottled for wholesale  distribution.
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •      Because  this facility is at sea level, there is some history of
             flooding when hurricanes and tropical storms impact the island.
             This audit was originally scheduled for September, 1989, but
             tragically Hurricane Hugo struck Puerto Rico at that time and the
             audit was postponed.
                                      48

-------
Process Information

•     Pipelines are clearly tagged, but color  coding,  flow  direction
      indicators, and valve position  indicators  are  missing from  many
      pipelines.

•     The facility does not regularly  inspect  its  chlorine  gas  cylinders
      and does not maintain an inspection checklist

•     Generally,  no back-up systems exist at the facility.   A flare
      burns any process generated bio-gas so that  combustible gases
      cannot accumulate within the process.  There is  also  an on-site
      wastewater treatment process for ocean discharges, but this  is  not
      a true back-up system.

•     Process control is centrally'located for the production area and
      because the processes are simple they are somewhat easy to monitor
      and control.

•     Each reactor is automatically monitored by computer for specific
      parameters such as time, temperature, appearance, and  taste.

•     Operational logs are maintained for each shift and they are
      reviewed frequently by the shift foreman.  Any unusual occurrences
      are reported to the shift foreman, who in turn will either take
      direct action or notify higher authorities,  in accordance with  the
      facility's prescribed .emergency notification procedures.

•     Specifically, there are two areas of the facility that pose the
      greatest potential for an accidental chemical release: the gas
      cylinder storage area and the chlorine cylinder storage area.  All
      gas cylinders, including chlorine gas cylinders,  are stored
      against a wall located directly across a narrow street from an  in-
      plant gasoline station.   In the event of a fire or vehicle
      accident, one area may be adversely affected by incidents
      occurring at the other area, i.e., the compressed gas cylinders
      should not be stored close to the gas station.

•     Manuals contain somewhat detailed directives, but the system has
      many pre-set operating parameters that tend to eliminate  many
      manual operations from the control of operators who monitor
      consoles and react to computer prompts.

Chemical Accident Prevention

•     The facility conducts public tours 'but lacks  provisions to inform
      the tourists of the presence of hazardous chemicals,  nor  does the
      facility have any provisions to evacuate or safeguard the  health
      of tourists during an accidental release.  In addition, the
      facility has no provisions to assist handicapped visitors  in the
      event of a chemical emergency or fire.

-------
•     The facility has written detailed SOPs and step-by-step directives
      for all production and materials handling personnel.  These SOPs
      covers all aspects of plant operation from the receipt of raw
      materials to the final shipping of product.  Employees are fully
      trained,  classroom and on-the-job (OJT),  in the meaning and use of
      these SOPs.

•     Management has established plant safety committees and provides
      employees with periodic training and .-efresher courses.

•     There is no training program for non-employees who frequent the
      facility, such as truck drivers and other vendors.

•     The facility has a good written preventative maintenance (PM)
      plan.  Equipment maintenance includes provisions for routine
      replacement of valves and other equipment subject to frequent
      failure.   The PM program also involves SOPs that specify how
      maintenance is to be performed.   The facility estimates that PM
      accounts for 50 percent of all facility maintenance.

•     Release prevention systems are in-place throughout the facility.
      These include check-valves in pipelines,  diking around storage
      tanks, catch basins for chemical run-off during spill incidents,
      fire suppression systems,  and extinguisher systems.

•     Alarm systems have simple back-ups,  e.g.,  audible alarms also have
      flashing red lights.

•     To preclude storage of large quantities of hazardous  substances,
      the facility maintains a small inventory of hazardous substances
      and, instead, frequently replenishes its  stock of raw materials.

Accidental Release Investigation

•     The facility experienced only one reportable release  --  150  pounds
      of chlorine gas released from a breached  cylinder.

•     The release investigation revealed that the chlorine  gas  is  stored
      directly on the ground outside where they are  exposed to  high
      humidity, rain, and salt-laden sea air.   As a  result,  the bottoms
      of the cylinders began to corrode.   One cylinder  corroded to  the
      point where the internal pressure of the  cylinder blew out  the
      rusted bottom and the entire contents was  released directly  to  the
      environment.  Because the cylinder was stored  outside,  there was
      no way to contain the release and two employees were  injured;
      however, no evacuation of the public was  needed.   Had this release
      occurred during the day, the gas could have impacted  a tour group
      with possibly disastrous consequences.
                                50

-------
      Facility Emergency Preparedness and Planning Activities

      •     Inside the facility grounds, evacuation routes are not marked  and
            the emergency evacuation plan is not posted.

      • .    Very little response equipment other than spill clean-up  kits  is
            available at the facility.  In the event of a serious spill, fire,
            or release, the facility would rely completely on outside response
            organizations.

      •     All essential personnel are required to carry voice pagers  and
            there is an in-plant public address system.  All facility vehicles
            are equipped with two-way radios and key plant personnel  also
            carry two-way radios.

      Community and Facility Emergency Response- Planning Activities

      •     The facility conducts annual practice drills and the local  fire
            department is familiar with the facility and participates  in these
            drills.

      Public Alert and Notification Procedures

      •     Public notification is through the local police department  and the
            local civil defense office.  A provision in the facility's
            response SOP requires facility personnel to conduct door-to-door
            notifications in the residential areas directly adjacent  to the
            facility.
Recommendations:

      Process Information

      •     The compressed gas cylinders storage area should be relocated to
            an area some distance from the refueling point.

      •     The facility should construct an enclosure for the chlorine gas
            cylinders and store them out of direct contact with the ground and
            outside air.

    •  •     The facility should contact the chlorine gas supplier and devise a
            cylinder inspection checklist.  All chlorine gas cylinders should
            be inspected by trained facility personnel,  and obviously
            defective cylinders should be rejected upon delivery or returned
            at the time the defect is noted.

      •     All pipelines should be color coded and equipped with both flow
            direction indicators and valve position indicators.

      •     The facility should consider installing back-up systems for its
            processes.

                                      51

-------
      Chemical Accident Prevention

      •     The facility should institute a chemical awareness program to
            inform tourists visiting the facility that hazardous chemicals are
            on the premises and how to react to emergency situations involving
            these chemicals.  Visitors should be briefed on warning alarms and
            evacuation routes and assembly points should be established.  Head
            counts should be performed to identify missing individuals and
            special provisions should be made for escorting and evacuating
            handicapped visitors.

      •     The facility should have its employees attend hazardous materials
            training courses on a regular basis.

      •     Training should be instituted for non-employees who frequent the
            facility, such as truck drivers and other vendors.

      Facility Emergency Preparedness and Planning Activities

      •     Evacuation routes should be clearly marked about the grounds.

      •     The facility should purchase a Chlorine "B" cylinder kit and one
            fully encapsulating Level A protective suit so that employees  are
            able to quickly respond to accidental chlorine releases.   The
            chlorine "B" kit is essentially useless without Level A
            protection.

      Community and Facility Emergency Response Planning Activities

      •     Visitors should be informed of the presence of hazardous
            substances, including chlorine gas,  and should be given the
            opportunity to decide as to whether they wish to continue  the
            tour.
Audit Team Member Composition:

Name and Title                Paul Kahn
Affiliation                   US EPA Region 2
Area of Responsibility        Audit Team Leader
Expertise                     Processes, process control,  ARIP,  and prevention


Name and Title                Angel Rodriguez
Affiliation                   US EPA Region 2
Area of Responsibility        PID, PM, training, SOP,  loss prevention
Expertise                     Same as above

Name and Title                Woody Douglis
Affiliation                   AARP
Area of Responsibility        Documentation review,  plan review
Expertise                     Chemistry

                                      52

-------
Follow-up Activities:




      By the Facility




      By the Regional Office:




      By State and local authorities:







Regional Contact:       Ellen Banner
                                      53

-------
54

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Goodyear Polyvinyl Chloride Facility
Facility Location:
Niagara Falls, Niagara County, New York,
Region 2
Date(s) Audit Conducted:
July 31-August 1, 1990
Description of Facility:

      SIC Code(s):


      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
Reason for Facility Selection:
2821 -- plastics materials, synthetic
resins, and non-vulcanizable elastomers

An urban residential/industrial portion of
Niagara Falls, one-half mile from the
Niagara River
Polyvinyl chloride polymer and other
rubber chemicals
In addition to private residences, three
schools and a nursing home are within a
five-mile rad.ius of the site.

The facility was chosen because of the
flammable/explosive nature of polyvinyl
chloride (PVC),  the history of incidents
in industries using PVC,  and the
reportable releases experienced by the
company.
      ARIP Reports:
Focus of Audit:

      Hazardous Substance(s)
      Examined:
Six ARIP questionnaires were submitted by
the facility from August,  1987 to April,
1988.
Polyvinyl chloride (PVC)
                                      55

-------
Physical Area(s) Examined
at the Facility:

      Storage and Handling

      •     Storage
            At any given  time,  nine  or  ten  23,000  gallon railroad cars of PVC
            may be on site.   In addition,  three  14,500  gallon storage tanks
            and two 22,000  gallon  storage  tanks  are  located on site  in a tank
            farm.

            Shipping and  Receiving

            Solid PVC is  delivered via  railcar.  It  is  then offloaded to
            storage tanks.  All other chemicals  are  delivered via truck.

            Material Transfer

            All materials are  forwarded from  the storage  tank area via a
            transfer station  to the  process area.  This  transfer  station
            consists of a building with pumps  for  each  chemical stream.
      Process Area(si
            Three production processes  for vinyl chloride are  in use at  this
            facility.  Two processes use an emulsified vinyl chloride
            reaction, and the Micro-Suspension Process (MSP) uses a seeded
            micro-suspension reaction.  The processes are similar in that the
            vinyl chloride is taken from storage and placed in a reaction
            vessel.  Cases from  Che reactors are vented to a recovery system,
            and  the  reaction products go to storage.  From storage, the
            product  is dried, blended,  and packaged for shipment.  Upon
            completion of the reaction  stage, all reaction chemicals,
            including the vinyl  chloride, are rendered non-hazardous.

            All  process equipment  is designed for handling vinyl chloride
            including the storage  tanks, piping, transfer, pumps, and reaction
            vessels.  This equipment has been in use and proven reliable.  The
            equipment is selected  based on industry standards, and its
            reliability is a result of  a history of use.
Summary of Audit Findings and Recommendations:

       Conclusions:

       Facility  Background Information

       •      The site  is  subject  to  storms which arise from the Great Lakes and
             may occur rapidly, with great force.  The site is not prone to
             flooding  from the river due  to geography.

                                       56

-------
•     The Niagara River could be  impacted  by  a  large  atmospheric release
      and fallout.

Chemicals Hazards

•     PVC poses a threat of fire  and explosion  based  upon  its  presence
      on-site in railcars, transfer piping, and reactor  vessels.   In
      addition, the carcinogenic  nature of PVC  poses  a threat  to the
      employees who handle it in  the event of a leak.

•     An ammonia leak in the coolant building was observed  during  the
      audit and poses an ongoing  release and  threat to personnel and the
      environment.

•     Medical records of annual physicals  and exposures  are maintained
      by the facility to track any suspected  acute or chronic  effects on
      personnel.

•     Material Safety Data Sheets (MSDS) are  available at all  times  in
      one of the facility's process control rooms.

Process Information

•     The plant's housekeeping conditions  and procedures do not appear
      to be consistently followed or implemented.  Poor  cylinder
      handling and storage practices, inadequate debris  and empty
      container removal, and rusty support beams on the  isopropyl
      alcohol tank were observed and greatly  increase the chance for
      accidents,  such as a support failure, or  releases  from a ruptured
      tank.  Empty drums, cylinders,  and debris were observed scattered
      throughout the facility as well as in the designated storage
      areas.

•     The storage tanks are labelled.  The tank farm is diked and
      maintained, however, the piping color codes have not yet been
      completed.   Incomplete color coding  and confusing labelling of
      piping can lead to either confusion  in  the .event of an emergencv
      or incorrect actions by new employees.  The railroad cars are
      properly placarded.

•     There are no back-up systems presently  in place.  Replacement
      equipment is always on hand.

•     Reaction vessel temperatures,  pressures, and incoming and outgoing
      flow  rates are all monitored by technicians and instrumentation.

•     Vinyl chloride vapor detectors are in place throughout the
      facility at the railyard unloading station, the transfer station,
      each  of the reactor vessels, the tank storage area, and throughout
      the process rooms.  These are key locations where vinyl chloride
      is present in large quantities and,  as  such,  could  pose a
      significant threat in the event of a release.  They  are all keyed

                                57

-------
      into Bendix monitors in the process control room.  Improperly
      placed vinyl chloride alarm sensors are too far from  the vinyl
      chloride source and could fail to detect or delay the detection  of
      a chemical release.

•     Ambient wind directions are monitored only at rooftop level.  A
      lack of ground level wind direction indicators could  cause
      employees to be exposed to fumes in the event of a release.

Chemical Accident Prevention

•     The facility undergoes constant evaluation by plant personnel and
      management via daily use and oversight of processes,  as well as  a
      yearly inspection by corporate safety engineers who perform a
      check-list and walk-through evaluation.

•     SOP manuals for items such as start ups and shut downs,  batch
      reaction procedures, miscellaneous process activities, and
      emergency procedures are located throughout the plant and are
      issued to all employees.  Strict lines of command and
      communication are delineated in the SOPs.   SOPs also  cover
      maintenance, including emergency repairs,  routine maintenance,
      scheduled and unscheduled shut downs,  and equipment inventory.
      They are updated as necessary and used extensively by maintenance
      and production personnel.   A lack of procedures for'drum and gas
      cylinder handling and storage has lead to incompatible material
      storage, inadequate aisle space,  and inadequate visibility of drum
      labels.

•     All facility personnel are trained in their job functions and in
      emergency procedures by senior production personnel prior to
      allowing them to take over a specific  function.   No mechanism is
      set up to train outside contractors or response agencies to allow
      them to safely function on facility property.

•     The facility is presently developing a computerized preventive
      maintenance system which they anticipate to put in use.
      Instrumentation is examined daily and  calibrated monthly.   Audio
      and visual alarms are tested periodically.

•     The facility is in the process of establishing a computer system
      capable of modelling air,  water,  and ground releases  of  vinyl
      chloride.

•     Release prevention systems include gauges,  check valves,  pressure
      releases to a blow down tank, vapor detectors,  sumps,  and fire
      suppression systems.  These are present throughout the facility  to
      detect releases of vinyl chloride which would  prevent an
      explosion, fire, and exposure danger to the public and
      environment.  The systems in place appear  to perform  effectively
      since there is no history of significant releases.  Visual  and
      audio alarm systems are present.

                                58

-------
•     Reaction vessels have -automatic  shutdown  capability  and emergency
      manual shutdown equipment.

Accident Release Incident  Investigation

•     Three releases have  been  reported  to  the  National  Response  Center
      (NRC) over a period  from  1988  to 1990.  None  of  these  releases
      impacted the environment  or  the  community off-site.

•     All releases are investigated  and  steps are taken  to ensure  that
      future releases are  prevented.

Facility Emergency Preparedness and  Planning Activities

•     Goodyear Corporation has  a standard Safety and Emergency Response
      Plan which is used by all of its facilities as general  guidance.
      The facility-specific emergency  response  plan is reviewed and
      updated annually or  when  a program change arises.  Misleading
      phrases in the emergency  response  plan can lead  to confusion in
      the event of an emergency or incorrect actions by new employees.
      A lack of posted emergency procedures throughout the plant could
      endanger on-site personnel.

•     Release, fire, and in-house emergency drills  are conducted
      periodically.  These drills are observed,  analyzed, and corrective
      actions are taken when needed.  Simulations are conducted once or
      twice a year in which employee response and program performance
      are evaluated.  Based upon this evaluation, management effects  •
      changes in procedures or  training  to correct  identified areas of
      concern.  However, in-house emergency training scenarios do not
      consider the outside agencies  that would be involved in the event
      of an incident.

•     Emergency exit routes are clearly marked and  ample.  All response
      personnel are trained in  fire  and plant shut  down operations.
      Outside agencies have been informed to report to the plant
      guardhouse for directions.

•     Fire suppression systems, heavy equipment, supplied air
      respirators, tools,  and vapor  detectors are readily available to
      deal with a release  situation.  Emergency breathing
      apparatus/airline systems appeared to need upgrading, and there
      was no schedule or procedures  for equipment maintenance.

•     In the event of an emergency,  the chain-of-command is as follows:
      operator, shift foreman, department manager,  plant manager.   The
      plant emergency action team, consisting of eight trained
      personnel, may be called as needed.

•     Two-way radios, telephones, and an alarm system are used to
      communicate emergency information  throughout  the facility.


                              •  59

-------
      •     An eight-person response team consisting of plant personnel are
            always on-call.   This team has received extra training in dealing
            with releases and incidents at this facility.  All other personnel
            receive basic evacuation,  fire,  and process shut down emergency
            training.

      Community and Facility Emergency Response Planning Activities

      •     Members of the Goodyear facility belong to the Local Emergency
            Planning Committee.

      •     A listing of materials on hand has been filed with the fire
            department.

      •     In the event of a release, the plant manager will notify the NRC,
            the New York State Department of Environmental Conservation, and
            the local police and fire departments,  as needed.

      Public Alert and Notification Procedures

      •     Fire and police personnel would go door to door notifying
            residents and workers of adjacent buildings.   No schedule for
            testing this type of notification has been implemented.   Fire and
            .police personnel are trained in this type of public contact.
Recommendations:

      Process Information

      •     Rusted support beams on the isopropyl alcohol tank should be
            repaired.

      •     The facility should completely color code  its pipes and should
            devise a more accurate pipe-labelling system.

      •     An ammonia leak in the coolant building should be  corrected.

      Chemical Accident Prevention

      •     Everyone working on the premises should be trained in plant-
            specific hazards,  including outside contractors.

      •     Drum storage and handling procedures,  including the coding of
            storage aisles and ensuring the visibility of all  labels  should be
            addressed.  Gas cylinder storage and handling procedures  should be
            developed and maintained.   Facility-wide housekeeping procedures
            should be enforced,  e.g.,  trash removal, empty drum storage, etc.

      •     The computerized preventive maintenance system currently  under
            development should be expedited and implemented.
                                      60

-------
      •     The vinyl chloride alarm system sensors should be located closer
            to the source's of the potential emissions.

      Facility Emergency Preparedness and Planning Activities

      •     Emergency procedures should be posted throughout the facility.
            Typographical errors and misleading phrases in the facility
            emergency response plan should be corrected.

      •     The current SPCC plan should include storage tank location.

      •     Current in-house emergency training scenarios should include
            outside agencies that need to respond.

      •     Emergency breathing apparatus/airline systems should be upgraded
            and maintained.

      •     Ambient wind directions should be monitored at ground level
            throughout the facility as well as at rooftop level.
Audit Team Member Composition:

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Paul Kahn, OSC
US EPA Region 2 OSC
Team Leader
PID, Release Prevention

Angel Rodriguez
US EPA Region 2 OSC
Team Member
PM Training, SPCC

Charles Fitzsimmons,  OSC
US EPA Region 2 OSC '
Team Member
Process control, response planning

Jeff Bechtel
Roy F. Weston, Inc. (TAT)
Information recorder,  scribe
Chemical processes
                                      61

-------
Follow-up Activities:




      By the Facility:




      By the Regional Office:




      By State and local authorities:







Regional Contact:             Ellen Banner
                                      62

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
BASF Corporation Industrial and
Performance Chemicals
Facility Location:
Washington, New Jersey, Region 2
Date(s) Audit Conducted:
September 10, 1990
Description of Facility:

      SIC Code(s):


      Location:
2843 -- surface active agents, finishing
agents, sulforated oils, and assistants

A rural town in western New Jersey
approximately 45 miles northeast of
Philadelphia in a mixed-use residential
and commercial area near the Pohatcong
River.
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
Reason for Facility Selection:
      ARIP Reports:
Surfactant polyol,  a long-chained polymer
used primarily in industrial and
commercial cleaning agents
Private residences, schools,  and a
hospital are within a two-mile radius.
The Pohatcong River could be  impacted by
an air release and subsequent fallout..

The facility was chosen because they had
at least one reported chemical release  and
the substances used pose a potential
fire/explosion and chemical release threat
to the surrounding community.

2/22/87 and'8/18/87 releases  of ethylene
oxide
Focus of Audit:
      Hazardous Substance(s)
      Examined:
Ethylene oxide (EO)
Propylene Oxide (PO)
                                      63

-------
Physical Area(s) Examined
at the Facility:

      Storage and Handling

      •     Storage Systems
            All liquids are received  in bulk and  transferred to  dedicated
            storage tanks.  These tanks are all placarded  with the  liquids
            hazard classification and all loading  spigots  are  tagged.   The
            tank farm is diked and maintained.

            Shipping/Receiving

            EO and PO are received via railroad tank car.  All other chemicals
            are received by trucks.   Cars are off-loaded to  storage tanks  on
            site.  The railroad cars  are properly  placarded  and  the storage
            tanks in the unloading area are clearly labelled.  From the
            storage tanks, the chemicals can be transferred  to any of  five
            batch reactor systems for processing.

            Material Transfer

            All chemicals are transferred from the storage tanks  to the
            process area via transfer pumps.  Reactor vessels are manifolded
            from central EO and PO feed lines that are maintained at elevated
            pressure.  This eliminates the need for individual process feed
            tanks.
      Process Area(s)
            All chemicals are transferred from the storage tanks to any of
            five batch reactors.  EO and PO are very reactive substances and
            are added at a slow rate to control a normally exothermic
            reaction.  Flow rates are controlled to prevent the temperature
            from reaching unsafe conditions.

            All process equipment is designed according to industry standards
            for handling oxide compounds, including the storage tanks, piping,
            transfer pumps, and reactor vessels.   This equipment has been in
            use for many years and has an industry-wide history of
            reliability.
Summary of Audit Findings and Recommendations:

       Conclusions:

       Chemical Hazards

       •     MSDSs are available at all times in the facility's laboratory.
            Ecology Coordinator's office, and the Lab Supervisor's office;

                                      64

-------
      however, MSDSs are not available  in  the  functional  fluids  control
      room.

Process Information

•     Storage of combustible materials  such as wood and debris near
      flammable chemicals increases  the risk of a fire.   Also, refuse
      was stored close to the wooden pallet storage area  and monomer
      tank car staging area.

•     Chemical storage tanks in the  warehouse were not labelled  with the
      name of the contents and the solvent storage room in the warehouse
      was unmarked as to contents of room.  Also, labelling and  color
      coding of piping, chemical transfer lines, fire control systems,
      and chemical storage areas is  both incomplete and confusing.  This
      could lead to accidental releases by plant personnel or outside
      contractors not familiar with  the systems.  Warehouse personnel
      were not fully aware of what chemicals were in storage, and were
      not fully aware of the location of all materials that were
      reportedly 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.

•     All personnel handling EO and  PO are trained in their respective
      functions and all material handling stages are supervised by plant
      personnel.

•     No caps were in place on the filler lines in the functional fluid
      area to prevent accidental filling of improper materials  in the
      wrong tank.  A shortage of adequate lighting and open,  unlabelled
      fill pipes could lead to spills, accidents,  or the mixing of
      incompatible materials.

•     Batch sheets have been developed for each.product and its
      associated reactor vessel, designating the materials to be  used,
      proper temperature and pressure, and raw material flow rates.

•     Replacement equipment for long procurement time  items is  kept  in
      stock.

•     Temperature interlocks have been installed on the reactors  to  halt
      addition of EO or PO should the temperature exceed the  specified
      range.  Reactor vessel temperatures,  pressures,  and ingoing and
      outgoing material flow are all monitored by technicians and
      instrumentation.

•     No plant-wide backup power system or general emergency  power
      provisions exist.  The decision was made to operate  the plant
      without a backup power supply.   The size and cost of a  backup  unit
      was considered prohibitive,  thus the operating procedures were
      developed and are closely followed to allow the  facility  to
      operate without backup power.  Emergency lighting capabilities  are

                  '  •            65

-------
      at key points in the process area, control  room,  and  at  all
      building exits.

•     Spills, leaks, reactions or tank  failures pose  a  potential process
      hazard because they may release oxide materials which could  lead
      to fire, explosion, or personal exposure.

Chemical Accident Prevention

•     BASF Corporation performs its own annual internal  chemical safety
      av.dit.  This audit includes review of all safety  procedures,  such
      as respiratory programs and lock, tag, and  try, ladder safety,  as
      well as a physical inspection of  the facility,  training  reviews,
      and interviews with employees.  This facility has  been deemed
      "acceptable" by BASF internal safety standards.

•     SOP manuals for process operations, maintenance, emergency
      actions, and safety are located throughout  the  plant  in  process
      control areas, plant manager and environmental  manager's offices,
      and are issued to all employees; however, no SOPs  were in the
      functional fluids control room.  These SOPs are followed whenever
      work is performed by plant personnel and outside contractors  and
      cover equipment maintenance, including emergency repairs, routine
      maintenance, scheduled and unscheduled shutdown maintenance,   and
      equipment inventory.  Instrumentation is examined  daily and
      calibrated monthly.  Audio and visual alarms are tested
      periodically.

•     Training is begun with new employee training and carried on with
      monthly training sessions within each work group.   For example a
      part of this training is spill handling for the operations and
      shipping personnel.  Further training is conducted for pertinent
      personnel when necessary.  Any new operator or oxide unloacer is
      required to have three days of classroom training on oxide
      handling, and is supervised for two to four months while on the
      job.  Key environmental/ safety/management staff have not updated
      their EPCRA/SARA Title III training.

•     The facility has conducted "What if"  analyses for air, water, and
      ground releases of oxide compounds.   The results have been used to
      formulate response actions which are  incorporated in the
      facility's Emergency Response Plan.

•     The EO and PO feed system is designed to shut down at any power
      interruption or any temperature or pressure rise above a pre-set
      level.  In .addition, all equipment handling oxides are designed to
      shut down in the event of an emergency.   Reactor vessels have
      automatic shutdown capability and manual shutdown equipment.

•     Visual and audio alarm systems are present and operational.   EO
      and PO vapor detectors are in-place throughout the facility at the
      railcar unloading areas, storage tank areas, and in the reaction

                                66

-------
      areas to detect any leaks that would yield a  fire, explosion,  or
      employee exposure.  They are all keyed  into monitors  in  the
      process control room.

•     To minimize the potential for future releases, BASF has  reduced
      on-site inventories by using a common feed line  to all reactors
      thereby eliminating individual storage  tanks,  installed  release
      prevention systems including gauges, check valves, pressure
      releases, vapor detectors, dikes, sumps, and  fire suppression
      systems, and storage tanks contain a blanket  of  nitrogen gas to
      eliminate explosive vapo.r conditions.

Facility Emergency Preparedness and Planning Activities

•     BASF Corporation has a Safety and Emergency Response Plan, which
      is provided to all of its facilities as general  guidance.  The
      facility emergency response plan is reviewed annually by
      management and updated annually or when a program change arises.
      Response information, however,  such as emergency contacts, phone
      numbers, continual training of plant and management personnel,  and
      medical facilities is not kept current.   The phone listing of
      essential personnel is not dated and the EPCRA Hotline phone
      number was still on the emergency response plan as' a release
      notification contact.  The correct release notification numbers
      are the National Response Center and the EPA Region II hotline
      number.

•     Releases equalling or exceeding a reportable quantity are reported
      by either the shift leader or plant manager,  depending on the
      availability of personnel during a release incident.   This is done
      by contacting the plant manager during day shift and the  on-call
      contact at all other times.   The shift leader has authorization to
      initiate any required emergency procedures.   Emergency
      notification is conducted via the plant alarm system.   In the
      event of an emergency, the following chain of command will apply:
      the shift leader notifies plant management and begins the
      appropriate response, which can include  notifying the appropriate
      authorities, shutting down operations,  closing manways or
      initiating any spill remediation.

•     Safety drills are conducted each year which put into  effect the
      SPCC program.  These drills may involve  spills, power outages,
      power interruptions, man down,  or fire scenarios.  The facility
      also conducts release responses and fire drills semi-annually in
      which performance and response is evaluated.   During  spill
      scenarios, self-contained breathing apparatus (SCBA),  vapor
      detectors, the plant internal alarm system,  personal  protective
      equipment, and the sprinkler system are  used.   These  drills are
      observed, and corrective actions are taken where  needed.

•     Evacuation routes and floor plans were not posted at  exits  on each
      floor.  Evacuation assembly,  which includes  contractors,  occurs

                                67

-------
      when the fire or drill alarm is sounded.  Assembly points are
      located in both warehouses at the loading docks.  The  supervisory
      contact is responsible for explaining the evacuation procedures  to
      contractors,  and for having an accurate head count of  these
      contractors.   Personnel are to evacuate if notified via  the  alarm
      system.

•     The facility's central fire alarm system is located in the control
      room,  and consists of individual activation switches for
      strategically located site deluge nozzles, as well as  individual
      fire alarms for each area of the facility where chemicals are
      stored or used.  In the event of a fire, explosion or chemical
      release that might disable a worker, the deluge or fire alarm
      could be activated from the relative safety of the control room.
      Identical switches are located at the individual work stations.
      The lack of fire fighting and suppressions systems in the oil
      storage area increases the risk of a fire.  The auto-deluge
      activation switches in the control room were labeled "Fire Alarm."
      The label does not reflect the actual function of the device.  The
      fire water system has a diesel pump backup,  but can operate by
      gravity feed.  This diesel pump system is tested weekly.

•     Fire suppression systems,  heavy equipment, supplied air
      respirators,  tools, and vapor detectors are  readily available in
      the event of a release.

•     No trained medical professionals are on-site.   The medical
      equipment stored in the first aid training room is suitable for
      primary first aid response only, such as splints,  bandages,  eye
      wash solutions, and stretchers.   Approximately 15  plant employees
      are trained in first aid and CPR.   Any incident that would require
      extensive first aid would require the summoning of the  rescue
      squad, stationed two miles from the facility.

•     The facility has a five-man response team that is  always  on-call
      consisting of plant personnel.   Members of this team undergo
      specialized hazmat and chemical safety training.

Community and Facility Emergency Response Planning Activities

•     A listing of all hazardous materials on-site has been filed with
      the local fire department.

•     Although the plant manager belongs to the Local Emergency
      Preparedness Committee, providing the committee with  information
      on chemical and industrial processes and hazards,  the  facility  is
      not involved in any other community outreach activities.

•     The facility did not verify whether the local  hospital  can
      accommodate chemically-contaminated victims.
                                68

-------
      Public Alert and Notification Procedures

      •     In the event of a release, fire and police personnel  would go  door
            to door notifying residents and workers in adjacent buildings.

      •     A schedule for testing door-to-door notification has  not  been
            developed.  Fire and police personnel are trained  in  this type  of
            emergency procedure.
Recommendations:

      Process Information

      •     Chemical storage tanks should be labelled with the name of the
            contents.  In addition, a diagram of warehoused materials should
            be maintained, posted and periodically updated.

      •     The refuse containers and wooden pallet storage areas should be
            moved away from the railroad tank cars containing EO and PO in the
            event of a tank fire.

      •     The door and outside wall of the solvent storage room should be
            marked with contents of room.

      •     A diagram of warehoused materials should be developed and
            maintained showing at least the location of any hazardous or
            extremely hazardous substances and their amounts.

      •     Chemical transfer lines should be color coded to distinguish them
            from water lines or other non-hazardous materials.

      •     Caps should be installed on the filler lines in the functional
            fluids area to prevent accidental filling or improper materials
            being sent to the wrong tank.

      Chemical Accident Prevention

      •     MSDSs and SOP manuals should be made available in  the functional
            fluids control room.

      •     BASF needs to study the lighting patterns for night-time
            operations to ensure adequate lighting of work areas.

      •     BASF key environmental/safety/management staff should have
            additional Title III training.

     . Facility Emergency Preparedness and Planning Activities

      •     BASF needs to list the appropriate hotline and emergency numbers
            in the call book (e.g., the EPCRA Hotline was listed  instead  of
            the NRC for release reporting).

                                     • 69

-------
            BASF needs to date phone contacts to reflect most recent changes
            in personnel phone numbers.

            Evacuation routes and floor plans should be posted at exits on
            each floor.

            Fire fighting equipment should be supplied to the waste oil
            storage area.
      •     The auto-deluge activation switches in the control room should be
            relabeled from "Fire Alarm" to reflect the actual function of the
            device.

      Community and Facility Emergency Response Planning Activities

      •     Facility should verify with local hospital whether medical staff
            can accommodate chemically contaminated victims.
Audit Team Member Composition:

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Paul Kahn
USEPA Region 2 OSC
Team Leader
PID, process, preparedness,  SOPs

Angel Rodriguez
USEPA Region 2 OSC
Team Member
Training, SPCC, PM

Jeff Bechtel
TAT
Administration
Chemical engineering
                                      70

-------
Follow-up Activities:




      By the Facility:




      By the Regional Office:




      By State and local authorities:







Regional Contact:       Ellen Banner
                                      71

-------
72

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Occidental Chemical  Corporation  (OxyChem)
Facility Location:
Delaware City, New Castle, Delaware,
Region 3
Date(s) Audit Conducted:
August 20 -.22,  1990
Description of Facility:

      SIC Codes (s)

      Location:
      Products Manufactured,
      Produced or Distributed:

      Proximity to
      Sensitive Populations
2812 -- alkalies and chlorine

Facility is on the Delaware River, 10
miles south of Wilmington, Delaware.

Chlorine, caustic soda, caustic potash,
and hydrogen.

The facility is located approximately 10
miles from the Christiana Medical Center,
and three miles from the Delaware City
Elementary School.  Also, the facility is
located three miles from Delaware City,
the closest residential area; and
approximately 20 residences are located
within a three-mile radius.
Reason for Facility Selection:
      ARIP Questionnaire(s):
The facility was selected following 15
releases of chlorine, mercury,  caustic
soda,  caustic potash, sulfur dioxide,  and
wastewater that have occurred over the
last few years.

8/5/89 release of chlorine
Focus of Audit:
      Hazardous Substance(s)
      Examined:
Chlorine
Mercury
Hydrogen
Sodium Hydroxide (caustic soda)
Potassium Hydroxide (caustic potash)
Carbon Tetrachloride
Sulfuric Acid
                                      73

-------
Physical Area(s) Examined
at the Facility:

      Storage and Handling

      •     Storage Systems
            Chlorine is stored at 35 psig and  -20 degrees  Fahrenheit in six
            150-ton and two 200-ton insulated  horizontal tanks  designed to
            handle 225 psig.  In the event of  an emergency,  a third  200-ton
            tank is used to transfer chlorine.  The tanks  are in  a stone-
            floored, diked containment area.   Mercury  is stored in a
            dedicated, locked building in 76-pound and one-ton  containers.
            Sodium hydroxide (caustic soda lye) solution is  stored in  three
            500,000-gallon, rubber-lined vertical tanks.   There is no  diking
            around these tanks; the facility expects to contain spills  through
            stone-lined ditches, which are part of the on-site  wastewater
            treatment plant.  Potassium hydroxide (caustic potash) is  stored
            in three rubber lined tanks:  Fifty percent caustic potash  lye  is
            stored in two 500,000-gallon tanks, and 45 percent  caustic  potash
            lye is stored in one 50,000-gallon tank.  Anhydrous potassium
            hydroxide is stored in a warehouse in bags, drums,  and supersacks.
            Sulfuric acid is stored in two 5-ton horizontal  tanks.   Spent
            sulfuric acid is stored in two 10,000-gallon horizontal, diked
            tanks.  The sulfuric acid tanks are Bright yellow for
            identification.  Hazardous materia. .nformation  system (HMIS)
            sheets are posted in the storage areas to identify hazards.

            Shipping/Receiving

            The facility uses approximately 470 tons of sodium chloride and
            200 tons of potassium chloride per day.   Railcars and trucks ship
            the salts to the facility.  Sulfuric acid is shipped by  tractor
            trailer.  Tanker trucks and railcars ship approximately  150 tons
            of potassium hydroxide (in liquid  and solid form) offsite per day.
            Tanker trucks, railcars, and barges ship 300 tons of liquid sodium
            hydroxide per day.   Approximately  20,800 pounds of hydrogen are
            piped to adjacent facilities per day.   Part of the hydrogen is
            piped offsite to two facilities;  the remainder is used as fuel
            onsite or venced to the atmosphere through a stack which is
            provided with a steam fire-suppression system.   Prior to shipment
            or use, the hydrogen is checked for oxygen to prevent any
            possibility of explosion.   Tanker  trucks,  railcar and pipeline
            ship 350 tons of chlorine per day.  One pipeline ships vaporized
            chlorine and another ships liquid.

            Material Transfer

            The facility uses several mechanisms,  including pumps, gravity
            feeders, and compressors,  to transfer chemicals throughout the
            facility.  There are transfer systems both inside and outside of

                                      74

-------
      the facility.  The pipelines, however,  are  mainly  within the
      industrial park,  limiting public  access.  The  chlorine  pipelines
      outside the facility are painted  yellow for identification.   Also,
      the facility is using site blueprints  to  number  the  plant tanks
      for quicker identification.   Compressed air or pumps transfer
      chlorine.  Some of the chlorine and hydrogen manufactured at  the
      facility is transported offsite via pipelines  to nearby companies.
      Safety cages surround compressor  and motor  fan belts.   The barge
      loading dock on the Delaware  River is  approximately  one-half  mile
      from the plant.

Process Area(s)

Chlorine, Caustic Soda, and Hydrogen Production.   Chlorine  and metallic
sodium are manufactured by the electrolysis  of  a  saturated  brine
solution of sodium chloride or potassium chloride  in water.   The
electrolysis is carried out in the  Denora mercury  cells, using flowing
mercury cathodes and titanium anodes.   The cell bottom is made  of steel
and the sides of the cell are rubber-lined steel;  the  inlet and outlet
boxes are also rubber lined.  In the cell, brine  flows above  the
mercury.  When DC voltage is applied, the brine is electrolyzed,
producing metallic sodium and chlorine.  The  metallic  sodium  dissolves
in the mercury, producing sodium amalgam.  The chlorine-produced is
drawn out of the cells under a small vacuum;  the cells are also
maintained under a small vacuum to  minimize  leaks.

The depleted brine from the cell is acidified and  dechlorinated  in a
vacuum to recover and recycle the chlorine.   The brine is made  alkaline
and treated to precipitate any calcium  or magnesium  in the solution.
The precipitate is allowed to settle in the clarifier.   The clarified
brine is filtered, preheated, or cooled as necessary, acidified, and fed
back to the cells.  The precipitated sludge  is filtered to remove and
recycle the brine.  The resulting filter cake is collected in rolloffs
and sent to permitted landfills.

To produce sodium hydroxide and hydrogen, the sodium mercury amalgam
from the cell room is treated with  water in the presence of a catalyst.
The sodium hydroxide is cooled using a heat exchanger.   To minimize
corrosion prior to cooling, nickel  equipment  is used for handling the
sodium hydroxide solution.  After it is cooled, the caustic lye is
filtered to remove residual mercury and graphite from the decomposer.

The chlorine is cooled and dried (losing much of its corrodibility), and
then compressed and chilled again to liquefy most of the chlorine.   The
liquid chlorine is stored in storage tanks while the remaining chlorine
vapor passes through a knock-out drum and is compressed and chilled  to
liquefy more chlorine.  Approximately 90 percent of the chlorine is
liquefied in the first stage and five percent in the second stage.   Any
remaining vapor remaining is known  as snift gas and is  passed through a
packed tower (absorber) with carbon tetrachloride to absorb all but
traces of chlorine.  The chlorine and carbon tetrachloride  in the stream
are separated in a stripper.  The stripped chlorine is  sent back to  the

                                75

-------
      first  stage  of liquefaction,  and the carbon tetrachloride stream is
      recycled to  the absorber.   Hydrogen generated in the decomposer is
      cooled and compressed to 20 psig and chilled further to condense mercury
      vapors.   The hydrogen is passed through an activated carbon bed to
      reduce the mercury vapor content to below one ppb(v).

      The  waste chlorine neutralization system consists of two vertical open
      tanks  filled with 18 to 20 percent caustic soda solution, which is kept
      circulating.Chlorine to be neutralized is passed to the solution through
      distribution pipes.

      Caustic Potash Production.  In the anhydrous plant, 50 percent caustic
      potash lye is concentrated in falling film evaporators.  The potassium
      hydroxide coming out of the evaporator is converted to flakes using a
      flaker.   The flaker is a cylindrical drum cooled from inside, rotating
      at a slow speed.   The bottom tip of the drum dips into the vat
      containing molten caustic potash.   There is provision for converting the
      flakes to briquettes or granular crystals.

      Waste  Water  Treatment.  Process water from the cell room,  brine,
      chlorine compression, and the mercury treatment areas is collected and
      treated at the mercury treatment plant.  Treatment consists of two-stage
      pH adjustment, sodium hydrosulfide iddition to precipitate mercury and
      other  metals, and filtration using a plate and frame precoated shriver
      filter.   Non-mercury process wastewater from other plant areas is
      collected and pH adjusted in neutralization tanks.   Water from the two
      treatment areas is combined with septic system waters in the
      chlorination pit, where it is chlorinated and pH adjusted prior to
      discharge to the Delaware River under a National Pollution Discharge
      Elimination  System (N'PDES) permit.
Summary of Audit Findings and Recommendations:

      Conclusions:

      Process Information

      •     The pressure safety valves on the chlorine storage  tanks  are
            currently designed to open directly to the atmosphere.

      •     The sulfuric acid tanks and the chlorine  pipelines  outside  the
            facility are painted yellow for identification.

      •     The facility uses site blueprints to number the  plant  tanks for
            quicker identification.

      •     The sensors of the Anacon chlorine  monitoring system are  located
            on one side of the site property, along the south fence bordering
            the Georgia Gulf facility.  The monitoring system does not  cover
            other sides of the OxyChem facility.
                                      76

-------
•     The potential for an explosion exists in the cell house,  snift
      recovery units,  and chlorine recovery process due to the
      possibility of hydrogen forming explosive mixtures with chlorine.
      The facility minimizes the explosion hazard by taking proper  care
      in processing brine, periodic sampling of chlorine at the main
      header and -the individual cells, and continuously monitoring  the
      hydrogen concentration in the snift gas.

•     Mercury vapor may enter the air during overhaul, cleaning of  the
      cells, or accidental leaks, creating a potential hazard to
      workers.  To minimize the possibility of mercury vapor poisoning
      and the release of liquid mercury, mercury is never exposed to air
      during operation.

•     The laboratory analyzes the stream exiting the carbon bed once per
      week to determine the mercury content.

•     High concentrations of mercury vapors collecting in the cell house
      is possible.  Laboratory personnel, therefore,  monitor the cell
      house daily and twice weekly at random intervals.

•     The chlorine transferring operation is monitored by personnel
      using a checklist system to minimize the chance of human error.

•     The facility uses the Systematic Approach for Emergency Response
      (SAFER) system for environmental monitoring.   The  Anacon sensors
      transmit exposure information on chlorine to  the SAFER system.  An
      additional warning system is sounded within the security building
      at the main gate when the concentration at the  sensor reaches  5
      ppm.   There is no automatic retransmission of this warning outside
      of the security building or outside of the plant's confines.

•     The facility has adequate back-up for the critical equipment.   The
      standby equipment is rotated once every week.   This  procedure
      ensures that the back-up equipment is ready for use  in an
      emergency, and allows time for preventive maintenance.

•     The facility is planning modifications  such as  the addition  of an
      emergency vent scrubber system with emergency power  back up  to
      incorporate new chlor-alkali technology and to  improve  the safety
      and environmental standards.

•     There is no backup power for lighting at the  facility.

Chemical Accident Prevention

•     Maintenance activities are organized through  a  work  order  system.
      Sections requiring maintenance submit work orders  which  are
      prioritized and scheduled by the maintenance  department,  in
      consultation with the department making the request.
                                77

-------
An established preventative maintenance  schedule exists  for
critical equipment (e.g., chlorine storage  tanks, knock-out
drums)..

In the near future, the facility plans to implement a computer
database for scheduling maintenance.

Containment dikes surround the storage tanks for liquid  chlorine,
spent sulfuric acid, HC1, and carbon tetrachloride.  Spills  in
other areas drain into a large drainage  ditch and are treated at
the wastewater treatment plant.  The wastewater facility has
several surge tanks and a ditch to handle large quantities of
waste/storm water.

The chlorine process is tied into the neutralization system at
several key areas to collect chlorine in the event of an
emergency.

The facility performed initial hazard evaluations before writing
the Community Awareness and Emergency Response (CAER) Plan.  The
facility revises the CAER Plan continuously; however, the facility
is considering using a more standard Hazard and Operability
(HAZOP)  system to refine and re-evaluate the original analysis.
The facility is currently working to develop a formal HAZOP system
to improve Che ability to document releases, determine causes,  and
track efforts to mitigate releases.

Comprehensive SOPs are available at appropriate locations in the
plant.  Process modifications are thoroughly reviewed,  verified,
approved, and incorporated into the SOPs.

The facility has manuals addressing specific critical concerns,
and handbooks detailing all aspects of handling various  chemicals
involved in the manufacturing process.

The facility also provides intensive training programs,  including
emergency response training,  for operators and maintenance
personnel.  Refresher training for operating personnel  is provided
every two years or whenever someone is transferred to a  different
position.

Response procedures for unsafe process parameter levels  are
clearly defined.  The standard operating procedures clearly cover
shut down and emergency procedures.

The facility has an established corporate policy on safety that  is
well publicized.  The corporation provides written and verbal
support for safety management,  and has made a significant
financial commitment to programs and policies pertaining to
chemical safety.
                          78

-------
•     The facility has a developed Hazard Communication  Standard  program
      as well as strictly enforced rules and regulations.

Accidental Release Incident Investigation

•     An in-plant accidental release incident investigation  report
      database allows the facility to examine the  total  number  of
      accidents by type of release and frequency.  The investigative
      report database also enables the facility  to determine  the
      underlying causes(s) of the release, take  follow-up  remedial
      action, and share general information.

•     The information in the in-plant database occasionally  does  not
      correlate with that in the facility's ARIP questionaires.

Facility Emergency Preparedness and Planning Activities

•     The facility's Emergency Action Manual addresses actions  to be
      taken in response to different types of emergencies, the
      organization and chain of command in the case of an  emergency, and
      each employee's responsibilities and duties.

•     The facility's Emergency Response Team is trained by the Delaware
      State Fire Training Academy, based on OSHA regulations  in 29 CFR
      1910.120.  Refresher training provided every two years or whenever
      a person is transferred to a different position.

•     The in-plant emergency coordinator must perform tasks in addition
      to those tasks outlined in the Emergency Action Manual.  For
      example, the in-plant emergency coordinator (Shift Supervisor)
      must alert the community following activation of the facility's
      alarms because no method exists to automatically alert the
      community.  In addition, the Shift Supervisor and Medical
      Technician are responsible for transmitting the "all clear"  signal
      over the public address system.

•     All personnel and visitors are issued safety equipment to  provide
      protection from minor accidents.

•     The facility is equipped for fire fighting and maintains fire
      hydrants, extinguishers, hoses, water pumps,  and sprinkler systems
      throughout the facility.

Community and Facility Emergency Preparedness and Planning Activities

•     OxyChem has been actively involved with the production of  the
      community's Emergency Response Plan.

•     Off-site assistance is not addressed in the Emergency Action
      Manual.  However, the Delaware City Fire Chief is the officer-in-
      charge of any on-site incident that may affect the  community.
                                79

-------
•     The facility holds periodic exercises of che Delaware City CAER
      Plan.   The exercises have tested notification, warning,
      evacuation, mustering, and search and rescue procedures.  In  1987,
      most agencies in the county participated in a major exercise.  A
      smaller scale exercise was held on July 17, 1990.  The next
      exercise is scheduled for November,' 1990.

•     The company is a participating member of the Chemical
      Manufacturers Association and the Chlorine Institute.  The
      facility is part of the regional Chlorine Emergency Response
      (CHLOREP) mutual aid program.

Public Alert and Notification Procedures

•     New Castle County does not have a fixed site outdoor siren system.
      In an emergency, therefore, authorities will use various means to
      alert the public within a potentially affected zone (e.g., mobile
      sirens, media announcements, emergency vehicles, Emergency
      Broadcasting System).

•     OxyChem and the Local Emergency Planning Committee are considering
      developing joint public alert and notification procedures.
      Currently, the facility relies on manual notification of the local
      fire department.  OxyChem is requesting permission for the use of
      the warning/notification system of a neighboring nuclear power
      plant in the event of a chemical release.   The details of such an
      arrangement remain to be worked out.

•     No method exists to automatically alert the community.

•     The audit team could not determine how the facility's transmission
      of the "all clear" signal over the facility's public address
      system relates to outside agencies or to the public.
Recommendations:

Process Information

•     The pressure safety valves on the chlorine storage tanks,
      currently open to the atmosphere, should be connected to the
      proposed emergency vent scrubber.

•     While providing a site plan and painting some tanks and piping
      yellow is helpful, the facility should consider developing a
      color-code system for all piping carrying hazardous materials.
      This would be very helpful to local response personnel responding
      to an incident at the facility.

•     The facility should install additional environmental sensors co
      the Anacon chlorine monitoring system to cover the entire
      perimeter of the site.

                                80

-------
            This would enable local response personnel  Co respond more  quickly
            in the event of an emergency.

            OxyChem should install an offsice warning system  in order to
            better notify the community of an emergency
Audit Team .Member Composition:

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Dennis D. Matlock
EPA Region 3
On-Scene Coordinator
N/A

Joseph P. Popp
EPA Region 3
Planning Assistant
N/A

Mrinal Biswas
U.S. EPA TAT Region 3
N/A
Civil Engineer

Joseph Albert
U.S. EPA TAT Region 3
N/A
Environmental Planner

Thomas Bars ley
U.S. EPA TAT Region 3
N/A
Chemical Engineer

James Wilcox
U.S. EPA TAT Region 3
N/A
Chemical Engineer

Robert A. Barish
Delaware Department of Natural Resources
N/A
Environmental Engineer

William E.  McCracken
New Castle  County
N/A
Emergency Preparedness Planner
                                      82

-------
•     The facility should carry out plans  to  install  an  emergency  vent
      scrubber with diesel power back-up.

•     The installation of back-up power for lighting  would be
      beneficial.

Chemical Accident Prevention

•     The facility should install an automated preventive and predictive
      maintenance planning system to provide  a periodic  reminder to
      plant operators.

•     The facility should dike all storage tanks to minimize the
      possibility of a major spill in the event of a  tank failure.

•     Facility should follow through with the planned purchase of  a
      HAZOP software package to improve the risk analysis data necessary
      for refining the Emergency Operations Manual.  Such a system would
      be beneficial to all aspects of plant operations,  including
      training, standard operating procedures.

Accident Release Incident Investigation

•     The facility should ensure that the in-plant release database
      contains information consistent with that in the ARIP
      questionaires.

Facility Emergency Preparedness and Planning Activities

•     To comply with Section (a)(8) of the Occupational Safety and
      Health  Act (29 CFR 1910.120),  the facility should provide annual,
      rather than biannual,  refresher training for all facility
      emergency responders.

•     Facility should conduct an annual full-scale exercise,  using a
      worst case scenario, to determine whether the span of control and
      management responsibilities of the Emergency Coordinator and
      Medical Technician are overwhelming and could lead to the omission
      of certain essential functions in an emergency.

•     In refining its Emergency Action Manual, the facility should refer
      to the "Plan Writing Format" used by the New Castle County
      Emergency Management Agency for hazardous materials.   The facility
      should also address all items mentioned in EPA's guidance document
      NRT-lA:  "Criteria for Review of Hazardous Material Emergency
      Plans". such as off-site assistance.   Adhering to a pre-designated
      format will also aid in future review and evaluation of the  plan.

Public Alert and Notification Procedures

•     The facility should consider installing an automatic alarm to
      notify the local fire department and emergency management agency.

                                81

-------

-------
Name and Title                      Richard Kendall
Affiliation                         Delaware City
Area of Responsibility              N/A
Expertise                           Community Awareness and Emergency Response

Name and Title                      John De Friece
Affiliation                         Delaware Department of Natural Resources
Area of Responsibility              N/A
Expertise                           Environmental Engineer


Follow-up Activities:

      By the Facility:

      By the Regional Office:

      By State and Local Authorities:


Regional Contact:       Joseph Popp       (215) 597-1357
                                      83

-------
Physical Area(s) Examined
at the Facility:

      Storage and Handling

      •     Storage Systems
            Methyl Methacrylate  (MMA)  Distillation Area.   Chemicals stored in
            this area include crude MMA,  uninhibited MMA,  inhibited MMA,  and
            third vent monomer.  Crude MMA is  stored in a  150,000-gallon
            storage tank.  This  tank  is  staged separately  from the  other  tanks
            in the area and  is completely encircled by  a four-foot  dike.   Six
            to eight railcars containing 23,000 gallons of crude  MMA are  also
            stored in the area temporarily before  unloading.   Inhibited MMA  is
            initially stored in  two 5,000-  and two 9,000-gallon run down
            tanks.  Two 3,500-gallon  tanks,  three  10,000-gallon tanks, one
            16,000-gallon tank,  and 300  to  400 fifty-five-gallon  drums in an
            outdoor storage area store MMA for facility use and final product
            sales.  Third vent monomer is stored in a 15,000-gallon tank,
            which is staged separately from all tanks in the area and diked  by
            four-foot concrete walls.  Rohm &  Haas (R&H) is nearly  finished
            constructing a new storage tank area for the MMA distillation
            area.

            PM Plant Area.  Inhibited MMA and  ethyl acrylate (EA) are used in
            the production of solid plexiglass resin pellets within the PM
            plant.  As previously mentioned, inhibited  MMA is  stored in the
            MMA distillation area, and EA is also  stored in that  area in  a
            150,000 gallon storage tank.   The  solid plexiglass  resin pellets
            are stored within a  designated  warehouse  in tote bags and steel
            containers.
            Shipping/Receiving

            MMA Distillation Area.  Crude MMA  is received at the facility by
            railcar.  About three 23,000- gallon cars are unloaded daily from
            the R&H Houston plant.  An operator is assigned to the unloading
            section during the transfer process.  Inhibited MMA is shipped
            from the facility by railcar, tank trucks, and in fifty-five-
            gallon drums.  The scheduling and quantities transported off site
            are based on customer demand.  Uninhibited MMA is transported off
            the facility by tank truck and in fifty-five-gallon drums.  It is
            refrigerated to the range of zero to five degrees Centigrade.

            PM Plant.  EA is shipped into the MMA distillation area by
            railcar.  The procedures used for receiving MMA are identical to
            those for EA in the MMA distillation area except that a completely
            closed loop unloading is employed due to EA's low odor threshold.
            The plexiglass resin pellets are shipped in tote bags and/or steel
            containers.
                                      86

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Rohm & Haas Delaware Valley,  Inc.  (R&H)
Facility Location:
Bristol, Pennsylvania, Region 3
Date(s) Audit Conducted:
January 7-10, 1991
Description of Facility:

      SIC Codes (s)


      Location:
      Products Manufactured,
      Produced or Distributed:

      Proximity to
      Sens it ive Populat ions:
2821 -- plastics materials, synthetic
resins, and non-vulcanizable elastomers

In an urban area of southern Bristol
township, on the Delaware River.

A wide variety of polymers using methyl
methacrylate.

One residential area is located on Rohm &
Haas property.   There are schools 0.5
miles and 1.5  miles away, and a hospital
is two miles away.
Reason for Facility Selection:
      ARIP Questionnaire(s):
A number of releases,  including methyl
methacrylate,  during the past two years.

4/6/90 release of methyl methacrylate
Focus of Audit:
      Hazardous Substance(s)
      Examined:
Methyl Methacrylate (MMA)
Ethyl Acrylate (EA)
Hydroquinone
Uninhibited methyl methacrylate
Hydroquinone solution
Monomethyl ether of hydroquinone
                                      85

-------
      Catalyst is manually added to the mixing  tanks  to enhance the conversion
      of the monomer.  The blended mixture is then sent through two pumps  in
      parallel, primarily to increase the pressure of  the  feed entering  the
      reactor.  Prior to entering the reactor the feed passes through  two
      additional filters in parallel.  This also removes any foreign material
      that might have contaminated the feed material  during blending
      operations.  The feed enters the reactor, which  operates at high
      pressure and moderate temperature.  The conversion of the'monomer  is
      approximately sixty percent.  The polymer passes through a letdown valve
      to reduce the pressure of the material before entering the extruder.
      Eighty strands of polymer are produced in the extruder and are then sent
      through a water slide.  The strands are pelletized, conveyed and then
      sent to the packaging system within the PM plant.  The water is
      separated when the polymer strands enter the pelletizer.
Summary of Audit Findings and Recommendations:

Conclusions:

Process Information

•     All monomer processing lines are handled within a closed pipeline
      system.

•     The plant has no fixed perimeter air monitoring and little in-plant
      permanent monitoring.

•     R&H does not use scientific methods or instrument readings in its
      investigations of odor complaints.

•     At least one operating area had small quantities of flammables,  acids,
      and caustic stored next to each other on the floor.

Chemical Accident Prevention

•     The company has summarized its safety policies in twenty documents
      covering a number of topics, such as "management policy," "safety
      regulations," and "fire control and prevention."

•     R&H has developed a Major Accident Prevention Program (MAPP)  to  ensure
      that their operations and products are free of unacceptable  risks to
      carriers, distributors, the general public, and the  environment.  This
      program provides plant managers with a database to assess potential on-
      site risks through computer simulations and decision-making  aids.

•     The older section of the plant demonstrates rusted and missing decking,
      little to no housekeeping, missing fire extinguishers,  broken safety
      showers and eyewash stations, unchained cylinders,  etc.
                                      88

-------
•     Material Transfer

      MMA distillation area:  A partially closed loop system transfers
      crude MMA from railcars to storage tanks with a self-priming  pump
      at atmospheric pressure.  This system is classified as a partially
      closed system because crude gaseous MMA is vented to the
      atmosphere.   A detailed unloading procedure is available within
      the unloading section of the area.  A comprehensive checklist of
      all connections in the partially closed system must be completed
      before the crude MMA is transferred.  Inhibited MMA is transferred
      from the process to run down tanks in a closed pipeline system, to
      verify product purity and to stabilize the material with
      inhibitor.  Inhibited MMA is then transferred to its respective
      storage tank and/or through its designated pipeline to other  areas
      of the R6H facility.  It is also transferred from storage tanks to
      railcars in a partially closed loop for final product sales.
      Inhibited MMA is also transferred into fifty-five-gallon drums
      through a closed loop automated system for final product
      packaging.

      PM Plant:  Inhibited MMA and EA are transferred from the MMA
      distillation area to the PM plant in separate closed pipeline
      streams.  The plexiglass resin pellets are transferred from the
      process area to a loading area, where they are packaged in
      appropriate storage containers.

Process Area(s)

The MMA Distillation Area.  The main function of this area is to remove
the impurities in crude MMA by vacuum distillation for use in subsequent
polymerization processes.  Liquid crude MMA is fed into the distillation
area where it is split.  One process line enters a distillation column,
where residual water is separated from the crude MMA off the top of the
column.  The bottom stream then enters a second column in series,  where
purified uninhibited MMA is taken off the top of the column and
transferred to its respective run down tank and the bottom stream is
sent to a fourth distillation column in parallel for further
purification.  The second stream of the main crude MMA is sent through a
preheater where it is converted to a vapor.   This stream enters a third
distillation, where the top distilled stream is purified uninhibited MMA
and is then combined with the above purified stream,  where it is
transferred into run down tanks.  The bottom stream of the third
distillation  is combined with the stream of the second distillation
column as feed for the fourth distillation column.   The top distilled
stream is recycled back into the distillation scheme and the bottom
stream third  stage bottom residual.   The third stage bottom is then
transferred to a storage tank.

PM Plant.  The PM-Line process observed by the audit team,  called the
 "continuous molding powder extrusion process," involves a transfer of
MMA and EA by pipeline from their storage tanks through separate
cartridge filters, where it is blended into three mixing tanks.

                                87

-------
•     To prevent releases Ln the MMA distillation area,  R&H  is  constructing a
      state-of-the-art tank farm for MMA storage, which  will  incorporate  high-
      level alarms that will automatically shut off  feed into  the  tanks,
      temperature sensor alarms connected within the distributive  control
      system, vents connected to a central scrubber, and completely  lined
      concrete dike floors.   This will be finished in mid-1991.  The
      installation of some aspects of the area are subject to  availability  of
      funds.

•     R&H has installed a fire suppressant foam injection system and  flame
      arresters on the vent lines.  The enclosed distillation  area contains  a
      sprinkler system that activates automatically  in the event of a  fire.

Accidental Release Investigation Procedures

•     Systematic procedures exist for accident investigation and follow-up,
      including an analysis of the nature and underlying cause  of an accident
      and suggested remedies.

Facility Emergency Preparedness and Planning Activities

•     The facility has a preparedness, prevention,  and response plan in place
      to assess and respond to emergencies.   This plan is a merger of  the
      offsite emergency response plan, the SPCC Plan, and the Plant Emergency
      Manual.

•     Emergency response simulations are conducted regularly to test and
      revise the facility plans.

•     The Bristol plant has a wide variety of emergency  equipment including
      fire extinguishers, fire hose lines,  fixed foam and dry chemical
      systems, breathing gear, two fire trucks, two safety/response vehicles,
      a tractor-trailer, and an extensive fire hydrant and sprinkler system.

•     The facility's self-contained breathing apparatus  (SCBA's) are located
      in areas where they are generally inaccessible to  the  area operating
      personnel in an emergency.

•     The Bristol plant emergency coordinator is the Plant Superintendent.
      This person has complete authority in any facility response action and
      is responsible for committing all the resources necessary to protect
      health, the environment, and the facility.

•     A trained emergency response team is on call  24 hours  a day,  seven days
      a week to respond to in-plant releases.  Procedures for responding to
      accidental releases are set forth in the facility's Spill Prevention,
      Control, and Countermeasures (SPCC) plan.

•     Training for the emergency response team is based on 29 FR 1910.120  and
      guidelines in NFPA 472.  Training is provided by the Pennsylvania State
      Fire Academy and private consultants.   Ongoing training for team members
      is conducted on a weekly basis.

                                      90

-------
R&H Bristol initiated a management safety audit program  in  April  1990,
with the intent of improving safety performance and minimizing
accidents.

R&H Bristol conducts scheduled audits every  three years.  R&H corporate
officials conduct safety, health, and environmental audits  every  two
years.   Consultants are hired occasionally to do specific audits.

A new facility wastewater treatment plant, scheduled  to  come on line  in
late 1991 is expected to further reduce emissions and odors  (the  main
source of public complaints about the R&H facility).

Operating manuals are available in the control room.  Critical emergency
operating procedures are posted in the MMA distillation  area control
room.

R&H either develops or imports intensive training programs  to achieve
competence levels for three types of employees:  operations personnel,
emergency response team members, and new employees or contractors.

The facility does not use graded testing or  evaluation to determine the
progress of employees in training.

A formal hazard communications class is required for all new employees
and an annual refresher is given to all employees to update them on new
processes or legislation.

The maintenance procedures at R&H are organized through a manual work
order system.  Work orders are initiated by  the plant section requiring
maintenance activity and are prioritized and scheduled by the
maintenance department in consultation with  the section making the
request.

The preventive maintenance system is primarily manual and concentrated
on annual relief valve and flame arrestor inspection,  critical
instrument calibration, and frequent-moving equipment inspection and
lubrication.  Detection and correction of minor leaks is a part  of the
daily responsibilities of production supervision and the area
maintenance department.

R&H Bristol recently installed a computerized Maintenance Management
System for preventive and corrective maintenance.   This  system will be
phased in during 1991-2 to cover all desired preventative and
predictable maintenance activities.

R&H Bristol has a systematic program for hazard evaluation.   The  risk
assessment involves safety, health,  and environmental reviews, HAZOPS,
major accident prevention program review,  and SAFER.   Any employee can
request a review if he or she thinks that an instruction or  operating
practice either violates plant safety policy or places an employee in
danger.  HAZOPS are generally conducted on new processes  and procedures
as they are introduced.

                                89

-------
Chemical Accident Prevention

•     Operator training should have some type  if graded  testing  to  indicate an
      employee's progress before hands-on work begins.

•     The facility should perform HAZOPS on existing as  well  as  new processes
      and procedures.

•     R&H should complete the planned construction projects,  including  the  new
      tank farm, in accordance with the stated design.
Facility Emergency Preparedness and Planning Activities

•     The facility should consider strongly relocating the SCBA units so  that
      they would be accessible to plant operating personnel.
Audit Team Member Composition:

Name and Title                      Walter Lee
Affiliation                         EPA Region 3 OSC
Area of Responsibility              Team Leader
Expertise                           Chemist

Name and Title                      Kevin Koob
Affiliation                         EPA Region 3 OSC
Area of Responsibility              N/A
Expertise                           Environmental Protection

Name and Title                      Joseph Popp
Affiliation                         EPA Region 3
Area of' Responsibility              Emergency Planning
Expertise                           SARA Title III
Follow-up Activities:

      By the Facility:

      (1)  May 31, 1991 letter to EPA Region 3 stating the facility's intent
      to respond to the recommendations of the audit report.

      (2) August 12, 1991 letter to EPA Region 3 discussing the facility's
      response to the  conclusions and recommendations of the audit report.

      By the Regional Office:

      By State and Local Authorities:

Regional Contact:       Joe Popp          (215) 597.-1357
                                      92

-------
Community and Facility Emergency Preparedness  and  Planning Activities

•     R&H Bristol is a participant  in  the CAER program,  and  supports a  number
      of outreach programs in the community.   Publications describing
      emergency response procedures, training  activities, health  and safety
      matters, and plant issues are available  at a reading room open to the
      public.

•     R&H plays a lead role in the developing  Buck County's  local emergency
      response plan.

•     R&H's emergency response team is equipped with vehicles and supplies to
      respond to both on and offsite emergencies involving R&H products.  In
      the event of an onsite emergency beyond  the  capability of the emergency
      response team, the Croydon Fire Department will provide assistance.

Public Alert and Notification Procedures

•     If external assistance for emergency response is needed, the local fire
      and police departments can be summoned by a  hot line from the main
      guardhouse.  A backup is available by radio.  An automatic-dial
      emergency notification system also exists to  serve the five homes in
      Maple Beach that are adjacent to the facility.

•     The Emergency Response Coordinator will  determine whether to notify the
      local emergency response agencies of a perceived need to evacuate the
      community.

•     The R&H Manager of Public Affairs is the designated contact for the news
      media.  The facility is proactive with the media except during a
      release, in which facility policy is to be reactive.
Recommendations:

Process Information

•     The plant should install some type of permanent perimeter air monitors
      with permanent recording capacity.

•     R&H should provide instrument readings and consider using highly
      sensitive instruments to investigate odor complaints.

•     The facility should increase maintenance and inspection activities to
      improve housekeeping in the older sections of the facility.

•     The facility should never store flammables, acids,  and caustic near each
      other.
                                      91

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      The liquid chlorine product  is stored  in  a  series  of tanks:

               Ten tanks of 100-ton capacity,
               One stand-by tank in case  there  is  a  leak,
               One tank at 200 psig to deliver  chlorine  to the  Bowater,
            -  One tank at 125 psig to deliver  chlorine  ~o the  HTH
               process; and
            -  Three tanks of 300-ton capacity.

      Sulfuric acid is stored in a 100-ton elevated  tank (about 15  feet
      in height) in close proximity to the chlorine  compressor  building.

      The finished caustic soda is stored in five  tanks,  two of which
      have much larger than the capacity of the smaller  three.   The
      maximum total storage at Olin is 2,930 tons.   One  of the  smaller
      tanks is dedicated to the storage of the  dilute  (20  percent) NaOH
      that is pumped to another facility across the  Hiawassee Ri- >r.
      The NaOH tank farm is located adjacent to the  rail  loading area
      which is near the barge loading area on the Hiawassee River.

      The maximum quantities of sodium hydroxide shipped out and/or used
      by mode are:
            Tanker trucks           150 T/day
            Barge (1 only)          Variable T/day
            Pipeline to Bowater     100 T/day
            HTH production          100 T/day
            Rail (other points)     Balance of production

      Prudential Bache supplies the mercury at a purity of 99.9 percent
      in standard 76-pound flasks.  These incoming flasks  are stored
      outside in a security area.  The mercury is removed  and used
      monthly on an "as needed" basis.

      Hydrochloric acid (HC1), at 32 percent concentration, is stored in
      two steel tanks, with a combined storage capacity of 56,000
      gallons, located in the vicinity of the brine preparation area.
      The HC1 is pumped to two additional tanks of unknown capacity for
      use in the pH control of the brine feed to the electrolytic cells.
      It is also pumped to the area where the filter cloths for the
      vacuum filters in the HTH process are cleaned.

      Liquid sulfur dioxide is stored in tanks adjacent to the Reductone
      manufacturing facility.
                                94

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Olin Chemical Corporation
Facility Location:
Charleston, Bradley County, Tennessee,
Region 4
Date(s) Audit Conducted:
May 1-5, 1989
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
2812 -- alkalies and chlorine
The plant is located near interstate 75,
1.5 miles west of Charleston, Tennessee on
the Hiawassee River.
The plant manufactures liquid chlorine,
caustic soda, sodium hydroxide, calcium
hypochlorite (HTH™)  and  aqueous sodium
hydrosulfite (Reductone™)
There are eleven people living or working
within one-fourth mile of the plant.
There are also several schools,  nursing
homes, and residential communities within
two miles of the plant.
Reason for Facility Selection:
      ARIP Reports:
The audit was triggered by an alleged
mercury release and worker exposure which
occurred on August 22, 1988.

None
Focus of Audit:
      Hazardous Substances(s)
      Examined:
Chlorine
Caustic soda (NaOH)
Mercury
Hydrochloric acid
Sulfuric acid
Sulfur dioxide
                                      93

-------
      The hydrochloric acid is pumped from the railyard  to  the  storage
      tanks through plastic-lined mild steel piping.

Process Area(s)

The Olin chlorine plant utilizes the mercury cell process to produce
chlorine, caustic (sodium hydroxide), and hydrogen which is used  as fuel
for the plant steam boiler.  The plant produces about 700 tons/day of
chlorine, 784 tons/day of 50 percent caustic, 225 tons/day of HTH, and
65,000 gallons/day of Reductone.  Part of the sodium/mercury amalgam is
used to make Reductone™  (sodium hydrosulfite).  The  major process st?ps
are as follows:

Brine Preparation and Saturation.   The raw sodium chloride (Halite).is
dissolved and purified.  This new salt solution resaturates the spent
brine from the mercury cells.  Hydrochloric acid adjusts the pH of the
brine for use in the cells to 3.5.   Approximately 15 percent of the salt
is used by the cells during electrolysis.

Mercury Electrolytic Cells.  The brine and mercury flows concurrently
through an elongated enclosed trough set at a slight angle to effect a
flow of mercury across the bottom surface.   Chlorine is produced at the
anode in the brine solution and the mercury forms an amalgam with the
released sodium.  The chlorine compressor,  maintaining a negative
pressure on the cells, draws off the chlorine gas.   Compressor vibration
is monitored on the DeLaval compressor to avoid failure or problems.
The mercury-sodium amalgam is treated with water forming sodium
hydroxide.  Loss of mercury flow in the cells will shut off the cell
power.  Computers control volts/amps to the various anodes on the cells.

Cooling and Drying.  The chlorine gas (negative pressure; is cooled in a
two stage shell and tube heat exchanger (one for each cell room).   There
are two parallel cooling trains, one for each cell room.   Concentrated
sulfuric acid dries the cooled chlorine gas in a fourstage tower system
(one for each cell room).

Compression and Liquefaction.  The  dried gas is compressed,  liquefied by
low temperature chilling, non-condensible gases are removed  (blow-off)
and the liquefied chlorine sent to  storage.   The compressor  maintains
the vacuum on the cells.
                                96

-------
The 95 percent potassium hydroxide  (KOH) is received  in  1000-pound
supersacks which are stored and repackaged into  50-pound
paper/plastic type bags all within  one area of the storage
building.  The building containing  this operation also acts  as  the
storage area for other dry bulk items such as activated  charcoal,
carbon granules, powdered cellulose  (filteraid)  and sodium
sulfite.

Finished products of calcium hypochlorite are produced in granular
and tablet forms.  Storage is limited in quantity per warehouse
and each unit containing the product is isolated from each other.

Shipping/Receiving

Weight measurement manually controls the transfer of liquid
chlorine to tank cars, pipeline, or barges.  Two parallel
pipelines provide the means for supplying the Bowater Paper Mill
with both chlorine and 20 percent sodium hydroxide.  These lines
are 9,000 feet long and run above the ground on  the south side of
the Hiawassee river and traverses across Olin and Bowater
property.  There are two bridges in this system which carry the
product across the Hiawassee to Bowater.  The chlorine pipeline
contains six tons of chlorine and 40-45 tons per day is
transferred to the Bowater facility.

Liquid sulfur dioxide, HTH™, and sodium chloride are  each shipped
by truck.  Mercury is shipped in standard metal flasks.   The 32
percent hydrochloric acid is received in rail tank cars and pumped
directly to the two main storage tanks.

Material Transfer

Wet chlorine from the electrolytic cell is transferred in
fiberglass-reinforced pipes with compressed gases (before cooling
and drying stage), and dry chlorine is transferred in carbon steel
pipes.

Carbon steel piping is also used for sulfuric acid.

The mercury is transferred to the cell buildings as required from
the storage area in the metal flasks by forklift.  The flasks are
emptied  into a sump at the ground level and the mercury is  pumped
to mobile tanks on the second floor where the electrolytic  cells
are located.

The spent and fresh brine from the electrolytic process  is  carried
through  the circuit in fiberglass reinforced plastic  (FRP)  pipes.

The caustic solution from the decomposers is transferred  to  the
cooling  and filtration sections in plastic-lined or nickel  pipes.
                          95

-------
The building containing the potassium hydroxide  repacking
operation also acts as the storage area for other dry bulk  items
such as activated charcoal, carbon granules, powdered cellulose
(filteraid) and sodium sulfite.

Finished products of HTH™ is  produced in  granular and tablet
forms.   Storage is limited in quantity per warehouse and each unit
containing the product is fully isolated  from each other with
reasonable access to each building in the event  of an emergency.

A caustic line runs from Olin to the Bowater facility.  This
pipeline contains 6 tons of chlorine and 40-45 tons per day  is
transferred to the Bowater facility.   Inlet pressure at Olin is
200 psig and at the Bowater facility, the discharge pressure is
160 pounds.  It had only one valve which was visible on the
suspension bridge 2/3 of the way across towards  the Bowater side.
The valve apparently needed maintenance as there vas a thick crust
of caustic formed around the stem and body.

The on-site storage tank for sulfuric acid is elevated.   Rupture
of the tank would cause an uncontrollable release that should
present a severe hazard to workers in the immediate area.

The overhead piping network includes pipes that carry hydrogen,
caustic, and water.  There is no visible color coding or labeling
of the pipes with the exception of the hydrogen.   The hydrochloric
acid line was the only pipeline that appeared to be coded in the
overhead rack.  After the storage tank,  the hydrochloric acid
lines were not as well marked.

The interlocking of critical equipment shuts systems down if
operating conditions exceeded prescribed safety operational
levels.  Relief valves set well below design specifications
protect the tanks.  The most noticeable out-of-normal operating
limits were on coolers when one of the cooling units had to be
taken off line.  However, excessive temperature rise would result
in a shut down.

In general, spare pumps provide back-up.   Cooling systems  and
compressors had excess capacity that could compensate for  outages
and minor problems.  Major failures would require shut down.

There is an interlock on the compressors such that any compressor
failure will cut off the cell room and stop formation of chlorine.

High and low pressure alarms are provided to avoid vacuum  in the
electrolytic cells.  High temperatures on the refrigeration and
cooling units also trigger an alarm.   Hydrogen in the chlorine  gas
is monitored continuously and hazardous levels are indicated by  an
alarm.  The operators provide manual measurements.   Most of the
chlor-alkali operations utilize manual controls rather than an
automated or computerized system.

                          98

-------
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     The total property  encloses  1,029  acres  and the  plant  proper
            occupies approximately  100 acres.   There are approximately 700
            employees, 500 of which are  plant  people.   The plant  is  non-union.

      •     There are one primary and two  secondary  roads that provide access
            to the Olin facility.   These roads  lead  to  a public road that
            leads toward 1-75 in one direction  and the  town  of Charleston  in
            the other.  The plant is also  accessible by barge and  by the
            Southern Railway.

      •     Olin has an on-site wastewater treatment facility.  It discharges
            approximately 2,700 gpm of treated  wastewater and non-contact
            cooling water as authorized  by Olin's NPDES permit.

      Chemical Hazards

      •     Over k percent hydrogen in the chlorine  gas could result  in an
            explosion in the compressor  as well as in the electrolytic cell.

      Process Information

      •     The area underneath the chlorine storage tanks was gravel.  Thus,
            penetration into the soil would take place  with  any spills.  The
            liquid chlorine storage farm would  be the location for the
            greatest potential  release.  The rupture of a tank could  release
            100 or 300 tons of  chlorine.

      •     No area chlorine monitors are  in place at the tank farm or loading
            station.

      •     Placards describing the hazards of  the chemicals were not on every
            tank that contained sodium hydroxide.  There  are no placards
            displayed in the mercury storage area to indicate the hazards of
            the stored materials.   The main HC1 storage  tanks were well
            labeled with placards prominently displayed.  The feed tank on the
            roof of the HTH™ building  was  not  labeled.

      •     Mercury is stored in standard  76-pound flasks in a security area.
            This area consists  of an 8-foot Lundy fence with a gate that is
            kept locked at all  times.  An  authorized requisition signed by the
            cell room supervisor gives access to the key.

      •     The HC1 tanks did not have any containment  walls built around
            them.
                                      97

-------
the activities of assigned sub-committees.   Filtering  down  from
the Executive Safety Committee,  additional  levels of employees
meet beginning with department managers and the  individual
supervisors of each area, then the  supervisors and  their
individual plant employees.   In  this  fashion, each  and every
employee is continually reminded in a formal setting,  meeting at
least once per month, of Olin's  commitment  to safety.  Each
meeting follows a structured  format and minutes  are published
upward to each level of management.

The training given in emergency  procedures  (fire/explosion, gas
release, plant evacuation and natural disasters) is periodically
reviewed.  Emergency training is  done by conducting emergency
drills.  The operators are warned that a drill will take place.
Because of low turnover, the need for formal operator  job training
is minimal.  However, when it becomes necessary  to  train new
operators in their jobs, Olin follows an established procedure.
New operators enter the work  force  into either the  "utility pool"
or "labor pool" and, after completing the safety training
indoctrination course, receive their  on-the-job  training in the
plant from their supervisor in concert with the  experienced
operators.  From time to time, the  supervisor certifies the skill
level of the new employee.  Refresher training is given when new
procedures, equipment, or processes are introduced.   Olin provides
about one-hour training orientation for contracted workers and the
contractors are required to conduct monthly safety meetings at a
minimum.  Olin provides all new  employees and contractors with
orientation related to hazardous  chemicals and safety procedures
at the plant.  Five safety sessions are held at  the  plant each
month.  Each employee must attend at  least one of these meetings.

Operating manuals for both standard and emergency procedures are
available in the control rooms.  Manuals are updated as procedures
change as initiated by the operations  staff/operators or from
safety reviews.  The manuals were written or updated in 1987 and
1988.  General flow diagrams are  also  located in the control
rooms.

The Manager of the 'Safety/Loss Prevention Department reports
directly to the. Plant Manger.  He is  also responsible for plant
security and allocates his time  among  his various duties in
proportion to the need of each activity, although safety has a
very high priority.  In addition .to the' safety director,  the
safety department includes a secretary, a safety supervisor,  and
eight technicians.

Records maintained on each employee show:
   Meeting attendance
   Safety equipment issued
   Training on the use and care  of  equipment
   Training received in critical  safe  work procedures
                          100

-------
•     The plant has a corrosion monitoring program  for determining  the
      degree of corrosion which has occurred in piping and  in  tanks.

•     There are no continuous environmental monitors, including no
      permanent mercury vapor monitor, in the chlor-alkali  system.
      Chlorine is monitored periodically by a portable instrument.  The
      air is monitored with a portable meter twice  daily.

•     The circulating mercury lines on the cells have a sight  glass for
      visual observation of mercury flow, which appears to  be
      susceptible to breakage and leaks.

•     On the brine lines, there was notable leakage at flanges.  This
      should not result in any hazard.

•     Portable monitors check for chlorine and hydrogen leaks.   For
      small chlorine leaks, ammonia is used to locate the source of the
      leak which is then isolated and repaired.   Chlorine liquid and dry
      gas lines are made of carbon steel.  Wet gaseous chlorine is
                  handled in fiber glass pipes that are resistant to
                  chlorine corrosion.

Chemical Accident Prevention

•     Spills of liquid sulfuric acid may be absorbed by a variety of
      material (vermiculite,  dry sand, earth).   However,  the elevated
      tank and lack of retaining walls would increase the mitigation
      problem.  Spills from the mercury lines are contained by  troughs
      and dikes that direct the mercury to drain into sumps in  the lower
      floor.  Commercial vacuum cleaners  are used where needed.

•     Operational log entries are made on an hourly basis.   Out of
      specification excursions or problems are also recorded.

•     The plant's safety audit procedures vary from standard safety
      audits to hazard operational audits using  consequence and fault
      tree analyses.  The consequence  analysis does not evaluate the
      potential effect outside the property line.   The fault tree
      analysis is not conducted on a step-wise basis but  addresses an
      integrated sub-unit (pipeline or reactor).   The hazard analysis  is
      based on Olin's SETCO (Safety Engineering,  Technical,  Construction
      and Operations) approach.  Hazard evaluations are conducted  after
      design, construction (or changes),  and start-up operations.   Any
      individual from operators on up  may request a hazard  evaluation.
      Results of these evaluations may result in change of  operating
      procedure or equipment.

•     Management participates in safety activities through  the  Executive
      Safety Committee, which consists of line managers  and staff
      managers and is chaired by the Charleston  plant manager.   The
      purpose of the executive committee  is to oversee the
      accomplishment of established safety goals and to  participate  in

                                99

-------
•     Hydrotesting of every storage  tank occurs  every  four  years.

•     Automatic control devices have manual bypasses.

•     Inspections are conducted annually on chillers,  couplings  and gear
      boxes.  Liquid pumps are subject  to  take down very  four  years.

•     The only protection system  in  the Reductone™ was venting on the
      top of the reactors.  These were  hooded and  vented  through a
      scrubber for S02 control.

Accidental Release Incident Investigation

•     There were six explosions within  the electrolytic cell in  1988.

•     Recent accidental releases  and alleged releases  of  Title III
      chemicals have occurred as  follows:

            DATE              SUBSTANCE         QUANTITY
      March 11, 1988    Chlorine                   10 Ibs
      May 17, 1988      Mercury                    4 Ibs
      June' 2, 1988      Calcium Hypochlorite     225 Ibs
      July 22, 1988     Caustic                 3600 Ibs
      August 22, 1988   Mercury
      February 2, 1989  Calcium Hypochlorite       50 Ibs
      April 6, 1989     Calcium Hypochlorite     350 Ibs

•     Olin has an accident investigation team comprised of operations,
      safety, maintenance and engineering personnel.  Other skills may
      be assigned to the team as needed.  This team has the
      responsibility of investigating the cause of an accident and
      developing corrective action plans.

•     Operators write accident reports after each occurrence.
      Supervisors, superintendents, maintenance,  the safety officer and
      the plant manager review these reports.   At any step,  a hazard
      evaluation may be requested.  The accident investigations also
      include near misses.

Facility Emergency Preparedness and Planning Activities

•     The Charleston plant has prepared a "Safety Standard Procedures
      Manual" which addresses every aspect of safety at the facility.
      The chapters of the manual are periodically reviewed and revised.
      Excerpts from the manual have been published in a pocket edition
      which is issued to each employee for reference.

•     Olin maintains emergency plans' dealing with fires,  natural
      disasters, bomb threats, as well as gas  releases.  The plan
      concentrates on extremely hazardous substances with special
      attention being placed on chlorine and sulfur dioxide.   The
      emergency plans do not identify an individual who would have full

                                102

-------
   Training received in emergency procedures
   Accident and injury history

The maintenance department consists of approximately 85 personnel
from Olin and contractual groups and is specialized into three
principal sections: Chlor-Alkali Mechanical, HTH™ Mechanical,  and
Instrumentation and Electrical.  The ratio of maintenance workers
to operating personnel is approximately 15:100.  The contract
maintenance deals with major repairs or construction.  The plant
maintenance is based on a computerized preventive maintenance
system and standardized work orders and lockout or lock and  tag
procedures. All failures or repairs are recorded and frequency of
required repairs are used to adjust preventive maintenance
frequency or evaluation of alternate equipment.  Devices that are
critical to continued operation of a process, are tabulated  on the
"critical safety device" list, which shows the type of equipment,
the priority of maintenance and the maintenance frequency.    The
"Operating Safety and Hazard Review Cycle" tabulation identifies
the hazard rating of various systems and/or equipment and the
optimum frequency cycle for maintenance or turn-around.
In-house technicians, who receive their training and re-training
at schools conducted by the instrument manufacturers and vendors,
perform instrument maintenance.

An air quality program has been initiated by Olin and consists of
three major parts:
         Identifying and quantifying continuous emissions of air
            toxics,
         Performing a risk assessment for major air toxic
            releases, and
         Reducing continuous emissions and the potential of
            releases where necessary or practical.

Risk assessment studies have been conducted by JBF Associates of
Knoxville, TN in October 1987,  and another by the Olin Chemical
Group on Air Quality from December 1986 to August 1988.   Before
the study by JBF began, the plant's MSDSs were studied in order to
select all the chemicals which could generate a toxic release.
Then, only those chemicals which were on the SARA and CERCLA lists
in excess of the RQs were included in the study.   This report then
determined the likelihood and consequence of various sizes of
chlorine and sulfur dioxide releases at the plant.   An atmospheric
dispersion analysis determined the areas impacted.

One chlorine storage tank is in stand-by condition under vacuum to
drain other tanks if a leak takes place.

The plant will be installing video cameras at chlorine loading
sites.
                          101

-------
Community and Facility' Emergency Response Planning Activities

•     Olin provided leadership in helping Bradley and McMinn Counties,
      the areas most likely to be affected by a chemical release  at
      Olin, develop and exercise county hazardous material plans.  There
      is on-going communication with officials in the towns of
      Charleston and Calhoun and with emergency management directors  and
      hazardous materials response team leaders in Bradley and McMinn
      Counties.

•     Olin's hazardous material team participated with local authorities
      in a recent actual railway accident in which several chemicals
      were spilled within two miles of t'-  Olin facility.

•     Olin has a current emergency response plan which is regularly
      exercised on site.  Although they have had no exercise with
      outside agencies based on a specific scenario involving a mock
      release at their facility,  they have been heavily involved with
      outside agencies in connection with mock highway and rail
      transportation accidents involving hazardous materials.

•     Olin management considers its own response capability to be
      sufficient to deal with any plant accident with the exception of a
      major fire.  The Charleston volunteer fire department',  which has
      been called to assist only once during the past nine years, come
      to the plant for training once per year.   Training is furnished to
      responders on a continuing basis.

•     Olin contracted with Safety Systems of Florida to train fire
      departments, hazardous material teams,  and emergency management
      directors from Charleston,  Calhoun,  Athens and Cleveland and from
      Bradley and McMinn Counties as part of their
      continuing training program.

•     Olin Corporation and Bowater Southern Paper Company have jointly
      published an information pamphlet explaining that they  maintain
      and use chemicals that could be harmful under certain conditions.

Public Alert and Notification Procedures

•     A review of Olin's notification .reports on chemicals  to  local and
      state governments shows they have been made on time and  in the
      form requested by the State Emergency Response Commission (SERC).
      Records show Olin, with minor exceptions,  has made  CERCLA and
      Title III release notifications as required.   Portions  of the
      Section 304 of Title III notification requirements,  however,  are
      not  included in Olin's notification procedures.
                                104

-------
and final authority during the  "off  shifts"  when senior  management
was away from the facility.

Emergency response exercises are conducted quarterly.  In  addition
to these, Olin has participated in mock highway  and  rail
transportation accidents involving hazardous chemicals.  Olin also
participated in a CAER exercise in which  schools in  Charleston and
Calhoun were evacuated.  Residents of the two towns  were not
evacuated, but the exercise showed that the  evacuation could  be
achieved successfully within the adequate time.   To  date,  Olin has
not participated in a specific simulated  incident involving a mock
release at the Charleston facility.

Plant sirens are in place for plant-wide warning of  significant
chemical releases.

There is only one road leading from  the Olin facility which would
be available for evacuation from the plant.   The road leads to a
public road which accesses Interstate 75 and Charleston.

Olin has a supply of well-maintained response  equipment.   They
have a fire truck, an ambulance, portable high-efficiency
lighting, self-contained breathing apparatus  and protective
clothing.  Fire protection is described on various drawings by
Jacobs Engineering Group.  Fire protection water  is provided  from
the river by 2500 gpm fire water pumps and back-ups.   Also,
associated drawings show the location of smoke detectors, fire
extinguishers, hose reels,  etc.

A medical doctor is on -duty 20 hours per week, and two registered
nurses serve during the normal workday.   Trained  emergency first
response technicians serve the night shifts.

During the daytime working hours,  in case of emergency,  the Plant
Manager and the Safety Manager would converge on  the  central
security station 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 the dry caustic office.
There is an emergency telephone system which connects security and
other critical points at the facility.  They have multi-channel,
two-way radios for internal operations and channels for
coordinating with Bowater.   They further have a console at  the
main security station which not only handles communications as
described above but also has ability to make either direct  or
indirect contact with all major outside emergency responders.   An
emergency may be identified by any of the facility personnel.   The
alarm is given over the emergency telephone system to the central
security station and the security technicians initiate the
appropriate plant alarms and responses.
                          103

-------
      •     Olin should install chlorine monitors at the tank farm and loading
            station.

      Chemical Accident Prevention

      •     Olin should give outside contractors more training in required
            plant safety procedures and protective gear.  Olin should consider
            implementing a standard safety training procedure for contiactors
            and visitors to the facility.

      Community and Facility Emergency Response Planning Activities

      •     Olin should consider joining with public officials to conduct an
            exercise  involving a scenario relating to an accidental release
            from the  Olin plant.

      Public Alert and Notification Procedures

      •     Olin procedures should be expanded to include all Title III
            notification requirements.   Olin's notifications should include
            the SERC  (TEMA) for all reportable release incidents.

      •     Olin Management should discuss notification time with Bradley and
            McMinn emergency management directors to determine if Olin's  off-
            site notification procedures meet their needs.

      •     Olin should secure and place on their alert procedures a  means of
            locating  the Bradley County Emergency Management Director after
            working hours since the phone number listed is  only  good  during
            business  hours.
Audit Team Member Composition:

Name and Title                Henry Hudson,  Team Leader
Affiliation                   US EPA Region  U
Area of Responsibility        N/A
Expertise                     Chemical Engineering

Name and Title                Pat Steed,  Deputy Leader
Affiliation                   US EPA Region  4
Area of Responsibility        Training,  Safety,  Management
Expertise                     Mechanical Engineer

Name and Title                Gaines Boone
Affiliation                   US EPA Region  4
Area of Responsibility        Emergency Planning
Expertise                     N/A
                                     106

-------
      Olin's emergency plan for a gas release divides response actions
      into three types or conditions depending upon the extent of the
      release.   These conditions are as follows:

            1.   A gas release occurs producing toxic materials limited
                to the immediate area where the gas release occurred.
            2.   A gas release occurs in which levels of gas or vapor
                released are expected to be contained within the plant
                perimeter (fence line).
            3.   A gas release occurs with possible effect on neighboring
                areas.

      Once Condition 3 is reached, security notifies the Charleston
      Police,  Bradley County Emergency Mgmt.,  and the National Response
      Center.   Depending on the wind direction, others may be notified.

      There are no public warning systems in the communities surrounding
      the Olin plant.  Should evacuation become necessary, citizens
      would be notified by public officials, (i.e., police and firemen),
      going from house to house.

      Emergency response officials noted Olin has reported no chemical
      releases which required public agency response.   However,  minor
      releases have occurred.

      Olin officials have worked closely with Bradley County Emergency
      Management Agency officials in developing emergency messages to
      broadcast in the event of a chemical accident at Olin.

      There is no means of locating the Bradley County Emergency
      Management Director after working hours.   The only phone  number
      listed is a business phone.
Recommendations:

Process Information

•     Because of the potential for a spill to penetrate into the soil,
      suitable containment beneath the chlorine storage tanks should be
      provided.

•     Placards should be displayed in the mercury storage ar*ea to
      indicate the hazards of the stored materials.

•     A more adequate corrosion monitoring program should be adopted.
      Electronic instrumentation for measuring piping and vessel wall
      thicknesses and integrity should be utilized.

•     Suitable containment for the mercury lines sight glass (e.g.,  a
      tube within a tube) should be provided.
                                105

-------
108

-------
Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Tom Plouff
US EPA Region 4
Chemical Systems
Environmental Engineer

Kelly Jane
US EPA Region 4
Chemical Systems
Chemical Engineer

Bill Ross
AARP, US EPA Region 4
Chemical Systems
PhD, Chemical Engineer

Tom Yabate
AARP, US EPA Region 4
Chemical Systems
Chemical Engineer
Follow-up Activities:

      By the facility:

      By the Regional office:

      By State and local authorities:
Regional Contact:
Henry Hudson
                                      107

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

     ' Photocircuits Atlanta stores chlorine  in  a  maximum of sixteen
      cylinders located in fenced, locked, and  covered enclosures.
      There are six chlorine cylinders which are  connected to  the
      manifold by ground level piping.  Temperature  regulation is
      necessary to keep chlorine  in  its vapor state.

      Hydrochloric acid is maintained in  two fiberglass  reinforced
      plastic tanks each with a maximum capacity  of  4,000  gallons.   The
      tanks are enclosed in a chainlink fence above  acid resistant,
      plastic coated concrete pads and floors with .concrete  dikes.

      Both the sulfuric acid and  sodium hydroxide tanks  are  inside  a
      waste treatment floor without  a dike.   Sulfuric  acid is  contained
      in stainless steel storage  tanks with  a capacity of  6,000 gallons,
      adjacent to sodium hydroxide fiberglass reinforced plastic tanks
      of the same capacity.

•     Shipping and Receiving

      The maintenance supervisor  is  responsible for  unloading  the liquid
      chlorine, which is brought  to  the plant by  truck in  one  ton steel
      cylinders from 7AM to 3PM.

      Hydrochloric acid reaches the  facility by tank truck during the
      7AM to 3PM shift and is unloaded by the waste water  treatment
      operator.

      The waste water treatment operator and the  maintenance supervisor-
      assume responsibility for unloading sulfuric acid  during the same
      7AM to 3PM shift.  They are also responsible- for the incoming 50
      percent aqueous solution of sodium hydroxide, which  is unloaded by
      a labelled quick connect nozzle.

•     Material Transfer

      Chlorine is transferred from the manifold into the pipeline and
      into the suction port of the eductor.   The  chlorine supply line
      under vacuum is maintained  by  a low pressure inlet to the eductor.
      The vacuum opens the chlorine  supply to the chlorine line.  This
      supply will be shut off if  the vacuum  fails.  The  chlorine
      transfer line, made up of PVC,  is labeled as to  contents.

      Tank trucks of hydrochloric acid,  sulfuric  acid  and sodium
      hydroxide use their own pumps  for unloading.
                                110

-------
                        CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Phococircuits Atlanta
Facility Location:
Peachtree City, Georgia, Region 4
Date(s) Audit Conducted:
February 12-13, 1990
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:

      Proximity to
      sensitive populations:
3672 -- semiconductors and related devices

Located in an industrial park about 30
miles south of downtown Atlanta
Manufacturer of printed circuit boards
The nearest housing development is a
quarter mile away from the industrial
park.
Reason for Facility Selection:
      ARIP Reports:
A release of hydrochloric acid on October
22,  1989, requiring evacuation of plant
personnel and nearby community.

One'-- 10/22/89
Focus of Audit:
      Hazardous substance(s)
      examined:
Chlorine
Hydrochloric Acid
Sulfuric Acid
Sodium Hydroxide
                                      109

-------
Chemical Hazards

•     The facility is most concerned with  the  possibility  of  a  chlorine
      release.

•     The corrosivicy of sodium hydroxide  is noted as a potential  threat
      to the facility.

•     Extremely hazardous substances and flammable chemicals  are kept  in
      a back'corner of a waste water treatment building.

Process Information

•     The storage tanks for sulfuric acid  and  sodium hydroxide  are
      adjacent to one another.  The unloading nozzle for sulfuric acid
      is identical to that of sodium hydroxide.  The proximity  is a
      major hazard in that the sulfuric acid can be unloaded  into the
      tank containing the caustic solution of  sodium hydroxide  by error.
      These two chemicals are highly incompatible.  The piping  and
      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.

•     The discharge piping system for the chlorine cylinders  is ac
      ground level.  This chlorine storage area is temperature
      controlled by pipes and electrical wiring which results in a
      tripping hazard. Temperature variation of chlorine is a threat if
      overheating occurs. Sprinklers are provided as a safe.ty
      precaution, especially since combustible material is stored near
      the cylinders.

•     Variations of temperature of chlorine in storage is a safety
      problem should a chlorine cylinder overheat.  Combustible material
      is stored near chlorine cylinders.

•     Excess etchant solutions containing chlorine and hydrochloric acid
      overflows to a sump and is eventually stored in tanks containing
      cupric chloride solution which is sent to a copper reclaimer when
      full.

•     Back-up equipment includes a fume abatement system.

Chemical Accident Prevention

•     Corporate and facility personnel were involved in
      emergency planning and operating procedures which include a
      comprehensive safety manual, safety meetings,  and a safety
      committee which periodically reviews procedures and condition of
      equipment.

•     Maintenance is usually performed during the first shift,
      occasionally during the second and third.  Activities are recorded

                                112

-------
Process Area(s)

The raw material for the manufacturing of circuit boards  is a  sheet  of
fiberglass or paper based material which is laminated with copper  on one  or
both sides.  The circuits are formed by defining the copper circuits,
protecting the desired pattern and etching and rinsing  the undesired copper
from the chemically inert base material.  The process results  in large
quantities of copper solution and metal-contaminated waste water.

Full cylinders of chlorine are fed through the supply line to  the
eductor on the etchers.  The etcher solution, which is  comprised of  water,
hydrochloric acid and cupric chloride, is circulated and  sprayed on  the
circuit board to strip unprotected copper.  A controlled  amount of chlorine  is
added to keep the copper in its cupric state. The enclosure of the etcher
controls the chlorine vapors.  A scrubbing fluid of 10  percent caustic
solution is used to maintain the enclosure. Material incompatibility has not
been noticed.  A waste water collection system collects any spillage.

Hydrochloric acid and water are added to the etcher and cause excess volume
which is pumped to cupric chloride tanks.  Spillage is  caught by the waste
water collection system and the resulting mixture is sent to a copper
reclaimer.  The concentration of hydrochloric acid and  the toxicity of copper
are considered to be moderately hazardous.

Waste water is treated with both sodium hydroxide and sulfuric acid.   The
Waste Water Treatment Area's two streams separate dissolved metals and
contaminated water from free heavy metals and runoff rain water.
Summary of Audit Findings and Recommendations

      Conclusions:

      Facility Background Information

      •     The external security of the plant is minimal. The plant's main
            fence enclosure has not been completed and there are no gates to
            the facility entrance.

      •     Large quantities of copper solution and metal contaminated waste
            water are treated and discharged.into the sanitary system.
            Principal drainageways are the Flint River and the South River.

      •     The terrain of Fayette County consists of ridgetops and hillsides.
            Annual precipitation is fairly heavy and severe local storms
            occasionally strike in the county.  Storms and tornados present a
            potential threat to the facility.

      •     Principal access routes to the facility by two lane paved roads
            are State Road 74 and Dividend Drive.
                                      Ill

-------
•     With the recent cutback in operations and personnel at  the
      Peachtree City facility, Photocircuits lost members of  its
      emergency response team.  Although these positions have been
      filled and new emergency response personnel briefed on  their
      duties, more in depth training is needed.  Photocircuits
      management has committed to this additional training.   In order  to
      meet OSHA's training requirements for responders, management plans
      to use a corporate trainer to meet immediate training needs.

Community and Facility Emergency Response Planning Activities

•     Photocircuit's management has cooperated with the Peachtree Fire
      Department and the Fayette County Emergency Management Agency.
      They have provided these agencies with the identity of chemicals
      present at the plant, furnished drawings of the facility and have
      allowed access to the facility for inspection.   In addition, the
      Peachtree City Fire Department has been brought on-site for
      training in dealing with a chlorine accident.   Photocircuits
      furnished the Peachtree City Fire Department hazardous material
      team with a plugging kit for inclusion in its response equipment.

•     There has been a lack of coordination between the facility and the
      community in developing a site specific emergency plan for
      Photocircuits.  No vulnerability ^one and no detailed' evacuation  •
      plans have been developed.

Public Alert and Notification Procedures

•     No procedures or alarms exist for notifying the public.

•     The facility has not coordinated interaction with the
      media.

•     The release of October 29, 1989,  showed the lack of coordination
      between the facility and public information and response
      activities.  Public concerns is based on the need to have
      notification of any release of extremely hazardous substances
      before the Title III Section 304 designated reportable quantity
      has been reached.
Recommendations:

Facility Background Information

•     The external security of the plant needs improvement.  The plant's
      fence enclosure should be completed and an entrance gate should be
      added.
                                114

-------
      on computer to keep track of the state of repair.  Service
      contracts are maintained with suppliers to maintain  instruments.

•     Preventative maintenance is an important concept with
      Photocircuits.

•     No formal hazard evaluation is conducted at the facility.

•     Using CAMEO II modeling, the audit team determined that nearby
      industries and communities located to the east and southeast of
      the facility could be at risk under specific situations.

•     There are sprinklers in the chlorine storage area to mitigate fire
      hazards and fusible plugs to avoid ruptures in the event of a
      fire.

Accident Release Incident Investigation

•     The only known release occurred on October 29,  1989.   Three
      hundred gallons of hydrochloric acid caused an evacuation of 2,000
      people, 37 of whom were treated for minor throat and eye
      irritation.

•     Facility investigation procedure,  found in the facility's
      contingency plan, requires an assessment or critique of all
      accidents.  However, these reports appear to analyze steps to
      mitigate future release.

Facility Emergency Preparedness and Planning Activities

•     Photocircuits has had an emergency response plan since their
      establishment.   The present version,  dated January 30,  1990,  was
      revised to reflect new emergency response personnel.

•     No chemical emergency exercise has been conducted by the facility,
      though the recent accident allowed the facility to assess
      emergency planning activities.   Lack of coordination between
      facility management and local response agencies was identified
      during the accident.

•     The only evacuation route is Dividend Drive.

•     There is one self-contained breathing apparatus available  at  the
      facility.  The facility has no two-way radio or emergency  lighting
      and the only fire fighting equipment is fire extinguishers.
      Communication consists of pagers for- the coordinators and  their
      assistants and an intercom system  tied to 15 telephones  throughout
      the plant.

•     Either an emergency response coordinator or an  assistant is
      present during any given shift to  manage emergencies.
                                113

-------
            pagers.  In case of a release, instructions should be given  to
            activate pagers assigned to facility response personnel. They
            should be easily reached in case they are needed off duty.

      •     Emergency response personnel at the facility should take part  in  a
            training program to ensure the expertise needed to perform
            assigned duties. The program should be in compliance with OSHA.

      Community and Facility Emergency Response and Planning Activities

      •     Photocircuits Atlanta should cooperate with Peachtree City and
            Fayette County in determining a vulnerability zone around the
            facility and in meeting the planning needs required to protect
            citizens and property which may be exposed if there is a release.

      Public Alert and Notification Procedures

      •     Photocircuits should consider the installation of an alarm to
            notify the public in the event of a release.
Audit Team Member Composition

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise'

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Henry Hudson, Taam Leader
EPA Region 4
N/A
Master of Chemical Engineering

P.H. Steed, Deputy Leader
EPA Region 4
Training, Safety, Management
Master of Engineering

Gaines Boone
EPA Region 4
Emergency Planning
N/A

Tom Yatabe, AARP
EPA Region 4
Chemical Systems
Chemical Engineering

Charlie Cartwright,  AARP
EPA Region 4
Chemical Systems
Chemical Engineering

Bob McCann
EPA Region 4
Chemical Systems
Chemical Engineering
                                      116

-------
Chemical Hazards

•     The fire department should be notified of the storage of  extremely
      hazardous and flammable chemicals in a back corner of a waste
      water treatment building.

Process information

•     The storage tanks for sulfuric acid and caustic solution  should
      have secondary containment dikes and should be separated  by
      greater distances.  Additional bracing is needed on the filter and
      piping.

•     Piping and wiring around the chlorine cylinders should be
      relocated to avoid the potential shock and tripping hazard.

•     Combustible material should not be stored near the chlorine
      cylinders.

•     Measures should be taken to prevent the mistake of unloading
      sulfuric acid and sodium hydroxide into the wrong tanks.  The two
      chemicals are highly incompatible.

•     High level alarms should be installed on the sodium hydroxide
      tanks to ensure that the tanks do not overflow while being
      refilled.

•     The installation of redundancy in the form of spare blowers could
      be used to minimize the risk of prolonged shutdown.

Chemical Accident Prevention

•     Formal hazard evaluation should be implemented by the facility for
      its hazardous operations.

•     In modeling, reevaluation of the vulnerable zone includes  the
      probability of occurrence.  To assure that any vulnerable  zones
      described are based on plume dispersion models that are
      realistically depicted, caution should be exercised when making
      revisions.  Peachtree City and Fayette County should be consulted
      when determining the vulnerability zone.

Facility Emergency Preparedness and Planning Activities

•     Emergency response exercises and simulations should be conducted
      in coordination with local responders and the LEPC's.

•     A second self-contained breathing apparatus would enable workers
      to work in a buddy system.

•     Communication with critical facility emergency management
      personnel should be expanded by using mobile telephones  and more

                                115

-------
118

-------
Name and Title                Lewis Nagler
Affiliation                   EPA Region 4
Area of Responsibility        N/A
Expertise                     N/A

Name and Title                Jack Krakell
Affiliation                   Fayette County Emergency Services
Area of Responsibility        N/A
Expertise                     N/A

Name and Title                Gerald Reed
Affiliation                   Peachtree City Fire Department
Area of Responsibility        N/A
Expertise                     N/A

Name and Title                Malcom Cameron
Affiliation                   Peachtree City Fire Department
Area of Responsibility        N/A
Expertise                     N/A
Post-Audit Follow-Up Activities:

      By the Facility:

      By the Regional Office:

      By State and Local Authorities:


Regional Contact:             Henry Hudson, Pat Steed
                                      117

-------
                                    Nickel chloride
                                    Nickel sulfate
                                    Chromic acid
                                    Nitric acid
                                    Sulfuric acid
                                    Sodium hydroxide
      Physical Area(s) Examined
      at the Facility:

      Storage and Handling

      •     Storage Systems

            Incoming chemicals arrive by truck in containers of up to 55-
            gallons and are stored in a common storage area in these same
            containers; nitric acid is received in 4-drum amounts.  Cyanide,
            and paint and paint supplies are each stored separately.

      •     Material Transfer
                                                               t

            Transfer of materials in the plant is by overflow from cell to
            cell within the electroplating system.  Externally, transfer is by
            centrifugal pump.  Some raw materials are transmitted manually.
Process Area(s)
      Kason Industries manufactures parts primarily for the refrigeration
      industry.  Metal cleaning is done exclusively with aqueous detergent
      systems.  During the plating operation, parts are cleaned through a
      series of steps including the use of cleaning solutions,  rinses,
      electrocleaning with reversing current, counterflow rinses,  and an acid
      dip.  The rinses are sent to the sanitary sewer.  Copper stride then
      occurs using copper cyanide, followed by copper plating,  copper dragout,
      two counterflow rinses, reverse current electrocleaning,  another rinse,
      and an acid dip in one percent sulfuric acid.

      Nickel plating in nickel sulfate and nickel chloride is the  next step
      followed by yet another dragout step to two counterflow rinses,  two
      batch rinses, and a chromium predip.  Parts.are then chrome  plated
      through a series of dragout and counterflow rinse steps.   Hot water
      rinsing completes the plating work.

      An  ion exchange unit removes aluminum and zinc from the chrome plating
      dragout solution, and the solution is then returned to the plating tank.
      Processing of waste water is by batch and ranges from weekly to as
      needed.

      Copper-bearing waste water is adjusted to a 'pH of 12,  the cyanide ion is
      destroyed with chlorine, the mixture is filtered, the solid  dried,  and

                                      120

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Kason Industries, Inc.
Facility Location:
Newnan, Coweta County, Georgia, Region  4
Date(s) Audit Conducted:
October 26, 1990
Description of Facility:

      SIC Code(s):

      Location:
3429 -- hardware

Located in an industrial park about 35
miles southwest of Atlanta.
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
Manufactures hardware, specializing in
locks, latches, and hinges for metal
commercial refrigerators, refrigerated
truck bodies,  and ovens.
The Shenandoah Industrial Park has a
daytime population of 5,000, with 300 to
400 residents in the park living in single
family homes.  Three daycare centers, two
motels, five industrial plants,  and
several car dealerships are within a 1/4
mile of the facility.
Reason for Facility Selection:
      ARIP Reports:
The facility was chosen due to
notification of a previously unreported
release of noxious chemical gases from the
facility,  and because of a spill from the
plating area into the sewer in October
1989.

None
Focus of Audit:
      Hazardous Substance(s)
      Examined:
Potassium cyanide
Copper cyanide
Caustic potash
                                      119

-------
Process Information

•     Placing vessels are primarily steel with a Koroseal  protective
      coating or stainless steel.  The nickel plating vessel  is  lined
      with rubber thus shielding the metal  in che walls of the vessel
      from corrosion.

•     Parameters monitored during the process, such as  temperature,
      concentration, voltage, and current density, are  done for  quality
      control purposes rather than a safety purpose.

•     Environmental monitoring consists primarily of monitoring  the.
      effluent water streams.  The facility takes grab  samples of ditch
      water and analyzes it for pH, cyanide, and metal  content.

•     There are no monitoring stations for releases, nor is there a
      meteorological station of any kind.  Lack of such stations impairs
      Kason's ability to minimize the results of a cyanogen or hydrogen
      cyanide release.

•     Kason management believes the major workplace hazard is the
      potential for injury to the eyes, back, and feet.

•     The likelihood of an accident thraatening the community is remote
      due to the relatively small quantities of chemicals stored on
      site.  Potential hazards include a hazardous substance release
      into the sewer system that would compromise the operation of the
      wastewater treatment plant, chemical burns, or minor explosions
      that may result in injuries to on-site personnel.

Chemical Accident Prevention

•     Facility safety committees tour the plant every two weeks,  and
      address committee concerns with the management.   Management then
      posts any decisions or actions.

•     There are no formal standard operating procedures at the Kason
      facility.

•     In most cases, Kason depends on facility supervision to  train and
      monitor worker performance.  MacDermott Corporation,  the chemical
      supplier of Kason Industries,  provides a three-day training course
      for plating operators.  The waste treatment operator has taken a
      course in order to receive state certification.   The facility
      conducts classes in evenings on alternate months  on MSDS sheets,
      safety, and Right-to-Know information.  The local Humana Hospital
      also conducts classes on first aid and CPR for the facility.

•     Kason has recently established a preventative maintenance program
      that calls for daily, weekly,  and monthly checks  of the  plating
      equipment including filters and duperators, the  loader and
      monorail system, the exhaust system,  evaporator  units, and other

                                122

-------
      the water is sent to the sewer.  The nickel-bearing  and  acid water  is
      adjusted to a pH of 7, flocculent is added, and  the  mixture  is  filtered.
      The filtrate is discharged to the sewer and the  filter cake  is  dried.
      Dried filter cakes are sent to a hazardous waste  landfill.

      Chrome-bearing waste water is treated with reducing  agents to change  the
      hexavalent chrome to trivalent, then filtered, and the filtrate air is
      agitated and sent to the sewer.  Water discharges are monitored for
      heavy metals, cyanide, and pH.
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     The facility does not maintain a security force, except for one or
            two security guards patrolling the area on evenings and weekends.
            The property is not fenced except for an outdoor area used to
            store hazardous wastes waiting for removal.  There have been two
            plant break-ins.

      •     Coweta County is not subject to hurricanes or floods, but there
            have been two tornados in the area within the past three years.

      •     There is only one road into or out of the industrial park; a
            median allows for entrance and egress.  The CSX railroad serves
            the industrial park; however, the rail does not side the Kason
            plant,  and shipments in and out of the plant are made by truck.

      Chemical Hazards

      •     Cyanide presents the greatest chemical hazard on site.   If cyanide
            solution were to pass to the county sanitary sewer system, the
            most likely result would be damage to the operations of the
            community wastewater plant through a reduction in microbial
            activity.

      •     Kason has not submitted MSDSs for potassium cyanide and nitric
            acid, two extremely hazardous substances (EHSs)  held on-site over
            their threshold planning quantities,  to the SERC,  LEPC,  and the
            local fire department.  This is required by section 311 of SARA
            Title III.

      •     Safety gear rules are enforced in the plating area for  face
            shields, rubber gloves, and respirators.

      •     Employees in the plating department do not receive annual
            physicals even though they are exposed to toxic  fumes and
            substances.
                                      121

-------
      incorrect.  Spills of EHSs over threshold quantities must  be
      reported immediately to the SERC, LEPC, and the National Response
      Center followed by a written report as soon as possible.   None  of
      the requirements of CERCLA or SARA are included in  the plan.  The
      contingency plan has not been updated since the county installed a
      911 emergency notification system.  The contingency plan also does
      not have the current fire department number.

•     The contingency plan is not exercised on a regular basis.  The
      fire and police departments are called in from time to time for
      facility updates.

•     Kason has an adequate supply of current plot plans covering the
      facility and surrounding neighborhood.  Fire,  evacuation,  and
      rescue corridors have been established.

•     Fire valves are monitored by a contractor to ensure they are in
      good working condition.   The facility has adequate fire hoses to
      fight fires until outside assistance arrives.   Fire hoses are
      available in most plant areas as are dry chemical and foam fire
      fighting equipment.   The manufacturing areas have sprinkler
      systems that are tested occasionally.

•     The emergency response chain of authority is not clear.   The plant
      manager acts as emergency coordinator and is responsible  for
      external notification, but it is unclear who reports releases to
      the coordinator or where he gets his information.

•     Communication within the facility is provided  by a public address
      system; there are no radios or other emergency back-ups..  A
      special evacuation alarm signal is activated only in the  event of
      total evacuation.  Telephones are located in a number  of  locations
      in the plant, and serve as back-up in case  the alarm system
      malfunctions.

•     The facility has its own fire brigade,  on standby  during  all
      general plant emergencies.  Fire fighting will be  performed by the
      brigade until outside assistance arrives.   The brigade  is trained
      by the local fire department and also receives periodic  refresher
      training.

Community and Facility Emergency Response Planning Activities

•     Kason has invited the Coweta Fire Department to the  facility
      several times to familiarize them with the  plant  layout and
      existing hazards.

•     The facility has maintained a close relationship  with Humana
      Hospital. Personnel at Humana are kept informed by personal
      contacts on how to treat cases of cyanide poisoning.

-------
      systems.  Kason's robotic machines  require  sophisticated
      maintenance.

•     Kason does not perform any formal hazard  evaluation.   The  facility
      does not perform any dispersion modeling.   The  audit  team
      determined., through use of the CAMEO program, that potassium
      cyanide could produce a toxic cloud of cyanogen at the  threshold
      limit value,  time weighted average  up to  500 yards under mild
      weather conditions.  A similar-sized cloud  of hydrogen  cyanide
      might also be possible.  No offsite hazard  is likely, however,  in
      either case.

•     Kason's practice of separating cyanides and acids in  the plant has
      reduced the likelihood of an air release.

•     Secondary containment for the plating area  is provided  by a pit.
      In the event of a spill, floor drains from  the  pit are  plugged.
      Fumes from the plating area are drawn into  a system for outside
      exhaust.

Accident Release Incident Investigation

•     In the fall of 1988, Kason Industries and the Environmental
      Protection Division of the Georgia Department of Natural Resources
      entered into a consent agreement resulting  from problems
      experienced by the Coweta County biological waste water treatment
      system, apparently due to releases by Kason.  Kason agreed to pay
      $4,000 and improve its management of discharges to the sanitary
      sewer.

•     In October of 1989, an employee,  while cleaning a vessel in the
      plating area,  allowed the vessel to overflow into the drains to
      the sanitary sewer.  As a result,  a secondary containment system
      for overflows was installed including removable plugs for the
      drains.

•     On October 18,  1990, a five-gallon bucket containing nitric and
      phosphoric acids in a cleaning solution began to generate fumes,
      irritating the lungs and eyes of workers.   The fumes  did not leave
      the building in sufficient volume  to be noticed off-site.

•     Kason does not have any written procedures for investigating and
      following up on releases.

Facility Emergency Preparedness and Planning Activities

•     Kason has a detailed contingency plan dealing with various  types
      of emergencies including specific  chemical releases.   Internal
      coordination and notification is very detailed,  but the plan does
      not adequately deal with notification procedures to federal,
      state,  and local officials.   For instance, the  requirement  in  the
      plan to report to the EPA Administrator 15 days  after  a spill  is

                                123

-------
      •      Because no nurse is present at the facility, Kason should consider
            providing first aid and CPR training to all employees.

      •      The facility should consider performing a formal hazard evaluation
            to minimize the potential for accidental releases.

      •      Kason may want to review secondary containment methods in light of
            the result of past spills to the drainage system.

      Accident Release Incident Investigation

      •      Facility management should consider adopting written procedures to
           . investigate and report releases,  and to lead to appropriate
            remedial measures.

      Facility Emergency Preparedness and Planning Activities

      •      Kason should update the contingency plan taking into account the
            county's 911 emergency notification system and the current Coweta
            fire department phone number.

     .•      Kason should exercise its contingency plan at least annually.

      •      Kason should clarify the reporting chain of authority in case  of
            an emergency.

      Community and Facility Emergency Response Planning Activities

      •      Kason would improve its coordination with the community if the
            facility complied with SARA Title III requirements.   The  facility
            should establish records showing compliance  with all  aspects of
            Title III reporting,  and make  these records  accessible to  all
            agencies and individuals entitled by law to  see them.

      Public Notification

      •      The facility should develop procedures  for notifying  the public
            about releases, and schedule testing of these procedures with  the
            county.

      •      Kason should designate and train a spokesperson to  coordinate  with
            a public spokesperson in time  of emergencies.
Audit Team Member Composition:

Name and Title     .           Charlie Cartwright
Affiliation                   EPA Region 4-
Area of Responsibility        Team Leader
Expertise                     N/A
                                     126

-------
•     The facility has at least two EHSs, potassium cyanide and nitric
      acid, that exceed their threshold planning quantities, and yet has
      not reported the EHSs under section 302 of SARA to  the SERC  and  to
      the LEPC.  Kason has failed to coordinate facility  planning  and
      outreach activities with the community because of its failure to
      satisfy  its SARA Title III requirements.

•     The Coweta County Emergency Management Agency (EMA) may apply to
      be designated as an LEPC for the county, but in the meantime, the
      EMA is drawing up a county emergency response plan.

Public Notification

•     Kason has no procedures or personnel responsible for notifying the
      public about releases.

Recommendations:

Facility Background Information

•     Kason should fence the property and review the security of
      dangerous chemicals.   The company should assure the security of
      stored chemicals to prevent unauthorized tampering.

Chemical Hazards

•     Employees in the plating department should receive an annual
      physical examination; such an examination for all employees would
      be desirable, if feasible.

Process Information

•     Because  of the potential for a chemical burn or minor explosion,
      Kason should review its chemical storage and handling operations
      with the goal of protection of each individual employee.   The
      facility could separate incompatible chemicals.

•     Chemical monitoring and meteorological stations should be
      provided.

Chemical Accident Prevention

•     Kason should develop a safety manual and distribute  copies  to all
      employees.  Kason should also develop formalized standard
      operating procedures, incorporate the SOPs into a manual,  and make
      them available to operators in the plating area.

•     To make  training more accessible, the facility should consider
      offering classes during working hours and requiring  employee
      attendance.
                                125

-------
128

-------
Name and Title                Stuart Eglin
Affiliation                   AARP
Area of Responsibility        N/A
Expertise                     N/A

Name and Title                Beverly Mosely
Affiliation                   EPA Region 4
Area of Responsibility        N/A
Expertise                     N/A

Name and Title                John Deutsch
Affiliation                   AARP
Area of Responsibility        N/A
Expertise                     N/A
Post-Audit Follow-Up Activities:

      By the Facility:

      By the Regional Office:

      By State and Local Authorities:


Regional Contact:             Pat Steed
                                      127

-------
Physical Area(s)  Examined
at  the  Facility:

Storage and  Handling

•     Storage  Systems

      Sulfuric acid  is  stored  in four storage tanks kept in a
      containment area  surrounded by 48  inch high walls with a holding
      capacity of 36,000 gallons,  three  times the capacity of the
      largest  tank.

      Aluminum sulfate  is  stored in six  storage tanks and eight holding
      pools.   The tanks withstand corrosivity and are located outside on
      the west end of the  facility.   One tank is kept indoors and
      contains heating  coils to  regulate its temperature.   The pools are
      either steel-  or  vinyl-shelled and are kept outdoors..

••     Shipping and Receiving

      Sulfuric acid  is  shipped to the facility in 10,000 gallon
      quantities  by  tank railcar and truck  three to four times monthly.
      The president  of  the  company,  who  has  years of experience in the
      chemical industry, monitors receiving  procedures.

      The end  product is shipped from the facility using common carrier,
      customer-owned vehicles, rental vehicles,  or a trailer.   The
      annual quantity of alum  ranges between 3,000 and 10,000 tons.

•     Material Transfer

      Sulfuric acid  is  transferred from  tank vehicles to storage  tanks
      by a  person with  extensive knowledge of the chemical  and of
      appropriate unloading procedures.   In  the .unloading process,  the
      transfer hose  is  filled  with acid  using a  Durco pump  for initial
      suction.  Flow is then by  siphon to the storage tanks.   The siphon
      is breakable at the  tank itself, the storage tank  inlet valve,  and
      at the valve contained in  the  hose.

      Alum  is  transferred  through the process using PVC  and CPVC  piping.
      The diameter of the  alum piping is 4 inches for suction to  pumps
      and three inches  from discharge.   It is pumped through the  process
      using Durco pumps.

Process Area(s)

Aluminum rich  ore, usually  kaolin clay or bauxite,  is acidified  in a
reaction vessel using sulfuric acid,  heat, and water.  The  exothermic
reaction produces aluminum  sulfate solution  and  silica rich solid
particulate.  Resulting high yield alum  and  clean particulate  solid are
separated by decantation.   The solid is  washed,  put on the  ground in  the
                                130

-------
                        CHEMICAL SAFETY AUDIT PROFILE
Facility Name:


Facility Location:
C & S Chemicals, Inc.
Austell, Georgia, Region 4
Date(s) Audit Conducted:
November 29, 1990
Description of Facility:

      SIC Code(s):

      Location:

      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
2899 -- chemical and chemical preparations

Ten miles west of Atlanta
Manufacturer of aluminum sulfate from
aluminum bearing ore and sulfuric acid
Public housing, a kindergarten,  and the
Austell Health Center (hospital) are all
within a quarter mile of the facility
Reason for Facility Selection:
      ARIP Reports:
The facility was selected because of a
hydrated aluminum sulfate release on May
12, 1990; public complaints of odor and
dust emanating from the facility also led
to site investigation.

None
Focus of Audit:
      Hazardous substance(s)
      examined:
Sulfuric acid
Aluminum sulfate (alum)
                                      129

-------
•     The leachable material remaining from  the draining process  is  sold
      and transported to customers.  There is no recorded quantity of
      alum captured from the draining process.  Spillage of acid  and
      clay are collected through the reaction process and containment
      walls.

•     The Durco pumps which transfer the sulfuric acid solution to the
      reaction vessel have rubber seals, 316 SS valves, and a 30  gallon
      per minute transfer capacity.  The reaction vessel is lined with
      various materials including lead and a.special acid resistant
      brick.   Piping around the storage area appeared well maintained
      and supported.

•     In the past,  C & S Chemical used a temperature as a parameter  for
      control of its digestion reactor.  The temperature was recorded
      using a thermocouple which was enclosed in a lead pipe to avoid
      damage from the acid.  However, this method proved to be
      ineffective due to a significant time lag.  The facility now
      monitors the reactor visually using the steam emitted by the
      digester.  Facility management believes that this is a better
      method of controlling the reaction since corrective procedures can
      be implemented as soon as a. problem is perceived.

Chemical Accident Prevention

•     Due to the small personnel staff and the simple,  standard
      procedures used for the process,  no standard procedures have been
      formally employed in written form.   Ideally,  such a process  would
      be written, if only to be sure no misunderstandings exist and to
      demonstrate and explain the company's organized methods and
      procedures to any of the public who might visit the site,  such as
      firemen.

•     Training is not performed using a formal procedure.   Employees  are
      hired with prior chemical industrial experience.   Due  to the small
      number of personnel,  they can be properly trained and  supervised
      on-the-job for the specific tasks required at the facility.

•     Maintenance and housekeeping are performed when necessary.
      Observation of the process and the storage areas  are made  during
      the course of a day by three plant operators.   There are no
      specific maintenance procedures or formal records.

•     Management believes there is no need for monitoring instruments.

•     C & S's hazards analysis involves developing  hypothetical
      scenarios using "what if" hazard evaluation technique.
      Additionally, C & S Chemical also consulted with  their  vendors  on
      ways to improve their safety procedures.   They will  also contract
      other chemical companies to perform a hazard  evaluation (e.g..
      DuPont).  Evaluations are scheduled every two years  or  when
      regulatory changes present a need for one,  whichever occurs  first.

                                132

-------
      open yard of the plant, and allowed  to  drain.   The  alum solution is
      adjusted to product specifications and  shipped  to  the  customer.
Summary of Audit Findings and Recommendations

      Conclusions:

      Facility Background Information

      •     Annual precipitation  is fairly heavy  and  severe  local  storms
            occasionally strike in the county.  Storms and tornados  present  a
            potential threat to the facility.

      •     The Southern Railroad side tracks to  the  front of  the  plant and
            can carry two tanks of sulfuric acid.  The fiberglass  tanks of
            acid are thus located adjacent to the railway.

      •     Fencing around the alum storage tanks protects the storage area;
            however, the gate is not closed or secured by a  lock.  The
            facility is enclosed with a wooden fence  backed  with a chainlink
            metal fence.  C & S does not maintain a security force to protect
            the plant at night or on the weekends.

      Chemical Hazards

      •     The most substantial  threat from a release is sulfuric acid
            entering Sweetwater Creek.  Airborne release is  not a  significant
            threat because kaolin clay is processed to evaporate any volatile
            organic material before shipment to C & S.

      Process Information

      •     The alum storage tanks utilize 30 mil PVC liners as their primary
            containment material.  Acid warning signs are posted in the area,
            and Department of Transportation labels identify tanks.  Storage
            tanks rest on lime, which neutralizes the acid in the  event of a
            spill.

      •     Sulfuric acid storage tanks are surrounded by concrete containment
            walls.  The thin sheet of metal surrounding the  exterior appears
            to be rusted, though  it is not part of the actual storage tank.
            The tanks of sulfuric acid and caustic solution  sit close to one
            another and do not have secondary containment dikes,  nor do they
            have proper bracing.

      •     The railroad track adjacent to the facility has  a derail, which is
            a device that prevents any railroad cars  from rolling  into the
            parked sulfuric acid  tank car.  The person unloading the tank car
            uses a timer, wears the appropriate protective clothing,  and
            possesses knowledge of chemicals and unloading procedures.
                                      131

-------
•     C & S has five dry chemical extinguishers and an adequate  supplv
      of lime to neutralize acid spills.  A small front end  loader  is
      readily available to apply the lime to chemical releases.

•     An internal' communication system does not exist within  the
      facility.

•     There are no emergency response training requirements.

•     There are no monitoring stations for chemical releases.  The
      facility does not have a meteorological station.  The audit team
      did not find these necessary under the circumstances.  The Georgia
      Environmental Department has monitored air emissions on several
      occasions in response to citizens complaints.   No violations were
      found.

Community and Facility Emergency Response Planning Activities

•     No .health care facilities have been contacted concerning the need
      for assistance during an accidental release.

•     Communication between the facility and the City of Austell has
      been poor for the past few years.   The city had filed 22 alleged
      code violations against the facility.   Communication with the
      Austell Fire Department is minimal.  The facility has not
      submitted information required under Title III to the LEPC and
      local fire department.

•     There is no local/community emergency response plan.

Public Alert and Notification Procedures

•     No procedures or alarms exist for notifying the  public.

•     The facility has not coordinated with the local  community on
      notification of releases.
Recommendations:

Facility Background Information

•     The fencing around the alum storage tanks west of the plant should
      be kept closed and locked.  Measures should be taken to protect
      the plant at night and on the weekends.   Security should be
      improved to prevent releases caused by vandalism.

Process Information

•     The storage tanks for sulfuric acid and caustic solution should
      have secondary containment dikes and should be separated by
                                134

-------
      Evaluations are reviewed by consultants, banks,  (as part  of  their
      financing procedures), insurance companies and the Georgia
      Environmental Protection Division.  Evaluation reports performed
      by consultants are given to the City of Austell  and the local  fire
      department for emergency analysis.  Recommendations generated  by
      these studies have led to preventative action such as centralizing
      tanks, installing containment walls and consulting vendors to
      improve safety procedures.

•     Due to its small size, the facility has not performed extensive
      modeling.

•     Water mist nozzles operate automatically to control the reaction
      rate within the vessel.  Water spray will help to reduce  the
      reaction rate.  If control is lost, a sump instaMed in the
      reaction area and the berm located in the front of the facility
      serve as primary and secondary containments.

Accident Release Incident Investigation

•     An alum release resulted from a rupture in a PVC-lined vinyl
      holding pool on May 12,.1990.  Approximately 200 gallons escaped
      the secondary containment system,  which contained 1,100 to 1,200
      pounds of aluminum sulfate.   The alum which escaped the
      containment system entered into the City of Austell storm water
      system.

•     A written investigation procedure does not exist but the release
      of May 1990 was examined.  Since the accident,  a 6-inch asphalt
      berm has been constructed outside the fenceline to divert  spills
      back to the same process area.   It also prevents spills of
      sulfuric acid from the tank car on the spur line from leaving the
      property.  Additionally,  three steel tanks replaced vinyl  pools
      after this incident.   No immediate plans were made to replace the
      other four vinyl-shelled holding pools.

Facility Emergency Preparedness and Planning Activities

•     Emergency procedures are documented in the company's  "Spill
      Response Manual".   It contains a step-by-step procedure for
      containment and cleanup of each chemical that might be  spilled.
      The Georgia Environmental Protection Department (EPD) has  been
      informed of recent steps taken to update its  Emergency  Response
      Plan.  C & S has only three  employees including the president and
      the plant manager.  Any one  of the three employees can  manage
      emergency coordination and make appropriate calls.   The emergency
      response plan has not been exercised.

•     Although the facility has up-to-date maps covering the  plant  and
      surrounding neighborhood, it does  not have planned evacuation
      corridors.
                                133

-------
      •     The audit team recommends that all requirements of  SARA  Title  III
            and CERCLA be complied with, including corrections  to  the  facility
            emergency response plan for reporting the .presence  and release  of
            EHSs (i.e., sulfuric acid and alum).  The facility  should  supply a
            copy of the MSDSs and Section 311 and Section 312 reports  for
            aluminum sulfate and sulfuric acid to the Austell Fire Department.

      Public Alert and Notification Procedures

      •     The facility should install an emergency alarm to signal an
            emergency to the public.
Audit Team Member Composition

Name and Title                Charlie Cartwright, AARP
Affiliation                   EPA Region 4
Area of Responsibility        Chemical Systems
Expertise                     Chemical Engineering

Name and Title                John Deutch, AARP
Affiliation     •              EPA Region 4
Area of Responsibility        Community/Facility Planning Activities
Expertise                     Chemist

Name and Title                Ralph McKeen, TAT
Affiliation                   EPA Region 4
Area of Responsibility        Report Compiler/Reviewer
Expertise                     Environmental Engineer

Name and Title                Bob McCann
Affiliation                   EPA Region 4
Area of Responsibility        Process Information/Hazard Evaluation
Expertise                     Chemical Engineer

Name and Title                Kevin Taylor
Affiliation                   EPA Region 4
Area of Responsibility        Process Information/Hazard Evaluation
Expertise                     Environmental Engineer
Post-Audit Follow-Up Activities:

      By the Facility:

      By the Regional Office:

      By State and Local Authorities:


Regional Contact:             Charlie Cartwright


                                      136

-------
      greater distances.  Additional bracing  in needed on  the filter  and
      piping.

•     Testing for potential leachate material  in the solid particulate
      might serve to preclude concern by the  public.  Measurements
      should be taken of aluminum sulfate which drains from solid
      particulates.   These quantities should  be recorded prior  to
      shipment to the customer.

•     A tertiary containment wall around the  product storage area should
      be installed to capture any release which escapes from the
      secondary wall.

•     In light of the alum release incident in May 1990,  C & S should
      continue their replacement of vinyl-shelled pools with steel
      tanks.

Chemical Accident Prevention

•     Standard operating procedures should be documented.

•     Times and dates of considerations and actions taken pertaining to
      safety should be recorded in a log.  Tank inspection and sump pump
      maintenance should also be recorded.

•     Although the facility is small,  modeling should be  conducted.

Facility Emergency Preparedness and Planning Activities

•     An emergency response exercise should be conducted  as soon as
      possible.  C & S should make every effort to ensure  that  someone
      from the Georgia EPD attend presentation of the C &  S Emergency
      Response Plan.

•     An internal speaker system should be  installed to improve
      communications in the event of an emergency.

•     Annual courses in first aid and CPR should be considered  for
      personnel training requirements.

Community and Facility Emergency Response and Planning Activities

•     A nearby health care provider familiar with acid burns  treatment
      ought to be identified and contacted.

•     The facility should improve its  communication with city officials
      and citizens in order to inform them  of recent safety and
      containment progress.  The Austell fire department should  be
      invited for frequent visits to keep them familiar with  the
      facility.
                                135

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      Liquid hazardous waste  is pumped  from  the  Oldover  facility,  a
      separate corporation owned by  the  same  parent  company,  and  used  in
      the burning operations  at Carolina Solite  Co form  lightweight
      aggregate.  All liquid  hazardous waste  used by Carolina Solite is
      stored at the Oldover facility.

      At the Carolina Facility, a 500 gallon  tank of No. 2 fuel oil and
      a 500 gallon tank of hydraulic oil  are  located beneath  the  No. 8
      kiln for operational purposes of  the kilns.  A 20,000 gallon stock
      tank of No. 2 fuel oil  is at the main office primarily  for  machine
      use.

•     Shipping/Receiving

      The liquid hazardous waste fuel is  pumped  to the kilns  through 1-
      1/2 inch boiler tubing  under 80 psi from the Oldover storage area.
      The tubing has been pressure testad to  150 psi.  Coal is carried
      into the facility via a railroad spur.  The produced lightweight
      aggregate is shipped off-site by both rail and truck.

•     Material Transfer

      The aggregate is transferred throughout the process by conveyor
      belt systems directly from the mining and sizing operations.
      Final aggregate product emerges 'from the kiln onto the ground in
      bays where it cools.  Front-end loaders pick it up for further
      processing and grading.  Final graded products are stockpiled for
      truck shipment and also placed into a tipple for rail shipment.

Process Area(s)

The shale from the company's  quarry is mined and passed through a jaw
crusher and other sizing steps and is conveyed to three 600-ton silos
where it is stored prior to being fed into the kiln.

At the Carolina plant, a jaw  crusher processes the raw material (shale.
clay or slate) and feeds it into the rotary kilns at approximately
2000°F.  The heat causes the  aggregate to expand and thus becomes
lighter and less .dense.  A "clincker" is formed that is discharged from
the kiln and then is further  crushed and processed to meet specific
customer requirements.

Although there are eight kilns on site,  only four are in operation.
Kilns 5,6,7 and 8 are permitted to burn liquid hazardous waste under
these conditions:

                                138

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:


Facility Location:
Carolina Solite Corporation
Norwood, North Carolina in Stanly County,
Region 4
Date(s) Audit Conducted:
December 4-5, 1990
Description of Facility:

      SIC Code(s):

      Location:

      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
3271 -- concrete block and brick

50 miles northeast of Charlotte, N.C.
Lightweight aggregate mining and
production plant.
The chemical storage area at the facility
is approximately 6,000 feet from Aquadale
Elementary School and within one mile of a
residential area.
Reason for Facility Selection:
      ARIP Reports:
The facility was chosen because liquid
hazardous waste is burned in rotary kilns.

None
Focus of Audit:
      Hazardous Substances(s)
      Examined:
Methyl Ethyl Ketone (MEK)
Toluene
Acetone
Xvlene
                                      137

-------
Chemical Hazards

•     Solite maintains waste profile sheets  from  the  manifested
      hazardous wastes when they arrive at the nearby storage  facility.
      The on-site laboratory verifies  this information with  their  own
      testing before placing it into storage  for  blending  into fuel  for
      the kiln.  Off-spec material could result in  hazardous emissions
      from the stack.

•     The facility only uses waste with a PCB content of below 5 ppm,  a
      chlorine content of below 2 percent, and a  minimum heating value
      of 50,000 BTU per gallon.

•     The following compounds, listed  as flammable  liquids, are
      characteristic components of hazardous wastes commonly received  by
      the Oldover Facility to be burned: MEK, toluene,  acetone, and
      xylene.

•     Solite has developed a generic Material Safety  Data Sheet to cover
      their waste mixtures.

Process Information

•     North Carolina Division of Environmental Management requested that
      Solite test emissions of metals  and volatile organic compounds
      (VOCs) from the combustion of liquid waste.   Solite hired a
      contractor to perform these tests.  All levels  found in  the
      testing indicated that all metals and VOCs  found  in the  samples
      were below the acceptable ambient levels.

•     Wet scrubbers on the exhaust gases are totally contained and the
      scrubber water goes to the wastewater treatment plant prior to
      discharge.  Wet scrubbers are to be replaced with bag filters to
      meet new air standards and to eliminate the  need  for the
      wastewater treatment facility.    Consequently,  the company has
      filed for a new air permit.

•     Sulfur dioxide (S02)  emissions  are limited at  the stack  to 2.3
      pounds S02 per  million BTU input.  S02 emissions are not  a problem
      with scrubber systems but, when  they are replaced with the bag
      filter system, lime treatment may be necessary.

•     The facility has few planned backup systems, except for routine
      checks by assigned instrument maintenance  personnel.   Detection of
      malfunctioning control equipment depends on  the  operators' skill
      and diligence.

•     The audit team noted there is 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.

-------
      •     Maximum amount of liquid waste burned is limited  to  350 gallons
            per hour per kiln.

      •     Chlorine content shall not exceed 2% by weight.

      •     Process temperature shall be maintained at a minimum of 1,900°
            Fahrenheit and a minimum flame temperature of  3,000°F  to achieve
            complete destruction of wastes.

      Although the kilns are slightly different sizes, their  processes are
      essentially the same.   Exhaust gases from each kiln  pass initially
      through preheaters.   Dust fans pull the gases through 36-inch ductwork
      to the crossflow gravity spray wet scrubbers (115 gallons  per minute
      liquid injection rate  each).  Following the scrubber, the  gases exit out
      smoke stacks without any further emission control.

      A 20-acre man-made lake on-site provides water for the  scrubber system.
      After it is used in the scrubber,  the water is piped to the wastewater
      treatment facility installed which was installed in  1990.  This
      wastewater is treated  with lime to adjust the pH to a minimum of 6.0.
      The four kilns use 700,000 gallons of water daily.   If necessary,  water
      from the wastewater treatment plant can be recycled and used to
      supplement water from  the lake.  Normally, an ample supply of water from
      the lake is available  and the water is discharged to the Rocky River.

      At the wastewater treatment plant, steel tanks allow for sufficient
      settling time of the sediment which results from the pH adjustment.   An
      extruder then mixes the sediment with clay and forms it into pellets
      that go to the kilns through an enclosed conveyor.


Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     The road access.to the plant is a two-lane asphalt road in good
            condition.  The  Aberdeen, Carolina,  & Western Railroad also
            provides access  to the plant.

      •     The only sensitive area identified is the Aquadale Elementary
            School which is  located approximately 6,000 feet from the  chemical
            storage area.

      •     The plant operates 24 hours  per day on a three-shift  rotation,  7
            days per week.  Each shift has a supervisor responsible for  the
            kiln operations.
                                      139

-------
supplied even though an emergency would mandate  that  the  fuel  flow-
be stopped.

Plant management is responsible for providing  the employees with
proper personal protective equipment.  The plant manager  conducts
monthly safety and production meetings.

Initial training of new employees in process operations begins  on
the fire deck, and then moves to all different areas  of the
operation.  After this initial training, employees learn  the
facility operations on the job, receiving no formal training.
However, the Safety Manager performs training concerning  hazardous
materials safety handling, first aid, and CPR.  When  management
feels comfortable with an employee's understanding of the
operations, he may then be assigned to operate a specific station.

The Corporate Safety Manager visits the facility at least once per
quarter to perform inspections and provide guidance on safety
policies.  He then works with the plant Environmental Coordinator
for implementation of these policies.

There are no SOP manuals available for the "kiln operations or the
associated quarry and rock crushing facilities.

Many electrical wires around the kiln areas were hanging  loosely.

The facility has prepared safety manuals and contingency plans;
both are available at the facility.

The equipment maintenance group performs daily inspections at the
beginning of each day shift as well as a variety of repairs to
reduce the need for outside contractors.  An in-house maintenance
group from the corporate office calibrates and inspects the
instrumentation.

Planned shutdowns for-each kiln are scheduled and performed
annually for complete overhaul.  The fire brick in the kilns is
replaced on an "as needed" basis between planned shutdowns.

The facility has performed no formal hazard evaluation.   The
corporate staff reviews modifications such as the proposed
baghouse air purifying system.

An outside consultant, performed air quality modeling at the kiln
stacks for air permitting requirements.   The results  were  reviewed
by the state.   The state decided their results were  adequate  and
no further air modeling is required.

The main item stressed by the plant manager to prevent a release
is to shut down the pumps supplying the liquid hazardous waste.
                          142

-------
•     Temperature of the incoming fuel to the kiln  is monitored with  an
      infrared eye connected to an automatic valve  which adjusts  the
      liquid feed rate to achieve the proper temperature.  These
      temperatures are recorded on the production logs.

•     Startup procedures for the kiln operation are critical.  In order
      to prevent hazardous vapors from escaping the stack due  to
      incomplete combustion of the liquid waste, coal or No. 2 fuel oil
      is used initially to raise the kiln temperature to 1900°F.   Then,
      liquid waste burning commences.

•     Response procedures in monitoring the process would be to 'adjust
      feed rate of the hazardous liquid fuel to the kiln.  Also,  feed
      rate of raw aggregate can be adjusted to provide a quality
      product.  Adjustment of pH at the wastewater  treatment plant can
      be done simply with the addition of more lime.

•     The facility monitors wastewater discharge weekly for pH and total
      suspended solids (TSS) bi-monthly.   NPDES permit specifies pH
      range of 6.0 to 9.0 and a maximum TSS daily concentration of 45
      mg/1.

•     There is no continuous monitoring of the stack emissions, but
      emissions sampling will be required after the baghouse  is in
      operation.  In general, there were  no recording devices on any
      monitoring instrumentation including the kiln temperature and
      wastewater treatment effluent discharge.

•     EP Tox and TCLP analysis on the finished lightweight aggregate is
      done monthly to determine leachability of the material.

•     At the request of a local environmental group, SCOTCH (Stanly
      Citizens Opposed to Toxic Chemical  Hazards),  eight nearby water
      wells were sampled and none of the  eight were contaminated.

Chemical Accident Prevention

•     The members of the Carolina Solite  Safety Program report  to  the
      Corporate Safety Coordinator,  who in turn reports  to  the  Vice
      President of Personnel in Richmond,  Virginia headquarters.

•     The facility goals are to follow the corporate policies  set  forth
      in the corporate Health & Safety Manual.

•     Solite's rock quarry operations use  explosives,  but they  do  not
      store these explosives at the facility.   A contractor brings the
      explosives in, conducts blasting operations,  and removes  blasting
      materials from the premises in approximately three-week  intervals.

•     Pumps that supply fuel to the burners  are  not controlled  at  the
      burners.  Therefore,  it is possible  for fuel  to  continue  to  be

-------
      the point where hazardous waste trucks are unloaded  into  the
      storage tanks.

•     According to the emergency plan, when an emergency occurs  at
      Solite, the-person discovering the incident notifies  the
      supervisor, if he is available.  If the supervisor is not
      available, the person discovering the incident notifies the
     - facility manager designated in the plan as primary emergency
      coordinator.   There are four other plan supervisors as back-up
      coordinators.  If no coordinator is on duty, provisions have been
      made to call off duty coordinators back to the plant.  Once a
      coordinator has been determined, he/she makes a judgement  on
      appropriate response measures.  Response plans address all types
      of emergencies and include provisions for containing and cleaning
      up hazardous materials releases.

•     Solite uses a horn located in the administrative area to alert
      personnel to an incident at the facility.   During incidents,
      management keeps personnel informed through portable radios.
      There are telephones at the fuel unloading area and on the decks
    .  at the kilns.

•     Although the Corporate Director of Safety provides comprehensive
      safety guidance, site-specific instructions are limited.

•     A corporate trainer with a degree in Fire Science and experienced
      in emergency management provides first responder training.

•     Trucks equipped with clean-up compounds and supplied by Oldover
      Corporation are capable of cleaning up small spills.
      Additionally, an inventory of lightweight aggregate is on hand
      that has a 20 percent absorption capacity by weight.

•     Fire departments have surveyed the Solite water supplies  and  have
      found an adequate water supply for responding to fires.

Community and Facility Emergency Response Planning.Activities

•     An Oldover trainer has given first responder training to  Stanly
      County emergency management and response personnel.  ..Solite
      operations and hazardous materials storage have been explained to
      them.

•     Solite recently purchased a foam cannon for the Aquadale  Fire
      Department.  The company had previously assisted the  Aquadale  Fire
      Department in purchasing a fire truck,  and has  also provided  foam
      and an asbestos fireman's suit to allow responders to approach
      extremely hot fires.

•     Should a hazardous materials release occur at Solite,  the  Aquadale
      fire chief would be the incident commander.   The Stanly County
      emergency management director would coordinate  in furnishing

                                144

-------
•     North Carolina DNR cited  fugitive  emissions  from  both  ends  of the
      kiln.  Solite resolved  this  problem  by  installing stainless steel
      overlapping plates as seals  over both ends of  the kiln.
      Additionally, repairing ductwork reduced  fugitive emissions.

Accidental Release Incident Investigation

•     Facility officials report that  they  have  experienced no  accidental
      releases of hazardous materials that would require an  emergency
      response.  No reports of  accidental  releases have been made by
      Carolina Solite to the  State of North Carolina.   The Aquadale Fire
      Chief who covers the facility has  never been called to a hazardous
      materials incident at the facility during his  11  years as fire
      chief.

•     The company recently reached a  settlement of $5,000 with the  North
      Carolina DNR for petroleum leakage onto the ground beneath  the
      trunnions of the kiln.  The  facility corrected the problem  so that
      cooling water into the  jacket of the trunnion  cannot escape.

•     Any serious incident would prompt  an investigation by  the
      corporate environmental manager and  he would critique  how the
      incident was handled.

Facility Emergency Preparedness and Planning Activities

•     One contingency plan covers  the operations of  both  the Oldover
      Corporation and the Carolina Solite  Corporation.  Corporate
      headquarters makes periodic  revisions to  the plan with the  latest
      noted revision being April 17, 1989.

•     Although there has been no general exercise of the  Solite
      emergency plan, portions  of  the plan are  exercised  during annual
      training given to employees.  Training includes hands-on
      experience with fire and  personal  protection equipment and  the
      testing of a warning horn that is  the means for alerting workers
      to an emergency.

•     The emergency plan includes  a facility evacuation plan that allows
      for multiple routes of  evacuation  to ensure workers will not be •
      evacuated into a plume  of release-.    The plan also has  provisions
      to account for the presence  of all site personnel after
      evacuation.

•     The facility's fire brigade  would  take immediate response to a
      fire until local fire department officials could respond.  No
      obstructions exist at the facility that would  impede entry into
      critical areas by fire-fighting personnel and equipment.   Brigade
      members have available  to them dry chemical fire extinguishers and
      use only the personal protection equipment required for their jobs
      at the facility.  A portable  300 gallon foam generating unit is  at
                                143

-------
      Chemical Accident Prevention

      •      The facility should develop a standard operating procedure manual
            for all operations.  Specific written procedures should be posted
            at key locations in the plant.  In addition, valves should be
            marked clearly to identify open and closed positions.

      •      The facility should install a pump switch on the fire deck to shut
            down the fuel pumps from Oldover in the event of an emergency.

      •      Though OSHA does not have jurisdiction over the Carolina Solite
            operation,  the. facility should review and adopt some OSHA worker
            protection standards.   For example, the electrical systems around
            the kiln areas should be examined closely since many electrical
            wires are hanging loosely.

      Facility Emergency Preparedness and Planning Activities

      •      Although the Corporate Director of Safety and Training provides
            comprehensive safety guidance,  the Carolina Solite Facility
            should generate and publish site-specific instructions.

      •      For proper reporting procedures of spills involving a CERCLA
            hazardous substance, the facility should post the telephone
            numbers of the National Response Center and the North Carolina
            Emergency Management Agency.

      Community and Facility Emergency Response Planning Activities

      •      Information contained in the  MSDS for their waste mixtures  should
            be made available to emergency response agencies.

      Public Alert and Notification Procedures

      •      Carolina Solite should install an audible alarm to  alert  the
            surrounding community in the  event of an emergency.
Audit Team Member Composition:

Name and Title                Pat Steed,  Team Leader
Affiliation                   US EPA Region 4
Area of Responsibility        Management  Activities
Expertise                     Mechanical  Engineer

Name and Title                John Deutsch
Affiliation                   AARP,  US EPA Region 4
Area of Responsibility        Process Information/Hazard Evaluation
Expertise                     Chemist
                                      146

-------
      assistance from other county emergency agencies, as needed,  to
      support the fire chief.

•     The facility has evacuation plans in place to evacuate  the
      Aquadale Elementary School should that be necessary.

•     The Solite plan has no listing of telephone numbers of  either the
      National Response Center or the North Carolina Emergency
      Management Agency.

•     Solite filed necessary MSDSs with the Stanly County Emergency
      Management Agency and the Aquadale Fire Department and  Tier  II
      reports with the same agencies on diesel fuel, bituminous coal,
      and shale rock.  Title III section 311 and section 313  reports
      were filed with the state emergency management agency; however,
      their records do not contain Solite's Tier II reports.

Public Alert and Notification Procedures

•     The Solite Facility lacks an alarm system for alerting citizens
      outside its boundaries, and Stanly County has no county-wide
      mechanical alerting system.  If it became necessary to alert
      citizens near Solite because of a release at the facility,
      notification would be made by police and firemen going house to
      house using a vehicle public address system.

•     Stanly County has a coordinated communications system operated
      through a centralized dispatching center at Stanly County
      Sheriff's Office.

•     Stanly County has conducted no testing of its alerting and
      notification procedures relative to Solite.   However,  their
      procedures have been tested in actual emergencies within the
      county.
Recommendations:

Process Information

•     Carolina should install instrumentation which automatically
      records the kiln temperatures, rather than relying on production
      log documentation.

•     Carolina Solite should install a backup automatic temperature
      controller.

•     For its own information,  the facility should install  continuous
      recorder devices on all meters that show temperature  or pH.

-------
148 '

-------
Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Ralph McKeen
TAT, US EPA Region 4
Report Compiler/Reviewer
Environmental Engineer

Gaines Boone
US EPA Region 4
Community/Facility Planning Activities
Chemical Engineer

Rock Callender
AARP, US EPA Region 4
Process Information/Hazard Evaluation
Chemist
Follow-up Activities:

      By the facility:

      By the Regional office:

      By State and local authorities:
Regional Contact:
Pat Steed, Team Leader (404) 347-6033
                                      147

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      The storage system of the liquid hazardous waste  consists  of six
      tanks interconnected with shut-off valves at  each tank.  Oldover's
      storage facilities consist of three 10,000 gallon tanks  and three
      20,000 gallon tanks for a total storage capacity  of  90,000
      gallons.  While all of these tanks are used for storage  of the
      liquid hazardous waste, only tank Number 6 is equipped with an
      agitator which allows for the blending of the fuel prior to being
      pumped to the kilns at Carolina Solite.

•     Shipping/Receiving

      Hazardous waste fuel is received in the tank  farm area.  Delivery
      is by tanker truck from which samples have been taken and
      laboratory approval given to unload.  The tanker  is  coupled to the
      storage system through a flexible hose.  The  fuel passes through
      four in-line filters made of stainless steel and  is  then pumped  to
      the selected storage tank by pumps equipped with explosion-proof
      motors.

•     Material Transfer

      The liquid fuel is transferred to the kilns at Carolina Solite
      with pumps (process pumps) equipped with explosion proof motors.
      Three pumps are provided and these are arranged so that one pump
      supplies the fuel to two kilns,  one pump supplies fuel to  the
      other two kilns and one pump is  a spare,  piped in such a way as to
      allow its use to supply fuel for either of the other two pumps
      that night be down for maintenance or some other reason.

Process Area(s)

The flow of liquid hazardous waste from the tank trucks to the kilns at
Carolina Solite is as follows:

  •   Tank truck is positioned at the  tanker unloading area.   The tanker
      is not allowed to be unloaded until its contents have been
      analyzed and found to be within acceptable profile limits.

  •   Samples are for the following:   presence of PCBs,  chlorine
      content, moisture, pH, BTU content,  specific gravity.

  •   The liquid hazardous waste (LHW) is unloaded from the tank  trucks
      at a rate of approximately 150 gallons per minute (gpm)  and placed
      in the selected storage tank having the capacity to contain the
      load.  The contents of one or more tanks may then be blended

                                150

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Oldover Corporation
Facility Location:
Norwood, North Carolina, Region 4
Date(s) Audit Conducted:
December 4-5, 1990
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
5169 -- wholesale trade - nondurable goods

Stanley County, approximately 1 mile from
Charlotte, NC.
Oldover is a waste storage facility that
receives and blends liquid hazardous
wastes which are pumped to the adjacent
aggregate production facility, Carolina
Solite.
The chemical storage area at the facility
is approximately 6,000 feet from Aquadale
Elementary School and within one mile of a
residential area.
Reason for Facility Selection:
      ARIP Reports:
The facility was chosen because of the
concern of local citizens and
environmentalists in the area about the
liquid wastes stored at the facility.

None
Focus of Audit:
      Hazardous Substance(s)
      Examined:
Liquid hazardous wastes
                                      149

-------
•     Oldover has its own fleet of 6,500-gall'on capacity  stainless  steel
      tankers.  The usual load is limited  to 5,500 gallons due  to over-
      the-road weight restrictions.  When  operating at peak capacity,
      approximately 42 tanker loads are req.uired weekly.  Fleet  tankers
      operated by Oldover Corporation are  routinely serviced and
      maintained by a local contractor.

•     The process pumps must have the capacity to pump the maximum
      permitted burn rate of LHW of 350 gallons per hour.  Based on  the
      min-max BTU specification of the LHW, these permit specifications
      result in a firing rate of 17,500,000 BTUs per hour and a maximum
      firing rate of 45,500,000 BTUs per hour.  However, Carolina Solite
      has the responsibility of insuring this burn rate is not exceeded.

•     All piping is of carbon steel and has been installed in accordance
      with API specifications.  A pipe breakage could occur in the tank
      storage area in which case it is conceivable a considerable
      quantity of LHW could be siphoned from the LHW storage tanks
      before someone could gain access to  the locked valve of the
      storage tank and close the valve.

•     At the present time, the only fail-safe control element exists at
      the unloading valve on the tanker which is being unloaded.  This
      valve is normally closed and requires air pressure (supplied by an
      on-site air compressor) to open it.   Therefore,  the loss of air
      pressure will automatically close the tanker valve.

•     There is no direct environmental monitoring performed at the
      facility.  However, the on-site laboratory performs screening of
      the liquid waste received.   This screening is an indirect monitor
      of what will ultimately be burned at the kilns and released out
      the stacks.

Chemical Accident Prevention

•     Every Oldover employee receives process safety training once a
      year which consists of six hours of class and two hours of hands-
      on training.  New employees are given this training within their
      first six months.  The training is formatted in  the  Corporate
      Health and Safety Guidelines and attendance by each employee is
      documented in records which are kept on file.   On-the-job training
      is done by the individual's supervisor.

•     While the parent corporation prepares the handbook on  safety
      training, the final responsibility for plant safety  rests  with the
      management staff at the plant site.   Every six months,1  an in-house
      environmental audit is conducted by a representative of the
      corporate headquarters in Ashland, Virginia.   This  audit  checks
      manifests, waste profiles,  profiles,  procedures,  and other
      elements of the permit which applies to this RCRA-regulated
      facility;
                                152

-------
            together to better approach  an  ideal blend  for  use  in the  kilns.
            Piping among the several  tanks  and pumps  is  arranged so to allow
            flexibility in the transfer  of  the liquid from  one  tank to
            another, to outload to a  tanker so as  to  haul a load to another
            facility or to transfer to the  kilns at the  neighboring Carolina
            Solite Corporation.

        •   The LHW is pumped to the  Carolina Solite  kilns.
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     Oldover is a fully regulated, permitted, commercial, hazardous
            waste storage facility.

      •     The road access to the plant site is a two-lane asphalt road  in
            good condition.  The plant is also served by the Aberdeen,
            Carolina, and Western Railroad.

      •     The tank farm is surrounded by a chain link, fenced area which is
            always kept secure with padlocked gates.

      Chemical Hazards

      •     Chemicals involved in the audit are contained in a non-homogeneous
            mixture of hazardous materials which varies from time to time
            depending upon the particular source that shipped it to the
            Oldover facility.  Facility management recognizes the hazards of
            these chemicals to be:  flammability,  explosivity,  and toxic
            fumes.

      •     Before waste is approved to be accepted, each generator submits a
            "waste profile sheet" which gives the chemical composition of a
            typical shipment of its LHW.

      •     Annual medical surveillance is given to all personnel who have
            occasion to come in contact with the liquid hazardous waste.

      Process  Information

      •     The LHW storage tanks are sevei  years old and rest  on steel
            supports one foot above the floor of the concrete containment
            area.  The tanks are made from mild steel in complete accordance
            with the specifications of the American Petroleum Institute.  Each
            tank is individually valved and is provided with a  crude but
            effective level indicator.
                                      151

-------
The plan also has provisions for all  sice personnel  once  the
evacuation has been completed.  Although there has been no  general
exercise of the Oldover emergency plan, portions of  the plan  are
exercised during an annual training given to employees.   Training
includes hands-on experience with fire and personal  protection
equipment and the testing of a warning horn which  is  the  means  for
alerting workers to an emergency.

There are no obstructions at the facility that would  impede entry
into critical areas by f*re-fighting  personnel and equipment.

The unloading operation is carried out by a trained operator
dressed in level "C" personal protective clothing and a full-faced
respirator.  He has, in the loading area, four ten pound  dry
chemical fire extinguishers, a 30-gallon foam machine, a  first  aid
kit, an emergency eye-wash station, a spill clean-up kit, and a
two-way radio.

For first response to a fire, the facility has a fire brigade
which would take immediate action until local fire department
officials could respond.  Brigade members have available  to them
dry chemical fire extinguishers.  A portable,  300-gallon  foam
generating unit is located at the point where hazardous waste
trucks are unloaded into the storage  tanks.   Personal protection
equipment for brigade members is limited to that used on  their
jobs at the facility.

According to the emergency plan, the person discovering an
incident notifies one of the following personnel: supervisor,
designated primary emergency coordinator, or four other plant
supervisors listed as back-up coordinators.   Except in unusual
circumstances, there is at least one coordinator on duty at the
site 24 hours a day.  If no coordinator is on duty,  provisions
have been made to call off-duty coordinators back to the plant.
All coordinators have been given full authority to direct
emergency response activities at the site and to expend necessary
resources for following their emergency responsibilities.   It is
their responsibility to make a judgement on appropriate response
measures.  In case of a major emergency,  the coordinator calls for
the notification of all facility personnel,  the shutting off of
operations, the evacuation of endangered workers and the
notification of local, state, and federal emergency response
agencies.  Provisions are also' in place for  containment and clean-
up operations should the incident involve release of hazardous
materials.

Oldover uses a horn located in the administrative area to  alert
personnel to an incident at the facility.   Personnel,  once alerted
by the horn, are kept informed through portable radios that are
carried by management and critical employees at strategic  points
at the facility.  There are telephones at the  fuel  unloading area
and on the decks at the kilns.

                          154

-------
•     No written operating procedures are in effect.

•     Storage tanks are scraped, brushed, and painted annually.
      Corrosion of tanks is measured annually by ultrasonic
      instrumentation.  At present, the corrosion monitoring  is at  the
      same four locations on each tank.  Fire extinguishers are tested
      and documented monthly.  Nitrogen tanks, used to supply pressure
      to oil seals on vacuum pumps, are checked periodically.  A visual
      inspection of all pumps, tanks, and piping is conducted at least
      once per day.  Oldover also utilizes contractual maintenance
      services quite extensively in activities such as tanker and
      vehicle maintenance, millwright services,  and general
      construction.

•     The concrete containment area around the storage tanks is
      surrounded by a three-foot wall and has a containment capacity of
      approximately" 56,000 gallons.  It is thus capable of containing
      the contents of two 20,000-gallon tanks plus one of the 10,000-
      gallon tanks.  Rain is pumped from the containment area as needed
      to maintain the containment capacity.   In the event of a spill,
      Oldover transportation personnel are summoned to remove, using a
      vacuum unit, any standing liquids.  Any remaining material will be
      collected by aggregate produced by Carolina Solite and having
      absorptive capabilities of 20 percent  by weight.

•     The unloading pumps have "gross object" filters  to filter foreign
      objects (such as gloves, etc.) to protect  the pumps.   Nitrogen
      pumps supply the necessary pressure to the oil which then seals
      the unloading pumps to minimize pump leakage and emissions.

Accidental Release Incident Investigation

•     Management conducts an investigation should there  be  an accidental
      release or spill in order to determine the cause  of the spill  and
      to eliminate future occurrences.   The  emergency  coordinator  makes
      arrangements for treatment,  storage, or disposal  of received waste
      contaminated soil,  surface water or any other contaminated
      material.

•     The facility had no history of any accidental releases.

Facility Emergency Preparedness and Planning Activities

•     The facility's Spill Prevention Control and Countermeasure Plan
      (SPCC) was prepared on March 1",  1988,  and does not reflect  the
      true current situation.  There is also one site contingency  plan
      covering operations of both the Oldover Corporation and the
      Carolina Solite Corporation,  and dealing with potential
      emergencies ranging from a minor localized incident to  one of
      major proportions.   The emergency plan includes a  facility
      evacuation plan which allows for multiple  routes of evacuation to
      ensure workers will not be evacuated into  a plume  of  releases.

                                153

-------
            maintenance.   Accidental electric generating set should be
            installed to provide back-up power for the process pumps  in  the
            event of interruption of utility power.

      •     Oldover should install an un-lock valve outside the fence and
            between the storage tanks and the process pumps in case a leak of
            LHW prevents access to the locked valve on the storage tank.

      Chemical Accident Prevention

      •     At present, the corrosion monitoring is at the same four locations
            on each tank;  the facility should make additional measurements
            near the top of the tanks inasmuch as corrosion could be mo-re
            severe in that area of the tanks.  It is also rec:amended that
            corrosion monitoring be conducted on the piping in the same manner
            it is done on the tanks and at the same frequency.

      •     The audit team recommends that a formal written procedure be
            prepared and made readily available at the facility.

      Facility Emergency Preparedness and Planning Activities

      •     Oldover should update their SPCC plan.   The corrected document
            must be prepared and certified by a registered Professional
            Engineer (PE).

      Public Alert and Notification Procedures

      •     For proper reporting procedures of spills involving a CERCLA
            hazardous substance, the audit team recommends  that telephone
            numbers of the National Response Center and the North Carolina
            Emergency Management Agency be obtained and posted throughout the
            facility.

      •     The audit team recommends that an audible alarm system be
            installed to alert the surrounding community in the event  of an
            emergency.

Audit Team Member Composition:

Name and Title                Pat Steed
Affiliation                   US EPA Region 4
Area of Responsibility        Team Leader
Expertise                     Engineer

Name and Title                Gaines Boone
Affiliation                   US EPA Region 4
Area of Responsibility        Emergency Response
Expertise                     Business
                                      156

-------
•     Corporate headquarters has on  its staff a  trainer who has  a  degree
      in Fire Science and who also is experienced  in  emergency
      management in the private sector.  This individual  gives first
      responder instructions on the  site plan to Oldover  employees
      annually.

Community and Facility Emergency Response Planning Activities

•     Stanley County emergency responders have been given first
      responder training by an Oldover trainer.  Oldover  operations and
      hazardous materials storage have been explained to  them.   Oldover
      recently purchased a foam cannon for the Aquadale Fire Department.
      The companies had previously assisted the Aquadale  Fire Department
      in the purchase of a fire truck and had provided the department
      with foam and an asbestos fireman's suit to allow responders to
      approach extremely hot fires.

•     Should a hazardous materials release occur at Oldover, the
      Aquadale fire chief would be the incident commander.  The  Stanley
      County emergency management director would coordinate in
      furnishing assistance from other county emergency agencies, as
      needed, to support the fire chief.

Public Alert and Notification Procedures

•     The Oldover Facility lacks an alarm system for alerting citizens
      outside its boundaries, and Stanley County has no county-wide
      mechanical alerting system.  If it became necessary to alert
      citizens near Solite because of a release at the facility,
      notification would be made by police and firemen going house to
      house using a vehicle public address system.

•     Stanley County has a coordinated communications system operated
      through a centralized dispatching center at Stanley County
      Sheriff's Office.

•     Stanley County has conducted no testing of its alerting and
      notification procedures relative to Oldover.   However,  their
      procedures have been tested in actual emergencies within the
      county.

•     The Oldover plan has no listing of telephone  numbers of either  the
      National Response Center or the North Carolina Emergency
      Management Agency.
Recommendations:

Process Information

•     Each kiln should be supplied with it: own pump with a fifth pump
      to be provided as a back-up to a purrp that is down for

                                155

-------
158

-------
N'ame and Tide
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Rock Callender
AARP
Technical Team
Chemist

John Deutsch
AARP
Technical Team
Chemist

Carlton Hailey
US EPA Region 4
Technical Team
Chemist

Ralph McKeen
TAT
Technical Team
Engineer
Follow-up Activities:

      By the facility:

      By the Regional office:

      By State and local authorities:

Regional Contact:             Pat Steed
                                      157

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      Methanol typically is stored outside  the process  buildings in one
      to six 55-gallon drums.  Potassium fluoride  is  stored in eight to
      twelve large, plastic -lir;d cardboard drums  in  a  wooden warehouse
      next to the process area.  Ethyl chloroacetate  is received and
      stored in approximately five to ten 55-gallon containers outside
      the processing buildings.  The empty  drums are  stored on the
      ground just inside the facility fence.  Ethyl fluoroacetate,  the
      intermediate reactant, is stored in 15-gallon stainless  steel
      containers and may be kept for short  periods of time  (up to 72
      hours) before being purified and incorporated into  the  product.

•     Material Transfer

      Methanol is transferred to the processing area  by a drum dolly and
      is pumped into the alcohol storage tank.  Potassium fluoride  is
      carried to the reactor area in 80-pound plastic containers and is
      scooped by hand into the slurry charger.  Ethyl chloroacetate  is
      moved to the reactor area with a hand dolly and is  transferred to
      the slurry charger by a drum pump.  Ethyl fluoroacetate  is
      transferred by hand into the process vessels.

Process Area(s)

Ethyl chloroacetate and potassium fluoride are mixed briefly  in a slurry
tank.  After the slurry contents are discharged into  the autoclave
reactor, the slurry tank is rinsed and the rinsing is collected and
discharged into the local sewer system.

The autoclave is then sealed and heated by a heat transfer  fluid.  A
gas-fired heat exchanger maintains the temperature of the heat transfer
fluid.  As the reactor temperature rises,  the pressure  in the  autoclave
rises to approximately 300 psig.   This initial reaction step is
completed in approximately six hours .

The gaseous product of this reaction is transferred through a  condenser
from the autoclave to a receiver tank.   Any liquid remaining in the
autoclave is drawn by vacuum into this receiver tank,  which vents to the
atmosphere.

The liquid product is then transferred by vacuum to a still for
purification.  The batch distillation system uses the same heat transfer
fluid as the autoclave reactor.  A 20-foot column packed with  ceramic
saddles separates the products.  The first material removed, an ethanol
and ethyl acetate forerun, is collected and discharged  to the  sewer
system.  The refined intermediate product,  ethyl-fluoroacetate, is

                                1.60

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
lull Chemical Company, Inc.
Facility Location:
Oxford, Alabama, Region 4
Date(s) Audit Conducted:
December 12, 1990
Description of Facility:

      SIC Code(s):


      Location:
      Products manufactured,
      produced, or distributed:

      Proximity to
      sensitive populations:
2879 -- pesticides and agricultural
chemicals

The total site area is approximately one
acre fifty miles east of Birmingham.
Sodium fluoroacetate,  a rodenticide
Tull is located in a small residential
area adjacent to a U.S.  highway.
Reason for Facility Selection:
      ARIP Reports:
The facility was chosen because of its
proximity to area residents and the highly
toxic nature of the compounds used and
produced.

None
Focus of Audit:
      Hazardous Substances(s)
      Examined:
Sodium fluoroacetate
Ethyl chloroacetate
Potassium fluoride
Ethyl fluoroacetate
Methanol
Sodium hydroxide
                                      159

-------
Process Information

•     Neither the methanol storage area nor the ethyl chloroacetate
      drums had any placards identifying the presence of flammable
      materials.

•     Empty drums and debris have been left in the process area.  Not
      all drums have been tripled rinsed, and the rinsing is not
      consistently collected and properly disposed.

•     The bailing wire used to stabilize and secure the pipes and
      fixtures in the process areas is inadequate.  The asbestos
      insulation surrounding the piping and vessels in the process areas
      is exposed.

•     The layout of the process line heat exchanger makes it unlikely
      that the temperature will increase out of control and raise
      internal pressures beyond critical limits.   The amount of heat
      generated is limited by the control mechanism and the capacity of
      the gas fired heat exchanger.  The still operation is safe at
      normal operating conditions.  Nevertheless, a malfunction could
      occur in the control mechanism or exchanger.  The operator
      monitors the pressure and temperature of the autoclave reactor
      every 30 minutes.  Pressure and temperature readings are recorded
      on a batch chart.  The still has three temperature probes at
      various stages, which are located on the bottom of the pot and the
      bottom and top of the column.  The still temperatures are manually
      recorded and no automatic control schemes are used.

•     Tull does not have any stations at the facility for monitoring
      chemical releases.

•     Ethyl fluoroacetate is transferred by hand,  which could result in
      a spill.  Potassium fluoride is scooped by hand into the slurry
      chargtr, exposing workers.

•     The methanol and ethyl fluoroacetate transfer points are the most
      likely areas of the process line for accidental releases to occur
      due to improper physical handling.

•     Uncontrollable temperature increases during the combination of
      methanol and sodium hydroxide are prevented by adding the  sodium
      hydroxide beads in small increments.

• .    Because the screening process of the final  Compound 1080 product
      from the oven is done under a hood without  an exhaust fan,
      screening process operators can be exposed to Compound 1080 dust.

•     Tull has had unidentified fugitive emissions.
                                162

-------
      boiled through the column and then collected in drums for subsequent
      hydrolysis.

      Hydrolysis is accomplished by reacting the clarified distillation
      product with a sodium hydroxide/methanol solution.  This caustic
      solution is  prepared by charging methanol to a tank and slowly adding
      sodium hydroxide beads.  The methanol/sodium hydroxide solution is  then
      pumped through a filter press.

      The hydrolysis process consists of charging a tank with the refined
      distillation product and slowly adding the caustic methanol solution.
      The solution is continually agitated by a mechanical stirrer.
      Hydrolysis requires approximately 12 hours to complete and is performed
      at night when no personnel are on-site.

      When hydrolysis is completed, the slurry is fed in small amounts to a
      centrifuge where the methanol is separated.  The recovered methanol may
      be reused in the hydrolysis reaction.  After the second use, the
      methanol is  collected and discharged to the sewer system.

      The Compound 1080 product is manually scooped from the centrifuge onto
      metal trays  for oven drying.  The drying consists of a 24-hour bake in a
      vacuum oven to remove all traces of methanol.   This final  step limits
      production capacity, since the maximum amount of Compound 1080 that can
      be dried in a 24-hour time span is 130 pounds.

      The final product is sieved manually though a filter screen into plastic
      bags, which are weighed, heat sealed and placed in metal cans for
      shipping.

Summary of Audit Findings and Reconjnendations:

      Conclusions:

      Facility Background Information

      •     The facility has only one primary employee,  the  owner.   The  owner
            occasionally is helped by his brother and a part-time  employee.

      •     There are no obstructions to fire department entry into the
            facility.

      •     The facility operates during the day and  otherwise  is  unattended.
            There are no sensors for detecting illegal  entry.  However,  due  to
            the size of the facility, a guf.rd service may not  be  feasible.
            Neighborhood children can gain access to  the facility's  equipment
            and grounds due to inadequate fencing and security measures.   In
            addition, Tull's front gate is left open  periodically,  even  when
            the facility is not in operation.   Employees and visitors  park
            automobiles at random within the enclosed fence.
                                      161

-------
      Community and Facility Emergency Response  Planning Activities

      •     lull filed no SARA Title III reports prior  to  February,  1989,  even
            though personal contact was made with  the lull owner by  a  Region
            IV representative of the U.S. Environmental Protection Agency.

      •     The facility owner has not implemented a program  familiarizing
            firemen with the plant, plant operations or the chemicals  used and
            produced on-site.

      •     Tull's owner does not have the telephone number for the  SERC and
            lacks procedures for reporting an accidental chemical release  to
            the SERC as required by Title III.

      Public Alert and Notification Procedures

      •     In the event of an accident, Tull will immediately notify  the
            appropriate emergency services by calling the emergency  telephone
            number 911.

      •     As stipulated in Calhoun County's emergency plan,  emergency
            information will be. broadcast over local radio stations.   However,
            alert procedures have not been tested.  No public alerting system
            covers the area in which Tull Chemical Company is located.   If
            alerting for evacuation is necessary, public safety officers would
            issue warnings using loudspeakers while driving through  the
            streets.
Recommendations:

      Background Information

      •     All vehicles should be parked either outside the fenced area or
            along the northern fence line to prevent the possibility of
            creating an additional ignition source.

      •     Security needs to be improved in order to prevent neighborhood
            children from gaining access to the equipment and grounds,  where
            they may come in contact with the manufactured compound.   Tull's
            fencing needs to be repaired and the front gate should be closed
            during non-operating periods.
            \
      Process Information

      •     Placards should be placed in those areas where flammable  material
            is stored.

      •     The excess drums and debris in the process area and the
            surrounding grounds should be removed soon.   Prior to their
            disposal, empty containers should be'triple  rinsed to remove any
            residue.  The rinsing should be collected and properly disposed.

-------
•     The filter press that clarifies the methanol solution has  visible
      signs of caustic powder, filter aid, and possibly Compound 1080  or.
      the filter screens and drip pan.

Chemical Accident Prevention

•     Highly formalized safety management practices may be deemed
      unnecessary by the management because of the small staff.

•     The submitted Standard Operating Procedures (SOPs) for original
      pilot operation are quite detailed, showing the concerns and
      considerations at each step in the process.  However, no updated
      "facility-specific" SOPs are available.

•     The facility does not require an operator to be on-site when the
      hydrolysis portion of the process is occurring.

•     Maintenance at Tull is done "as needed."  No formal preventive
      maintenance program is in place.  The owner does all maintenance
      at the facility.

•     The nature of the operation, the raw materials used,  and the
      products produced do not lend themselves to modeling analysis.

•     Open drainage troughs present a hazard to operators.   A
      containment curb installed along the eastern boundary would impede
      and channel drainage of vessel waste water from the process area.
      The accumulation from a containment curb could hold contaminants
      at levels significant enough to warrant pretreatment before
      discharge.

Accidental Release Incident Investigation

•     Tull Chemical has never experienced a chemical accident at the
      facility requiring public safety assistance.   The Oxford Fire
      Department confirmed this claim.

Facility Emergency Preparedness and Planning Activities

•     Tull Chemical Company lacks a written emergency plan.

•     The facility does not have an emergency shower,  an eye  washing
      station, a first aid station,  or a fire alarm system.

•     All on-site emergency communicition would be  by word-of-mouth,
      since the owner and any other employees would be working in the
      same area.
                                163

-------
            reactions.  An appropriate hose and nozzle should be available  at
            this source in a protected, unlocked, weatherproof housing.

      •     For personal safety, an emergency shower and an eyewash station
            should be provided by the facility.

      •     An emergency phone should be located in the process areas  to allow
            for prompt notification of local emergency personnel.

      •     The feasibility of installing intrusion and fire alarms that can
            be tied into the alarm control center at the Oxford, Alabama,
            Police Department should be investigated.  If an intrusion and
            fire alarm system is feasible, lull should implement such -a
            system.

      Community and Facility Emergency Response Planning Activities

      •     lull should comply with the Title III reporting requirements.  The
            owner should furnish information about sodium fluoroacetate to the
            Local Emergency Planning Committee, the fire department servicing
            the facility, and the SERC.

      •     Tull should provide local fireiren with information on facility
            operations, the identity and Ic.ation of chemicals,  and the
            protective actions required in the event of an accident at the
            facility.
Audit Team Member Composition:

Name and Title                Pat Steed
Affiliation                   US EPA Region 4
Area of Responsibility        Audit Team Leader
Expertise                     Engineer

Name and Title                Gaines Boone
Affiliation                   US EPA Region 4
Area of Responsibility        Emergency Preparedness
Expertise                     Business

Name and Title                Carin DeBenedictis
Affiliation                   US EPA Region 4
Area of Responsibility        Process System
Expertise                     N/A

Name and Title                De'Lyntoneus Moore
Affiliation                   US EPA Region 4/TAT
Area of Responsibility        Process System/Safety
Expertise                     N/A
                                      166

-------
•     Metal strip fasteners or metal braces should be installed  to
      replace the bailing wire currently being used to stabilize  and
      secure the pipes and fixtures in the process areas.  Exposed
      asbestos insulation surrounding the piping and vessels  in  the
      process areas should be removed or encapsulated.  Grating  should
      be installed over the drainage troughs in the process area.

•     Appropriate monitoring stations to detect releases of chemicals
      should be installed.

•     Either lull should improve transfer methods for ethyl
      fluoroacetate and potassium fluoride or the facility should
      provide spill/splash containment trays.

•     An exhaust fan that discharges through a carbon filter is
      recommended for the hood located at the final product screening
      process.

•     While the still is safe under normal operating conditions,  a
      liquid level indicator and high temperature cut-off in the pot
      should be considered to prevent abnormal conditions.   An
      electrical cut-off should be readily accessible in the operation
      or yard areas to quickly and easily stop all process  motors.

•     The over-pressure alarm on the autoclave should be repaired.

•     Sources of fugitive emissions should be  identified and eliminated.

•     The filter press should be thoroughly cleaned of any  residue which
      might remain during long periods of non-use.

Chemical Accident Prevention

      A formal safety plan should depict process  hazards and appropriate
       nereencv resoonse procedures.
emergency response procedures.
•     Existing pilot plant SOPs should be condensed,  updated,  tabulated,
      and made available at the facility.

•     An operator should be on-site when the hydrolysis  portion of the
      process is occurring to guard against emergency situations.

Facility Emergency Preparedness and Planning Activities

•     A reference guide should be created that details the  procedures
      for notifying local government and the SERC in  the event of  a
      hazardous chemical accident.   Emergency information should also be
      made available in a reference guide.

•     Water and chemical extinguishers for  fire protection  should  be
      installed.  It should be capable of providing a deluge  of
      water/chemical retardant in order to  stop runaway  chemical

                                165

-------
168

-------
Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Lew Nagler
U.S. EPA
Air Modeling
N/A

Larry Palmer
AARP
Process System
N/A
Follow-up Activities:

      By the facility:

      By the Regional office:

      By State and local authorities:

Regional Contact:             Pat Steed
                                     167

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Virtex Chemical Corporation  (proposed
construction plan)
Facility Location:
Bristol, Tennessee, Region 4
Date(s) Audit Conducted:
January 30-31, 1991
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
Reason for Facility Selection:
      ARIP Reports:
2819.-- industrial inorganic chemicals

The plant will be located in an industrial
park in Bristol, TN, on the border of
Tennessee and Virginia.
Sodium azide, a propellant in automobile
safety airbags.
There is an elementary school three miles
southeast of the proposed site.   The
Bristol Regional Medical Center  and a
nursing home are approximately eight miles
west of the site.  Approximately 400
residents are within one mile of the site.

EPA performed the audit because  of public
concerns over the hazards associated with
the production of sodium azide.

None
Focus of Audit:
      Hazardous Substances(s)
      Examined:
Sodium nitrite
Sulfurxc acid
Hydrazine hydrate
Butanol
Ethanol
Sodium hydroxide
Sodium azide
Butyl nitrate
                                      169

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      Sodium nitrite solution will be stored  in  20,000-gallon  carbon
      steel storage tanks.  Dry sodium nitrite will be  stored  in  the
      warehouse separate from ''ncompatible chemicals.

      Sulfuric acid, at 93X concentration, will  be stored  in a 20,000-
      gallon carbon steel tank.  By using 93X concentration, the  need
      for freeze protection on storage tanks will be eliminated.

      Hydrazine hydrate will be stored in a 10,000-gallon  tank
      constructed of 304 stainless steel and equipped with an  internal
      nitrogen blanket.

      Required alcohols will be stored Ln 20,000-gallon carbon steel
      tanks.

•     Shipping/Receiving

      All liquid raw materials will arrive in tank trucks  and  will be
      pumped to storage.  The quantity received will be a  full  truck,
      and the delivery schedule will be a function of the  rate  of
      production.  All shipping will be on the day shift, when  the plant
      manager will be the responsible person.   The Bristol Industrial
      Development Commission access road, Industrial Drive, will be  the
      transportation corridor into the facility.

•     Material Transfer

      The facility will transfer liquid raw materials from storage
      delivery trucks and storage tanks using centrifugal pumps, and dry
      materials, in bags or drums, will be moved by forklift.   A screw
      conveyor may be used to add solid sodium hydroxide to the alcohol
      mix tank and sodium nitrite to its mix tank.

Process Area(5)

The Virtex  process produces sodium azide, a propellent in automobile air
bags, in a  two-step system.  In the first step,  butyl nitrite is
produced from butanol, sodium nitrite, and sulfuric acid.  In the second
step, sodium azide is produced from butyl nitrite, hydrazine hydrate,
and sodium  hydroxide.

STEP  1:  In the butyl nitrate reactor, reactants  are fed through an
automatic process control system.  In this exothermic reaction, reactor
temperature is controlled using chilled water.  A butyl nitrite product
and an  aqueous product will contain sodium sulfate as the primary solute

                                170

-------
      and will be sent to the waste treatment plant.  Traces of other
      chemicals used or created in the process will be  in the water.  The
      butyl nitrite product will be saved to make sodium azide.

      STEP 2:  The sodium azide reactor functions in the same way as the butyl
      nitrate reactor.  Sodium azide crystals form  in the reaction process.
      The crystals are then separated from the sodium azide reactor product,
      washed, and then sent to a steam heated dryer.  The drying will be
      conducted at a low temperature under an inert atmosphere.

      When the drying operation is complete, the product, will be discharged to
      a container ready for packaging.  This container will be blanketed
      internally with nitrogen.  The finished sodium azide will then be
      packaged in fiber drums of 120-pound capacity with a plastic lining or
      in tote bins of 2,000- to 4,000-pound capacity.  The packages will be
      removed from the packaging area and stored in the warehouse.
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     Initially, the facility plans to produce 1,000 tons per year of
            sodium azide.  It will be operated by approximately 80 personnel
            and will occupy a 10-acre site.   Virtex plans to operate on three
            shifts per day, 7 days per week, 330 days each year.   The azide
            reactor will initially produce approximately 6,000 pounds per day,
            with an ultimate production of 4,000,000 pounds per year of sodium
            azide.

      •     Virtex Chemical plans to build a 10,000 square foot production
            building, a 3,750 square foot warehouse, and a 3,750 square foot
            office building for the manufacture and shipment of sodium azide.

      •     The proposed plant can be accessed by a Norfolk and Southern
            railroad spur, by a major highway currently under construction,
            and by several two-lane roads in the industrial park.

      Chemical Hazards

      •     Sodium azide will form explosive compounds in the presence of
            heavy metals such as lead or copper.

      •     Hydrazine hydrate, when in contact with oxidizing agents,  may
            result in spontaneous ignition.

      •     Butanol is flammable and its vapors may explode if ignited in an
            enclosed area.
                                      171

-------
•     Sodium nitrite will increase the intensity of a  fire and  ic  may
      produce toxic gases when burned.  Ic may also cause a  fire  if
      placed in contact with combustibles.  Prolonged  exposure  to  either
      heat or fire may result in the sodium nitrite exploding.

•     Sulfuric acid s very corrosive and highly reactive and may  cause  a
      fire when placed in contact with combustibles.

•     Sodium hydroxide may cause fire if placed in contact with
      combustibles.  When placeJ in contact with metals, it  may produce
      flammable gases.

•     Butanol, ethanol, and butyl nitrite are flammable liquids and
      their vapors may explode if ignited in an enclosed area.

•     Virtex has received data from other chemical companies on various
      chemicals and maintains a file of MSDSs.  This data was readily
      available in the Barker Corporation Construction Office.

•     Virtex does not have a system to ensure rapid access to, or
      updates of, hazard documentation.

•     A procedure does not exist to determine product content of water
      and ethanol.

Process Information

•     All tanks will be monitored for corrosion and maintenance needs on
      a scheduled basis.   Observations and corrective action will be
      recorded in log books.

•     Shipping and receiving activities  are not supervised by a trained
      and experienced person.

•     The fa-ility will transfer liquid raw materials from storage
      delivery trucks and storage tanks  using centrifugal  pumps.   All
      piping will be color coded and labeled.

•     The planned distribution system is not adequately refined.

•     The process flow rates are roughly dependent on the  estimated
      production rate.  Initially,  the rate will  be about  two million
      pounds per year with the plant capacity about twice  that amount.
      The facility views the additional  capacity  as a safety factor to
      prevent hazards due to over-filling the tanks.

•     Packaging of sodium azide after crystallization appears to be the
      most hazardous operation.  Workers in this  area will  be exposed to
      poisons, explosion potential,  and fire.

•     The butyl nitrite reactor will have 50% over-capacity by volume.
      Flow rates and reaction temperatures will be automatically

                                172

-------
      controlled with an automatic over-temperature cutoff  of  reactants.
      The sodium azide reactor will be similarly equipped.

•     Power failure will result in automatic shutdown of all equipment
      in a fail safe mode.

•     The proposed butyl nitrite reactor will be equipped for  both
      heating and cooling.  It will have a high temperature device  to
      shut off any feed if the temperature is too high.  The reactor
      will be made of a corrosion-resistant material.

•     The proposed sodium azide reactor will have an automatic
      temperature control system.  The temperature indicator controller
      will apply steam or chilled water as needed.

•     The proposed facility lacked a system for detecting a chemical
      release or atmospheric monitoring equipment.

Chemical Accident Prevention

•     Barker Corporation, which will own and construct Virtex,  will
      prepare a detailed safety manual before start-up of the plant.
      Virtex management will follow the process procedures set forth in
      this Corporate Safety Manual.

•     Safety placards will appear throughout the plant.

•     Detailed process instructions for the operators will be present at
      each work station.  The work station will also show steps to be
      followed in case of releases.  All appropriate worker protection
      standards will be prominently displayed.

•     The production manager will be responsible for making certain all
      formalized procedures are carefully followed.

•     Barker Corporation will audit all plant procedures on a regularly
      scheduled basis.  Safety and operating personnel from other
      outside companies will be invited to audit process safety.   Virtex
      will rely heavily on Olin Corporation because  of its  experience in
      handling hydrazine.

•     Barker Corporation has designed dike systems throughout the
      manufacturing and storage tank areas.   Each diked  area,  i.e.,
      around a storage tank, has a sump pump to recycle  the  spoil to the
      tank from which it spilled.

            The 20,000-gallon sulfuric acid tank will  be diked  '
            separately from the other storage tanks,  and the containment
            will have a volume of 30,000 gallons.

            The hydrazine hydrate tank will be  diked to  hold one  and
            one-half the tank's capacity.   The  system  will be equipped

                                173

-------
            for vapor recycling during receipts  (an  air  permit
            requirement) and will be held under  positive pressure.

            Alcohol tanks will be diked to hold  one  and  one-half  times
            the tank capacity.

•     The warehouse and manufacturing areas will be  equipped with
      sprinkler systems.  A dry chemical system will be  utilized  around
      the dryers.  A water tank will be stationed above  the hydrazine
      hydrate storage area to sprinkle the outside of  the storage  tank
      in the event of fire.

•     Facility management will make certain appropriate protective
      equipment is available for employees and visitors.  The plant
      safety director will monitor all safety procedures.  He will
      maintain and review logs for safety and accident considerations.

•     Virtex lacked formal training requirements for plant employees at
      the time of the audit.  They plan on establishing training
      guidelines for all employees prior to hiring personnel.

•     The facility does not have a system for recording corrosion
      inspections and their results.

•     There are sampling stations in the effluent holding tanks for
      monitoring the waste stream.  An "azide kill tank" using sodium
      nitrite and sulfuric acid will be used to prevent sodium azide
      from entering the effluent holding tanks.

•     The room in which drums are filled with sodium azide will be
      constructed with a surrounding chamber to prevent releases of
      powder to the atmosphere or surroundings.

•     There does not appear to be a way to ensure the complete removal
      of the sodium azide from the centrifuge.

Facility Emergency Preparedness and Planning Activities

•     The Personnel and Public Relations Director are preparing the
      Virtex Emergency Response Plan as required by the LEPC under Title
      III section 303.  Virtex has ordered the Computer-Aided Management
      of Emergency Operations (CAMEO) software system to enhance their
      emergency preparedness.

•     Virtex will exercise emergency response plans at least once  a
      year, and fire drills will be held frequently.   Any mitigation
      systems recommended by Olin Corporation in the  storage and
      processing of hydrazine hydrate will be utilized.

•     Virtex plans to conduct emergency exercises to  train and
      strengthen their emergency response capabilities.  Virtex had no
                                174

-------
      definite exercise scenarios or training schedule  at  the  time  of
      the audit.

•   •  The fire fighting capabilities for the Bristol area  include  the
      Bristol, Virginia, and Bristol, Tennessee, fire departments.
      These two units have mutual aid agreements, and both  respond  to
      the 911 Emergency System.

•     All personal protection gear for Virtex employees must have
      periodic inspections conducted by the hazardous materials  team
      from the fire department's staff.  All employees must receive
      emergency equipment training from either the Sullivan County
      Emergency Management Agency or the Bristol fire service.

•     Virtex lacked a formal emergency response chain of command at the
      time of the audit.

•     Virtex lacked formal emergency response management procedures at
      the time of the audit.  Virtex should include these procedures in
      the facility's standard operating procedures.

•     Virtex did not have provisions for an emergency communication
      network at the time of the audit.

•     Virtex lacked a formal procedure for the follow-up and
      investigation of chemical releases.   Virtex plans to establish
      procedures for release follow-up and investigations prior to
      having chemicals on-site.

Community and Facility Emergency Response  Planning Activities

•     Virtex plans to develop a schedule of testing the emergency
      procedures following construction'of the plant.

Public Alert and Notification Procedures

•     Because the facility is not yet constructed and lacked formal
      procedures at the time of the audit,  an evaluation of this  area  is
      not possible.

•     The county has a 911 emergency system for use  in calling for
      assistance.
Recommendations:

Chemical Hazards

•     Virtex should design a system to ensure rapid access to hazard
      documentation at the actual facility.   Also,  a system for updating
      this information is needed.
                               ,175

-------
•     Because of the toxic effects of the chemicals used, Virtex should
      establish a medical monitoring program for all employees.

•     Virtex should establish procedures to determine product content  of
      water and ethanol.

Process Information

•     The packaging operation must be done in an area sealed to prevent
      migration of the sodium rzide from the packaging room.  The
      packaging equipment must be designed to prevent exposure of
      personnel in the packaging area to sodium azide.

•     Personnel entering the packaging room should wear boots,
      protective gloves, goggles, positive pressure breathing apparatus
      and special protective clothing.  Contaminated clothing must be
      isolated and decontaminated.

•     Automatic control systems will be needed to assure that the sodium
      azide reactor will be operated with an excess of sodium hydroxide
      at all times.

•     Virtex should perform all shipping and receiving activities under
      the supervision of a trained and experienced person.

•     Virtex should further refine the planned distillation system.

•     Virtex should refine the vent system for the storage tanks to
      minimize the organic vapor emissions.

•     Virtex should review the need for a freeze protection system for
      the sulfuric acid storage tank.

•     Virtex should evaluate the need for an inert atmosphere in the
      sulfurif acid storage tank to minimize corrosion.

Chemical Accident Prevention

•     Virtex should establish a formal system to record corrosion
      inspections and their results for all tanks,  reactors,  and piping
      systems.

• •    Virtex needs to develop a system for training personnel on the
      toxic effects of chemicals at the plant.

•     Appropriate fire protection will be needed and a conservation  vent
      is recommended.

•     Virtex should incorporate standard operating procedures into a
      manual.
                                176

-------
•     Virtex should write a safety manual and each employee  should
      receive a copy when hired.

•     All employees should periodically receive training  in  the  use  of
      emergency equipment and protective equipment.

•     Virtex should try to minimize the inventory of  the  raw materials
      and finished product to help ensure safety.

•     Virtex should adequately maintain and clean the packaging  room to
      ensure that no fugitive particles may escape to the other  work
      areas or the environment.

•     Virtex should establish a safe method for the sampling,
      measurement, and disposal of sodium azide crystals.

•     Virtex should review the feasibility of using a plow to remove  the
      sodium azide from the centrifuge from a safety standpoint.

•     Virtex should install a valve between the azide reactor and
      centrifuge that will automatically close in the event  of a power
      failure.

•     Virtex should use a hazard evaluation system,  like the "what if"
      model, to determine the potential hazards associated with various
      plant or process malfunctions or failures.   They should also use
      scenarios involving a fire in the finished product (sodium azide)
      warehouse, fire around the hydrazine storage tank, and fire in the
      sodium azide dryer.

Facility Emergency Preparedn2ss and Planning Activities

•     Virtex should write a formal Emergency Response Plan.   This should
      include the emergency response procedures,  the chain of command,
      communication procedures, emergency response exercise plans and
      accident investigation procedures as a minimum.

•     Virtex should establish protective clothing requirements  for all
      areas of the facility.

Community and Facility Emergency Response Planning Activities

•     Virtex Chemical should try to improve relations with the  community
      by holding seminars explaining the safety measures they are
      implementing.  Guest speakers Trom outside  the  organization might
      assist in this effort.   A frank discussion about the properties of
      hydrazine and sodium azide should be helpful in allaying  fears.

•     Virtex should coordinate the shipping and receiving of the  raw
      materials and finished product with the community response  plan.
                                177

-------
            Virtex should hold community meetings to improve community
            relations, distribute information about the chemicals used.
            answer questions.
                                          and
            The EPA suggests that the Virtex emergency response plan be
            exercised every six months.  This will help to develop an
            effective response capability for any emergency.  These exercises
            should include the Bristol Fire Department, Sullivan County EMA,
            and the Bristol Medical Center.
Audit Team Member Composition:

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Charlie Cartwright,  Team Leader
US EPA Region 4
N/A
N/A

Edward Carreras
US EPA Region 4
N/A
N/A

John Deutsch
AARP
N/A
N/A

Dennis Wile
AARP
N/A
N/A
Follow-up Activities:

      By the facility:

      By the Regional office:

      By State and  local authorities:
Regional  Contact:
Charlie Cartwright,  Team Leader
                                      178

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Cape Coral Reverse Osmosis Water Treatment
Facility
Facility Location:
Cape Coral, Lee County, Florida, Region 4
Date(s) Audit Conducted:
February 20-21, 1991
Description of Facility:

      SIC Code(s):


      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive .populations:
9511--- administration of environmental
quality and housing programs

Nearly surrounded by water on the southern
Gulf Coast of Florida approximately 120
miles west of Miami
The facility treats raw water to meet
drinking water specifications.
Two schools are located within a one-mile
radius of the plant.   The facility is
located in an area with the potential for
substantial residential development.
Reason for Facility Selection:
      ARIP Reports:
The facility was selected due to an
accidental release of chlorine gas which
occurred at the'plant in February, 1989,
resulting in the death of an employee and
the hospitalization of an employee and an
emergency responder.

none
Focus of Audit:
      Hazardous substance(s)
      examined:
Flocon 100 (polyacrylic acid)
Sulfuric acid
Sodium hydroxide
Chlorine gas
                                      179

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      Flocon 100 is stored at the Hydranautics  Plant  in  a  labeled 1,200-
      gallon above ground storage tank.  It  is  then transferred to an
      80-gallon day tank.  In r'.ie Dow Plant, Flocon 100  is  stored in the
      Flocon storage room in the 55-gallon drums  in which  it  is
      received.  The material is then transferred to.  a 225-gallon day
      tank for use.

      The Hydranautics Section and a set of  outside bulk storage  tanks
      for sulfuric acid and sodium hydroxide were  added  in  1984.
      Sulfuric acid is stored outside in the Dow  Plant area in  a  15,000
      gallon lined storage tank, which is connected to a pump that
      carries the chemical into a 610 gallon day  tank located in  the
      sulfuric acid room inside the facility.

      Sodium hydroxide is similarly stored outside in a  lined 6,000
      gallon tank.  The chemical is pumped into a  200 gallon day  tank
      within the facility.

•     Shipping and Receiving

      Flocon 100 is shipped in twenty 55-gallon drums to the facility
      monthly by truck.

      Both sodium hydroxide and sulfuric acid are shipped to the
      facility in 3,000-gallon tank trucks.  Six truck loads of sulfuric
      acid and one-half truck loads of sodium hydroxide  are received
      monthly.

      Chlorine is shipped to the plant in one-ton containers via  truck.
      The quantity of chlorine ordered depends on the fluctuation  in
      water demand.  Th« facility receives three to four shipments of
      four tons each month.

•     Material Transfer

      Operators remove the Flocon 100 from the trucks using forklifts
      and transport the drums with drum grapplers to the appropriate
      storage areas.

      The sodium hydroxide and sulfuric acid truck operator, who is
      monitored by an employee of the Reverse Osmosis facility,  is
      responsible for unloading the substances into their respective
      outdoor storage tanks.
                                180

-------
            The chlorine containers are unloaded onto a deck and positioned
            using a monorail and a three ton electric hoist equipped with a
            standard lifting beam.

      Process Area(s)

      The plant operates as two separate water producing units under the same
      roof;  one unit is referred to as the Hydranautics Plant, which supplies
      the semipermeable membrane used in the treatment process, the other unit
      is the Dow Plant.  The chemical treatment requirements are essentially
      the same for both plants.

      The computer-controlled, pre-treatment process occurs when sulfuric acid
      and Flocon 100 are added to water pumped from the lower Hawthorne
      aquifer.  The water passes through filters and is pumped into the
      reverse osmosis units at a pressure of 260 psi.  At this stage the water
      is separated into usable and reject water.

      Dissolved hydrogen sulfide is removed from the usable water.   Gaseous
      hydrogen sulfide is released when the water contacts the air flowing
      through degasifiers.  The usable water then passes into the clearwell
      where chlorine is added for disinfection and sodium hydroxide is added
      to raise the pH.   At this point, the water is stored in tanks and is
      available for pumping to the consumer.

      The rejected water (brine) is discharged from the system through the
      brine line.  The brine is highly concentrated with impurities and is
      treated with chlorine and oxygen to maintain environmental standards.
      It is then evenly diffused throughout a salt water lake using submersed
      spray nozzles.

      Both the treated water and brine are chlorinated before being
      transferred to the storage tanks or the lake.   Vacuum is created at  the
      injectors drawing the chlorine gas from the tanks through the rotameter
      and the V-notch variable orifice valve which is manually operated for
      controlling the flow.  The chlorine gas enters the water flowing through
      the injectors.   Chlorinated water is added to the flow of usable  water
      at the discharge end of the degasifier where it is then pumped to the
      storage tanks.
Summary of Audit Findings and Recommendations

      Conclusions:

      Facility Background Information

      •     The perimeter of the plant is protected by an eight-foot,
            chainlink fence topped with barbed wire.   The front  gate  is
            operated by a switch just inside the front entrance  of  the
            building.  The front gate and the immediate grounds-are monitored
                                    .  181

-------
      by the operators in the control  room  by  a  single  video  camera.   No
      perimeter surveillance is conducted.

Chemical Hazards

•     An accidental release of chlorine vapors has  the  greatest
      potential of posing a substantial threat to the surrounding
      population and personnel within  the plant  area.

•     MSDSs for all chemicals used on  site  are readily  available  to all
      employees for reviev.

Process Information

•     The storage area is a roofed, three-sided, concrete block building
      open on the receiving end, and also open between  the  side of the
      plant wall and the end of the north back wall.  Protection  from a
      driving rain from the west is not necessary because containers are
      raised well above the floor level.

•     The Hydranautics Section has day tanks similar to those  in  the Dow
      Section.  However, the chemicals enter the appropriate  tanks
      through gravity feed instead of pumps and  the operator must
      manually open/close a valve while observing the tank  sight  glass
      to determine the fill level.  The tanks are also  located in a
      three-sided diked area.  The fourth side, open to common trench,
      creates a hazard because of the potential for the mixing of acid
      and base substances.

•     In the Dow section, sodium hydroxide and sulfuric acid tanks have
      their own unique fittings to minimize the chance of cross-loading
      from the tank truck to incorrect tanks.  An additional set of
      outside bulk storage tanks for sodium hydroxide and sulfuric acid
      use the same fitting for unloading,  which creates the potential
      for add vug incompatible materials to the system.

•     The tank pumps are controlled manually through palm switches which
      will automatically shut off if released.   This helps to reduce  the
      possibility of tank overflow.

•     There are detectors mounted to detect chlorine vapors outside the
      building.  Sensors in the chlorine operation area are checked
      weekly.  They will activate both a strobe light warning in the
      main operations building and an audible warning signal in the
      control room.  No exterior visual or audible alarms exist.

•     Hydrogen sulfide gas around the degasifiers is noticeable.   The
      facility has done no quantitative study of this discharge.
                                182

-------
Chemical Accident Prevention

•     All employees must attend a monthly  safety meeting  which include
      discussions on various safety  topics,  such as  chemical  hazards,
      employee safety precautions, etc.

•     Written safety and procedure manuals are available  to Reverse
      Osmosis Plant employees.  The  management is  awaiting the
      completion of the construction at  the  facility before updating
      these manuals.

•     Training at the facility emphasizes  chemical dangers and addresses
      these dangers in relation to operations rather than to  emergency
      response.  Training of employees in  1990 covered safety and
      handling of sulfuric acid, chlorine, and caustic soda.   Employees
      were also acquainted with the  new  chlorine system.  The Reverse
      Osmosis Water Plant management stated  that a seminar on chlorine
      handling is held for employees every six months.  A mandatory
      workshop on the application of a chlorine tank repair kit type B
      is presented by the supplier on an annual basis.  All employees
      must attend a monthly safety meeting which include  discussions on
      various safety topics, such as chemical hazards, employee safety
      precautions, etc.  Also, all operators must review  and  practice
      using the safety air packs every three months.   Once a  year, an
      eight hour Occupational Safety and Health Administration training
      is required for all of plant employees.

•     Maintenance is performed during the day shift,  when possible, to
      reduce the electrical usage during peak hours.

•     Formal hazards evaluation does not exist at the facility.
      However, the director of Lee County Emergency Management Agency
      has developed a hazards analysis on chlorine and sulfuric acid for
      the facility using computer modeling.  The likelihood of a release
      occurring was deemed low.  In  a worst case scenario projection,  a
      chlorine release might create health effects out to three and one-
      tenth miles downwind from the  facility.

••     Both sodium hydroxide and sulfuric acid tanks have their own
      concrete diking systems filled with limestone and similar
      containment capacities as the  Dow  Section.   However, their
      separate rooms do not have diking.   Each day tank room has its  own
      individual drain system which  allows the chemical to flow to an
      area where it can be neutralized.

Accident Release Incident Investigation

•     Investigation of the February  1989 release showed that  the
      chlorine sensor was not working properly.   There is  some
      discrepancy concerning the amount  of-chlorine released;  however.
      as much as 3,000 pounds of liquid chlorine was  released  as gaseous
      chlorine before the alarm from the pressure sensor sounded.

                                183

-------
•     As a result of the February  1989  release, weather  stripping  was
      replaced, three additional breathing apparatus were  added, the  air
      conditioning system was moved  to  the roof,  two chlorine  alarms
      were installed with emergency  strobe lights, and leak detectors
      were replaced with five new  sensing devices.  Also,  the
      chlorination system was changed over to an  all-vacuum system
      engineered to minimize the risk of further  releases.  As a result,
      the Dow Section and the Hydranautics Section have  their  own
      chlorination system.

Facility Emergency Preparedness and  Planning Activities

•     The Reverse Osmosis Facility has  no single  written emergency
      response plan.  Instead, they  rely on a number of  incomplete and
      fragmented documents.  The highest ranking  employee  is responsible
      for appropriate action.  The plant also has detailed instructions
      for dealing with chlorine emergencies and an emergency telephone
      list comprised of home telephone  numbers for all facility
      personnel plus numbers for the police, the  local hospitals,  and
      the schools.  The facility also has 800 telephone numbers for the
      Harcross Chemical Company which may be called in case of a
      chlorine emergency.

•     .There has been no emergency response exercise to simulate
      emergency response procedures.

•     It appeared that little consideration has been given toward  the
      safety of visitors and contractor employees.

•     Evacuation routes based on wind direction have been outlined
      should a release of chlorine occur and evacuation become
      necessary.  The Cape Coral Fire Department would be the  initial
      responding agency to a chemical release.   The Lee County Emergency
      Management Director would coordinate county agencies and private
      resource.* as needed to support the City of Cape Coral response.

•     Emergency equipment provisions include three breathing apparatus
      with a 30 minute supply of oxygen, two apparatus with 15 minutes
      of oxygen, two acid suits, ten two-piece chemical resistant suits,
      face shields, gloves, boots and goggles.   Personal  protective
      equipment is located at well-labeled points within  the facility,
      including the control room.  Safety showers are located  in each
      chemical room and at each chemical storage tank site.  Class  A
      personal protection must be used  in the event of a  release.

•     Equipment located in areas adjacent to the sulfuric acid and
      sodium hydroxide bulk storage  tanks is not adequately marked.

•     There is no single person on-site in charge of the  facility for
      emergency purposes; however,  the plant superintendent would have
      the most responsibility in the case of a release,  followed by the
      chief operator and the control room operator on duty.  In the

                                184

-------
      event of an emergency, it is the on-shift duty operator's
      responsibility to notify facility management, who  in turn will
      notify the risk safety manager.

•     The Division of Water Supply for the City of Cape  Coral, of which
      Reverse Osmosis is a part, has a policy regarding  the succession
      of authority within the division during emergencies.  In this
      policy, the director delegates authority and places responsibility
      for appropriate action on the highest ranking employee at the site
      of a water supply emergency.

•     The facility uses an in-plant paging system which  may be activated
      from any of the plant telephones.  Internal alarms exist, but
      there are no alarms located on the outside of the  building.

Community and Facility Emergency Response Planning Activities

•     Facility management has invited the Cape Coral Fire Department to
      visit the plant and become familiar with chemicals present and
      their use at the facility.

•     A release of sulfuric acid at the facility was projected as most
      likely to remain within the plant boundary.

Public Alert and Notification Procedures

•     A two-way hand-held radio to the fire department's frequency is
      kept in the control room.  This radio is to  be used in the event
      of an emergency situation.

•     The Cape Coral Fire Department hazardous materials officer noted
      that should evacuation be desired it would be commenced by rescue
      squads and Cape Coral Police going street to street with
      loudspeakers.

•     Plans are in place to initiate emergency broadcasts through a  24-
      hour Fort Myers, Florida radio station.   Similar arrangements  have
      been made for furnishing emergency information to local radio  and
      television stations through FAX transmissions.

•     The emergency broadcast system in Lee County is  tested  weekly.

•     There has been substantial interaction between the facility and
      the media due to the February 1989 chlorine  accident.
                                185

-------
Recommendations:

Facility Background Information

•     Security  should be tightened by  screening  of  traffic  through  the
      front gate.  The facility  should build a second  entrance  into the
      property  from 20th Avenue.

•     The proximity of the  two schools is of concern to  the  Cape  Coral
      Fire Department and necessitates implementation  of reliable
      chemical  process safety schemes.

Process Information

•     The Reverse Osmosis facility should use an unloading system with
      similar safety features as found in the Dow section.   Bulk  storage
      tanks should have dikes, separate fittings, manually controlled
      transfer  pumps, and should be located next to each other  on
      facility  grounds.

•     A monitoring system for emissions of hydrogen sulfide  gas should
      be implemented.

Chemical Accident Prevention

•     The updates of the safety and operating procedures  should be
      completed.

•     A training program in hazardous  materials for facility employees
      should be implemented in conjunction with the fire  department's
      hazardous materials section.

•     Either the fittings on the outside sulfuric acid or the sodium
      hydroxide storage tanks should be changed to prevent accidental
      mixing of chemicals.  An overflow prevention device should be
      installed in the Hydranautics day storage tanks.

•     Preventative methods  should be taken to control the mixing of
      sulfuric  acid and sodium hydroxide in common trench shared by both
      rooms.

Facility Emergency Preparedness and Planning Activities

•     Current emergency documents should be revised into a more complete
      written emergency plan.

•     Security  should be tightened by  screening traffic at the front
      gate of the facility  to help promote the safety of visitors and
      contractor employees.

•     The facility should consider conducting table-top exercises that
      include plant personnel, local fire and police departments,

                                186

-------
            emergency medical services, and the County Emergency Management
            Agency.

      •     Better marking on required safety equipment should be used -in the
            areas adjacent to the sulfuric acid and sodium hydroxide bulk
            storage tanks.

      •     Reverse Osmosis should designate an employee for emergency
            purposes during second and third shifts.

      •     Visual and/or audible exterior chlorine alarms should be
            installed.

      Community and Facility Emergency Response and Planning Activities

      •     Reverse Osmosis should work with the Hazardous Materials Section
            of Cape Coral Fire Department in providing the recommended
            emergency entrance on the front side of the property and in
            developing hazardous materials training for personnel.

      •     Reverse Osmosis should conduct table-top exercises which would
            include plant personnel,  the local fire department,  the local
            police department, emergency medical services,  and the  County
            Emergency Management Agency.

      Public Alert and Notification Procedures

      •     The facility should work with the Cape Coral Fire Department to
            ensure that hazardous chemical releases are reported in a manner
            that meets the needs of the fire department and the  community.
Audit Team Member Composition

Name and Title                Carin DeBenedictis
Affiliation                   EPA Region 4
Area of Responsibility        Team Leader
Expertise                     N/A

Name and Title                Connie Landers
Affiliation                   EPA Region 4  •
Area of Responsibility        N/A
Expertise                     N/A

Name and Title                Lew Nagler
Affiliation                   EPA Region 4
Area of Responsibility        N/A
Expertise        -             N/A
                                      187

-------
Name and Tide                Thomas Yabate
Affiliation                   AARP
Area of Responsibility        N/A
Expertise                     N/A

Name and Title                Darrell Thomas
Affiliation                   TAT, EPA Region 4
Area of Responsibility        N/A
Expertise                     NT/A

Name and Title                Cl-uck Bruner
Affiliation                   AARP
Area of Responsibility        N/A
Expertise                     N/A

Name and Title                Gaines Boone
Affiliation                   Contractor, EPA Region 4
Area of Responsibility        N/A
Expertise                     N/A

Name and Title                Dennis Wile
Affiliation                   AARP
Area of Responsibility        N/A
Expertise                     N/A
Post-Audit Follow-Up Activities:

      By the Facility:

      By the Regional Office:

      The Region will conduct a follow-up within six to nine months following
      the audit date to observe the progress in implementing recommendations.

      By State and Local Authorities:


Regional Contact:             Pat Steed, Winston Smith
                                      188

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Cape Coral Canal Pumping Stations
Facility Location:
Cape Coral, Florida, Region 4
Date(s) Audit Conducted:
February 25-26, 1991
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
N/A
Pumping Station 5 at 20th Street and Santa
Barbara Boulevard in Cape Coral, FL,
approximately 120 miles west of Miami.
The facility will supply lawn irrigation
water from a secondary water distribution
system.
Cape Coral High School is approximately
one quarter of a mile south of the pumping
station.
Reason for Facility Selection:
      ARIP Reports:
The facility was chosen because of
citizens' concerns about chlorine storage
and use at the facility.

None
Focus of Audit:
      Hazardous Substances(s)
      Examined:                     Chlorine
                                      189

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      Total storage within the building can reach eight one-ton  chlorine
      containers.

•     Shipping/Receiving

      The chlorine will be shipped from its source by truck  to the City
      of Cape Coral pumping stations in one-ton containers.  Shipments
      will be as consumption requires but are expected to be
      approximately monthly.

•     Material Transfer

      The containers are moved into position using a two-ton, overhead,
      monorail mounted, electric hoist equipped with standard lifting
      beam.  The containers are positioned on roller blocks equipped
      with load cells.  Each load cell arrangement will weigh two
      containers at a time.

Process Area(s)

The city, to conserve this drinking water obtained from the supply
aquifer, is installing a parallel system of pipelines for lawn
irrigation water.  This irrigation water is to be a blend of freshwater
from the canals and recovered wastewater.   This water will be
chlorinated at pumping stations as a biological treatment.

This station is one of two designed by Boyle Engineering Corporation
that are under construction and estimated to be about 80% complete.   The
Boyle design incorporates the chlorination principles used by the
Reverse Osmosis system.  This system is an all vacuum ejection system
designed to minimize the risk of an accidental release.

The chlorination ejection system contains valves installed directly on
each container that open only under negative downstream pressure
conditions.

The vacuum necessary for transferring the chlorine is generated by
ejectors powered by water pressure (150 psig)  developed by booster
pumps.  The ejector water is a sidestream withdrawn from and
reintroduced into the main irrigation water stream after chlorination.

The chlorine containers are to be operated in pairs.   At any time, two
will be manifolded together "on-line" and two will be ready for
automatic switchover.
                                190

-------
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     The Cape Coral,  Florida area  is  under  the  threat  of  hurricanes
            that develop in  the  southeastern areas  of  the  Atlantic  and those
            that develop in  the  Gulf of Mexico  during  the  hurricane season
            beginning in September.

      •     Santa Barbara Boulevard provides easy  access .to the  pumping
            station.

      •     Vulnerable zones include the  Cape Coral High School  and the nearby
            residential areas, as well as  Santa Barbara Boulevard and  20th
            Street due to their  heavy traffic flow.  There are about 30
            residents across the canal, about 500  feet to  the southwest.

      Chemical Hazards

      •     At any given time, the pumping station may have up to eight tons
            of liquid chlorine stored in  one-ton containers.  Liquid chlorine
            can cause irritation and burns to the  skin and eyes, and,  if
            released to the  atmosphere, will rapidly vaporize and remain at
            floor level.  It is  highly reactive.

      Process Information

      •     The facility has installed two independent chlorinator ejector
            systems.  One system is required for operations with the second
            being a backup.  Switchover from one system to the other is done
            manually.

      •     Two booster pumps are provided,  one active and the second a
            standby.  Switchover from one  to the other is automatic if  a
            problem with the "active" pump is sensed.  Residual chlorine in
            the water is to  be 1.0 ppm, consistent with state regulations for
            effluent water used  for irrigation.

      •     The chlorine containers, chlorinators,  and related equipment are
            located in a room separate from  the irrigation pumps, electrical
            switchgear, other electronics, and, where supplied,  the stand-by
            electrical generator.

      •     The safety of the chlorine ejection system comes from pressure
            actuated valves  installed directly on each container.  These
            valves open only under negative  downstream pressure conditions.
            In the event of  system failure,  (i.e.,  loss of vacuum due to a
            pump shutdown, pipe  leak, etc.)  the valves will immediately close.
                                      191

-------
•     The chlorinator equipment piping is schedule 80  PVC.  All
      equipment and piping are color coded.

•     The pumping stations are to be unmanned during normal operations.
      However,  alarms will be sent by radio signal to  the Everest
      Parkway Water Reclamation Plant by wire (a telephone autodialer),
      to the fire department, and other selected locations for  immediate
      response.

•     Besides the radio and telephone signals, the chlorine alarm
      triggers a small wa/ning light at the personnel  entrance door  into
      the chlorine storage area.   This must be "acknowledged" (e.g., an
      operator must physically shut off the alarm) before entering to
      reset the alarm.  In addition, the chlorine alarm will switch  the
      two-speed ventilation fan to high speed to help  exhaust any
      chlorine from the area.  .\s designed, the exhaust will discharge
      from the top of the building to the atmosphere.

•     Two chlorine detectors are  mounted in the chlorine storage-
      chlorinator area on the interior wall near the chlorinators.   The
      detectors are about five feet above the floor with the air
      sampling ports located approximately 1 1/2 inches above the floor.
      The alarm will respond to a 1 ppm chlorine concentration.   Once
      actuated,  the alarm must be "acknowledged" before it can be reset.

Chemical Accident Prevention

•     Management recognizes that  alternate treatment chemicals may be
      used.  Consideration is being given to using sodium hypochlorite
      (bleach).   This reportedly  would be more expensive and require
      additional deliveries of raw materials.

•     Management of the pumping stations will be shared by the Reverse
      Osmosis Water Treatment Plant Supervision and the Cape  Coral  Fire
      Department Hazardous Materials Coordinator.   The  water  treatment
      plant will provide daily monitoring,  chlorine tank switchover and
      inventory control, equipment calibration,  and maintenance
      services.

•     The Fire Department will provide all emergency response  and
      routine monitoring.  All pumping stations  will be inspected at
      lease once per day.

•     At the time of the audit, written operating instructions,  safety
      manuals, and emergency response plans were incomplete.   Management
      expects to have all appropriate documents  complete before  startup
      commences.  To the extent possible,  these  will be adapted  from
      current procedures and plans used at the desalination  facility and
      other facilities owned and  operated by the City of Cape  Coral.

•     The city conducted a model  of an airborne  release of extremely
      hazardous substances.  It is limited to  vapor dispersion modeling

                               192

-------
      used to predict the extent, duration, and concentration  of  a  plume
      or cloud of released toxic gas or aerosol.  They considered a
      "worst case" scenario release which consisted of an  instantaneous
      release (10 minutes) of chlorine from a 2000 pound cylinder.

•     The Reverse Osmosis facility superintendent has the  responsibility
      for equipment maintenance and the handling of the changing  out  of
      the chlorine tanks.  The Cape Coral Utilities Department will
      operate the balance of the system and provide a daily  inspection
      of each site.

•     The Reverse Osmosis facility's licensed operators receive training
      emphasizing chemical dangers associated with the changing of  the
      chlorine tanks at both the Reverse Osmosis facility  and the
      pumping stations.

Accidental Release Incident Investigation

•     The City of Cape Coral is presently developing the necessary
      written procedures for incident investigation.

Facility Emergency Preparedness and Planning Activities

•     Battery backup will be provided for the telephone autodialer.   No
      alternate power source is provided for the radio.   However,  the
      radio equipment is part of a network and is continually "polled."
      Any "non-reporting" wil'l be treated as an alarm.

•     There is a written policy on succession of authority at the
      Reverse Osmosis Plant where the highest ranking employee at  the
      site acts appropriately for any water supply emergency.  Detailed
      instructions for dealing with chlorine at the plant also would
      apply at all the pumping stations for the secondary system.

•     Management plans to have two exercises a year with one of these
      alternating between the Reverse Osmosis plant and the pumping
      stations and the other a county-wide chlorine release simulation.

•     In an emergency, the main access to Pumping Station Number  5 would
      be by Santa Barbara Blvd. and 20th Street.   EMS  teams would  use
      these same streets to reach Cape Coral Hospital  and Medical  Center
      three miles to the northeast on Del Pardo Blvd.   Helicopters could
      use the space around the pumping station for landings and takeoffs
      for evacuation.

•     The canal system around City of Cape Coral  is extensive with only
      a few bridges, making evacuation difficult  in an  emergency.
      Decisions for using particular evacuation routes  would rely
      heavily on the available 15-minute weather  updates  at the  time of
      the emergency.  Arrangements for obtaining  these  on a timely basis
      have been made with the emergency center for Lee  County.
                                193

-------
•     The Cape Co-ral Hospital and Medical  Center  does  not have  a
      decontamination room to use in a chemical emergency.   Information.
      on which hospitals in EPA Region 4 have  such  facilities available.
      was provided to the Hazardous Materials  Coordinator.

•     Two 30-minute SCBAs are to be located  in the  pump/equipment  room
      away from the chlorination room.  In addition, one chlorine
      container, will be located in this same  area.  Safety  showers  are
      planned for outside the building on  the  side  closest to the
      chlorine storage and processing area.

•     In an emergency, TV stations will serve  as  backup information
      sources by bringing mobile units to  the  site.

•     All emergency response and emergency management procedures are the
      responsibility of the Hazardous Materials Coordinator.  He/She (or
      appointed alternate) would perform as  the incident commander in an
      emergency.  If an emergency should occur while the Reverse Osmosis
      Plant operators are on-site, the operators  remain under the
      supervision of the Reverse Osmosis superintendent only until the
      Hazardous Materials team arrives.  The Hazardous Materials
      Coordinator is presently preparing an  emergency response plan.

•     Two thirds of the members of the Cape  Coral HAZMAT'Unit have
      received training for dealing with a chlorine emergency.  All
      first responders will receive this training eventually for the
      city's fire services.

•     Management of the city of Cape Coral believes it has a
      sufficiently trained staff and enough heavy equipment to handle
      the necessary actions following a release from any of the
      secondary systems.

Community and Facility Emergency Response  Planning Activities

•     The Cape Coral Fire Department will  initiate emergency response
      when an alarm occurs from the chlorine detectors, and from fire,
      intrusion or breakdown alarms at the pumping stations.   They will
      provide primary response and the Hazardous Materials Coordinator
      will act as incident commander for those chemical releases of
      consequence.

•     Present plans are for the Cape Coral High School, located one
      quarter of a mile to the south of the plant, to "shelter-in-place"
      the students and staff, shutting down all air handling equipment
      and closing open doors, windows,  etc.  Sealing openings around
      doors and windows would be done on orders from the incident
      commander.

•     The Director of the Lee County Emergency Management  Agency stated
      they have provisions for county response in their county emergency
      response plan.  His agency had previously prepared a hazard

                                194

-------
      analysis for the Reverse Osmosis Facility for chlorine using
      computer modeling.  From this analysis, he believes a serious
      incident from a chlorine release from the two secondary water
      treatment facilities about to go on line seems low.

Public Alert and Notification Procedures

•     Evacuation plans will call for rescue units and the Cape Coral
      Police Department Units, using loudspeakers, to alert residents by
      going street to street and knocking on doors.  Emergency medical
      service units will standby to evacuate those handicapped or
      bedridden .if the need arises.

•     An emergency telephone list for all facility personnel plus police
      and hospital exists.  In addition, employees have the Harcross
      Chemical Company's 800 number for chlorine emergency consultation,
      if needed.

•     There are no audible or visual alarms on the exterior of the
      building other than the small light at the entrance.  The
      Hazardous Materials Coordinator and city management feel that
      other exterior alarms for public notification are unnecessary.

•     Plans and procedures exist to initiate emergency broadcasts on the
      24-hour Fort Myers radio station.   Emergency information also
      would be available from local radio and television stations.

•     The emergency broadcast system is  tested weekly,  and the
      facility's alert system is monitored constantly from the 911
      network.
Recommendations:

Facility Background Information

•     If practical, Utility Management should consider locating future
      pumping stations in less sensitive population areas.

Process Information

•     Management should continue to keep current on chlorine sensing and
      detection equipment and keep equipment and practices  at current
      state-of-the-art.

Chemical Accident Prevention

•     Utility management should continue to evaluate the use of
      alternate chemicals (i.e., sodium hypochlorite solution,  etc.)
      that may be safer than chlorine.
                                195

-------
      •     Management should insure that written operating instructions,
            safety manuals, and emergency response plans are all in place
            before operations of the pumping stations start.

      •     Air from the "chlorine room" is exhausted from the top of the
            building to the atmosphere.  Alternate discharge techniques should
            be investigated.

      Accidental Release Incident Investigation

      •     As part of the written procedures, management should insure that
            an adequate incident investigation procedure is in place and that
            recommendations are evaluated and implemented where appropriate.

      Public Alert and Notification Procedures

      •     Management should reconsider their decision not to install
            exterior audible or highly visible alarms,  including safeguards to
            prevent "false" alarms.
Audit Team Member Composition:

Name and Title
Affiliation
Area of Responsibility
Expertise.

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Pat Steed
U.S. EPA Region 4
Team Leader
N/A

Thomas Yatabe
AARP,  U.S. EPA Region 4
N/A
N/A

Dennis Wile
AARP,  U.S. EPA Region 4
N/A
N/A

Charles Bruner
AARP,  U.S. EPA Region 4
N/A
N/A
                                      196

-------
Follow-up Activities:




      By the facility:




      By the Regional office:




      By State and local authorities:






Regional Contact:             Pat Steed
                                     197

-------
198

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Columbia Organic Chemical Company
Facility Location:
Camden, Kershaw County, South Carolina,
Region 4
Date(s) Audit Conducted:
March 27, 1991
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced or distributed:

      Proximity to
      sensitive populations:
2812 -- alkalies and chlorine

Cassatt community of eastern Kershaw
Councy located about 45 miles northwest of
Columbia, South Carolina

Monochloroiodine is the only chemical
produced on a regular basis.

Four homes are within a quarter mile of
the facility and Midway Elementary School
is located approximately three miles away
from the facility.
Reason for Facility Selection:
      ARIP Reports:
The audit was conducted at the request of
the South Carolina Department of Health
and Environmental Control.

None
Focus of Audit:
      Hazardous Substance(s)
      Examined:
Monochloroiodine
Sodium cyanide
Chlorine
Phosphorus Pentoxide
                                      199

-------
      Physical Area(s)  Examined
      at  the Facility:

      Storage and Handling

      •      Storage systems

            Columbia Organic chemical Company has an inventory of 4,000
            chemicals which are considered hazardous in the presence of a
            fire.  The majority of the chemicals are stored in the 10,000
            square foot warehovse, which is built of concrete walls and a
            metal roof.  Most solvents present in drum quantities are stored
            outside the warehouse under the shed, on the pad.   Some of' the
            heat sensitive solvents are stored inside the warehouse with the
            shelves of bottled chemicals.

            Acetone and methanol are kept on site on concrete pads under a
            shed.  Sodium cyanide is stored in fiber drums which resc in the
            raw material and finished goods warehouse.   Chlorine cylinders are
            stored in 150-pound cylinders.   Phosphorus pentoxide is stored in
            five pounds glass-lined cans in the oxidizer room.  Chemical
            storage is kept to a minimum by avoiding excess shipments of
            chemicals.

      •      Shipping/Receiving

            Sodium cyanide is purchased and received in powder form and
            chlorine is usually delivered to the site in two 150-pound
            cylinders.

      •      Material Transfer

            All materials are transferred manually except for  gaseous
            substances.  Vapor from the chlorine cylinder is fed into the
            reactor using a pressure regulator.

Process  Area(s)

As orders are received, raw materials are purchased, production is scheduled
and incorporated in the production worker's schedule.  There are four chemical
production workers, each with his own laboratory.   Processing takes  place  in
what is  essentially laboratory glassware which ranges in size  from two  liters
to twenty-two liters.

Chlorine, hydrochloric acid and crystalline iodine are  used in the production
of monochloroiodine.  Chlorine is fed as vapor from 150 pound  cylinders.
Hydrochloric acid is charged to a 150-gallon reaction vessel,  then iodine
crystals and chlorine are added appropriately.  Other chemical processes were
not investigated.
                                      200

-------
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     COCC merged with Wateree Chemical Company  in 1982  and  continued
            Wateree's waste disposal system, discharging hazardous  materials
            to an on-site septic tank.

      •     A section of perimeter security fencing near the drum  storage  area
            can be easily penetrated.

      Chemical Hazards

      •     Chlorineiodide is the most hazardous material in production at  the
            facility.  Tt is a fire hazard and produces irritating  or
            poisonous gas when burned.

      •     Columbia Organic's management is aware of all hazards associated
            with chemicals used, stored, and produced at the facility.
            Material Safety Data Sheets for all chemicals in uie are available
            to operating personnel but not to workers in the processing rooms
            and the warehouse.

      •     When a chemical is first used, the General Manager reviews
            particular hazards with personnel working with the substance.

      •     In abidance with SARA Title III, COCC reported quantities of six'
            hazardous chemicals to the Governor's Office,  the Kersh?w County
            Emergency Management Director, and the Cassatt Fire Department in
            October of 1987.  In January 1991,  the plant notified public
            authorities of three additional hazardous chemicals at the
            facility.

      •     The facility has not reported toxic chemicals  sufficiently as
            required under the Toxic Substances Control Act (TSCA).

      •     Using CAMEO II modeling,  the audit team determined that any nearby
            residents could be at risk if the wind patterns at the  time of a
            chlorine release carried the plume to their area.   This credible
            worst case scenario is based on specific situations.

      •     Under a court order, an attempt was made to absorb odors in
            activated carbon before they were blown toward a nearby
            residential site.   A further attempt, will be to design  an absorber
            by pulling inside air through activated carbon just before it  is
            discharged by the two blowers.  Although odors  were strong,  the
            concentration of organic vapors was below the  level of  detection
            by the -Organic Vapor Analyzer (OVA) brought to  the site.
                                      201

-------
Process Information

•     Many chemicals are stored and  identified by  fading numbers  on  old
      labels which are difficult to  interpret.

•     Chlorine cylinders contained chemicals other than chlorine  and had
      no feature to prevent them from falling over.

•     The manager supplies a recipe  book to the workers which  is  used  to
      produce any specific product.  Therefore, according to  the manager,
      by naming a product, in his operating log, he is also specifying
      everything from chemicals to be used to amounts to be  made. There
      are no other processing records of chemical quantities or product
      yields.

•     The septic tank used to store  hazardous wastes showed  significant
      levels of mercury.  Under court order,  Columbia Organic has
      removed and drummed the septic tank waste.  Drums of hazardous
      wastes were stored at the facility in excess of the ninety  day
      storage limit because Columbia Organic could not find  a waste
      disposal company willing to take the waste.

•     The 4,000 miscellaneous chemicals are often separated  and kepc in
      five different storage areas which contain water reactive
      chemicals, aqueous acidic chemicals,  aqueous basic chemicals,
      oxidizing agents and reducing  agents.  They are stored either for
      resale which can include repackaging or in anticipation of custom
      made orders.  Generally, they  are stored in amounts less than 5
      pounds.

•     No monitoring of emissions to  air is conducted at the  facility.

Chemical Accident Prevention

•     Facility personnel have not developed a comprehensive health or
      safety manual at the facility.   There are no standard operating
      procedures or written production records at the facility.

•     The four chemical production workers specialize in different
      chemical processes and have developed expertise in their assigned
      area.  This expertise has reduced the potential for hazards
      involved in the production process.

•     There  is no documented training manual,  all training occurs on  the
      job.

•     A designated plant employee performs a monthly inspection checking
      for cracks in glassware and deficiencies in vacuum pumps;  however,
      no maintenance manual or procedures exist.

•     The general manager or his assistant performs a monthly safety
      inspection which involves searching for leaking containers,

                                202

-------
      testing the vacuum in the lab hoods, and  inspecting  safety
      showers, eye wash stations and fire fighting  equipment.

•     There are no firewalls in the facility  to mitigate' the  fire
      hazard.  The facility water supply comes  from small  community
      lines which are not equipped to handle  the  supply  needed  for any
      accident of great magnitude.

•     The outside eye wash and shower stations  did  not have a water
      supply.  The manager explained the water  supply is shut off until
      someone enters the area for work and that this is  done  to prevent
      freezing in the winter months.

Accident Release Incident Investigation

•     In 1988, a lab worker was severely injured  from a  chemical
      explosion.  An excess amount of hydrogen was  generated  as the
      worker was using acid to clean a container  which has accumulated
      zinc.

•     After the 1988 incident investigation, management  took
      preventative measures and changed the process so that no residual
      zinc would be produced in the reaction.

Facility Emergency Preparedness and Planning Activities

•     A written emergency response plan has been  filed with the South
      Carolina Department of Health and Environment, the Camden Police
      Department, the Cassatt Fire Department, the Kershaw County
      Hospital, and the Division of Public Safety Programs of the
      Governor's Office.  The- plan deals with emergencies that may occur
      at the facility but has not been recently updated.

•     The emergency response plan has never been  tested  in an exercise
      simulating an accident.

•     The only evacuation route is Mt.  Zion Road.

•     Emergency equipment consists of basic protective clothing,  one
      self-contained breathing apparatus,  several fire extinguishers  in
      poor condition, eye wash and shower stations.   Production workers
      rarely wear protective clothing;  however,  gloves are occasionally
      worn and face shields and rubber aprons are used when handling
      corrosives.  The facility does not have a fire brigade or a
      hazardous materials team.

•     The facility manager, who lives on site, assumes responsibility
      during an emergency response.   Two trained workers  are left in
      charge during his absence.

•     The facility has no internal communication network. •
                                203

-------
Community and Facility Emergency Response Planning Activities

•     Kershaw County has developed a plan for hazardous materials
      response which would notify Police and Fire Departments  in Kershaw
      County should a release occur.  Telephone numbers for  facilitv
      emergency response personnel have been filed with local  and  state
      emergency response agencies.

•     The County plans immediate evacuation of those within  three
      thousand feet of the facility, possible evacuation of  those  within
      a five mile radius including the Midway Elementary School three
      miles away.

Public Alert and Notification Procedures

•     The facility has an 118 decibel air horn to warn the surrounding
      population in the event of an emergency.

•     Kershaw County plans to use the Camden radio station's emergency
      broadcast system to notify the public of an emergency  release.

•     Law enforcement and rescue squad personnel would use loudspeakers
      to notify the public should an evacuation be necessary.

•     There is no historical record of notification procedures.

•     The plant manager would act as spokesperson in the event of an
      emergency at Columbia Organic.
Recommendations

Facility Background Information

•     Security measures at the drum storage area and at the rear of the
      property should be reviewed.

Chemical Hazards

•     Copies of the Material Safety Data Sheets should be distributed to
      the facility processing rooms and warehouse.   Any other
      documentation on hazards should be made available to personnel.

•     In accordance with the Toxic Substances Control Act, Columbia
      Organic should document and report even small quantities of toxic
      chemicals.

Process Information

•     The chemicals which are stored and identified by fading numbers  on
      old labels should be made legible by replacing those labels with
      clear  identification of container contents.

                                204

-------
•     All storage cylinders that are standing upright and  that have
      their caps removed should be chained or otherwise prevented  from
      tipping.

•     The weight of each chemical ingredient and each product yield
      should be recorded in a log book.

•     Columbia Organic should immediately process the drums of hazardous
      waste which have been stored for longer than the permitted ninety
      days, especially the radioactive thorium oxide stored in the
      warehouse.

•     No drums should be stored in the warehouse with the 4,000
      miscellaneous chemicals.

Chemical Accident Prevention

•     A health and safety manual should be created and distributed to
      personnel as they are hired.

•     A standard operating procedures document for all operations should
      be developed.

•     A training program should be implemented to inform personnel of
      the toxic effects associated with each chemical.   CPR and first
      aid courses should also be considered.

•     Fire protection professionals should evaluate the facility and
      recommend a fire prevention system.  In addition,  firewalls should
      be installed to limit the magnitude of any fire which might occur.

•     Water lines to the safety showers and eye wash stations  should be
      properly maintained so that water is available to these  areas at
      all times.

Facility Emergency Preparedness and Planning Activities

•     Columbia Organic's emergency response plan should be  revised
      immediately. They should add a list of the EHSs and CERCLA
      chemicals to their emergency plan and attend to fire  hazards in
      the warehouse.

•     Drills simulating emergency situations  should be  performed
      annually.  Drills simulating real fires should be conducted under
      the supervision of the local fire department.

•     Personnel protection should be reviewed;  a second self-contained
      breathing apparatus and steel toed boots  should be  provided to
      ensure safety.   Fire extinguishers should be  enclosed in some kind
      of container in order to keep them in good working  condition.   All
      safety equipment should be properly maintained to ensure operation
      during an emergency situation.   Local fire officials  and Kershaw

                                205

-------
            County emergency management personnel should visit the facility
            and familiarize themselves with chemical operations and layout.

      •      Emergency telephone numbers and NRC numbers should be added to the
            emergency plan.  Response personnel should carry pagers at all
            times.

      •      The facility should install an emergency exit at the rear of the
            property.

      Community and Facility Er^rgency Response Planning Activities

      •      Columbia Organic should revise its methods for contacting facility
            emergency coordinators.  The facility should coordinate with the
            county emergency management director in revising their procedures.

      •      Columbia Organic should coordinate with the director of the
            Kershaw County Emergency Management Director to devise a plan for
            emergency alerting, warning, and evacuating procedures.

      Public Alert and Notification Procedures

      •      The facility should document the notifications made as a result of
            accidental releases.
Audit Team Member Competition:

Name and Title                Charlie Cartwright,  Team Leader
Affiliation                   US EPA Region 4
Area of Responsibility        N/A
Expertise                     N/A

Name and Title                Gaines Boone
Affiliation                   US EPA Region 4
Area of Responsibility        N/A
Expertise                     N/A

Name and Title                Lew Nagler
Affiliation                   US EPA Region 4
Area of Responsibility        N/A
Expertise                     N/A

Name and Title                John Deutsch
Affiliation                   AARP
Area of Responsibility        N/A
Expertise                     N/A

Name and Title                Ralph McKeen
Affiliation                   Technical Assistance Team
Area of Responsibility    .    N/A
Expertise                     N/A

                                      206

-------
Post-Audit Follow-Up Activities:




      By the Facility:




      By the Regional Office:




      By State and Local Authorities:






Regional Contact:             Pat Steed
                                     207

-------
208

-------
                         CHEMICAL  SAFETY  AUDIT  PROFILE
.Facility  Name:
General Electric Plastics  (GEP)
Facility  Location:
Mt. Vernon, Indiana, Region 5
Date(s) Audit  Conducted:
May 14-18, 1990
 Description  of  Facility:

       SIC  Codes (s)


       Location:

       Products  Manufactured,
       Produced  or Distributed:
       Proximity to
       Sensitive Populations:
2821 -- plastics materials, synthetic
resins, and non-vulcanizable elastomers

Mt.  Vernon, Indiana, on the Ohio River.

Resins such as Lexan, Ultem, and Supec,
and other plastics such as Lcmod and
Xenoy.

Within a five-mile radius
there are 12 schools, seven nursing homes,
and two medical facilities.
 Reason  for  Facility Selection:
A September 3, 1988,  release of toluene.
       ARIP Questionnaire(s):
8/19/88, 1/18/89,  4/19/89,  9/6/89,
9/25/89, and 10/19/89 releases of
Methylene Chloride
9/2/88 release of Toluene
9/21/88, 10/7/89,  and 3/31/89 release of
Nitrogen Dioxide
 Focus of Audit:
       Hazardous Substance(s)
       Examined:
Toluene
Bis-phenol A
Phosgene
Methanal
Phenol
Acetone
Cumene hydroperoxide
                                      209

-------
      Physical  Area(s)  Examined
      at  the  Facility:

      Storage and Handling

      •      Storage  Systems

      Toluene is  stored in two above-ground tanks at the facility.  The tanks
      are in a  tank  area with five other tanks containing monomethyl amine,
      ortho-dichlorobenzene,  caustic,  phthalic anhydride, and a material
      General Electric  Plastics (GEP)  calls "concentrated waste."   Tanks are
      separated by ten  to twenty feet.

      A  second  tank  farm area contains  tanks of acetone, phenol, methyl
      isobutyl  ketone,  and sulfuric acid.   Tanks are labeled with material
      contents  and had  the three-color  National Fire Protection Association
      (NFPA)  hazard  warning signs.


      •      Shipping/Receiving

      Materials are  shipped and received by barge,  truck, and railcar by the
      Ohio River, Highways 62 and 29,  and the CSX railroad,  respectively.   All
      rail and  truck shipping is done  during the day shift.   Barges are
      unloaded  upon  arrival.   GEP has  trained material handlers for loading
      and unloading.  For barge loading and unloading,  GEP follows the U.S.
      Coast Guard requirements for 48 hours of training for  operator
      qualification.  For truck and rail unloading,  100 hours of training is
      required.  Until  a new material handler has the required number of hours
      of training, a qualified material handler will accompany that unloader.

      •      Material Transfer

      Toluene is  received on site by tank truck and  is  pumped into the toluene
      storage tank.   Hook up and transfer is performed by GEP personnel.   The
      toluene is  pumped from the storage tank via piping to  the processing
      area where  it  is  filtered, purified,  and heated before it enters the
      extraction  column.

Process  Area(s)

In the ULTEM process, toluene is used  as an extraction solvent only and does
not enter into the chemical reactions  that  generate  the monomer or the
polymer.   Purified hot  toluene is fed  into  the extraction column at 175 psi.
The extraction column is constructed of stainless steel and  is about 60 feet
tall.  The flow rate is such that there is  a complete turnover of toluene
within the tower  every  36 hours.  The  extraction column is equipped with  a
rupture  disc in a spool piece flanged  to the unit; this is where a toluene
release  occurred  on September 3, 1988.
                                     210

-------
Summary of Audit Findings and Recommendations:

Conclusions:

Chemical Hazards

•     Material Safety Data Sheets  (MSDS) are kept  for  all  chemicals  on-site.
      A master set of MSDSs is kept  in the Safety  and  Fire Building,  and  MSDSs
      applicable to a certain process area are kept within the  appropriate
      process area.  An industrial hygienist on-site is  responsible  for
      updating the MSDS in both the  master set and the individual  sets used  in
      the process areas.

Process Information

•     In high-hazard areas, pipes are double-piped, space  between  pipe walls
      is swept with nitrogen, and the nitrogen is  analyzed for  contaminants.

•     Buildings where 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.  The  piping for
      toluene is color-coded blue.

•     Release mitigation systems include environmental monitoring  systems,
      scrubbers for the chlorine and phosgene systems,  storage  basins, ground
      water testing, and area monitors in chlorine and phosgene process areas.

•     To guard against the formation of nitrated toluene compounds, material
      from the exchange area of the Ultem process  is held  in a  storage tank,
      analyzed for toluene using liquid chromatography methods,  and must show
      no detectable toluene concentration before being pumped to the nitration
      area.

•     The control room has a computer operated console with three sections and
      a back up 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.  If there is a process upset, alarms on the
      console automatically alert the operator for corrective action.

•     The facility has perimeter air monitoring stations and ground water  well
      monitoring stations.  However, no in-place sensors are utilized to
      detect toluene releases at the processing stations.  The September 3,
      1988, release of toluene was first detected when an operator noticed a
      toluene odor while working in  the vicinity of the extraction column.

•     .No in-place sensors are used to detect releases at the processing
      stations.

•     There is no pressure- alarm in  the Ultem tower to  detect equalization in
      pressure between the rupture disc and the relief valve.
                                      211

-------
Chemical Accident Prevention

•     GEP has developed PULSE, an  internal  self-auditing  program enabling the
      facility to assess compliance status  through  a  periodic  self-appraisal
      in the areas of industrial/chemical process safety,  industrial  hygiene.
      occupational medicine, and environmental protection,  including  SARA
      Title III.

•     GEP's audit system and PULSE program  are conducted  on an annual basis.
      The program guides personnel in establishing  plans  and goals by
      supplying information on iegulatory requirements and  GEP-recognized
      practices.  PULSE provides a measuring and reporting  system that allows
     ' management to track progress and plan resources.

•     Standard operating procedure (SOP) manuals are  available,  including the
      Safety and Health Manual, the Staff Duty Officer (SDO) handbook,  the
      Emergency Manual, and the Best Management Practices Manual.  There  are
      no process SOPs for any area except the on-site hazardous  waste
      incinerator.

•     GEP is developing written SOPs for normal run conditions.   GEP  plans to
      write SOPs for emergency operating conditions after the  normal  run  SOPs
      are finished.

•     Checklists exist for loading and unloading barges,  but no  other
      operating checklists are used at the  facility.

•     The facility us.-3 on-the-job training and a mentor system  in its
      training program.  New operations personnel must show proficiency in
      their field before they can work on their own.  GEP indicated that  the
      facility is preparing job descriptions and lesson plans  for each area of
      operation, and have contracted a training consulting firm  to determine
      their initial training needs.

•     The facility uses a department log book procedure for initiating any
      required equipment maintenance.  Operations personnel indicate what
      needs to be done and the first shift  maintenance crew does  the work.

•     The facility does not have a written  preventative maintenance program in
      place.

•     Hazard and Operability Studies (HAZOPS) are conducted to identify
      process hazards and to quantify results of equipment malfunctions.  They
      are performed by outside consultants  or.trained GEP personnel.

•     The facility uses the computerized Systematic Approach for Emergency
      Response  (SAFER) system for  tracking  hazardous substance releases into
      the air, primarily for emergency response.  A meteorological station
      continuously feeds weather conditions into the computer,  which is
      programmed to track chlorine, phosgene, methylene chloride, nitric acid,
      nitrogen oxides, and ammonia.  A backup power supply exists that will
      instantaneously kick in when a power  outage occurs  preventing any loss

                                      212

-------
      of time or data.  This is further backed up by  a  diesel-powered
      generator.

Accidental Release Investigation Procedures

•     Since 1986 the facility has documented  12 spills  or  air  releases over
      the.reportable quantity (RQ) as specified.by  SARA Title  III.
•     GEP's policy on spill reporting is to report  any  spill or  air release of
      any amount to the Environmental Control Center.   The LEPC  and the Posey
      County Health Department are notified of a spill  or  air  release over
      one-half the RQ.

•     There are no written procedures for investigating a  spill  or  incident,
      for sharing information about causes and prevention  of spills  with
      other parts of the facility, or for spill investigation  follow-up.  The
      facility does follow informal procedures for  these activities,  including
      forming an investigation team that determines the  cause  of an accident
      and recommends preventive actions to be taken.

•     No detailed failure analysis was performed in the  investigation of the
      release of toluene on September 3, 1988.

Facility Emergency Preparedness and Planning Activities

•     The Environmental and Safety Manager is responsible  for  an annual review
      and update of all emergency procedures contained  in  the  facility
      Emergency Manual.  It is also this person's responsibility to  generate
      and promulgate all new emergency response procedures for the manual.

•     GEP conducts mock disaster exercises and drills at the facility on a
      quarterly basis.  Each simulated event is designed with  specific goals
      and objectives in mind.

•     The General Emergency Alarm System uses a coded signal to alarm the '
      plant.  The system is tested weekly.

•     The Toxic Gas Alarm System is initiated by a pushbutton alarm box, and
      sounds oscillating sirens and air horns.  The Tornado Alarm System,
      activated from the Central Emergency Control Center,  sounds bells and
      buzzers.

•     Emergency equipment is limited to structural firefighting and/or fires
      involving flammable materials.   Little equipment is available for
      hazardous materials emergencies.

•     The facility emergency team is composed of employees  who  have been
      trained and equipped to respond to site incidents such as fires and
      explosions, unconfined vapor releases, and the rescue of  injured
      persons.

•     The air monitoring network consists of two ambient air stations at the
      north and south ends of the plant, and five toxic stations  .about the

                                      213         •'

-------
      remainder of the site's perimeter.  There  are  eight  ground  water
      monitoring wells on-site and routine analysis  is performed  for  methylene
      chloride, benzene, phenol, and bisphenol-A.

•     The facility's Emergency Manual, Mt. Vernon's  ALERT  system  (a joint
      city/facility emergency management  "all hazards planning" strategy),  and
      the LEPC contingency plan are not integrated.

Community and Facility Emergency Preparedness and Planning Activities

•     GEP holds open houses to educate the public about plant operations.
      Area fire departments exercise quarterly with  the GEP Emergency Team.

Public Alert and Notification Procedures

•     Public notification of releases is  limited to  telephoning "911."


Recommendations:

Process Information

•     The facility should install in-place sensors to detect releases at
      processing stations.

•     GEP should install a pressure alarm to detect  an equalization of
      pressure between the rupture disc and the relief valve in the ULTEM
      tower that was the site of the September 3, 1988, toluene release.

Chemical Accident Prevention

•     GEP should complete a written equipment maintenance SOP as soon as
      feasible.

•     SOPs should be completed for emergency operating conditions and for
      normal run conditions.

•     GEP should finalize a written training program together with a means for
      documenting each individual's training.

•     A formal preventive maintenance system,  including an instrument
      maintenance program, should be adopted throughout the facility.

Accidental Release Investigation Procedures

•     A number of items in accident reporting and investigation should be
      written and formalized.  These include:  1) responsibilities  for
      determining whether a spill should be reported, communicating the
      details of the spill, and ensuring that the investigation team follows a
      well-defined time schedule; (2) responsibility for ensuring that the
      recommendations of the investigating team are acted upon and enforced:
      (3) procedures for reporting and investigating spills below the  RQ:

                                      214

-------
      (4) procedures for investigating trends in spill and  incident  causes,
      and for the actions to be taken as a result of- the  investigations;  and
      (5) lessons learned from investigation.
Audit Team Member Composition:

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
David Napierski
U.S. EPA
Team Leader
Biologist

John Kjellstrand
U.S. EPA
Deputy Team Leader
Chemist

Byron Maggos
U.S. EPA
Supporting Technical Reviewer
Chemist

Helen Holm
U.S. EPA TAT
Technical Reviewer
Chemical Engineer

Mitzy Guiher
U.S. EPA TAT
Verifier
Mechanical Engineer
Follow-up Activities:

      By the Facility:

      By the Regional Office:

      By State and Local Authorities:
Regional Contact:
Mark Horowitz (312)  886-1964
                                      215

-------
216

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Exxon Refinery
Facility Location:
Baton Rouge, Louisiana, Region 6
Date(s) Audit Conducted:
January 17 - 18, 1990
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
2911 -- petroleum refining

2200 acre facility is located on the
iMississippi River east of Baton Rouge.
Primarily petroleum products, including
gasoline, heating oil, diesel, kerosene,
and jet fuels.
There is a preschool/day care center
within one mile, and similar facilities
and nursing homes within 2-3 miles.
Reason for Facility Selection:
      ARIP Reports:
Focus of Audit:

      Hazardous Substances(s)
      Examined:
The facility was chosen because of the
explosion,  fire, and release that occurred
on December 24, 1989,  and resulted in two
deaths and seven injuries.

11/29/88 and 4/1/89 releases of hydrogen
sulfide, and 6/5/87,  6/17/87,  8/3/87,
8/3/87,  8/6/87, 3/10/89,  3/16/89,  and
3/29/89  releases of methyl  chloride.
Natural Gas
Benzene
Sodium Hydroxide
Hexyl Alcohol  -
Orthoxylene
Naphtha
Sulfuric Acid  .
Caustic Soda
                                      217

-------
      Physical Area(s) Examined
      at the Facility:

      Storage and Handling

      •     Shipping/Receiving

            Most shipping and receiving is done by pipeline and barge,
            although there are limited shipments by truck of some sulfur
            products.   Exxon has docking facilities along the west border of
            the facility on the Mississippi River for barge unloading
            operations.

            The refinery receives propane/ethane from a separator at another
            location via an 8-inch pipeline to the fractionation unit.  This
            line, which was the initiating factor in the 12/24/89 incident, is
            located in a pipeband which includes approximately 99 pipelines,
            of which 85 were in service at the time of the incident.  The
            pipeline is equipped with a high/low pressure alarm system that
            activates in the event of overpressure or rupture in the line.


Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     Although the facility is located along the Mississippi River,  it
            is not susceptible to flooding.   Hurricanes,  however,  do present a
            potential threat to the refinery.

      Chemical Accident Prevention

      •     Exxon publishes a monthly safety bulletin and conducts corporate
            safety audits at the refinery.   Each department has 12 safety
            committee representatives.   Weekly safety meetings  are held
            covering specified topics,  and there are no limits  on time or
            input from employees.

      •     Exxon's practice of employing a full-time person for oversight of
            contract personnel training is commendable,  fixing  responsibility
            within the company, rather than delegating it to the contractor.
            The contractor safety coordinator reviews a detailed checklist of
            anticipated activities and tests contractor employees.

      •     Training programs are conducted by a large staff of company
            personnel and outside contractors certified by educational
            institutions as qualified trainers.   Training methods  include  the
            use of lectures, demonstrations, and videotapes,  as well as
            classroom and on-the-job training.
                                      218

-------
New employee training  is part  of  the  four-year  apprenticeship
program.  Employees are given  refresher  courses  as  needed  or as
required and are trained either in  advance  or upon  implementation
of changes in equipment, processes, or procedures.   Effectiveness
of training is determined by frequent testing,  including on-the-
job tests and test drills, and are  evaluated by  supervisors.

Managers are given extensive training in hazard  evaluation and
accident prevention.

The refinery maintenance department consists of  a department head,
six section supervisors, 24 first-line supervisors,  and 201
mechanics.  Maintenance mechanics are trained annually; training
for instrument technicians includes a four-year  apprenticeship
program and updated training as necessary.

Refinery maintenance and inspection activities  include:

      Pumps and/or compressors are  inspected three  times a  week
      for increase vibrations, and  the results recorded.

      Critical instruments are inspected monthly by  instrument
      technicians.

      Isometric drawings are used to  locate and  test critical
      points in a piping system.  Radiographs,  penetration  tests,
      magnetic tests, and visual inspections are conducted.

The maintenance program is highlighted by a multi-level work
permit system that is controlled under four different work
experience sign-offs to ensure proper oversight.  A safety  review
committee meets monthly to review completed work documentation and
follows up on any discrepancies with  the individuals involved..

Within the maintenance section, an annual audit is conducted on
each unit within the refinery.  During scheduled turnarounds,
maintenance and inspectors review the unit for  additional  repairs
beyond the present scope of work.

Exxon has conducted a vulnerability analysis for hydrogen  sulfide',
ammonia, and chlorine, however, Exxon identifies the threat of  a
BLEVE to be more of a concern to the surrounding community  than
toxic gases.  Exxon has performed extensive BLEVE hazard analysis
work for the refinery  -- areas of tho surrounding community could
potentially be seriously impacted by a BLEVE.

New equipment designs must be approved by the  technical and
process supervisors, the safety in design subcommittee,  and the
safe operations committee (SOC),  composed of experienced
engineers.  The SOC conducts a procedure review for  the entire
refinery every three years and is  also implementing  a HAZOP
program -- three units will be examined this year.

                          219

-------
•     Chlorine was engineered out of  refinery  processes  and replaced
      with bromine, which is significantly  less  toxic.

•     Processes using ammonia were  re-engineered to  use  low pressure
      gaseous, rather than liquid,  ammonia.

Accidental Release Incident Investigation

•     The pipeline involved in the  12/24/89  incident carries
      propane/ethane from a nearby  facility, thereby eliminating the
      need for loading/un..oading operations.   The  shutoff  for  this  line
      is located in the field; due  to the amount of  piping at  the
      refinery, it would be difficult to establish an effective
      emergency shutoff system in the control  room.

•     The refinery and the adjacent Exxon chemical facility reported 32
      releases in 1987, 24 releases in 1988, and 60  releases in  1989
      under CERCLA, SARA, and CWA.

•     The investigation procedures manual covers both accidents  and  near
      misses.  The manual covers the communication of incident
      information to management, the appointment and responsibilities of
      the investigatory committee, and the preparation and review of  the
      investigation report.

•     Investigation reports are completed within two weeks  of the
      incident; lessons learned are to be disseminated through the
      issuance of a Safety Spotlight within one week of the  incident.

•     An Exxon investigation committee reviews releases or  accidents,
      and considers alternatives to prevent recurrence.   The committee
      works closely with local,  state, and federal agencies.

Facility Emergency Preparedness and Planning Activities

•     Exxon maintains two emergency procedures manuals,  one  for  the
      facility superintendent and another for all other plant personnel,
      which appear to overlap in certain areas.

•     The emergency procedures manuals are updated as needed --  the last
      revision occurred in March 1988.  A number or employee committees
      have input in updating the manuals.

•     The 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.

•     Recommendations from the emergency exercises are delegated to a
      member of the response team, who follows up on any action items
      identified, such as improvement of communication measures.
                                220

-------
•     No plant-wide evacuation simulation has ever been conducted.

•     There are ten major defined egress routes in the plant, marked
      with distinctly colored signs leading to specified off-site
      staging areas.  Large evacuation maps were posted throughout  the
      plant in 1989 to show people the closest exit from their  location.

•     There have been two videos developed for Exxon employees  and
      contractors which explain the procedures to take during an
      incident which requires an evacuation.

•     The refinery has in-place protection procedures which inform
      personnel to go into safe shelters, shut off all fresh air intakes
      and fans, and seal cracks around doors and windows.   Radios,
      telephones, and pagers will provide further instructions.

•     There is a siren system for toxic or hydrocarbon gas releases;
      personal pagers, issued to employees but not contractors, serve as
      a backup.

•     Emergency response personnel, including mutual aid personnel,  are
      thoroughly trained -- no untrained volunteers are allowed on-site.

Community and Facility Emergency Response Planning Activities

•     Exxon contributed to the brochure "What To Do in Case of a
      Chemical Emergency," published by the North Baton Rouge Emergency
      Response Task Force.  The brochure provides valuable information
      to the general public, and could serve as a model for other LEPCs.

•     One section of the emergency organization and procedures manual
      details how to activate the mutual aid system,  which consists  of
      over ninety industries and municipalities.   The mutual aid plan
      lists equipment available to each of its private and public
      members.  The mutual aid system includes a hotline between
      industries and local agencies that is tested twice daily.

•     The Baton Rouge LEPC indicated that the company has  been very
      involved in its activities and had served on several committees.
      The refinery is also very involved in the CAER program.

•     Exxon has participated in various exercises that were sponsored by
      the city and the parish.

•     The city of Baton Rouge performed a vulnerability and risk
      analysis in 1988.  Hydrogen sulfide .was ranked as the sixth
      highest chemical of concern among 23 chemicals,  with a potential
      vulnerability zone of 1.3 miles after 15 minutes.

•     The current public education program may be inadequate --  many
      area residents are illiterate and unable to understand printed
                                221

-------
            mailings,  and many area residents do not own television sets to
            view informational programs.

      Public Alert and Notification Procedures

      •      Although the emergency siren is audible well outside the boundary
            of the refinery,  interviews with residents indicated that they
            were unaware of what was the appropriate response to the siren.
      Recommendations:

      Facility Emergency Preparedness and Planning Activities

      •     Exxon should consider combining the two emergency manuals into one
            document for the sake of efficiency and continuity.

      •     The facility should consider conducting a plant-wide evacuation
            exercise.

      •     Contractors should be issued electronic pagers so that they are
            fully tied into the facility emergency alert system.

      Community and Facility Emergency Response Planning Activities

      •     Exxon should submit their BLEVE analysis as well as  their
            vulnerability and risk analysis to the LEPC and the  SERC.

      •     Emergency plans should include a revised public education program
            coordinated with the LEPC (e.g., a door-to-door outreach program).

      Public Alert and Notification Procedures

      •     Although the on-site emergency communication system  is excellent,
            the facility should review potential neighborhood warning systems.


Audit Team Member Composition:

Name and Title                James Staves
Affiliation                   US EPA Region 6
Area of Responsibility        Team Leader
Expertise                     Emergency Planning

Name and.Title                Dusty Pruitt
Affiliation                   US EPA Rejion 6
Area of Responsibility        Title III Reporting
Expertise                     Emergency Planning
                                      222

-------
Name and Title
Affiliation
Area of Responsibility
Expertise
George Allman
US EPA Region 6
Health and Safety/Training
Emergency Planning
Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name- and Title '
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Steve Mason
US EPA Region 6
Title III and Public Relations
Emergency Planning

T. Craig Carlton
US EPA Region 6
On-Scene Coordinator
Environmental Engineer

Del Krehbiel
US OSHA
Hazard Communication
Inspector

John Gillespie
TAT,  US EPA Region 6
Process Systems
Engineer

Tom McKinney
Louisiana SERC
Off-site Impact
Emergency Planning

Bruce Hammatt
Louisiana DEQ
Air Monitoring
Scientist
Follow-up Activities:

      By the facility:

      By the Regional office:

      By State and local authorities:
Regional Contact:
Steve Mason
                                      223

-------
224

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:


Facility Location:
Olin Corporation
Lake Charles, Louisiana, Region  6
Date(s) Audit Conducted:
April 17 - 19, 1990
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
2869 -- industrial organic chemicals

Flat, marshy, industrial area on the
Calcasieu River located 100 miles west of
Baton Rouge,  LA.


Toluene diisocyanate, chlorinated dry
bleach, hydrazine, hydrated hydrazine,
nitric acid,  and organic phosphate flame
retardants.
While the area is primarily industrial,
the closest residential area is over one-
half mile to the north.
Reason for Facility Selection:
      ARIP Reports:
The facility was chosen because of a
release of phosgene gas on 12/3/89.

12/16/88, 12/22/88, 3/17/89,  5/17/89,
5/17/89, and 6/11/89.releases of ammonia,
and 3/28/89 and 4/15/89 releases of
nitrogen dioxide
Focus of Audit:
      Hazardous Substances(s)
      Examined:
Toluene Diisocyanate (TDI)
Phosgene
Sodium Hydroxide
Chlorine
Monochlorobenzene

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      From seventy to one hundred chlorine  tanks  cars  are  on-site.

•     Shipping/Receiving

      Raw materials are received in tank cars, barges, and tank  trucks.
      Products are loaded at unit prod-..  :ion  locations and shipped  in
      tank trucks, rail cars, drums, and motor freight bags  and  boxes.
      The Southern Pacific railroad enters  the plant on  the  east, and
      there are docking facilities along the  Calcasieu River to  the
      south for barge unloading and loading operations.

•     Material Transfer

      The company uses a switch engine to move tank cars.   During an
      emergency, sucn as a major incident,  the rail cars may have to  be
      moved.  Three full-time employees are trained to run the switch
      engine.  Lead cars are always manned  and facility  personnel place
      blue flags to indicate rail car wheels  have been chocked.

Process AreaCs)

The facility is primarily an organic chemical manufacturer.  Olin is  the
only source of propellant grade hydrazine, used as a rocket  fuel.  On an
annual basis, approximately 20,000 rail cars, tank trucks, and barges
are shipped each year out of the facility.  The focus of the audit was
the TDI Production Unit, involved in the phosgene release  of 12/3/89.

The chemical processes examined involve the manufacture of phosgene and
TDI in two separate units.  Phosgene is produced by reacting carbon
monoxide with chlorine in the phosgene reactor.  Carbon monoxide feed
for the reactor is obtained from Hyco unit where natural gas is  reacted
with steam and carbon dioxide to produce hydrogen and carbon monoxide.
Chlorine from the storage cylinders is fed directly into the phosgene
reactor.

In the TDI plant, phosgene is reacted with toluenediamine  in the TDI
reactor.  The resulting hydrochloric acid vapor is collected, purified,
and later used for acid production.  The impure TDI product  is stripped
off the phosgene, which is then recycled.  TDI is further purified in
the process.  The residue recovered during the TDI purification process
is incinerated.  The TDI process unit also  includes the TDI  recovery
system.  "Excess" caustic is fed into the caustic scrubbers  to prevent
any accidental release of vent gases to the atmosphere.
                                226

-------
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      ••    The facility is above the  100-year  floodplain, but  the  area  is
            historically subject to hurricanes,  tornadoes, storm  surges,
            flooding, drought, and fires.

      .Chemical Hazards

      •     Chemical hazards include direct contact or inhalation of phosgene,
            TDI, sodium hydroxide, chlorine, and monochlorobenzene.

      •     MSDSs are available for all employees, who have been  trained to
            interpret the data on these sheets.

      Process Information

      •     Chlorine rail cars are the primary  storage method at the facility.

      •     The National Fire Protection Association fire diamond 704 system
            is in place throughout the plant and employees are trained in
            interpreting the system.

      •     The facility has no procedures for verifying the correct operation
            of the automatic track switching system to ensure that tracks are
            properly set for incoming or outgoing rail traffic.

      •     Unusual corrosion was noticed on the outer walls of piping and
            some of the structures of the phosgene and TDI plants.

      •     Automatic and manual controls have been provided throughout the
            phosgene/TDI manufacturing process.  The majority of the process
            parameters are continuously monitored and recorded through a
            sophisticated computer control system.   The control  room is
            located in a building isolated from  the phosgene/TDI plant.

      •     There are two types of perimeter monitoring and detection systems.
            Fourteen STATOX devices continuously monitor the phosgene in  the
            environment and toxic paper tapes are in place and checked daily •
            for the presence of phosgene.

      Chemical Accident Prevention

      •     The overall plant safety plan is continually revised and updated
            on a three to five year basis.

      •     A comprehensive corporate audit is performed every 18  months,  and
            generates a list of action items,  all of which must  be addressed.
                                      227

-------
Plant operator activities are consistent with written  operating
procedures established by the facility.

Fork lift operators are all trained and certified by written test
and are distinguished by symbols on their hard hats.

Personnel receive product-specific training for  loading  and
unloading operations.

Contract employees seemed to have little or no emergency response
training, and some had not undergone any hazard  communication
training.  Olin relies upon its contractors to train their own
employees, and conducts no oversight of these efforts.

Preventive maintenance is conducted all though the year;  however,
most maintenance is not regularly scheduled -- the only  scheduled
maintenance is conducted during plant shutdowns.

Preventive maintenance (PM) is recorded and tracked through  an  in-
house computer program which indicates equipment number,  required
frequency of PM, and the date of the last and the next PM.   A
review of one such record shows that for a number of pieces  of
equipment, the scheduled due date was in 1988, 1989, and  early
1990; there was no indication of whether these were'conducted.

For major equipment in the TDI plant,  PM is conducted through work
order.  Following inspection of the equipment, a formal  report  is
prepared, including recommendations for action,   if necessary.

Olin follows similar procedures for instrument maintenance.   A
computer program tracks PM for all instruments including  critical
safety devices (CSDs), such as pressure gauges,   flow control
devices, and reactor temperature monitors.   A review of records
for instrument maintenance indicates that the scheduled PM date
for many of the CSDs had already passed,  without apparent action.

Olin has implemented the Safety in Engineering Technology
Construction Operations program.  A safety and hazards review is
conducted at specific points in the development  and execution of
engineering projects.  The safety/hazard review  department
continually reviews hazardous operations,  including technologies,
operations, design, and startup problems.

The audit team believes that the HAZOP study conducted for the
"A,B,C" process kettle may not fully address design standards and
codes.

The facility participated in a Combined Plant Analysis, a
voluntary initiative by 12 area facilities  to perform dispersion
modeling analysis of ground-level concentrations from emissions,
considering each facility individually and then  cumulatively.
                          228

-------
•     Olin has not conducted any worst-case modeling  for  releases  of
      phosgene and TDI, although it has  the CAMEO  and SAFER  air
      dispersion models available.

•     A caustic scrubber unit has been installed to prevent  accidental
      releases of vent gases into the atmosphere.  The caustic tanks has
      125,000-gallon capacity; an additional  80,000-gallon emergency
      caustic supply is available.

•     During shutdown or scheduled maintenance, an elephant  trunk
      scrubber hose is used to remove the excess phosgene/TDI from the
      process vessels and the work area, and  to contain releases and/or
      prevent air dispersion of these chemicals.

•     Olin primarily relies on pressure  relief valves  to  reduce the
      potential for catastrophic releases from phosgene/TDI  operations.
      Releases from these valves are sucked into the vent header and fed
      into the caustic scrubbing unit.

Accidental Release Incident Investigation

•     The notification procedures manual, covering internal  and external
      communication on releases and fires, was last revised  on 1/15/90.

Facility Emergency Preparedness and Planning Activities

•     Facility emergency procedures do not cover ensuring the safety of
      chlorine tank cars during a potentially threatening emergency.

•     Drills are held quarterly, either  facility-wide or unit-specific.
      The last simulation occurred in March 1990, -and involved the CAER
      group and local and state agencies.  Each simulation is followed
      by a critique and revision of procedures if necessary.

•     Fire and evacuation corridors are  identified in the plan and
      posted throughout the facility.

•     All personnel have access to supplied air respirators and
      protective clothing.  All plant personnel protective equipment
      inspected appeared to be well-maintained and in good condition.

•     Wind socks are placed throughout the facility and are readily
      visible from all operational areas.

•     Some contractor safety equipment was discovered lying on the
      ground and subject to damage or contamination.   Some contract
      personnel did not fully understand alert and evacuation
      procedures.  The safety orientation given to contractor personnel
      appeared to be short and vague.
                                229

-------
•     Shutdown chain of command and procedures  is described  in  the plan
      and familiar to the operators interviewed by  the  audit  team.

•     Emergency communications procedures and equipment were  understood
      and efficiently located among plant personnel.  Some contract
      personnel, however, did not know who to tell  when given a
      potential emergency scenario.

•     All plant operators were trained on and aware of  emergency
      procedures.

Community and Facility Emergency Response Planning Activities

•     Olin has demonstrated a good working relationship with  nearby
      facilities and with the LEPC, which has led to a  coordinated on-
      site emergency preparedness program.

•     The facility is part of a twenty-seven member CAER system
      consisting of representatives of local industry,  city,   state, and
      Red Cross and other community organizations.  The CAER  group has
      developed its own emergency response plan and has developed a
      dedicated two-way radio system which serves as a  alert  and release
      notification system among its members.

•     In the past, communication of release incidents by the  facility to
      first response organizations has been prompt and  the facility has
      been open with information.

•     Community relations may be a problem.   A survey of neighboring
      residents showed very little knowledge of plant activities,
      products, or emergency response procedures.   However,  the facility
      conducts periodic open houses and cross-training with local
      response agencies.

Public Alert and Notification Procedures

•     Public notification during emergencies is carried out by the
      standard siren method and assigned mobile PA systems.   Interviews
      with civilians revealed that the mobile PA systems are  difficult
      to hear and are not easily understood.   Many said they  knew  that
      the sirens indicated a problem,  but did not know what to do.

•     Local media contribution to public awareness of Title  III  issues
      and interaction with Olin provides for an even and accurate  flow
      of information.
                                230

-------
Recommendations:

Process Information

•     Long-term inventory should not be stored in tank cars.   The
      installation of bermed storage tanks could be considered as  a
      possible means of reducing the number of tank cars on-site.

•     The facility should establish SOPs to verify that the automatic
      railroad track switches are in the correct position to safeguard
      the operation underway.

•     Olin should immediately address the unusual corrosion noticed on
      the structures of the phosgene and TDI plants and on the  outer
      walls of piping, painting any exposed metal to slow corrosion and
      replacing heavily corroded sections.

Chemical Accident Prevention

•     Olin should develop a simple,  but adequate training course for
      contract workers.  As a precautionary measure,  the Olin safety
      department could run random checks on contract employees  to insure
      compliance with this training requirement.

•     Olin should re-examine, and implement corrective action as soon as
      possible, for the entire inspection and preventive maintenance
      program, including:

            Frequency and procedures for regular inspections;
            Procedures for corrective action when a problem is
            encountered, and specifically recommended by inspectors;
            Construction material for all equipment,  the welding
            material, and the corrosion/wear rates;
            Frequency of wall thickness inspections;  and
            Design of the TDI and the phosgene reactors.

      Preventive maintenance and inspections of all critical  safety
      devices and equipment with moving parts is  essential  to  any
      effective program.

•     Olin should reevaluate the HAZOP analysis conducted for  the
      "A,B,C" kettle with respect to design standards  and codes.

•     The facility should model worst-case scenarios  for a  release  of
      TDI and phosgene, thoroughly evaluate all potentially  impacted
      areas, and notify the residents to the north of  the plant if  they
      could be affected.
                                231

-------
      Facility Emergency Preparedness and Planning Activities

      •     The facility should incorporate procedures for removal of the
            chlorine tank cars from the site in the event of an emergency  into
            unit emergency plans.

      Community and Facility Emergency Response Planning Activities

      •     Olin should hold an open house on a regular basis, allowing the
            public to learn first hand about the facility and how their
            operations relate t<. the community at large.

      •     Olin should encourage operators to speak at community events (PTA,
            Kiwanis,  Chamber of Commerce) to help foster goodwill and trust in
            the community.
Audit Team Member Composition:

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Steve Mason
US EPA Region 6
Team Leader
Emergency Planning

George Allman
US EPA Region 6
Health and Safety/Training
Emergency Planning

Fendol Chiles, AARP
US EPA Region 6
Chemical Systems/Transportation
Transportation and Emergency Response

Keishor Fruitwala
TAT,  US EPA Region VI
Chemical and Process Systems
Engineer

John Gillespie
TAT,  US EPA Region VI
Process Systems
Engineer

Mike Williams
Louisiana State Police
Transportation Safety/Release Investigation
Emergency Response
                                      232

-------
Name and Title                Sam Russell
Affiliation                   Calcasieu Parish LEPC
Area of Responsibility        Observer
Expertise                     Emergency Planning
Follow-up Activities:

      By the facility:

      By the Regional office:

      By State and local authorities:


Regional Contact:             Steve Mason
                                     233

-------
234

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:


Facility Location:
Sid Richardson Carbon Company  (SRC)
Borger, Texas, Region 6
Date(s) Audit Conducted:
March 6-7, 1991
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:

      Proximity to
      sensitive populations:
2895 -- carbon black

Northwestern Texas, 220 miles west of
Oklahoma City, OK
Carbon black
The facility is located in an industrial
area;  the closest residential area is
almost one ,mile to the south.
Reason for Facility Selection:
      ARIP Reports:
The facility was chosen because of a
series of releases of hydrogen sulfide
during 1989 and 1990.

1/22/90,  2/13/90,  3/10/90,  4/1/90,
5/13/90,  6/1/90, and 6/11/90 releases of
hydrogen sulfide
Focus of Audit:
      Hazardous Substances(s)
      Examined:
Carbon black
Carbon black oil
Carbon black tail gas
Carbon black tail gas,  burned
Chlorine
Sulfuric Acid
Hydrogen Sulfide
                                      235

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      Chlorine is stored in five to six 150-pound cylinders  on  a
      concrete pad next to the cooling tower.

      Sulfuric acid is stored in one 2,000-gallon and one  750-gallon
      tank near the chlorine storage area.

      Feedstock oil is stored in four tanks around the facility --  one
      75,000-barrel, one 25,000-barrel, and two 10,000-barrel tanks.

•     Shipping/Receiving

      Approximately sixty percent of the feedstock oil is piped in  from
      the nearby Phillips Petroleum refinery; the rest is delivered by
      truck or railcar from other sources.  Natural gas arrives by
      pipeline.  Chlorine and sulfuric acid are brought in by truck.

      Seventy percent of the carbon black product is shipped by rail car
      and the remainder by truck.

Process Area(s)

The furnace process for production of carbon black involves the use of
four raw materials -- feedstock oil, natural gas,  water,  and air.
Preheated streams of feedstock oil and air are injected into one end of
the cracking furnace.  The air is injected in a controlled stream to
ensure only limited combustion occurs;  the feedstock oil is injected as
a fine mist to minimize contact with the furnace walls.   As the cloud of
air and oil proceeds through the furnace,  large aromatic molecules  are
cracked into small carbon molecules.  As the vapor cloud nears the  other
end of the furnace, water is misted into the chamber to top or quench
the reaction by cooling the vapor cloud that now contains the newly-
formed carbon black particles.   This gas is then further cooled by
another quenching to protect the filter bags which collect the carbon
black from the gas stream.

The product is recovered by periodic back-flushing of the filters  with
clean gas.  After recovery from the bag filters,  the carbon black
particles are pumped through a micropulverizer which pulverizes  any
impurities such as coke or refractory materials.   The carbon black  is
then pumped to a pelletizing chamber where steel rods continuously blend
it with water and certain additives to form pellets  that can be  handled
and shipped.

The off-gas stream is collected after passage through the baghouse
filters in headers and used,  along with a supplemental supply of natural

                                236

-------
      gas, to fire three steam boilers  to  generate  electricity  for  the
      facility.  Combustion of off-gas  to  fire  the  boilers  also  converts  the
      hydrogen sulfide to sulfur dioxide and water,  and  significantly reduces
      particulate and other pollutant emissions.
Summary-of Audit Findings and Recommendations:

      Conclusions:

      Process Information

      •     The chlorine storage area is surrounded by a yellow pipe rail,
            placarded with signs and the NFPA fire diamond.  The cylinders
            were cl-early and legibly labeled chlorine.  However, the cylinders
            and their connections are vulnerable to high winds and other
            hazardous weather conditions and flying debris.

     . •     No placards were on the sulfuric acid tanks, although National
            Fire Protection Association fire diamonds were taped to the tanks
            to indicate their hazards.

     . •     The process is completely automated and controlled by computer
            from a central computer control room.  The computer system
            monitors furnace temperatures and the injection rates of feedstock
            oil, air, natural gas, and water into the system.  Flows of air,
            water, and natural gas are monitored, charted,  and kept on file.

      •     In addition to displays in the central control room, computer
            terminals in the offices of the plant operators also provide
            process information from the control system.   These additional
            monitors are for informational purposes,  however; adjustments can
            only be made by control room technicians.

      •     Computer-activated alarms are set to detect deviations both above
            and below a standard set point, which depends on the size of
            carbon black particles being produced.

      •     No backup or redundancy systems exist at the SRC plant other than
            the co-generation system of boilers used to burn the off-gases.

      •     No monitoring is carried out for hydrogen sulfide,  even when an
            extended release is occurring.   There are also  no facility
            chlorine detection systems.

      •     Quarterly monitoring for total suspended particulates  is
            performed, but has never indicated a particulate problem.
                                      237

-------
Chemical Accident Prevention

•     The corporate office conducts periodic audits, usually  as  an
      unannounced inspection.  A list of action  items  is generated  and
      follow-up action and reporting are required until resolution;
      immediate hazards are to be reconciled at  the  time of the  audit.

•     The plant safety team -- the plant manager, the  safety  director,
      and three hourly employees -- conduct a monthly  internal audit.
      Important results are discussed at subsequent  safety meetings.

•     Standard operating procedure manuals for each  section of the
      process are readily accessible to section  operators.  Manuals
      contain piping diagrams and equipment descriptions as well as a
      section for emergency shutdown procedures, which provides
      information on the basis and impact of shutdown procedures.

•     All employees attend monthly safety meetings.   Additional safety
      training is provided by first line supervisors, and may be
      developed from the results of internal or  corporate audits.

•     Each employee receives six weeks of on-the-job training after
      which a written essay test is administered to ensure knowledge and
      skills for that position.  Test results are kept or.- file to track
      skill levels and qualifications.

•     Plant supervisors complete the job progression prior to promotion,
      and thus are thoroughly familiar with all activities and
      operations in the plant.

•     Lockout/tagout procedures authorize any employee to lockout/ragout
      equipment, regardless of their department.

•     Maintenance requests may be written by any employee,  and work
      orders are scheduled weekly and daily.   Thorough paper records of
      maintenance activities are kept on file and indicate that SRC
      conducts routine maintenance and inspection of equipment and
      instruments.  A separate maintenance file is kept on each piece of
      equipment.

•     Critical instrumentation is checked weekly, maintained as needed,
      and calibrated annually.

•     SRC has not conducted any hazard evaluation or analysis  on any of
      its chemicals in storage, operations,  or processes.   Management
      stated that the absence of high pressure conditions  or highly
      flammable materials, in combination with the preventive
      maintenance program, preclude the need for such analysis.

•     No modelling scenarios have been conducted by  the facility.
                                238

-------
Accidental Release Incident Investigation

•     SRC has reported a large number of releases of hydrogen  sulfide to
      the NRC -- 7 in 1988, 125 in 1989, 53' in 1990, and  15  during  the
      first quarter of 1991.  Because the facility does not  possess an
      air permit to release hydrogen sulfide. as do other carbon  black
      plants, it must report these releases.

•     The key issue for the facility is the intermittent  releases of
      hydrogen sulfide, which are not permitted by the Texas Air  Control
      Board.  The releases occur due to a failure in the  co-generator
      system; the plant then vents the off-gases straight to the
      atmosphere instead of burning them.  Hydrogen sulfide  is present
      in the tailgas at less than one-tenth of one percent by volume.

•     There are no written procedures for investigating releases, but
      there is an informal procedure for the plant manager and safety
      director to investigate any accident within 24 hours.  A written
      report is sent to the corporate office,  and significant findings
      are discussed during monthly safety meetings.

Facility Emergency Preparedness and Planning Activities

•     The current facility emergency plan was written by  the safety
      director in April 1990 and was revised in January 1991.  There  is
      no schedule for revisions or updates to the plan.

•     The plant has not conducted any simulations or exercises to test
      their emergency response plan,  but plans to participate in a
      community-wide exercise with the LEPC and other industries in the
      area later this year.

•     Evacuation routes are not specified in the emergency plans.

•     The plant union leader was unable to identify the designated safe
      evacuation areas listed in the emergency response manual.

•     The basement of the main office building,  designed as a civil
      defense shelter, has communications equipment and can be used  for
      in-place sheltering.

•     The plant manager and the safety director,  or their alternates,
      are in charge of any emergency situation.

•     SRC has a two-way radio communication system,  talking pagers,  and
      regular telephone lines so that contact  with most essential
      personnel can be almost instantaneous.

•     There are no designated facility emergency response  personnel.
      Employees receive fire safety and extinguishing training and Scott
      air pack training annually.   The plant is  in the  process  of  giving
      first aid and CER training to'all employees.

                                239

-------
Community and Facility Emergency Response  Planning  Activities

      •     The safety director is responsible  for  making  any  required
            notification and reports to the LEPC, state  agencies,  EPA,  and
            corporate headquarters.

      • -    The safety director is the section  302  facility  coordinator and
            the facility's representative  on  the Hutchinson  County LEPC.

      •     The plant does not hold any open-houses,  training, or  other types
            of outreach activities for the local community.

      •     The nearby Phillips Petroleum  Refinery  has its own fire department
            and emergency rescue team, and has  verbally  agreed to  assist  SRC
            with equipment and personnel during an  emergency incident.

      Public Alert and Notification Procedures

      •     SRC depends on government agencies  to notify the public should  it
            be necessary to do so during an emergency.

      •     The plant manager or his designated alternate  is responsible  for
            interaction with the media during an emergency.
      Recommendations:

      Process Information

      •     The facility should install more permanent hazard information
            labeling  for the sulfuric acid tanks.

      •     The plant should provide additional protection for the chlorine
            cylinders, such as a storage cabinet or shed.

      •     SRC should consider installing a monitoring system around the
            chlorine  storage area and in the water treatment building.

      •     The facility should set up monitoring stations to measure the
            toxic gases (e.g., hydrogen sulfide) released during processing
            operations.  Sampling similar to that done for particulate
            contamination could be used to determine if there is a need for
            additional safeguards.

      Chemical Accident Prevention

      •     The plant should investigate the feasibility of using a portion of
            the off-gas stream to heat the pellet drying furnace to eliminate
            the venting of off gases during breakdowns or maintenance.
                                      240

-------
      •     SRC should conduct a vulnerability and risk analysis and/or
            modeling for its extremely hazardous substances and provide  a  copy
            of the results to the LEPC and the SERC.

      Facility Emergency Preparedness and Planning Activities

      •     The plant should ensure that all personnel are familiar with the
            provisions of the emergency response plan, including the on-site
            evacuation areas.

      •     The facility should design an exercise schedule to test the
            efficiency of the emergency plan and familiarize plant personnel
            with the plan.

      •     SRC should develop evacuation routes out of the plant area.

      o     SRC should consider equipping the office basement for sheltering
            and as a secondary emergency operations center for the Hutchinson
            County LEPC.

      Community and Facility Emergency Response Planning Activities

      •     The facility should coordinate their emergency planning with the
            LEPC to ensure that the county plan accurately reflects all the
            hazards present at the facility.
Audit Team Member Composition:

Name and Title                Steve Mason
Affiliation                   US EPA Region 6
Area of Responsibility        Team Coordinator
Expertise                     Emergency Preparedness

Name and Title                Jane Nakad
Affiliation                   US EPA Region 6
Area of Responsibility        State Coordinator
Expertise                     Emergency Preparedness/Modeling

Name and Title                Craig Carroll
Affiliation                   US EPA Region 6
Area of Responsibility        On-Scene Coordinator
Expertise                     Environmental Engineer

Name and Title                Ky Nichols
Affiliation                   TAT, US EPA Region 6
Area of Responsibility        Process Hazards
Expertise                     Chemical Engineer
                                      241

-------
Name and Title                Danny Richards
Affiliation                   Hutchinson County LEPC
Area of Responsibility        Observer
Expertise                     Emergency Planning
Follow-up Activities:

      By the facility:

      By the Regional office:

      By State and local authorities:


Regional Contact:             Craig Carroll
                                      242

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Citgo Refinery
Facility Location:
Lake Charles, Louisiana, Region  6
Date(s) Audit Conducted:
May 1 - 3, 1991
Description of Facility:

      SIC Code(s):

      Location:
      Products -manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
2911 -- petroleum refinery

Industrial district along the Calcasieu
Ship Channel, 30 miles north of the Gulf
of Mexico.
Gasoline, aviation turbine fuel, and other
refined products.
None
Reason for Facility Selection:
      ARIP Reports:
The facility was chosen because of the
explosion that.occurred at the facility's
"A" catalytic cracker unit on 03/03/91,
which resulted in five deaths among
facility and contractor employees.

None
Focus of Audit:
      Hazardous Substances(s)
      Examined:
Because of the nature of the incident
prompting the audit,  a description of the
chemicals involved was not warranted in
the report.   Various  hydrocarbons,
hydrogen sulfide,  ammonia, chlorine,  and
sulfuric acid are  present on-site.
                                      243

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      The refinery has the capacity  to hold  ten million barrels  of  crude
      and product in storage tanks.  The  storage  tanks vary  in sizes;
      specific chemicals are normally stored in certain tanks.

•     Shipping/Receiving

      Train and truck loading areas  are situated  throughout  the
      refinery, and docks for tanker and  barge traffic are located  on
      the Calcasieu Ship Channel.  Pipelines  also carry product  to  off-
      site locations for further processing.  Daily and weekly shipping
      and receiving rates can show large  variations, but their monthly
      rates generally follow the average  production rate.

•     Material Transfer

      The refinery's piping facilities include in-plant piping within
      and between processes, between the  storage and the process areas,
      and between the storage and the shipping/receiving areas.

Process Area(s)

The fluid catalytic cracking process involves the breakdown of the
relatively long-chain hydrocarbon molecules  in the feedstock at high
temperature in the presence of fluidized  zeolitic-type catalysts.
Products from the cracking process include motor gasolines,  butylene and
propylene, and off-gases (fed to the fuel system).

The process can be divided into three basic steps -- reaction, catalyst
regeneration, and product fractionation.   Feedstock is preheated and
then co-mingled with hot regenerated catalyst.  It then enters the
reactor where the catalyst and oil are separated using cyclone
separators.  The product vapors enter the fractionator tower, where the
vapors are cooled and condensed, and then sent to other parts of the
refinery for further processing.

The catalyst leaves the reactor and  is carried to the regenerator by a
stream of combustion air.  The carbon deposited on the catalyst  in the
reactor is burned off in the regenerator,  and the catalyst is then
recirculated to the incoming feed to the  reactor.   Combustion flue gases
pass through cyclone separators for  recovery of catalyst,  and are then
cooled in a waste heat boiler before entering electrostatic
precipitators to remove any remaining catalyst prior to release  to the
atmosphere.
                                luu

-------
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     The refinery is the eighth largest in the country, with  a  rated
            capacity of 320,000 barrels of crude oil per  day,  and has  1,260
            full-time employees and 700 contract employees.

      •     Calcasieu Parish is historically subject to hurricanes,  tornadoes,
            wind-driven water, storm surge, flooding, drought, and fires.  The
            facility is above the 100-year flood plain, but is prone to  the
            effects of hurricanes despite its distance from the coast.

      •     The primary vulnerable populations are the employees of Citgo and
            several other nearby chemical facilities.

    •  Process Information

      •     Storage tanks had identifying marks,  but were not  labeled with a
            warning sign stating the specific chemical contents.   Data on
            chemical contents of tanks is at the pump control building and
            tank labelling is being instituted under the new HAZOP program.

      •     Inspection of the shipping docks indicated that personnel had been
            properly trained in safely using the equipment.  The condition of
            the dock did not indicate any leakage or spillage.  Dock personnel
            complained of sloppy bargemen and shippers who caused problems
            using poor techniques.  Several transporters have been refused
            future work because of spillage history.

      •     Most of the piping was not labeled and the associated valves and
            pumps were not labeled or marked for easy identification.  The
            labelling and color coding of piping and associated equipment is
            being implemented under the new HAZOP program.

      •     Process schematics and diagrams reviewed were dated from 1942-
            1951, and did not indicate the extensive modifications  that have
            been made in the intervening years.   The engineering  manager
            indicated that 23 contract employees  are currently working on
            updating these diagrams by computer.   The audit team  commends the
            effort to update the Piping and Instrumentation Drawings  to "as
            built" status and the conversion to computer drawing  files.

      Chemical Accident Prevention

      •     Citgo, with the assistance of outside consultants, conducts
            environmental and safety audits at the refinery.   A list  of
            deficiencies is discussed during an exit interview with  the unit
            supervisor and the area manager,  who  must provide  the  refinery
            manager with a schedule of improvements  and progress  updates.

-------
Many of the SOPs contain references to tables  and  charts  in  other
sections without adequate information on  interpreting  the  data.

Training personnel are not formally certified;  they are generally
safety department or experienced company  personnel.  Training
methods consist of lectures, video tapes, demonstrations,
classroom training,, and on-the-job training.

After three weeks of introductory training, new employees  receive
five to ten weeks of on-the-job training  at a  specific unit,
during which they a~e evaluated every five days.   All operators
progress through a series of on-the-job training levels, which
require demonstrable competence before supervisors and foremen.
Operators take annual refresher training  consisting of a test on
standard and emergency operating procedures.

A computer training record is kept for all employees, and  a
separate record is also maintained in each employee's file.

There are two fractionation tower simulators used  to test  all
operators on their response to emergency  "stress conditions."

Respiratory protection, hazard communication,  and hearing
conservation programs are part of normal  employee training.

Supervisors do not receive special training in addressing  safety
and health concerns from a management perspective.

In 1988, an industrial psychologist conducted  interviews with
hundreds of Citgo employees and validated the existing training
program with some minor recommendations.

Contractors are responsible for training  their own employees,
although Citgo does offer emergency and safe work permit training,
and monitors their "turnaround" training.

Repair work is scheduled and repairs are overseen by the safety
department and the unit foreman.  A system of notification and
sign-off sheets is required for high hazard repairs.

The facility has begun to design a HAZOP analysis program for its
processes to follow the guidelines in the American Petroleum
Institute's Recommended Practice 750.   Five studies have been
completed so far, and Citgo estimates that three to five years
will be required to cover all of its operations.

Although the SPCC plan specifies that releases into the ambient
air cannot be contained on company property,  most of the
refinery's emergency response and planning effort has focused on
fire and fire-related hazards.  The refinery has not conducted  any
hazards analysis for an accidental air release.
                          246

-------
•     Although the facility has conducted modeling  studies  related to
      continuous emissions for various  permit  applications,  no modeling
      of accidental releases has been conducted.

Accidental Release Incident Investigation

•"     The March 3, 1991, explosion  occurred  in the  F-7  slurry settler,  a
      vessel that receives hot oil  containing  some  catalyst  from  the
      bottom of the fractionator.   Incoming  oil  contacted water in the
      settler, causing  immediate vaporization  of water  to steam and
      over-pressurization of the vessel.

Facility Emergency Preparedness and Planning Activities

•     There are three principle emergency plans  --  the Citgo  Emergency
      Response Organization Policy  S.tatement (CERO), a Spill  Prevention
      Control and Countermeasures (SPCC)  Plan, and  the Citgo  Refinery
      Fire Response Plan.  All three contain internal notification
      procedures, a list of emergency equipment, and chain of command.

•     The CERO and the  refinery fire manual  are  reviewed and  updated on
      an as-needed basis, and were  revised in April 1990 and  March  1991,
      respectively.  The SPCC manual was  last updated in March  1985,
      although its procedures mandate a three-year  review cycle.

•     The Citgo corporate office has developed an Accident Response Team
      Manual that establishes procedures  for senior corporate-level
      response and support for specified  levels of  incident severity.
      Assigned duties for corporate personnel are listed; the manual was
      last revised in July 1990.

•     The facility does not have a  regular exercise schedule.  The last
      exercise was a mutual aid scenario  involving  the nearby PPG  and
      Conoco facilities in May 1990.  The  scenario  tested the emergency
      preparedness capabilities of  the companies' response teams.

•     The fire response manual has  a map  designating fire brigade  pick-
      up stations and routes,  but there are  no designated emergency
      evacuation routes.

•     The on-site fire  station houses 142  SCBAs, pumping equipment and
      trucks, an ambulance, an equipment  trailer, two-decontamination
      trailers, and a mobile communications  command post van.

•     The CERO manual describes the response structure in detail,
      including specific strategic,  tactical, support,  and process
      control functions, using a modified  Incident Command System.

•     Throughout all three plans,  overall  control and responsibility
      varies and shifts according to the  type and degree of the
      incident.  It appears that the strategic and tactical  functions
      tend to become blurred and/or overlap  in an emergency.

                                247

-------
•     The CERO addresses the emergency communication network within  the
      facility, consisting of radio, telephone, and steam whistle.   No
      procedures or instructions are given for non-fire emergencies.

•     The guardhouse phone can be a choke point for incoming calls in an
      emergency situation -- the gate guard will be overloaded with
      activity and thus unable to serve as a reliable communicator.

•     Refinery emergency response staff consists of shift emergency
      response teams, fire brigades, and volunteer call-out emergency
      response personnel.  Some employees are sent to Lamar University
      and/or Texas A&M University for fire training.

•     Although there is an EMT on call at all time on-site, the EMT  does
      not accompany all injured personnel to the hospital or clinic;  in
      many cases, the employee accompanying the injured person in the
      ambulance has only been trained as an emergency care attendant.

Community and Facility Emergency Response Planning Activities

•     The safety officer is the facility's representative on the LEPC,
      but has not participated in LEPC meetings.   As a member of the
      Southwest Louisiana Mutual Aid Association,  Citgo has provided a
      list of equipment available for call-out, but the facility has  not
      actively participated in other Mutual Aid and CAER activities.

•     Citgo is a member of the Calcasieu Parish CAER Committee.   CAER
      has established a two-way radio system between 21 industrial and 6
      city, state, and private members.   The system is tested daily and
      provides notification of upsets as well as  actual releases.   CAER
      has also distributed a brochure on emergency response,  "Are  You
      Prepared?" to the public.

•     In order to address the legitimate concerns  in the  parish between
      the public, local agencies, environmental groups,  and industry, a
      number of organizations have been established -- CAER,  Mutual Aid,
      LEPC, Right-to-Know Coalition, CLEAN,  and a  Citizen Advisory
      Committee.  Each of these groups can make a  positive contribution
      to the parish, but the audit team foresees  the potential  for in-
      fighting and redundancy among these groups,  and thus confusion
      among non-member citizens.

•     Citgo participated in the last Earth Day celebration for  Calcasieu
      Parish and gave out over 1,800 oil recycling kits to the  public.
      Citgo also holds open houses for employees  and their families,
      gives tours to interested groups,  and encourages employees  to
      speak to public and civic groups.

•     Citgo is working with other area companies  to establish a  two-year
      associate degree program for operators in process plant technology
      at a local university.
                                248

-------
•     Based on interviews with area hospital personnel,  the audit  team
      would like to recognize the cooperation between  the  facility/CAER
      group and the area hospitals, with the exception of  Memorial
      Hospital, where hazardous material awareness was limited.

Public Alert and Notification Procedures

•     The testing procedure for the CAER siren system, due to  the  lack
      of clarity of the loudspeakers, has the potential  to incorrectly
      indicate that an actual emergency is occurring.

•    , The public affairs officer and the refinery manager  are  authorized
      to speak with the media.  The employee recreation  center normally
      serves as the media information center, but due  to its proximity
      to the A catalytic cracker, it was not used during the March 3,
      1991, incident.

•     Three members of the local media indicated that  there was no
      initial notification of the March 3, 1991, incident  either through
      the CAER alarm or direct phone call.
Recommendations:

Process Information

•     Citgo should investigate the feasibility of installing additional
      redundant sensors (e.g., pressure, flow, or temperature
      indicators) around the process vessels to provide operators with
      more time to make process adjustments when deviations occur.

Chemical Accident Prevention

•     The refinery should involve operations and shift employees more
      directly in the facility's safety meetings, even if on a rotating
      basis.

•     Citgo should implement a program to review unit start-up
      procedures throughout the plant and take corrective actions as
      required.

•     Citgo should expand the classroom training program for both
      operators and supervisory personnel to achieve a better balance
      between such training and on-the-job training.

•     Hazard analyses should be conducted for all EHSs at the facility
      (hydrogen sulfide, ammonia, chlorine, sulfuric acid,  etc.) for
      scenarios developed with the Hazardous Materials Planning Guide
      and some air dispersion modeling system.
                                249

-------
Accidental Release Incident Investigation

•     To address one of the concerns arising  from  the  3/3/91  incident,
      alarms should be installed on the  fractionator/slurry  settler
      system to alert operators when abnormal  conditions  exist  during
      start-up.  In addition, start-up procedures  should  be  specific
      concerning temperature profiles in the  system  during start-up.

Facility Emergency Preparedness and Planning Activities

•     The emergency resporse plans should address  accidental  releases
      and spills of hazardous materials  as well as fire hazards.

•     Emergency plans should be revised  so that the  command person
      directing the response to an incident is not directly involved  in
      tactics and mitigation.

•     The facility should have more operators  trained  as  EMTs to ride
      with injured employees in the ambulance.  EMT  duties should be
      formalized, and possible full-time EMTs  employed.

•     The facility recently purchased an emergency communications van
      and has trained personnel in its use.

•     The facility should establish procedures for immediate set up of a
      command and communication post away from an emergency situation.
      The post should be manned by at least one knowledgeable official,
      who should maintain contact with local agencies  and serve as the
      primary off-site information source.

Community and Facility Emergency Response Planning Activities

•     The facility should participate more actively  in the LEPC, sharing
      its expertise in hydrocarbon operations and emergency
      preparedness, as well as its considerable resources.  This would
      help to improve the refinery's appearance in the public eye.

•     Citgo should devise and implement  training on  the use of the
      emergency mobile communications van for local  government and
      private industry response personnel.

•     Citgo, a member of many of the parish groups established to
      promote the health and safety of residents,  should consider
      playing a role in establishing a system that brings these
      committees together, improving coordination on critical issues.

•     The facility should expand its involvement in  the local ^'.utual  Aid
      and CAER groups.
                                250

-------
      •     As a member of the CAER group,. Citgo should  support  an  outreach
            program to hospitals (e.g., Memorial Hospital)  and other  emergency
            response agencies that may not be fully aware of CAER's
            capabilities.

      •     The Citgo LEPC representative should establish  a closer
            relationship with his counterparts in local  agencies and  install
            an emergency phone to keep them apprised of  the status  of an
            emergency situation and coordinate actions to address off-site
            impacts.

      •     To improve emergency response coordination with local responders,
            Citgo should consider inviting outside emergency preparedness
            agency personnel to internal safety meetings.

      Public Alert and Notification Procedures

      •     The facility should establish formal procedures for relaying
            information from the incident scene to the media liaison  to help
            with rumor control and provide accurate, current information.

      •     Citgo, as part of the CAER network,  should evaluate the need to
            change testing procedures for the CAER siren system.
Audit Team Member Composition:

Name and Title                Steve Mason
Affiliation                   US EPA Region 6
Area of Responsibility        Team Leader
Expertise                   ,  Emergency Preparedness

Name and Title                Jane Nakad
Affiliation                   US EPA Region 6
Area of Responsibility        State Coordinator
Expertise                     Emergency Preparedness/Modeling

Name and Title              .  Dick James
Affiliation                   US EPA Region 6
Area of Responsibility        Shipping/Handling
Expertise                     Engineer

Name and Title                Ky Nichols
Affiliation                   TAT, US EPA Regior. 6
Area of Responsibility        Chemical Process Safety
Expertise                     Chemical Engineer.

Name and Title                Jenniffer Shields
Affiliation                   TAT, US EPA Region 6.
Area of Responsibility        Safety
Expertise                     Chemical Safety
                                      251

-------
Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Chuck Handrich
Louisiana Department of Environmental Quality
Shipping/Handling
Engineer

Bennet Farrier
Louisiana Department of Environmental Quality
Chemical Process Safety
Engineer

Bubba Naquin
Louisiana Department of Environmental Quality
Emergency Preparedness
Inspector

Brian Smith
Louisiana Department of Environmental Quality
Chemical Process Safety
Inspector

William Coltrin
Louisiana Department of Environmental Quality
Chemical Process Safety
Supervisor

Lieutenant Tom Chisholm
Louisiana State Police
Emergency Preparedness
Hazardous Materials Officer

Charles Walts
US EPA Student Intern
Emergency Preparedness
Contingency Planner

Del Kreihbel
US OSHA
Training
Investigator

Sam Russell
Calcasieu County LEPC Emergency Coordinator
Observer
Emergency Preparedness

Shirley Goldsmith
Calcasieu County LEPC
Observer
Private Citizen '
                                      252

-------
Follow-up Activities:




      By the facility:




      By the. Regional office:




      By State and local authorities:






Regional Contact:             Steve Mason
                                     253

-------
•254

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
ICI Americas - Agricultural Products
Formulation Plant
Facility Location:
Omaha, Nebraska, Region 7
Date(s) Audit Conducted:
October 25, 1990
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:

      Proximity to
      sensitive populations:
5191 -- wholesale trade-nondurable goods

42 acre site located on the southeast side
of Omaha, NE, along the Missouri River.
Distribution of technical grade pesticides
The Omaha Municipal Zoo and a school are
located within a half mile north of the
facility.
Reason for Facility Selection:
      ARIP Reports:
The facility was chosen at the request of
local fire service managers who wanted EPA
to evaluate the impact of a potential
release from the facility.

None
Focus of Audit:
      Hazardous Substance(s)
      Examined:
Dyfonate
                                      255

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      The warehouse product storage area  is divided  into  three  equal
      sections, each separated by a rated fire wall, and  protected  with
      sprinklers.  Openings between the sections are protected  by rated
      self-closing fire dcors and equipped with emergency manway
      openings to allow for escape of trapped personnel or entry by
      responders.  Convex mirrors are placed at every intersection  to
      improve visibility, and escape aisles are maintained along every
      wall in the warehouse.

      The north tank farm is a bulk storage area consisting of  four
      250,000 gallon storage tanks, and two smaller 24,000 gallons  tanks
      mounted on load cells and connected  to an electronic scale.

•     Shipping/Receiving

      Technical grade pesticide materials  arrive in non-pressurized
      railroad tank cars.  The material is unloaded from  the rail cars
      into a scale tank and weighed, and  then pumped through a  filter
      into one of the large tanks.

      The facility packages and ships both bulk and non-bulk liquids and
      non-bulk solids.  Finished non-bulk materials are packaged on
      pallets, which are identified by batch number and stored  for
      shipment in the warehouse.

•     Material Transfer

      The bulk tanks at the north tank farm are connected to the other
      tank farms by means of a pipeline system, allowing material to be
      moved to other areas as needed.

Process Area(s)

The facility packaging lines are designed to produce a number of
agricultural products; general practice is to package these in
"campaigns" to meet seasonal needs.  Overall,  the facility pr-duces
about 4 million gallons of liquid product and 4 to 6 million pounds  of
packaged or dry product annually.  Since there is generally a single
daytime shift, these numbers represent about one-third of potential
production capacity.

The Eradicane tank farm runs automatically after the operator sets  it
up.  From the scale tank, the operator pumps the product to a mixing
tank.  The material is then sampled and checked by laboratory personnel
before packaging.

                               256

-------
      The Sutazine production unit is designed to formulate a product  with  a
      large number of ingredients.  Included in this tankage and  equipment  is
      a wet grinding operation which allows particle-size product to be
      reduced.  This product is packaged in the warehouse.
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     There is a single vehicle access road to the facility.   In  the
            event of a fire with north or northwesterly winds, incoming
            responders could be exposed to a chemical plume.

      •     Two rail service crossings to the west of the facility are
            periodically blocked and could cause problems for responders or
            for personnel trying to leave the area in the event of a release.

      •     No formal vulnerable zone calculations have been done by the
            facility or local hazmat personnel, although the materials  of
            concern and the affected media have been identified.

      Chemical Hazards

      •     The principal high hazard materials are the technical grade
            pesticides -- the most toxic of which is Dyfonate.

      •     There is a significant flammability hazard since many of the
            pesticide commercial formulations include organic solvents or
            petroleum fractions.  Some traditional flammable or combustible
            solvents used as dilutents or carriers for the products have been
            replaced by water-based emulsifiers.

      •     The facility provides a comprehensive system of MSDSs, available
            in the management area and for the employee's use.  MSDSs are
            arranged alphabetically within five use categories.

      •     The plant requires an annual physical examination for employees in
            hazard areas, a wellness testing program for fitness and health
            improvement, and an industrial hygiene monitoring program.

      •     The quality of the MSDSs provided by some vendors is poor,  and
            there does not appear to be a process in place for obtaining
            updates from vendors, reviewing the MSDSs,  or following up.on
            those that are inadequate or incomplete.
                                      257

-------
Process Information

•     There is extensive electronic sequencing  of  controls  to  prevent
      inadvertent operational errors.

•     The hazard labeling system for storage and daily-use  process  tanks
      is the American National Standards for the Precautionary Labeling
      of Hazardous Industrial Chemicals, not the NFPA  704 system
      familiar to response personnel.

•     Highly piled stock .'n the warehouse may inhibit  sprinkler
      operation by shielding the lower pallets  and their contents from
      the sprinkler discharge.

•     Management and storage of returned merchandise,  including obsolete
      and damaged goods returned without notice, appears to need
      improvement.  The facility lacks adequate physical space and SOPs
      to promptly pack, store, and inventory this material  for future
      recycle, transfer, or disposal.

•     The facility is using a standard pesticide-industry hazard marking
      system with black and white labels applied to most tanks.  These
      labels would not be clearly visible to personnel effecting rescue
      or fire operations during an emergency.

•     During the audit, none of the railroad tank cars had any
      identification on them to indicate whether they were full or
      empty, or what the hazards of the contents might have been.

•     Facility efforts to reduce hazards include clearing and widening
      forklift and other travel aisles.

•     The facility maintains an area for employees with separate break
      and lunch rooms.  No entry is permitted into the lunch area
      without showering and changing clothes.

•     All bulk finished product loading racks have independent checks of
      both volume and weight of material.

•     Although the facility ships in bulk containers, they do not  allow
      loading from bottom outlets to minimize release potential as well
      as volume spilled.

•     Process areas and ground were clean with no visible stains,  odors,
      or evidence of vegetation harm.

•     The facility maintains a set of colorimetric tubes for on-site
      monitoring, but no specific procedures for off-site monitoring
      during a release incident have been established.

•     The most dangerous air release problems will likely be as a  result
      of a fire at the facility.

                                258

-------
Chemical Accident Prevention

•     There are 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
      include required safety gear and cautions  for the specific tasks,
      are used for training purposes, and are routinely evaluated.

•     Cross-training of plant personnel on all process activities is
      carried out to produce a more comprehensive understanding among
      employees of all specific process tasks.

•     There is extensive use of secondary containment  for liquid
      materials and similar protective devices for transfer lines and
      exposed utility and water service connections which might be
      damaged by rail, truck, or towmotor traffic.

•     The LEPC and the facility have not performed a quantitative hazard
      assessment of the potential for potential exposure of the zoo or
      school atop the bluff to the west.

•     The facility has prepared a comprehensive hazard communication
      program based on a corporate model.

•     Incoming raw material tanks are physically separated from the
      finished product storage tanks in separate tank farm areas.

•     Surface runoff paths have been identified and holding ponds  are in
      place to control runoff from a spill or fire incident.   The  north
      tank farm is adjacent to an emergency runoff pit, to which all
      material can be diverted in the event of an emergency.   There is
      also a runoff pit located on the south end of the plant.

•     Appropriate switches have been wired to operate only in the
      correct sequence to reduce the likelihood of environmental
      discharges and tank overflows.

•     A formal safety review system has been established,  consisting of
      collection and evaluation of plant safety statistics,  job  injury
      analysis program, and monthly injury summaries,  provided to
      management for discussion with employees.

•     There is a formal inspection/audit process examining housekeeping
      items as well as identifying potential deficiencies  in operating
      units based on maintenance records and experience.   These
      observations have resulted in formal commitments  to  purchase
      equipment, to conduct investigations into process improvements,
      and to develop a continuing waste minimization program.

•     The facility has a well-documented training system,  conducted  by
      the foreman based on a topics list developed by plant  management.

                                259

-------
•     Safety meetings are conducted by the foreman and maintenance
      supervisor, and the plant superintendent holds plant-wide  safety
      meetings at least quarterly.

•     The facility maintains an incentive program to reward good safety
      performance by employees.

•     The job task analysis program serves as the basis for identifying
      training needs, and is coordinated during weekly meetings  of  the
      plant superintendent and training personnel.

•     There is a formal safety suggestion program, and management policy
      is to provide a written answer to all suggestions.

•     Training and orientation to facility hazards is also required for
      all contractors entering the facility and is specified in  their
      hazard communication program documentation.

•     All plant process equipment is checked weekly and recorded on a
      formal basis, including close visual inspection of pumps and
      associated piping.

•     Maintenance personnel conduct a documented inspection of the
      facility hardware, including valves and pipes to and from  the tank
      farms, on a weekly basis.

•     The facility has a detailed waste management plan for collection
      and disposal of pesticide  contaminated packages,  rags,  and minor
      process wastes.

•     Staff outline activities to evaluate or mitigate potential
      incidents in an annual Safety, Health,  and Environmental Plan.
      The 1990 plan included the following proposed actions:

            HAZOP reviews for various process units;
            Investigation of wastewater treatment options;
            Investigation of better release prevention systems for the
            tank truck unloading stations;  and
            Comprehensive review of fire protection for the warehouse
            production room.

•     SOPs for emergency shutdown of process  areas contain as  many as 10
      separate actions on the part of the operator and may involve
      significant additional risk for process operators attempting to
      comply with this guidance.

Accidental Release Incident Investigation

•     The facility has operated since 1955 without a significant release
      of hazardous materials, and since 1982  without any employee
      exposure resulting in lost time.
                                260

-------
•     No procedures are specified for  investigation or documentation  of
      off-site releases.

Facility Emergency Preparedness and Planning Activities

•     Training includes not only process safety, but also respiratory
      training, fire suppression, and  spill mitigation.

•     Respirators are issued to all employees in process areas, and are
      washed daily and provided with new combination cartridges.  The
      facility's current practice of once-a-year SCBA use does not
      appear adequate for response personnel to become proficient in  its
      use.

•     In areas where small leaks or spills might occur, absorbents, dry
      vacuum systems, and marked storage containers for holding spilled
      product prior to recycling are present.

•     The facility has a comprehensive emergency response plan (ERP)
      which was last updated in August 1990.

•     The ERP identifies plant responsibilities and resources and
      includes procedures and contacts for obtaining corporate resource
      support and assistance.

•     While the ERP is comprehensive for incidents occurring during
      operating hours, the plan does not sufficiently cover incidents
      occurring at other times.  Significant delays are possible until a
      designated responsible employee is contacted.  Currently,  the
      local fire department plans to remain outside the facility during
      an emergency until responsible plant management is  present in
      order to protect responders;  this action,  coupled with a delay in
      the arrival of responsible plant management,  may result in
      substantial product release,  facility damage, or environmental
      harm.

•     A review of both the SPCC plan and the emergency response  plan
      disclosed an apparent discrepancy about the normal  open/closed
      status of valves in the north supplemental holding  pond.
      Discussions between plant management and maintenance  personnel
      indicated that there was some confusion due to concerns over
      management of normal runoff.

•     The ERP states that evacuation will occur in an upwind direction,
      but the plan sketches show employees evacuating to  a  location
      which, with prevailing winds,  can be expected to be downwind.

•     Many new responsibilities, assigned to pre-existing plant
      personnel positions, have been given additional titles in  the  ERP
      (e.g., Bomb Threat Director)  that do not correspond with  the
      regular job titles.
                                261

-------
•     The facility conducts annual fire and chemical  release  drills  that
      include deployment of mitigation materials and  use of PPS  and
      respiratory gear for employees with these responsibilities.

•     The ERP identifies a sequence of alert signals  for evacuation  as
      well as an audible, plant-wide paging system and  the persons
      responsible for managing evacuations in each process unit.

•     Evacuation routes do not adequately take into account the
      potential for increased risk as a result of long  distances or
      crossing hazardous ..reas between work station and control  areas.

•     The plant engineer is responsible for maintenance of the fire
      suppression equipment.  Periodic checks and tests appear effective
      in maintaining in-house response capability.

•     Spill control and recovery equipment is well stationed around  the
      facility and appears to be ready for use.

•     A series of incoming and outgoing phones are provided with power
      failure switches to facilitate communication during an emergency.
      There is also a cellular phone for security personnel.

•     There is a diesel emergency fire pump,  drawing water from the  fire
      service mains, in the event that an emergency causes disruption of
      water service inside the plant.

•     The ERP provides emergency shutoff and restoration procedures  for
      water, electrical, and natural gas supplies.

•     Basic emergency procedures call for the facility shift  foreman to
      take charge immediately and for the plant manager and/or
      superintendent to be notified as soon as possible.

•     The facility maintains a facility phone/paging system with
      emergency capability and a clear set of operational instructions.

•     Phones which receive only and those with limited outside lines  are
      potentially confusing in times of emergency unless such  phones  are
      clearly labeled as to their capability.

•     Certain facility employees have.been trained in accordance  with 29
      CFR 19101.120(q) requirements,  but no specific documentation,
      including training materials, was provided to the audit  team.

Community and Facility Emergency Response Planning Activities

•     There has never been a joint exercise involving the local fire
      service or other emergency responders and facility personnel.
                                262

-------
•     Although the facility carries out rapid, personal  response  to
      neighborhood complaints about odors, the facility  has  no  regular'
      scheme of groundwater monitoring.

•     The facility undertook an extensive effort to plant  decorative
      vegetation to reassure residents that no damage  to adjacent
      gardens was occurring.

•     The facility has met with adjoining industry to  discuss and
      coordinate incident response.

•     The facility has invited neighboring industries  and  residents on
      the nearby bluff to annual open houses and facility  tours.

•     The assistant to the plant manager is an industry  representative
      to the Omaha LEPC.

Public Alert and Notification Procedures

•   .  Notification of a significant release at the facility would be to
      the fire service through normal 911 procedures.

•     There is no schedule for testing notification procedures.
Recommendations:

Facility Background Information

•     The facility should identify and quantify potential release
      scenarios through a formal vulnerability calculation, and develop
      plans to manage such a release if it occurred.  In particular, ICI
      could evaluate the hazards to workers and to the general
      population by quantifying release constituents, both on and off-
      site.

Chemical Hazards

•     For more effective use by employees or local planners and
      responders, the MSDS package could be improved by providing
      additional information on quantity on hand,  container types,  and
      specific on-site location.

•     Vendors providing incomplete or outdated MSDSs should be contacted
      and more comprehensive information on material contents and
      protective measures should be requested.

Process Information

•  .   Experts in the field are currently requiring the entire design
      scenario for fire protection of high piled stock.   ICI should
                                263

-------
      recognize this problem at their facility and plan  for
      modification, when new codes are approved.

•     Plans for off-site air exposure monitoring  in  the  event of  a
      release should be supported.

•     The facility should consider use of the color-coded NFPA  704
      hazard identification system for each building and storage  tank  to
      assist local response personnel by making labels more visible
      under response conditions.

•     Based on the visible problems that returned products have made in
      the new finished goods storage facility, these products should be
      logged and consolidated in a separate detached storage and
      handling area.

•     Although it is possible that all the railroad cars were empty at
      the time of the audit, in the event of an emergency,  there should
      be a positive indication of their contents readily visible.

Chemical Accident Prevention

•     ICI should review and simplify its process emergency shutdown SOPs
      to provide for more rapid evacuation of potential hazardous  areas.
      Relocation of electrical controls or installation of a single
      master control for electrical service for each process area  would
      solve most of the problem.

Facility Emergency Preparedness and Planning Activities

•     The evacuation plan should be modified to take into account  the
      potential for differing weather conditions and long escape routes
      for certain employees.

•     Personnel expected to use SCBA apparatus during a release  incident
      should use full tank of air (20 minutes) no less  than bimonthly/
      monthly while performing typical work tasks.

•     Discrepancies between the Spill Prevention Containment
      Countermeasures (SPCC) plan and* the ERP about the status of  valves
      and gates on the north holding pond should be reconciled.  The
      facility should conduct an internal review of appropriate
      procedures and change in the documentation to promote  consistency.

•     New titles attributed to existing positions should be  eliminated;
      it might be more useful to  continue to identify these  persons by
      their regular job title.

•     Facility personnel and local fire forces may want to  jointly
      review the facility plan and consider possible  improvements  in
      response capability during non-operating periods.
                                264

-------
      •     The facility should schedule an on-site or table-cop joint
            exercise with plant and fire service personnel to provide an
            opportunity to evaluate existing procedures.

      •     The facility should consider contacting on-call personnel, perhaps
            by pagers, to reduce notification and response times.

      •     ICI should simplify its phone system or make portable cellular
            service available during an emergency.  Existing phones should be
            labeled as to their capabilities.

      •     The facility.should identify specific 29 CFR 1910.120(q)
            competencies and should list the training content for each
            competency.  Where paragraph (1) or (p) training is used to
            satisfy (q) requirements,  this should be stated in the records.

      Community and Facility Emergency Response Planning Activities

      •     There should be a joint, on-site exercise involving local fire
            department and facility personnel to evaluate the ability of these
            groups to effectively coordinate a response incident.
Audit Team Member Composition:

Name and Title                Bill Keffer
Affiliation                   US EPA Region 7
Area of Responsibility        Emergency Planning and Response
Expertise                     N/A

Name and Title                Alan Cummings
Affiliation                   TAT, US EPA Region 7
Area of Responsibility        N/A
Expertise                     N/A

Name and Title                Tammie Holley
Affiliation                   NE Department of Environmental Control
Area of Responsibility        N/A
Expertise                     N/A

Name and Title                Clark Smith
Affiliation                   NE Department of Environmental Control
Area of Responsibility        N/A
Expertise                     N/A

Name and Title                Captain Paul Liebman,  Hazmat Coordinator
Affiliation                   Omaha Fire Department,  Region 7
Area of Responsibility        N/A
Expertise                     N/A
                                      265

-------
Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Dedriel Newsome
US EPA Region 7 - Des Moines, IA, office
RCRA
i\/ A

Kathleen Fisher
TAT, US EPA Region 7
N/A
N/A

K-^n Gruber
Omaha Fire Department Hazmat Team
N/A
N/A

Peter Jennings
Orsaha Fire Department Hazraat Team
N/A
N/A

Mike Rueb
Omaha Fire Department Hazmat Team
N/A
N/A

Elisa Nissen
Omaha Fire Department Hazmat Team
N/A
N/A
 Follow-up Activities:

       By the facility:

       By the Regional office:

       By State and  local authorities:
 Region  Contact:
Bill Keffer
                                      266

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Jacobson Warehouse Company,  Inc.
Facility Location:
Des Moines, Iowa, Region 7
Date(s) Audit Conducted:
November 20, 1990
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
5191 -- wholesale trade-nondurable goods

Northeast side of downtown Des Moines,
Iowa.
Storage of end-product insecticides,
herbicides, fumigants,  and fungicides.  No
materials are processed or repackaged in
this warehouse facility.
Located in a commercially zoned area that
borders single family homes.
Reason for Facility Selection:
      ARIP Reports:

Focus of Audit:

      Hazardous Substance(s)
      Examined:
An audit of the Jacobson facility was
requested by the Des Moines fire
department to determine the impact of a
potential release on the adjacent
population and to learn more about
response methods for warehousing and
storage of agricultural products.

None
Phosphine
Permethrin
Carbaryl
Atrazine
Picloram
Me thorny 1
                                      267

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      The Jacobson facility includes 185,000  square  feet  of  warehouse
      and office space used to store finished agricultural chemicals
      (mostly pesticides) and some process intermediates.  The warehouse
      is used for storage only;  no processing,  formulation,  dispensing,
      or repackaging is conducted on site.  It  is divided into distinct
      areas including the shipping/receiving  docks,  a flammables  storage
      room, a corrosives storage room, office areas, and  other storage
      areas.  These other storage areas are separated based  on
      recommended minimum storage temperatures,  flammability, toxicity,
      corrosivity, and other requirements.  The  storage areas include
      heated storage for highly toxic compounds, heated storags for less
      toxic compounds, and unheated storage for  less toxic compounds.
      Most of the pesticides are stored either  in palletized, 50-pound
      bags or in one- to five-gallon liquid containers.   Some
      intermediates are stored in 55 gallon drums which are  primarily
      housed in the flammables vault.

      The heated storage area for highly toxic compounds  (those
      chemicals requiring a poison label) is  located in the  northernmost
      section of the warehouse adjacent to the other heated  storage
      section and to the flammables storage room.  The heated storage
      area for less toxic compounds may be accessed  through  an overhead
      rollup door usually left open.  Fork lifts negotiate between this
      section and the adjacent unheated storage area through striated
      clear, heavy plastic drops over the doorway.  The unheated storage
      area can be accessed via concrete ramps that go over the secondary
      containment blocks near the loading docks.  The flammable storage
      area is accessible through the unheated storage area for less
      toxic substances and from two exterior doors on the west side of
      the warehouse.  The corrosive storage area is  isolated from the
      other storage areas, but remains within the warehouse structure.
      The floors throughout the storage areas are smooth-finished
      concrete.  Walls are poured concrete and/or filled concrete block
      with exposed steel columns and bar joists supporting a Q-deck
      roof.  Non-masonry portions of the walls are completely
      sheetrocked with taped seams.

 •     Shipping /Receiving

      The facility maintains a computer data base on shipping and
      receiving information for a given product name.  Shipping and
      receiving procedures take place at an indoor truck dock area using
      fork lifts to load and unload trucks from the dock to  the
      warehouse.  Almost no materials are transferred at this facility,
                                268

-------
            the sole exception being the collection  and  overpacking of
            materials and equipment after a release/spill  has  occurred.
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     A reasonably flat surrounding terrain provides good drainage.  The
            area receives moderate snowfall and  icing conditions during
            winter, but the facility's construction seems sufficient  to bear
            the imposed weight of snow-loading.

      •     Emergency responders may approach the area from either the north
            or the south using major transportation routes to avoid proceeding
            through a potential release plume.   Access to the facility itself
            lies to the west, north, and south.  Swails and berms located
            along the west side of the warehouse, as well as several usable
            railroad tracks, make continuous access difficult.

      •     The Des Moines Fire Department has identified off-site vulnerable
            zones with information supplied to them by the Jacobson facility.

      Chemical Hazards

      •     Chemical hazards at the facility vary seasonally based on the
            demand for agricultural product storage, making exact product -
            specific hazards difficult to calculate.

      •     Jacobson personnel werft not aware of the potential for fire
            conditions to create large quantities of toxic gas such as
            hydrogen chloride (or other decomposition products of stored
            chemicals) which could affect workers and.off-site personnel.

      •     Jacobson maintains, a complete MSDS library and public right-to-
            know information center in the shipping and receiving office.   The
            information center contains Tier II  information as well as hard
            copies of the MSDSs stored alphabetically by trade name in
            binders.  Not all of the MSDS sheets had been reviewed or updated
            to the most current version by knowledgeable staff.   Although the
            center also contains a computer data base of hazard information
            for use by facility employees, Jacobson does not offer facility
            training on the data base.

      •     Facility personnel do not have the expertise to review MSDS
            information for accuracy.  Several MSDSs contained "boiler plate"
            information concerning personal protection equipment (e.g.,  wear
            gloves, but does not specify type) and compatibility provisions.
            For example, the facility keeps nitrile gloves on hand for spill
                                      269

-------
      cleanup,  although such gloves do not provide sufficient protection
      for symmetrical triazines (which are stored in the warehouse).

•     All employees have had a cholinesterase level blood test, but are
      not part of a continuous medical monitoring program.  At the
      present rate of one minor release per month requiring cleanup,  it
      is uncertain that a medical monitoring program would be required.

Process Information

•     Stored materials ar- segregated by hazard; those classified as
      major hazards are separated by rated fire walls and or^nings.

•     Storage areas are clean and well lit by the combined illumination
      of skylights and artificial lighting.  Aisle widths are sufficient
      for forklift operation and are well marked for maintenance.  Floor
      markings clearly outline the layout of the storage areas,
      identifying each by means of a numbering system.   Piled stock
      appeared stable, well organized, and reasonable in height.   Pile
      separation was sufficient for visual inspection from the aisles
      for easy leak detection.

•     Approximately 100 five-gallon metal containers and several 2.5-
      gallon palletized plastic containers, all with DOT hazard labels
      attached and completely empty, were stored in the warehouse.
      Apparently, manufacturers were storing these containers until
      needed.  Transportation of empty, labeled containers to and from
      the warehouse is a violation of 49 CFR 172.401(a)(1);  storage of
      such containers is not a violation, but it provides employees and
      responders with inaccurate and confusing information.

•     Stacks of palletized, 2.5-gallon containers containing a pesticide
      were wrapped in translucent plastic that virtually obscured the
      DOT hazard labels on each container.   Transportation of these
      pallets would violate 49 CFR 172.406 (f);  storage of these  pallets
      with obscured labels is not in violation,  but is  potentially
      misleading.

•     Operation of the warehouse was consistent with the facility's
      written SOPs.  Release prevention steps begin with container
      inspection, continue with forklift safe operation and  properly
      maintained storage and aisle areas, and end with  shipping
      procedures.

•     A written SOP for shipping and receiving covers accurate
      inventory, receiver accountability, and responsibilities during
      the unloading process.  It also stipulates that:

            Truck wheels be chocked before forklift operation inside  the
            truck; and
                                270

-------
            Damaged freight can either be accepted or refused depending
            upon ownership of the product, but  it does not help  identify
            the significance of a given release or the sequence  of
            response actions.

      The facility did not have an SOP to prevent loading pesticide
    .  materials with other materials  (e.g., food, clothing) on trucks
      receiving goods from Jacobson for distribution.  There are no
      references in the SOPs to placarding requirements of trucks when
      loading has been completed.

•     Between four and seven personnel work in  the warehouse area.
      Forklift operators were the only persons normally operating in the
      storage areas, and, although not written  into any of the observed
      SOPs, they use the "buddy system."

•     Ambient air characterization in the storage areas has not been
      documented.

Chemical Accident Prevention

•     Corporate management has been active in developing comprehensive
      standards for agricultural chemicals storage and handling.
      Jacobson is involved in the Mid-West Agricultural Chemicals
      Association's (MACA) efforts to develop industry standards  for
      storage structures, to minimize potential public exposures, to
      evaluate mitigation systems, and to examine health and safety
      issues.  The draft document prepared to date has been used  by the
      audit team at other locations, and recommended to a variety of
      local governments for their use in auditing hazardous storage
      warehouses.

•     Jacobson has a peer review program in which facility managers
      periodically evaluate each other's facilities,  training,  and
      preparedness programs.

•     Supervisory personnel conduct weekly facility inspections using a
      pre-specified checklist to look for incompatible storage, leaking
      containers, dangerous stacking conditions, and other potential
      problems in the warehouse.  Observations from these inspections .
      are formally recorded.

•     Facility management conducted a self-audit using a  "Survey  Form
      for Public Warehousing" developed b> Safe Agricultural  Chemicals
      Storage (SACS) of the National Agricultural Chemicals Association
      (NACA).  This inspection form allows personnel  to  rate  their  own'
      facility in eight areas, determine adequacies and weaknesses,  and
      take appropriate actions for improvement.   The  survey  tabulation
      sheet provides a clear picture of deficiencies  requiring action to
      raise overall safety.  Each area is appropriately weighted  with
      its importance to overall chemical safety.
                                271

-------
Jacobson provides a training manual  chat  covers  cen  programs.
Mosc of the training occurs twice each year  to coincide  with  non-
peak seasonal activities and is taped so  that employees  unable  to
attend receive the same training at  a later  time.  Training
materials include chemical industry  material, internal policy and
SOP training, and materials from the Des  Moines  Fire  Department
Hazardous Materials Coordinator.  A  complete training file  is
maintained for each employee, along  with  training  test results.
Health and safety training needs further  improvement.  Employees
are not adequately trained to recognize the hazards  of the  stored
materials or to mitigate releases of these materials.

Facility personnel are briefed on the stored materials and  their
hazards.  Each employee that receives this training  signs a form
kept in the facility's training files.  Temporary  employees
obtained for seasonal peak times are assigned to the  non-hazardous
areas to free up regular trained employees for hazardous materials
handling.  In this way, Jacobson ensures  that only trained
employees work with hazardous materials in the warehouse.

The Des Moines Fire Department used  the Macintosh  CAMEO ALOHA
program to provide air release plume modeling.   The modeling
assumed a catastrophic air-release and identified  a potential off-
site downwind vulnerable zone of .4 miles.  Because of the  small
container storage, vulnerable zone calculation indicates that
primary hazards would be contained on site.

The largest factor present to reduce the  seriousness  of a
potential release is the small size of most of the individual
containers stored in the warehouse.  Most granular solids are
stored in palletized 50-pound bags and most liquids are stored  in
2.5-gallon containers.

Heating ducts for the flammable storage area are dampered with
fusible link controls, and the heating plant is outside of  the
flammable liquids room.

The warehouse was designed as a 500,000-gallon secondary
containment system of solid concrete block and silicone seams.
This bermed area will hold a continuous 1.5-hour discharge of all
ten sprinkler systems or a 14.8-hour discharge  of one sprinkler
system.  Should the berms be overwhelmed,  all runoff  from the
warehouse will collect in a "bermed swail" on the west side of the
facility adjacent to the railroad track.   The berraed swail was
formed by grading this grassy area and placing  a small dike at the
down gradient to provide for temporary holding  of additional
runoff water.  Runoff storage in this location  would prevent
uncontrolled discharge direct to area sewers but could represent a
threat to groundwater.

The flammable storage area has a separate, 18,000-gallon flammable
liquid recovery system that removes released flammables from the

                          272

-------
      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.

•     The flammable storage area and the heated storage  areas for highly
      toxic chemicals and for less toxic chemicals are surrounded by
      four-hour non-parapet fire walls, and three-hour fire  rated rollup
      overhead fire doors normally in the  "open" position and
      automatically closed by fusible links.  These areas are fully
      sprinkled.

•     The flammable storage area is an individual zone for  the  sprinkler
      system with the riser and valves located outside the room.  It has
      a two-hour rated ceiling completely  seamed below the Q-deck roof.
      Recovered spilled materials are overpacked and stored  in  this
      section until they can be returned to the manufacturer for
      recycling.

•     There are no apparent means of detecting a leak or spill  after
      hours.  Interior smoke or fire alarms are not provided at the
      facility.  The building perimeter is alarmed and the security
      company responds if this intrusion alarm sounds, but additional
      response and notifications are not specified in the plans.

•     Emergency plans stipulate that storm sewer openings should be
      diked if the previous containment provisions are in danger of
      being overwhelmed.

Accident Release Incident Investigation

•     The only reported release occurred on April 15,  1988,  when two
      2.5-gallon containers fell from the back of a delivery truck
      releasing five gallons of Amine 4.   The released material  was
      confined to the dock area, sorbed and overpacked by facility
      personnel, and returned to the manufacturer for  recycling.  No
      off-site hazard existed during the accidental release.

•     Facility plans specify that all incidents will be investigated and
      appropriate reports will be submitted within the time  allotted by
      regulation.  The local LEPC has developed a specific  incident
      report form for facilities that provides  for notification  of the
      state and the NRC.

Facility Emergency Preparedness and Planniag Activities

•     Jacobson regularly revises and updates their emergency response
      plans.  The Des Moines Fire Department has copies of  these plans
      on file in its Dispatch Center and Hazardous Materials vehicle.

•     Facility plans do not provide for personal protective  equipment,
      monitoring equipment, or personnel training to determine the
                                273

-------
nature or quantity of gases  that might  be  generated  due  to  a
release involving fire.

Evacuation corridors are sufficient  both  in  numbers  and  location
throughout the facility, and exit markings are  readily
identifiable under normal operating  conditions.   Personnel
operating in the warehouse seem very familiar with all egress
locations.  Fire department preplans correctly  indicated all
exterior building openings suitable  for use  for  rescue and
firefighting operations.  Visitors are  only  allowed  in the
warehouse when accompanied by facility  personnel, and therefore
should have no difficulty accessing  the closest  exit should an
emergency arise.  Plans do not identify a planned meeting point
for roll call after an evacuation.

An emergency exit door was partially obstructed  by piled stock
during the audit.  No stairs were present outside the facility
behind the door, and the drop from door level to ground was
approximately four feet.  Floor markings for potential storage
areas were such that partial blockage of these doors could be
possible during peak storage times.

Jacobson maintains supplies and equipment sufficient to handle
leaking containers and small releases.  Sorbent materials,
shovels, vacuum cleaners, and overpacks are placed throughout the
facility in designated areas for quick  access, and are clearly
labeled.  Small spills and leaking containers are overpacked and
returned to the appropriate manufacturer.

Fire emergency equipment includes numerous, properly installed,
and well-marked fire extinguishers.   Personnel records indicate
that all employees are trained in the proper operation of the
portable extinguishers.  All fire extinguishers checked by audit
team members had been inspected within  the past 30 days.   Red
panels visible above warehouse piled stock indicate the location
of the closest fire extinguisher.

A ten-zone automatic sprinkler system provides emergency fire
suppression.  The sprinkler is monitored, and when activated,
triggers an alarm on a monitored central station.  Proper
notifications are then assumed to be made by the alarm company.

Air purifying respirators (APR) are used during spill cleanups,
but no documentation exists to identify respiratory hazards  or
material concentrations present during cleanups.  Jacobson has
just purchased self-contained breathing apparatus,  but no
procedures exist to indicate when SCBA would be used, procedures
for downgrading to APRs, or confirmation of cleanup levels.

Neither emergency plan addresses emergency response procedures
after normal working hours.  Although both business and home phone
numbers are listed in the emergency phone listings,  procedures  for

                          274

-------
notification are not listed.  For instance,  if a  fire  were  to
occur after hours, the plan implies that the alarm  company  would
notify both the fire department and an emergency  contact  for the
facility.

SOPs for spill and fire responsibilities exist, facility  personnel
have received training, and the plans are exercised annually.   In
both the fire and spill plans, fire department personnel  are to
assume control of an incident, but criteria  for control transfer
and persons responsible for causing such transfers  are not  listed.

SOPs for the.spill response plans list the agencies  to be notified
in case of a release, but do not assign responsibility for
differentiating between minor and reportable releases.  In
addition, the spill response plan does not state  who is
responsible for assuring that evacuation of  the area and product
identification are accomplished.

The wording of the fire emergency response plan is  also ambiguous.
The plan does not address notification of the warehouse manager.
The plan is misleading when it states thaT Jacobson's position  is
"to continue to fight a fire until the facility's roof collapses."
This would appear to mean that facility personnel would combat  a
blaze until the structure collapses.   Instead,  the statement
probably intended to state that Jacobson will not turn off active
sprinklers until the fire department so orders or the structure
collapses.

Other than "word of mouth",  there were no apparent communications
links between fork lift operators and personnel working in the
shipping/receiving office.  Office areas have a telephone/intercom
capability.  Emergency operations are conducted via telephone,
somewhat limiting communications  capabilities.

All employees are trained in containment, 'recovery,  and
overpacking skills.  There are no regular drills  to practice spill
control and clean-up operations.

Jacobson health and safety staff  were not aware of the  need for,
and the elements of,  a complete respiratory program, but had
purchased self-contained breathing apparatus (SCBA)  for their  in-
house response program.

SOPs are weak in defining selection of personal protective
equipment, proper donning and doffing of this equipment, and
decontamination of personnel and  equipment.   Chemical protective
footwear is not specified in existing SOPs.

Jacobson personnel appear well trained in spill control and
product recovery.  Procedures indicate that spills are  evaluated,
appropriate control measures are  instituted,  product manufacturers
                          275

-------
      are contacted, and the release material  is recovered  and  returned
      to the manufacturer for recycling or disposal.

•     Jacobson's initial emergency response plans were deficient  in
      health and safety considerations.  The plan 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.

Community and Facility Emergency Response Planning Activities

•     Jacobson personnel have responded to right-to-know  questions,  but
      have no specific outreach program in place with the community.

•     There are no references in the spill emergency plan to release
      documentation or to reports to state and federal agencies,  other
      than requirements for filing necessary reports with local
      officials.  The plans are vague in establishing specific
      responsibilities for achieving rep vting requirements.  This
      procedure is known by facility personnel, but not listed  in
      facility SOPs.

•     Local response organizations have not participated  in facility
      exercises.

•     The facility has coordinated well with loca"  emergency response
      officials.  Fire department inspectors and  ^zardous materials
      specialists had significant input into the structural and system
      design.

•     The fire departzent has initiated pre-planning inspections
      conducted by personnel from "first in" fire companies including
      the fire department hazmat team and Jacobson personnel.

Public Notification

•     The Jacobson facility has no provision in place for public  ilert
      and notification.  Instead, public notification would be provided
      by emergency responders coordinating with the on-scene fire
      department public information officer.

•     Jacobson has not had a release that was reportable to local
      emergency authorities, making assessment of the notification
      procedures difficult.  Because of Jacobson's  practice of small
      container storage, releases have been minor and hazards  associated
      with the  releases have been limited to the site.   Cleanup of these
      releases were handled by Jacobson personnel with manufacturer
      advice.   Fire department notification was provided during or after
      the mitigation.
                                276

-------
Recommendations:

Chemical Hazards

•     Jacobson should consider reviewing each MSDS  as  it  is  received
      from the manufacturer, and collect specific  information,  such as
      clothing compatibility information,  from  either  the  manufacturer
      or a health and safety consultant.

•     Jacobson could consult an occupational physician specializing in
      pesticides to evaluate employee health and safety during  normal
      warehouse conditions, to suggest a medical monitoring  program
      suitable for the facility, and to develop a comprehensive
      respirator and protective equipment  safety program.

Process Information

•     Jacobson management may want to contact the product  manufacturers
      to find a solution to the container/hazard labeling  problems.

•     The facility may want to consider performing  air  and personal
      monitoring in the warehouse to establish normal worker exposures
      and background levels for spill cleanup activities..  Documentation
      of past minor releases requiring respirator use may  be helpful in
      making this determination.

•     Shipping SOPs should include a specific reference to the Spill
      Containment/Cleanup Procedures for proper identification of a
      given release and the appropriate sequence of response actions.
      The shipping SOPs should also reference loading compatibility and
      proper vehicle placarding procedures.

Chemical Accident Prevention

•     In addition to their weekly facility inspections, Jacobson may
      want to consider weekly, documented  inspections concentrating on
      the effectiveness of current storage conditions and operating
      procedures.  The checklist for such an inspection could include
      specific storage requirements by hazard category for each storage
      location in the facility.

•     Additional health and safety training based on 29 CFR 1910.120
      requirements and including basic chemistry,  toxicology, and use  of
      select personal protective items should be included in the
      facility training package.

•     Facility management should meet with the local fire officer to
      discuss improvements for release and fire detection and
      notification after normal working hours.   Interior alarms  could  be
      added to existing intruder alarms or connected directly to fire
      service dispatch centers.
                                277

-------
      Facility Emergency Preparedness and Planning Activities

      •      Jacobson should revise its plans to include procedures for
            emergency response after normal working hours.

      •      Spill and fire emergency response plans should identify primary
            and secondary meeting points for employee accountability after an
            evacuation.

      •      Jacobson should avoid potential blockage of exit doors during peak
            storage times, and should consider installing stairs outside the
            exit door noted.

      •      Jacobson management should consider upgrading their spill response
            plan to include assignment of responsibilities and more specific
            training on health and safety information.   Jacobson may also want
            to rewrite the fire emergency response plans to include a more
            detailed list of fire emergency activities  and responsibilities.
            The facility should conduct regular internal response drills, and
            drills with local fire forces to improve response preparedness and
            to practice spill control and clean-up operations.   Des Moines
            Fire Department personnel offered to assist Jacobson in developing
            a more comprehensive plan in conjunction with fire  department
            preplans.

      •      The facility may want to consider installing an intercom in
            storage areas to allow prompt reporting of  problems,  including
            employee injury.   Portable radios,  intrinsically safe for
            flammable storage areas,  could be another alternative for storage
            area workers.

      •      Training on personal protective equipment should be more
            comprehensive.

      •      Jacobson should consider updating the  emergency contractor  listing
            to include documentation of licensing  and training  for recovery
            and disposal of hazardous materials.
Audit Team Member Composition:

Name and Title                William Keffer
Affiliation                   EPA Region 7
Area of Responsibility        Emergency Planning and  Response
Expertise                     N/A

Name and Title                Alan Cummings,  TAT
Affiliation                   Ecology and Environment,  Inc.
Area of Responsibility        N/A
Expertise                     N/A
                                     278

-------
Name and Title                Kathleen  Fisher,  TAT
Affiliation                   Ecology and  Environment,  Inc.
Area of Responsibility        N/A
Expertise                     N/A

Name and Title                Ron Kozel
Affiliation                   Iowa  Department  of  Natural  Resources
Area of Responsibility        N/A
Expertise                     N/A

Name and Title                Randy Lane
Affiliation                   Iowa  Department  of  Natural  Resources
Area of Responsibility        N/A
Expertise                     N/A

Name and Title                Matthew Woody
Affiliation                   Des Moines Fire  Department/Hazmat Unit
Area of Responsibility        N/A
Expertise                     N/A
Post-Audit Follow-Up Activities:

      By the Facility:

      The facility has updated  their shipping SOPs to cover compatibility of
      loaded materials with materials already present on trucks and proper
      placarding requirements of loaded trucks, and has provided training to
      their employees on this issue.

      Jacobson management  is upgrading their emergency response plans to
      include specific assignment of responsibilities, and is coordinating
      this plan development with the local fire department hazardous materials
      team and codes inspection personnel.

      Jacobson has revised their spill and fire emergency response plans, with
      the help of the Des  Moines fire service and state response personnel,  to
      improve health and safety training and response planning.

      Spill and fire emergency  plans have been updated to include primary and
      secondary meeting points  for employee accountability.

      Jacobson has built exit stairs outside the building for all doors.

      Jacobson management  has since updated the emergency contractor listings
      to include licensing and  training capabilities with the assistance of
      local agencies and the Iowa Department of Natural Resources.

      By the Regional Office:

      None planned unless  requested by facility, or state and local
      responders.

                                      279

-------
      By State and Local Authorities:

      The Des Moines fire service and state response personnel are actively
      assisting Jacobson in hazmat planning,  preparedness,  and response
      upgrades and will include Jacobson in announcements of training provided
      by state and local forces in the Des Moines area.
Regional Contact:             Bill Keffer
                                      280

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:


Facility Location:
Amoco -- Casper Refinery
Casper, Wyoming, Region  8
Date(s) Audit Conducted:
June 26 - 29, 1990
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
2911 -- petroleum refining

Partially within the city limits of
Casper, WY, bounded on the north and west
by the North Platte River.
Unleaded gasoline, diesel, jet fuel,
propane, asphalt, and lube oils.
A residential area borders the refinery to
the south and a quarter-mile vacant buffer
zone exists to the east between the
facility and the center of Casper, WY.
Reason for Facility Selection:
      ARIP Reports:
The facility was chosen because of a
referral from the Wyoming SERC and two
fatalities which occurred at the refinery
on December 23 and 29, 1989.

None
Focus of Audit:
      Hazardous Substances(s)
      Examined:
Benzene
Isobutane
Hydrogen Sulfide (H2S)
                                      281

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      Over 100 product tanks, with capacities  from  2,000  to  55,000
      barrels, are in use at the refinery.

•     Shipping/Receiving

      Crude oil arrives by pipeline and products  leave  the refinery  by
      pipeline, truck, and rail.

•     Material Transfer

      A system of centrifugal pumps and steel  pipe  is used to  transfer
      process streams to different stages of processing.

Process Area(3)

The crude pipe still and vacuum pipe still unit performs  a gross
separation of crude oil components.  Although  jet fuel, kerosene,  and
diesel products result here, most of the effluent is feed for  other
units.  Distillation columns are used to achieve  the separation.

In the alkylation unit, sulfuric acid is utilized as a catalyst to
maximize the octane content of refinery products.  The desired reaction
typically combines isobutylene or propylene with  isobutane to  form high
molecular weight isoparaffins.  The desired product, alkylate, is  a high
octane branched paraffin such as isoheptane or isooctane.

The ultraformer performs a catalytic reaction which takes the crude
fraction between gasoline and kerosene and converts it to aromatic
hydrocarbons in a hydrogen-rich environment.  Catalyst selection is very
important to maximize the conversion and octane content.  Coke deposits
on the catalyst must be burned off routinely.

The fluid catalytic cracking unit (FCCU) takes low value  crude bottoms,
and obtains a seventy percent conversion to high "ilue gasoline.   This
is possibly the most hazardous process since air    added for catalyst
regeneration; process controls are in place to prevent an explosive
mixture of air and hydrocarbons.

Approximately 1,000 gallons per minute move through the separator in the
waste treatment area.  Once most of the oil is removed,  the resulting
water is pumped approximately five miles northeast to a settling basin
where lime settles to the bottom and remaining volatile organics
evaporate or are biologically decomposed.  The effluent from the
settling basin goes to the adjacent, 650 acre Soda Lake natural basin.
                                282

-------
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility. Background Information

      •     There is one road for entry and  exit  from  the  refinery,  which
            could be a limiting factor in  case  of a  significant  incident.

      •     At the time of the audit, a foul odor, sediment  staining,  and poor
            water quality were observed at the  settling basin.   Soda Lake  has
            good water clarity and no odors.
                                        »
      Chemical Hazards

      •     Chemical hazards which Amoco focuses  on  are:

                  Flammability of crude oil,  oil  constituents, and byproducts;
                  Corrosivity and erosivity  of  certain process stream; and
                  Personnel occupational exposure  to hazardous substances.

      •     Amoco Headquarters recently completed an epidemiological study to
            identify if causes of death for  Amoco  employees  are markedly
            different than the national average.

      Process Information

      •     Process flow lines, pipelines, and  equipment are not routinely
            labeled and numerous pipe lines  are not  insulated.  Although some
            pipelines are spray painted to indicate  flow direction or the
            presence of asbestos insulation,  the  lack of uniformity could
            cause confusion during operations,  maintenance,  or an emergency.

      •     An area which the audit team felt needed attention was general
            housekeeping.  Problems included small items and insulation covers
            lying on the ground, makeshift pipe supports of wood blocks and
            bricks, tripping hazards, and  a  layer  of oil covering the floor
            and process equipment at the FCCU.

      •     Contents of the storage tanks  are not  apparent by labeling.
            Instead, there is a seasonally-dedicated use for each tank and a
            numbering.scheme to keep track of each product.

      •     Flow rate, temperature, pressure, and  liquid level indicators and
            controllers, linked to pneumatic  control valves,  are the primary
            control room instruments.  If  their power source is interrupted,
            the controllers remember their set  points until  it is restored.

      •     Differing design philosophy over  time  is exemplified by the
            presence of both explosion proof  switchgear and open electrical
            equipment at the crude unit.
                                      283

-------
•     Upset conditions caused by equipment failure can usually  be
      handled by back-up equipment or shutting down one unit
      independently of other units.

•     All critical pumps have steam-driven backup pumps used  if the
      primary pump goes down or the electricity fails.

•     Valves controlling catalyst flow in the FCCU are set  so that
      catalyst, air, and p^roleum feed flows maintain their proper
      direction.  If these flows were reversed, a very hazardous  --
      potentially explosive -- situation would result.

•     A TV monitor in the Alky"lation control room for observing unusual
      events or operator problems has a distorted, fuzzy picture.  In
      response to the discussion at the exit briefing, the  facility will
      be correcting the problem.

•     Most of the pressure gauges associated with the pneumatic
      equipment at the FCCU could not tolerate the extreme  temperatures
      present and are deformed.   Gauges for pneumatic controls were
      often rusted and non-functional.

•     H2S monitors are located only in  the  compressor  room at  the FCCU.
      Each control room has a portable  explosim<_ter/H2S/oxygen detector,
      which are only taken out if the operator believes it  is  necessary.

•     Since most plant operations involve variou^  . =troleum fractions at
      elevated temperatures,  any system leak provides  an opportunity for
      a fire to start.

Chemical Accident Prevention

•     Corporate involvement can be seen in the corporate  guidelines for
      conducting HAZOPs and in annual audits  of randomly  selected
      facilities.

•     By placing the environmental/control/safety/security group at a
      department level, these programs  have greater  awareness  among
      plant employees and within the organizational  structure.

•     There is a health and safety committee,  consisting  of twr
      representatives each from the company and .the  union,  whi-  . serves
      as a means of communication on safety matters.

•     Weekly safety meeting are  conducted by  the  shift supervisor.
      Operators have the opportunity to bring up  safety concerns.

•     The facility is fenced around the entire perimeter  of the
      operating and storage areas.  The plant operates 24 hours  a day,
      seven days a week, and constant surveillance is  maintained with a
      guard on duty at the plant entrance.
                                284

-------
When a unit shutdown  is necessary, operators must  follow a  set  of
written manual procedures, rather  than simply  activating an
automatic shutdown system.

The crude unit desalter liquid  level  is checked manually.   The
operator must open a  sequence of valves until  the  water  level is
found, causing potential exposure  to  hot oil and water.

A makeshift systems of using hot water to wash an  oil  leak
emanating from a process line to the  water treatment plant  was
observed during the audit.  If  this system is  not  practical, a
vacuum truck is used  to pick up the spill.

While only on-the-job training was used for operators  in the past,
a new basic operator  training program was initiated in February
1990.  This twelve-day comprehensive  classroom training  is
required for operators and maintenance personnel.

Current operators are given periodic  refresher training  based upon
interest and supervisor input.

Heavy equipment operators receive  instruction  in notification of
the emergency coordinator in the event of an accident.

Maintenance work orders with safety implications are flagged to
receive higher priority and more supervisor follow-through.

Equipment repairs are made upon failure or if an operator observes
abnormal operations.  There is only a limited preventive or
predictive maintenance program.

Each maintenance shift contains an instrument technician.  Due  to
the age of some instruments, repair can be delayed while waiting
for parts.  Some of the instruments are being replaced.

What If exercises are performed by each shift on each unit
monthly.  Written responses go to the training supervisor for
review.

Numerous observations of the lack of maintenance were made:

      There are many unrepaired steam and oil leaks;
      Acid brick in the Alkylation unit is in disrepair;
      Many process lines are not tied down or supported;
      Pipe and heat exchanger insulation is in disrepair; and
      A new KOCH mixer at the Alkylation unit is supported by
      temporary wood bracing.

The environmental and safety initiatives undertaken by Amoco
include the following:
                          285.

-------
            Discontinued use of chromate in to^er water assures that
            cooling tower sludges will no longer be hazardous wastes;
            Placement of floating cover on the wastewater/oil separator
            limits volatile emissions (hydrogen sulfide);
            Removal of tetra ethyl lead unit;
            Initiation of non-mandatory fugitive emissions program;
            Replacement of chlorinated solvents with hydrocarbon
            solvents for cleaning purposes, with intent to replace these
            with steam cleaning apparatus; and
            Substitution of portable feed containers for 55 gallon drums
            reduces waste.

•     One release prevention technique is the utilization of sentry
      holes, small holes drilled partially through transfer lines.
      Corrosion or erosion thus causes a small leak at the sentry hole,
      which can detected prior to a potentially catastrophic release.

•     A remote camera is used to monitor the flare, which can only be
      restarted manually at the flare itself.  Steam flow to the flare,
      used to maintain the flow of gas during cold weather conditions,
      can be controlled from the control room.

•     All tanks are subject to periodic integrity testing using such
      techniques as hydrostatic, visual inspection, and non-destructive
      shell thickness testing.  These tests are conducted annually.

•     Major oil tanks in basins are cone roof ty - for evaporation
      reduction and are completely surrounded by earthen dikes or
      retaining walls.  Earthen dikes are also installed around each
      product tank, and there is a large ditch between the facility and
      the North Platte River to contain spills not captured by diking.

•     There are currently at least four unique hydrant systems,  and due
      to the age of the water lines,  some failures have occurred.

Accident Release Incident Investigation

•     A release of butane gas at the refinery resulted in one death and
      one injury to facility employees.   There have also been three
      releases reported to the Wyoming DEQ in recent years:   20-25,000
      gallons of diesel fuel; 12,500 gallons of waste water;  and 3,800
      pounds of sulfuric acid.  There have also been releases of 20-
      30,000 pounds of non-hazardous catalyst.

•     As a result of an incident in December 1989 involving a fatality,
      a revised winterization program will'be utilized this  year.

•     A systematic method of analyzing serious incident reports  to
      detect safety/training program weaknesses has been implemented.

•     Serious occurrence incident reports are used to document fires,
      releases, and equipment failures.   These reports, numbering  about

                                286

-------
      fifty per year, have been entered on a computer database.  One
      manager has performed various sorts on the database to identify
      weaknesses in operator training ard trends in incident causes.

Facility Emergency Preparedness and Planning Activities

•-     The existing plan contains individual unit maps -- showing the
      location of hose reels, fire extinguishers, monitors, and possible
      escape routes -- rather than a single map of response equipment
      location and evacuation routes.  Each unit.has an emergency plan
      for shutdown and evacuation procedures.

•     A general spill contingency plan for the Casper Refinery provides
      instructions for dealing with spills and some sample scenarios.

•     The facility has developed computer software to instruct plant
      personnel on how to respond and mitigate spills,  and to direct the
      emergency coordinator to notify the appropriate agencies.

•     A twenty-company cooperative, spearheaded by Amoco,  purchased and
      stocked a semi-trailer with spill response equipment to more
      effectively respond to spills in the North Platte River.

•     The refinery has developed a fire protection training program that
      will provide at least one training session per month.

•     A facility volunteer fire department and two pumpers are  utilized
      to deal with an estimated 10 small fires which occur each year.

Community and Facility Emergency Response Planning Activities

•     The facility is a member of the Wyoming SERC and  cooperates  with
      the Natrona County LEPC.

•     The refinery will send one Casper City and one Natrona County fire
      fighter to the Texas A & M Industrial Fire School  annually.

•     The facility has received complaints about petroleum emission
      odors from products at the tank farms from nearby  residents.

Public Alert and Notification Procedures

•     Guidelines for media interaction are provided in  the  general  spill
      contingency plan.
                                287

-------
Recommendations:

Process Information

•     Housekeeping practices should be  reevaluated.  Current practices
      not only create safety hazards, but also can negatively  impact
      worker attitudes.

•     Process flowlines, storage tanks, and equipment should receive
      permanent labeling.

•     The facility should replace the non-functional pressure  gauges and
      pneumatic controls at the FCCU.

•     Additional combustible gas and H2S detectors,  with audible and
      visual alarms, are needed at the  refinery to provide early
      detection of equipment failure.

Chemical Accident Prevention

•     A system of preventive and/or predictive maintenance should be
      considered for all critical equipment.  The current practice of no
      maintenance until a breakdown occurs may be contributing to the
      number of incidents at the facility.

•     A uniform system of fire hydrants should be installed to replace
      the present system of at least four unique hydrant systems in
      order to avoid possible confusion during an emergency.

Facility Emergency Preparedness and Planning Activities

•     A single map showing response equipment location and evacuation
      corridors should be developed to replace the existing maps.

•     Vapor release drills should be considered for emergency planning
      and the facility should conduct training for response to releases
      of toxic and flammable gases.

Community and Facility Emergency Response Planning Activities

•     Given the proximity of the residences to the south and the odor
      complaints received, there is a need for improvement in
      coordination with community emergency response planning.

•     The plant should become an active participant in the LEPC,
      allowing its experience and expertise to benefit the community.
                                288

-------
Audit Team Member Composition:
Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Due Nguyen
US EPA Region 8
Team Leader
Chemical Engineer

Dave Christenson
US EPA Region 8
RCRA
RCRA Enforcement

Jerry Goedert
TAT, US EPA Region 8
Lead Technical Reviewer
Chemical Engineer

Doug Hamilton
TAT, US EPA Region 8
Technical Reviewer
Chemical Engineer

Scott Matthews
TAT, US EPA Region 8
Non-Technical Reviewer
Administration

Gary Schwartzkoph
Casper Fire Department
LEPC Observer
Hazmat Specialist/Engineer
Follow-up Activities:

      By the facility:

      By the Regional office:

      By State and local authorities:
Regional Contact:
Due Nguyen
                                      289

-------
290

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Western Zirconium -- Westinghouse Electric
Corporation
Facility Location:
Ogden, Utah, Region 8
Date(s) Audit Conducted:
August 27 - 31, 1990
Description of Facility:

      SIC Code(s):



      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
3339'-- primary smelting and refining of
nonferrous metals,  except copper and
aluminum
1100 arid acres fifteen miles west of
Ogden, Utah, east of the Great Salt Lake,
and 30 miles north of Salt Lake City.
Zirconium metal tubeshell, bar. wire,  and
strip; hafnium; and magnesium chloride
The nearest community,  West Warren,  has a
population of 400 and is three miles from
the facility.
Reason for Facility Selection:
      ARIP Reports:
The facility was chosen because of a
referral from the state of Utah based on
releases of 6671 pounds of ammonia on
7/1/89 and 5,000 gallons of methyl
isobutyl ketone on 3/23/90.

7/1/89 release of ammonia and 11/10/87
release of chlorine
Focus of Audit:
      Hazardous Substances(s)
      Examined:
Ammonia
Chlorine
Methyl Isobutyl Ketone  (MIBK)
Silicon Tetrachloride
                                      291

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      There are numerous storage  tanks  with  varying  capacities.   All
      stationary tanks are  located  inside  concrete lined  dikes.   Zircon
      sand, petroleum coke, and magnesium  chloride are  stored as  solids
      in hoppers and silos. Chlorine  gas is  fed  to the  process from rail
      cars at the railcar unloading platform.  During normal  operations,
      there are 2 to 4 cars, each with  a 180,000 pounds capacity".

•     Shipping/Receiving

      Zircon sand raw material is imported from  Australia and arrives  by
      train.  Other raw materials arrive by  train and truck.   Products
      are shipped out via truck.

•     Material Transfer

      Liquid process streams are  transferred throughout the facility by
      pumps and piping.  Flowable solids are transferred  using bucket
      elevators, augers, and pneumatic  conveyors.  Solid  metal in the
      reduction area is moved with  fork lifts.

Process Area(s)

Zircon sand, petroleum coke, and  chlorine  are reacted at  elevated
temperatures in fluidized bed "chlorinator"  reactors to produce
zirconium tetrachloride, silicon  tetrachloride,  and off-gases.  The off-
gases pass through water scrubbers  and  a caustic scrubber before being
released to the atmosphere.  Crude  silicon tetrachloride  is purified by
distillation for sale.  Zirconium tetrachloride  is dissolved  in water
and goes to the separations area  for  further processing.

The separations process extracts  impurities  from crude zirconium
tetrachloride with liquid-liquid  extraction  and  selective precipitation.
The principal elements removed in this  step  are hafnium and aluminum.
The process uses liquid-liquid extraction  columns,  precipitation and
filtration systems, and two calcining systems.  The zirconium  is
converted to the oxide and  goes to  the  pure  chlorination process.

In the pure chlorination process, chlorine,  petroleum coke, and pure
zirconium react to produce  a very pure  zirconium tetrachloride.  This
product is sent to the reduction  department  for conversion into metal.
The pure chlorination step  also removes phosphorous,  using hydrogen, and
iron  from the zirconium tetrachloride.

The reduction process takes pure  zirconium tetrachloride and reacts it
with  high-purity magnesium  metal  in an  evacuated retort and crucible.

                                292

-------
      The reaction is carried out at elevated temperatures and produces
      zirconium sponge metal with magnesium chloride as a by-product.  The
      zirconium sponge goes to a separate breakout,.breakup, grading,
      crushing, and blending systems to ensure there is no product cross
      contamination.

      The metals produced in the fabrication area are immersed in pickling
      baths to remove metal working traces and metal oxides.  The pickling
      baths contain various acids, caustic, and water at different
      concentrations.

      The five aqueous waste streams at the plant include sodium chloride,
      calcium chloride, ammonium chloride, sodium sulfate, and the emergency
      stream.  Waste streams are neutralized with lime and then sent to
      evaporation ponds.   The ponds have monitoring wells installed upgradient
      and downgradient, and are monitored quarterly.  Generated hazardous
      wastes are segregated and managed in a new hazardous waste facility.
      Wastes are then manifested off-site.
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     There is only one road for entry and exit from the facility,  which
            could potentially limit response operations.

      Chemical Hazards

      •     The primary chemical hazards are the flammability of the large
            quantities of MIBK in the separations area,  as well as other
            solvents, and the corrosivity of process streams -- hydrochloric
            acid and chlorine.  In addition, zirconium metal is pyrophoric and
            will burn in the presence of air,  and small  particles can explode
            due to high surface area.

      •     MSDSs for each chemical are kept in the process control room.

      •     The audit team had to wait several hours before the facility  Title
            III coordinator was able to find or extract  Title III information
            from computer or file cabinet.

      Process Information

      •     A labeling program entitled "Know your Chemical" is used at the
            facility.

      •     Many of the pipes and piping systems were not labeled;  instead,
            operator knowledge is used to verify the contents of lines.


                                      293

-------
•     During the facility tour, a large amount of metal, debris,  pipe,
      and trash was observed and there often were obstacles  that  had to
      be walked over or around.

•     The extraction columns located in the separation area  are no
      longer used for hafnium and zirconium chloride separation.  Piping
      systems used for transferring hydrochloric acid, MIBK,  and
      sulfuric acid are in poor condition and no longer  in service.

•     Some leaks were apparent in piping in the separations  area  and
      there was also unsupported plastic pipe.

•     All pressurized vessels are protected with safety  relief valves
      which are checked on a six-month schedule.  In addition, some  of
      these vessels also incorporate an explosion disk.

•     There are emergency diesel generators which kick in if  the  plant
      experiences a power failure.  The generators cannot operate the
      entire site, but can keep critical equipment and areas  running.

•     Process control is achieved using analog and digital controllers
      and programmable logic controllers (PLCs).  The long range  goal of
      the facility is to move all control to PLCs; the facility is about
      halfway toward this goal.

•     Flow monitoring of certain process streams has been instituted
      using a data acquisition network (DAN).   The system tracks  flows
      in the sewer and monitors the balance between the  influent  and the
      effluent.  Material that is sewered into the ENU unit is sampled
      on a sporadic basis.

•     The facility does not have stationary monitoring equipment capable
      of continuously detecting toxic gases on- and off-site.

•     Stack gas is monitored on-line for chlorine and sulfur dioxide.
      An alarm sounds if the concentrations go over the preset limit.

•     Routine personal air sampling is performed for nitric acid,
      hydrofluoric acid, nitric oxide, MIBK, dust, sulfur dioxide,
      chlorine, ammonia, phosgene, and carbon dioxide.

•     Very high process temperatures provides  the potential for injury
      from the release of hot fluids or solids.

Chemical Accident Prevention

•     The operating and storage areas are fenced.   Operations continue
      round-the-clock and guards are on constant duty at the entrance.

•     Evidence of the corporate commitment to  safety is the funding  of a
      clinic which, when completed, will be used for employee physicals
      and emergency coordination.

                                294

-------
Because the safety manager  reports  directly  to  the  plant  manager,
there is high visibility  for  the  safety  program.

A safety steering committee meets about  14 times  a  year  to  address
issues brought up by facility employees.  The committee  consists
of seven management personnel and three  regular employees.

Regular safety meetings are held  to discuss  a variety  of  topics
including chemical safety.

The facility has implemented  the DuPont  STOP safety program in
which any worker can stop an  activity considered  to be unsafe.
Management cannot override  the stop notice,  and a formal  report is
prepared as soon as possible  addressing  the  incident.

Audits are conducted on a periodic basis by  corporate personnel.
Lengthy reports are issued  outlining good points  and corrective
actions; however, the audit teams are not that  familiar with
chemical processing since this is the only "chemical" facility in
Westinghouse.

The facility uses outside companies and  other specialists to
assist in audits.  Three or four internal audits  are done each
year and outside auditors come in every  three years'.

SOPs are available in all process areas  for  operator reference.
They are extremely detailed and cover upset  conditions and how to
respond in an emergency.  They are updated every  six months.

The facility has a formal, documented training program for plant
operators, .which covers all the chemical hazards which will be
encountered at the facility.  New employees  have one week of
classroom training prior to going to their departments; each
department has a full-time trainer.   Retention tests are used to
confirm operator knowledge of procedures.

The predictive maintenance program includes  ultrasonic thickness
testing, vibration analysis,  and infrared video imaging to
identify when equipment should be changed or taken out of service.

Under the preventative maintenance'program,   the maintenance
computer produces a weekly schedule which has achieved a leveling
in the maintenance workload.

Instrument maintenance includes both predictive and preventative
maintenance.  Each shift has  at least one instrument maintenance
person performing preventative maintenance on a quarterly basis.

Preliminary risk assessments  and "What If" diagrams  are used to
analyze designs and processes.  Four critical systems  have been
identified:  ammonia, chlorine,  MIBK,  and silicon tetrachloride.
                          295

-------
•     Western Zirconium has adapted the probability/severity  evaluation
      program to determine the relative importance of each piece  of
      equipment and each operation having potential for a chemical
      releases.

•     A worst-case accident was modeled involving the rupture  of  a full
      chlorine rail car.  The calculated maximum radius of impact for
      such a release was 2.5 miles from the plant -- the nearest
      community is three miles from the site.

•     The CAMEO dispersion modelling program is being purchased,  and
      will be used in conjunction with an automatic weather station for
      emergency response situations and simulated emergencies.

•     Release prevention systems include the installation of above-
      ground or double-lined pipe when replacing failed sewer pipe and
      the installation of sumps with no connection to the sewer system
      inside diked areas.

•     The facility, aware of the large volume of liquid waste generated,
      is undertaking a program to drastically reduce stream volumes and
      reclaim evaporation ponds to their natural states.

•     As originally designed, the facility's piping and drainage system
      was not entirely suitable for use in conjunction with MIBK,  HF,
      and other corrosive/hazardous substances.   Over the years, the
      facility has replaced these unsuitable components.

•     Redundant failsafe shutdown systems for chlorine operations  and
      area chlorine monitors will be installed in 1991.

•     All tanks are contained in concrete dikes  which are designed to
      hold more than the maximum contents of the tank.

•     Excess flow valves are used on the ammonia tank cars  to prevent
      large releases.  Quick seating safety release  valves  are used on
      all tanks to minimize the amount of an overpressure release.

•     The separations area has blow-out panels to relieve the pressure
      of an explosion.

•     Many fire hydrants and some permanent foam systems  are  located
      about the plant.  The thermal oxidizer has a stand-alone Fenwal
      fire suppression system.

Accidental Release Incident Investigation

•     The facility has had five significant releases  involving six
      different hazardous substances and five fires  involving fire
      brigade response during the last six years.
                               296

-------
•     As a follow-up to the release of MIBK,  the facility  installed  a
      stationary alarm monitoring system in the area of  the  release.

•     Supervisors conduct incident investigations and prepare  reports  on
      any spill over 16 ounces in volume.

Facility Emergency Preparedness and Planning  Activities

•     The facility has an extensive written emergency response plan,
      addressing emergency preparedness, emergency procedures, post-
      emergency procedures, drills, and training.

•     Based on the facility's on-site storage capacity, Western
      Zirconium is subject to the oil pollution prevention regulations
      under 40 CFR Part 112, which require the preparation of an oil
      Spill Prevention, Control, and Countermeasure (SPCC) plan.

•     Simulated emergency drills, announced and unannounced, are held on
      a periodic basis.  Four planned drills  are held every six months,
      and there is an annual drill to check all emergency assembly
      points.  Eight drills are held annually on the chlorine system.

•     There is a duty officer on-call to coordinate the response to
      incidents at all times.  The duty officer has a manual which
      outlines the system of release procedures.

•     Nine spill equipment storage shacks are strategically located to
      handle spills at specific facility locations.   Western Zirconium
      emergency equipment includes 80 SCBAs,  2 chlorine kits, 6 Level A
      suits, 7 fire house locations,  and 385 fire extinguishers.

•     The Emergency Communication Center/Clinic being completed will
      handle and monitor all emergency situations,  and will include
      release tracking and modelling,  communication,  and incident
      command equipment and chemical and process reference materials.

•     There is a plant intercom with a warble emergency alarm signal.

•     The facility has a 52-member fire brigade supported by a water  and
      foam pumper, a newly constructed fire house,  and an in-house
      training facility.

•     There is a 32-member hazmat team which also works with the  coun'ty
      on hazardous materials emergencies.   A new facility hazmat  truck
      is being constructed.

•     Members of the response teams have received a  variety of training:
      fire academy, SCBA, respirator,  personal protective equipment,  and
      first aid and CPR certification.
                                297

-------
Community and Facility Emergency Response Planning Activities

•     Western Zirconium is an active member of the SERC and  the  LEPC  and
      has held training exercises in conjunction with  the LEPC.

Public Alert and Notification Procedures

•     There is a plan for communicating with the nearby communities and
      the hospital in the event of a serious incident.  A 911  emergency
      notification protocol has been developed, and the emergency
      telephone list is update quarterly.

•     The emergency response plan contains procedures  and guidelines  for
      media interaction.
Recommendations:

Chemical Hazards

•     Title III and RCRA records should be organized in a readily
      retrievable format.

Process Information

•     The policy of placing process flow lines above the ground should
      be continued.

•     In the Separations liquid-liquid extraction area, piping systems
      which are no longer needed should be dismantled.

•     The facility should implement a daily cleanup policy and
      inspection to address lax contractor cleanup.

•     Pumps, valves, chemical process equipment, and buildings should be
      labeled and identified in conjunction with the SOPs for easier
      training and to support response efforts.

•     Bookkeeping/housekeeping programs for drainage ditches should also
      be considered, and housekeeping needs to be improved in the
      Separations liquid-liquid extraction area.

•     pH probes should be located throughout the sewer systems wherever
      a potential spill might take place.  When a spill occurs,  feedback
      to a control panel would immediately locate the spill and permit
      local containment.

•     Identified waste streams for the EMU unit should be sampled on a
      more periodic basis and sampled for constituents  that would be
      encountered from process waste flows.
                                298

-------
      •     Two other types of detection probes are recommended:  conductivity
            probes dependant upon an induced change in the dielectric constant
            and ultrasonic probes which are triggered by changes in viscosity.

      •     For buried pipes, valves, and fittings, cathodic protection
            systems should be used.  Pressure drop fail-close devices should
            be in place to activate alarms and initiate shutdown procedures.
            Mass flow rate indicators should be used for hazardous material
            storage tank inventory control.

      •     The facility should consider the placement of monitors for toxic
            gases both on and off the plant site.

      •     To detect aboveground storage tank leaks,  the condensate from
            internal heating coils, if present, should be monitored for the
            presence of oil or hazardous chemicals using conductivity probes.
            Inspection sumps should be installed as a visual detection method.

      •     To provide advance notice of future releases,  audible and visual
            stationary alarm monitoring systems for chlorine and combustible
            gas should be installed wherever MIBK and chlorine are present.

      Chemical Accident Prevention

      •     There should be more input from employees  actually performing work
            in the plant to the safety steering committee.   A fifty-fifty mix
            of management-plant employees seems more reasonable.

      Facility Emergency Preparedness and Planning Activities

      •     Alternate evacuation routes should be identified in case  the
            primary roadway cannot be used during a hazmat  release  or fire.

      •     The facility should consider writing a Spill  Prevention,  Control,
            and Countermeasure (SPCC) plan for oil spills.   The plan  should  be
            prepared in accordance with good engineering  practices  to prevent
            the discharge of oil into navigable waters.
Audit Team Member Composition:

Name and Title                Due Nguyen
Affiliation                   US EPA Region 8
Area of Responsibility        Team Leader
Expertise                     Chemical Engineer

Name and Title                Doug Hamilton
Affiliation                   TAT, US EPA Region 8
Area of Responsibility        Technical Reviewer
Expertise                     Chemical Engineer
                                     299

-------
Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Jerry Goedert
TAT, US EPA Region 8
Technical Reviewer
Chemical Engineer

Edwin Coker
TAT, US EPA Region 8
Technical Reviewer
Civil Engineer

Dave McCleary
Utah Bureau of Solid and Hazardous Waste
RCRA
Geologist/Environmental Health Scientist

Mark Woodliff
Utah Bureau of Solid and Hazardous Waste
RCRA
Chemical Engineer

Woodrow Campbell
Utah Bureau of Solid and Hazardous Waste
RCRA
Environmental Engineer

Robert Wright, Ogden Fire Marshal
Weber/Morgan County LEPC
Title III
Emergency Planning
Follow-up Activities:

      By the facility:

      By the Regional office:

      By State and local authorities:
Regional Contact:
Due Nguyen
                                      300

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
JEMM Plating Company
Facility Location:
Denver, Colorado, Region 8
Date(s) Audit Conducted:
November 1, 1990
Description of Facility:

      SIC Code(s):



      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
3471 -- electroplating, plating,
polishing, anodizing, and coloring
3931 -- musical instruments

A single, two-story brick building in an
industrial, manufacturing area northeast
of downtown Denver.
Specialty metal products, Including metal-
plated items, chalk chucks,  batons, and
practice drum pads.
There are several schools located within a
two mile radius of the facility.
Reason.for Facility Selection:
      ARIP Reports:
The facility was chosen because of a
referral by the Denver Fire Department.

None
Focus of Audit:
      Hazardous Substances(s).
      Examined:
Hydrochloric.Acid
Sulfuric Acid
Nitric Acid
Sodium Cyanide
Potassium Cyanide
Chlorothene
                                      301

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      JEMM maintains a minimal chemical inventory  in  two  storage  areas.
      One area is next to the electrodeless nickel plating  line,  labeled
      "toxic chemical storage," is for flammable materials.  The  other
      storage area, labeled "chemical storage," is for non-flammable
      materials and is located in the back of the building.

      Waste and chemicals are stored in 10 to 15 drums with capacities
      ranging from 5 to 55 gallons.  Chemical waste storage is  located
      near the north building exit.  Only two partially full 55 gallon
      drums contain hazardous waste, and the facility is  inquiring as to
      the proper method of disposal.

•     Shipping/Receiving

      There are infrequent deliveries of chemicals to the designated
      shipping and receiving area.  Materials received are moved  into
      the facility with a small fork truck.

•     Material Transfer

      Only a minimal amount of material transfer takes place at the
      facility.  Small amounts of solids and liquids are added to the
      plating baths -- solids are scooped out of drums,  and liquids are
      transferred with a small hand pump.

Process Area(s)

JEMM Plating plating operations involve plating electrodeless nickel,
copper, nickel, chrome, zinc, and irridite,  and anodizing metal.  Most
of the chemicals used are contained in the rinse and plating baths,  with
volumes of 100 to 200 gallons.  The aqueous  rinse and plating tanks are
cast iron and the caustic and acid tanks are polyethylene; there are 40-
50 tanks in the plating area.  Temperature control of the plating
solution is accomplished either by steam,  electrical heat, or
refrigerant cooling.

The electrodeless nickel plating process plates ni<- ~el onto substrates
using a chemical reaction without electricity.   As in conventional
electroplating, the substrate to be plated is cleaned and rinsed in
preparation for immersion in the plating bath.   After plating,  the piece
is rinsed to remove excess reagents.  The composition of the cleaning
and rinsing agents varies with each process  and the type of substrate to
be plated.
                                302

-------
      Using traditional electrochemical methods,  a  variety  of  metals  (copper,
      nickel, chrome, zinc, etc.) are  plated  onto substrates.  The  substrate
      to be plated is first cleaned  and rinsed.   Plating  is  carried out  by
      using the piece as the anode of  an  electrochemical  plating  bath.
      Rectifiers convert AC to DC current,  the  driving  force behind the
      plating process.  After plating, the  pieces are rinsed to remove plating
      solution and further treated as  necessary.
Summary of Audit Findings and Recommendations:

      Conclusions:

      Chemical Hazards

      •     MSDSs received from manufacturers are converted into a standard
            format; this makes it much easier for employees to understand.
            They are updated annually or when new information is receiver*.

      •     The facility is developing a hazard communication program and has
            produced an initial manual, available at the main bulletin board
            and' in the lunchroom.

      •     There is no industrial hygiene o.r medical monitorir.g program.

      Process Information

      •     There is currently no labeling of waste drums or processing vats
            as to contents or hazards.  The new hazard communication program
            will require labeling of all containers of hazardous chemicals.

      •     Chemicals are stored in chemical cabinets,  storage areas are clean
            and well-organized, and non-flammable and flammable materials are
            stored separately.  Containers, cabinets, and storage areas,
            however, are not labeled as to contents or.hazards.

      •     The storage tanks and process vats are old,  and most of the tanks
            are corroded and deteriorating and not coated.  The foundations
            and supports of the tanks are deteriorated and the tank bottoms
            cannot be inspected. -Periodic, but not continuous,  sampling of
            the sump in the plating room floor is performed.

      •     The audit team was concerned about the use of a single hand pump
            for the transfer of caustic and acid liquids.  The facility
            indicated that this pump is only used once a week, but they, will
            try to purchase an additional pump.

      •     There is no backup or redundant equipment at the  facility.   Manual
            operations provide management with flexibility in case of
            production problems or equipment failure.
                                      303

-------
•     The plating processes, voltage, amperage,, and  immersion  times  are
      manually controlled; only the temperature control  of  the bath
      solutions is done automatically.  Manual quality control checks
      are done by the quality control department.

•     The temperature control boxes are located on top of open process
      vats and could be subject to moisture, resulting in corrosion  or
      short-circuits.

•     No air monitoring is performed inside the plating  area.   A new
      program is being instituted to contract with outside  consultants
      to provide air monitoring on a routine basis.

•     JEMM uses some flammable solvents to clean substrates to  be
      plated, although the quantities of flammable materials used  is
      extremely small.  In addition, the spray area  for  the flammable
      paint extends out of a dry area and does not meet  fire codes.
      According to fire department codes,  the facility must expand the
      sprinkler system to this area or switch to non-flammable  paint.

•     The temperatures maintained in the plating baths are high enough
      to cause burns if the solution comes in contact with  the  skin.

•     Corrosive chemicals such as hydrochloric acid,  sulfuric acid, and
      sodium hydroxide are a key feature of the plating process.
      Employees are thus required to wear safety glasses, rubber boots,
      respirators, rubber sleeves, and aprons.

•     The primary risk of release is from leaking plating tanks.  The
      level in the tanks is checked every morning before work begins,
      and if the level has decreased,  further investigation takes place.

Chemical Accident Prevention

•     The quality and safety bulletin board at the entrance to  the
      plating area contains articles,  RTK information,  common MSDS
      terms, and the JEMM hazard communication program.   Monthly
      employee safety meetings are also held.

•     Facility security is provided by the Denver Burglar Alarm Company.
      JEMM operates one day shift, and there is no one on the premises
      afret hours.

•     Operating procedures -- plating and rinsing sequences, times  and
      temperatures relating to specific plating procedures --  are kept
      in a three-ring binder in the plating room.

•     There is a classroom area for employee meetings with videotape
      capacity.  There is a two-week training program,  consisting of
      classroom and on-the-job instruction,  for new employees.   It  has
      not been used because there have been no hirings in the  last  18
      months.  A master file of training attendance has  been maintained.

                                304

-------
•     Due to the size of the company and maintenance staff  (one
      maintenance person and a helper for the facility), there is only  a
      small amount of scheduled maintenance; most of the maintenance  is
      done when equipment breaks down. Preventive maintenance is
      performed on all pumps in the plating area.

•     An instrument quality control program has been initiated.  Quality
      control personnel check voltage and amperage readings for the
      plating baths against a standard, and maintenance performs any
      necessary repairs.

•     The facility does no formal HAZOP studies of its processes.  Each
      new specialty plating job is evaluated by management before it  is
      accepted; a primary area of concern to management is the amount of
      waste generated by the process.

•     No modelling has been done of the potential impact of an incident
      on the surrounding community.  The company has determined that no
      incident in the plating area could involve its neighbors.   This
      judgment is based on the small quantity of chemicals used and the
      direct control of the plating operation possible in a small firm.

•     The 30-gallon sump, located at a low point in the plating area,
      which pumps to the sewer system, must be manually shut off in the
      event of a spill.  This system does not provide sufficient
      protection against spills reaching the sewer.

•     The facility relies primarily on the skills of the operators  and
      management to detect potential problems and provide solutions.

•     All areas with potential for leaks are diked to prevent  liquid
      from migrating outside the immediate spill area.

•     The facility plans to install a waste water holding tank.   Water
      from the collection sump,  waste water from normal operations,  and
      any spills or releases would be pumped into the holding  tank,  and
      then sampled before discharge into the sewer.

•     All chemical processing areas are protected by a sprinkler  system.
      The facility will install sprinklers in the future upstairs
      training room as required by the Denver Fire Department.

•     Plating tanks emitting especially toxic vapors are equipped with
      ventilation hoods.

Accident Release Incident Investigation

•     The facility is in the very early stages of developing a plan  for
      reporting and investigating accidental releases.
                                305

-------
Facility Emergency Preparedness and Planning Activities

•     Facility management is in the process of  rewriting  their  emergency
      response plan.  Due to the small size of  the  facility, emergency
      situations can immediately be assessed by management personnel,
      and response actions can be directed.

•     No emergency exercises have been performed  to date, but a
      simulation exercise will be held when the plan is completed.

•     Management decides whether a facility evacuation is necessary;
      none have taken place to date, although evacuation routes are
      indicated on a floor map of the plating area.

•     An emergency spill kit, containing absorbent booms, coveralls,
      goggles, gloves, sorbent pads, and a shovel, and located  near the
      entrance to the plating area, is used by the facility response
      team to contain spills.

•     There is an insufficient quantity of coveralls to fully support
      emergency response activities by facility personnel.

•     The public address system is used to notify employees of an
      emergency situation.

Community and Facility Emergency Response Planning Activities

•     At this time, the facility has no response plan coordinated with
      the community.  They are in the process of developing a plan.
Recommendations:

Chemical Hazards

•     An inventory of the :hemicals at the facility should be
      maintained, and the location of the list should be known to the
      fire department.

Process Information

•     In order to comply with the local fire code, JEMM should move the
      storage area for flammable chemicals to an approved area of the
      plant and/or investigate an alternative to using flammable paint
      in the spray booth --  perhaps non-flammable paint.

•     Hazardous waste storage should be maintained in a well-labeled
      area.  If the waste if flammable, storage policy should be
      consistent with the local fire code.

•     All equipment, rooms,  and chemical containers should have better
      labelling.   A color-coded system might be developed.

                                306

-------
      •     The temperature controller/indicator at each plating bath  should
            be enclosed in watertight cases to prevent moisture from damaging
            the instruments.

      •     Air monitoring of the employee work space should be performed  to
            ascertain whether they are being overexposed to chemicals.

      •     In order to address the potential for a leak from containment,  the
            facility should investigate the installation of a spill detection
            device such as a pH probe in the sump.

      Chemical Accident Prevention

      •     Upgrading the current sump system should be carefully considered,
            perhaps a holding tank between the sump and the sewer system.

      Facility Emergency Preparedness and Planning Activities

      •     JEMM should increase the number of coveralls in the emergency
            spill kit in case additional people are needed for response.

      •     In order to comply with Denver Fire Department requirements, a
            separate emergency spill kit should be  purchased for the chemical
            storage area.

      •     In order to comply with OSHA requirements,  a respirator training,
            fitting, and testing program should be  established.
Audit Team Member Composition:

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Due Nguyen
US EPA Region 8
Team Leader
Chemical Engineer

Doug Hamilton
TAT, US EPA Region 8
Technical Reviewer
Chemical Engineer

Jerry Goedert
TAT, US EPA Region 8
Technical Reviewer
Chemical Engineer •

Lieutenant James Atencio
Hazmat Division, Denver Fire  Department
Fire and Release Prevention
Hazmat Specialist
                                      307

-------
Follow-up Activities:




      By the facility:




      By the Regional office:




      By State and local authorities:






Regional Contact:             Due Nguyen
                                      308

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
SAS Circuits, • Inc.
Facility Location:
Littleton, Colorado, Region 8
Date(s) Audit Conducted:
February 6-7, 1991
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
3672 -- printed circuit board

A commercial and residential area of
southwestern Littleton, CO, in the Denver
metropolitan area.
Prototype printed circuit boards and one-
of-a-kind boards for commercial and
military applications.
There is a residential area just north of
the facility and an elementary school one-
half mile to the northeast.
Reason for Facility Selection:
      ARIP Reports:
The facility was chosen because of a
request from SAS Circuits to assist the
facility in identifying management
mechanisms to prevent releases.

None
Focus of Audit:
      Hazardous Substances(s)
      Examined:
Hydrochloric Acid
Sulfuric Acid
Ammonium Hydroxide
Tetrafluoromethane
Methylene Chloride
Methyl Ethyl Ketone
1,1,1-Trichloroethane
                                      309

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      SAS Circuits has a small inventory of chemicals on-site.  Most  of
      the chemicals are contained in the various plating, etching,
      cleaning, and rinsing baths.  There are 30-40 separate  tanks  in
      the main chemical process area, containing about 40 gallons of
      solution each.  Most of the bath tanks were constructed of
      polyethylene by the facility using plastic welding techniques.

      There are two areas where drums of fresh chemicals are stored;  one
      room contains "acids" and the other room contains "alkalis."  The
      very small quantities of solvents used by the facility are stored
      in an approved fire safety cabinet.

•     Shipping/Receiving

      A designated shipping and receiving area is located in the
      southwest corner of the building.  Materials received into the
      facility are moved by a small fork truck.   Receipt of chemicals is
      very infrequent.

•     Material Transfer

      Liquids and solids are transported by hand from the chemical
      storage areas to the process areas, and are added to the baths by
      the chemist and operators.

Process Area(3)

There are twelve processing steps at the facility:   pre-production CAD-
CAM work, imaging, wet processing, quality control and inspection,
lamination, drilling, plasma etching, wet processing,  solder,  screen
printing, routing, and quality control and inspection.

The circuit boards are dipped into the tanks by hand;  special racks are
sometimes used to hold small pieces which must be dipped into the  tanks.
Cleaning and changing of the bath contents is also done manually.   There
are exhaust hoods over the bath tanks that emit noxious fumes.
                                310

-------
Summary of Audit Findings and Recommendations:

      Conclusions:

      Chemical Hazards

      •   .  The production process uses corrosive  chemicals  such  as
            hydrochloric acid,  sulfuric acid,  and  sodium  hydroxide.

      •     The facility intends  to  locate MSDSs in  the department where  the
            substance is handled; they are currently located in the  emergency
            response cabinet and  in  the Environmental Affairs Coordinator's
            office.  The facility is evaluating computer  software to use  in
            standardizing the MSDS format.

      •     The facility is implementing a hazard  communication program and is
            developing a safety awareness program.   There are no  industrial
            hygiene or medical monitoring programs at the facility.

      •     Although the company  supplies gloves,  uniforms,  aprons, safety
            glasses, and rubber boots to all chemical process employees,  there
            is currently no enforcement procedure  in place.

      Process Information

      •     The only inventory control for the chemicals  in  the storage rooms
            is a sign-out sheet posted on the wall where employees indicate
            approximate quantities of chemicals removed from storage.

      •     Prominently displayed placards describing the hazards of various
            chemicals are present in some, but not all, parts of the facility.

      •     Entry and egress from the two chemical storage areas is obstructed
            by diking -- installed to meet fire codes -- surrounding the
            entire chemical storage area.  There are 18-inch high concrete
            walls in the doorways, which creates a potential hazard when
            carrying chemicals  in or out of the storage areas.  In general,
            the storage areas are congested and disorganized.

      •     Chemical containers were stacked on racks in each of the storage
            rooms;  some were double stacked on the top rack near the ceiling,
            creating a potential  stability problem.  There is no obvious
            method of placing or  retrieving chemical containers from the racks
            that were elevated off the floor.

      •     Both storage areas have exhaust ventilation ductwork to minimize
            fumes.   The design of the ductwork could be improved;  each duct
            run has four ninety degree bends, causing pressure drops and
            turbulent flow in the ducts, and considerably reducing the capture
            velocity at the end of the duct.
                                      311

-------
      Sections of Che 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.
•     The facility has a POTW discharge permit for  their waste water,
      and must report its discharges to the Littleton/Englewood waste
      water treatment plant.  Effluent pH and copper content  is
      monitored before waste water is discharged to the public sewer
      system.  Copper-bearing waste water is sent to a recovery system
      where the copper is removed and sold to a scrap metal dealer.

•     Ventilation of areas containing corrosive chemicals is  necessary
      to reduce employee exposure, but the general area ventilation in
      the chemical process area is not very effective.  Odors and
      irritation of the eyes and nose were noticed in this area.

•     The audit team identified several problems with the developer
      ventilation system (which was designed to reduce ammonia fumes):
      the design and placement of the ventilation hood, the ductwork
      installation, the use of duct tape to seal ductwork connections,
      and the use of corrodible, galvanized metal for the ductwork.
      Similar problems with ventilation hoods are also present in the
      legend screening room.

•     There are no back-ups or redundant equipment;  all chemical process
      operations are performed manually,  providing management with the
      flexibility to adapt to equipment breakdowns and failures.   The
      only automatic control in the process is the bath temperature
      control; all other control is done manually,  such as testing of
      bath solutions to ascertain if they meet specifications.

•     There are no process alarms or spill detection equipment.   Any
      process deviations or spills must be identified by operators.

Chemical Accident Prevention

•     The facility has hired an environmental affairs coordinator,
      responsible for health, safety,  and hazardous  waste issues,  who
      reports to the corporate financial officer,  rather than facility
      management or a corporate -level,  health and safety manager.

•     Employee safety meetings are held twice annually.   Weekly
      departmental safety meetings are planned for the future.

•     The new environmental affairs coordinator is implementing  a  safety
      auditing program in each department on a monthly basis.

•     There are no formal emergency operations procedures.
                                312

-------
•     There is no formal training program  for employees; most  of  the
      training is on-the-job from observation of experienced operators.
      As a result of high employee turnover  in  the chemical process
      area, many new untrained workers are stationed  in  this area.

•     There is one maintenance supervisor  and helper  for equipment and
      instruments at the facility, and a small  maintenance office.  Only
      critical spare parts are stocked by  the maintenance department.
      Due to the size of the company and the small maintenance  staff,
      most maintenance is done after equipment  failure.  Preventive
      maintenance, however, is performed on critical  equipment, and
      written records are maintained.

•     The facility had a formal hazard evaluation-system, but  it now
      relies primarily on the skills of the employees to recognize
      hazards and potential problems and come up with solutions.

•     No modeling has been done to determine the effect of an  incident
      on the surrounding community.

•     Sections of the chemical process area with the potential for leaks
      drain to the sump for containment, and the chemical storage areas
      are diked with concrete walls to contain  releases.

•     The facility is protected by a fire water sprinkler system,  but
      there are no smoke detectors or fire monitors in the chemical
      storage areas.

Accidental Release Incident Investigation

•     The facility has had no reportable accidental releases.

•     The facility has no formal incident reporting procedures.  All
      spills are investigated by the environmental  affairs coordinator,
      but a report is only generated if a spill .is  large  enough or has
      an impact on the employees at the facility.

Facility Emergency Preparedness and Planning Activities

•     The facility has a preliminary emergency response plan  and has
      filed a contingency plan with the Jefferson County  LEPC.

•     Evacuation routes are posted on bulletin boards in  the  lunchroom
      and the production area,  but there is no written evacuation plan.

•     The facility has a complete and well stocked  spill  control cabinet
      for responding to small spills.  It contains  MSDSs,  respirators
      and cartridges, protective clothing,  DOT spill  response  guidebook,
      non-sparking tools,  lime, and various absorbent materials.

•     Due to the small size of the facility,  emergency situations  can  be  '
      assessed by management personnel directly.

                                313

-------
•     The individual discovering a spill reports  to  the  department
      supervisor,  another supervisor, or the environmental  affairs
      coordinator, and a clean-up team is assembled.

•     The paging system is used to notify employees  of an emergency
      situation.

•     The facility does not have a formal hazmat  or  spill control  team;
      although they are organizing a trained hazmat  team.   Currently,
      spill cleanup is conducted and overseen by  trained personnel using
      MSDS information and the DOT emergency response guide.

Community and Facility Emergency Response Planning Activities

•     The company has a working arrangement with  a nearby medical
      facility to handle emergencies and workmen's compensation claims.
Recommendations:

Process Information

•     In order to avoid instability problems, the facility should
      discontinue stacking bulk chemical containers to the ceiling in
      the chemical storage area.

•     Chemicals should be kept in locked storage areas with controlled
      access and incompatible materials should be segregated.

•     An inventory list of chemicals should be posted at entrinces to
      the chemical storage areas to ensure chemicals are stored in the
      correct location.

•     A tracking system for chemical usage rate, ordering date, and
      expiration date should be implemented for both storage rooms and
      chemicals stored in the laboratory.

•     The facility should have placards for all areas and implement a
      labeling program for all processes and chemical storage
      containers.  The acid and base containers used for waste water
      neutralization should be clearly marked as to their contents and
      potential hazards.   All of the pipes, valves,  and pumps that are
      used to transfer materials should be coded or labeled.

•     Empty or full drums stored outside the facility should be in a
      locked, fenced area.  Waste drums stored in the shipping and
      receiving area should be clearly dated and labeled, and should be
      shipped off-site for treatment, storage, or disposal within 90
      days.
                                314

-------
      •     If SAS qualifies as a small quantity waste generator under RCRA,
            the facility should comply with the NFPA's 50-foot buffer zone
            requirements for ignitable wastes.

      •     Procedures should be developed for the proper handling and
            transfer of chemicals from the chemical storage area to the
            process area to avoid tripping and falling hazards (e.g., do not
            carry open beakers of liquids with bare hands).

      •     To avoid mishandling chemicals, the chemist who generates the
            make-up sheets should be the only one responsible for adding
            chemicals to the baths.   This procedure would also restrict access
            to the chemical storage areas.

      •     The ventilation systems in the process area and the screening
            areas should be improved.   If necessary,  a consultant should be
            hired to design the systems and experienced contractors should
            then be hired to properly install the systems according to
            engineering specifications.

      Chemical Accident Prevention

      •     The audit team believes that environmental and safety matters
            could be better addressed if the environmental affairs  coordinator
            reported to a facility manufacturing or engineering manager.

      •     The maintenance department area should be expanded to provide more
            space for spare parts and equipment.

      •     Fire detection in the chemical storage areas  could be improved
            with the installation of smoke detectors.

      Accidental Release Incident Investigation

      •     SAS should track and expand the scope of  existing release
            investigation programs for near-misses and small-scale  releases,
            particularly those which do not require reporting under
            environmental regulations.
Audit Team Member Composition:

Name 'and Title                Due Nguyen
Affiliation                   US EPA Region 8
Area of Responsibility        Team Leader
Expertise                     Chemical Engineer

Name and Title                John McCambridge
Affiliation                   US EPA Region 8
Area of Responsibility        Technical Reviewer
Expertise                     Chemist
                                     315

-------
Name and Title
Affiliation
Area of Responsibility
Expertise
Doug Hamilton
TAT, US EPA Region 8
Lead Technical Reviewer
Chemical Engineer
Name and Title
Affiliation
Area of Responsibility
Expertise
John Noto
TAT, US EPA Region 8
Non-Technical Reviewer
Geologist
Follow-up Activities:

      By the facility:

      By the Regional office:

      By State and local authorities:
Regional Contact:
Due Nguyen
                                      316

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Kodak -- Colorado Division  (KCD)
Facility Location:
Windsor, Colorado, Region 8
Date(s) Audit Conducted:
February 19 - 21, 1991
Description of Facility:

      SIC Code(s):


      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
3861 -- photographic equipment and
supplies

The facility occupies a 2,240 acre site 50
miles north of Denver, bordered on the
south by the Cache la Poudre River,  and on
all other sides by farmland.
X-ray film,  graphic arts film, color
photographic paper, lithographic plates,
microfilm, 110 camera film,  16mm movie
film, and photo-typesetting paper.
The town of Windsor,  population 4,277,  is
a half-mile from the  facility.
Reason for Facility Selection:
The facility was chosen because of a
release of ethylene dichloride on 6/11/90
from an overfilled' underground storage
tank in plate manufacturing.
      ARIP Reports:
None
Focus of Audit:
      Hazardous  Substances(s)
      Examined:
Ethylene Dichloride (EDC)
Nitric Acid
Sulfuric Acid
Phosphoric Acid
Sodium Hydroxide
                                      317

-------
Physical Area(s) Examined:
at the Facility:

Storage and Handling

•     Storage Systems

      There are three 8,000-gallon  tanks of  ethylene  dichloride,  one
      8,000-gallon tank of waste  solvent,  two 4,500-gallon  tanks  of
      sodium hydroxide, one 4,500-gallon tank of  sulfuric acid, one
      4,500-gallon tank of nitric acid, and  four  4,500-gallon  tanks of
      phosphoric acid for the plating  area.  In addition, there are a
      number of fuel oil, gasoline, and propane tanks, as well as
      fourteen underground storage  tanks,  four of which are  in service.

•     Shipping/Receiving

      Raw materials for KCD production arrive by  truck and  train and
      products are shipped out via  truck.

•     Material Transfer

      Liquid process streams are  transferred throughout the  area using
      pumps and dedicated piping.

Process Area(s)

The audit focused on the lithographic  plate  manufacturing in building C-
60.  This area, site of the ethylene dichloride spill, involves the use
of many other corrosive and hazardous  chemicals;  the  lithographic plate
manufacturing process at KCD is the only process  where virgin raw
material comes in one end of the building  and a final, finished,  salable
product comes out the other end.

Rolls of aluminum sheets are treated with  various chemicals and
processes to produce metal which can be coated with photopolymers in the
next process step.  All tanks in  the chemical mix area supporting the
prep operation are equipped with ventilation ducts to remove fumes from
the area.

Treated aluminum sheet  is coated with  photopolymers via a proprietary
process.  Ethylene dichloride, used as a carrier  solvent in this
process, is recovered using carbon bed adsorption ard is recycled back
into the process.

Coated aluminum sheet is cut to customer's specifications and packaged -
over 12,000 different catalog items are produced  for customers.  Due  to
the large number of catalog items,  the finishing  areas constructs  its
own packaging containers.  All packaging waste material is recycled.

Solid hazardous waste is collected  in  drums  and stored on an uncovered
RCRA-permitted concrete pad for removal.   The concre~e pad is diked on

                                318

-------
      all sides to prevent leaking waste from migrating beyond  the  pad.   A
      sump is used to collect any leaking materials or precipitation.   Liquid
      hazardous waste is sent back to Kodak in Rochester, New York,  by  tanker
      truck for burning in a permitted hazardous .waste incinerator.
Summary of Audit Findings and Recommendations:

      Conclusions:

      Chemical Hazards

      •     For most chemical compounds, Kodak produces Safety  Spec  Sheets
            that are more detailed than a typical MSDS.  Safety Spec Sheets
            and MSDSs are kept in the receiving, production, and  foreman's
            office.  MSDSs are available throughout the facility, and are
            provided to contractors for the area in which they  are working.

      •     The primary chemical hazards are:

                  Explosivity.  Hydrogen is released to the ventilation system
                  during the metal preparation process and presents a severe
                  explosion hazard.  There are hydrogen gas concentration
                  monitors on the exhaust gas.

                  Flammability and Toxicity.  EDC is a flammable  solvent that
                  forms toxic compounds when heated to decomposition; as a
                  result, KCD is trying to eliminate its use.

                  Corrosivity.  There are many corrosive chemicals,  including
                  nitric acid, sulfuric acid, and sodium hydroxide.

      •     Kodak has an in-house labeling system to classify materials
            according to their hazard ranking.

      •     Personnel working with ethylene dichloride are monitored for
            exposure twice per year.

      Process Information

      •     Drums in the plate manufacturing area are located in specially
            designed storage area, stacked only two high on a rack,  and are
            individually labeled.  The area is clean and well-lighted.

      • .    Flammable wastes are stored outside without roofing, exposing
            waste drums to high temperature during the summer and increasing •
            the potential for a release to occur.

      •     Small quantity chemicals are weighed out under a ventilation hood
            with a high efficiency particulate filter prior to mixing.
                                      319

-------
•     All of the piping and process equipment  is well  labeled,  and no
      leaking pipes or equipment were  identified.

•     An emergency generator, which automatically  starts  during a  power
      failure, allows the command control center to  continue  operating.

•     Two rotating carbon beds recover EDC  from the  drying  process.   The
      beds are designed to switch automatically; if  the set point  is
      exceeded by fifty percent, an alarm sounds locally  and  in the
      Plant Protection department.  As an additional backup,  a  timer
      will switch the beds every 30 hours.

•     Secondary fans prevent exposure  to solvent vapors from  the dryers
      in the coating process if the primary fans fail.

•     Many of the process operations are controlled by programmable
      logic controllers (PLCs).  The facility has made a  decision  not  to
      backup the PLCs after analyzing  all control  loops and processes
      and determining that no danger or hazard would result from a PLC
      failure.

•     Process parameters are controlled either by  instrumentation  or
      manually by experienced operators.  Although SOPs are the official
      guide for running the processes, they are supplemented by the
      knowledge and experience of seasoned operators.

•     KCD has been conducting river surveys every six weeks in
      cooperation with Colorado State University.   The Cache la Poudre
      River is sampled at eight locations; if the pH is out of range,
      the discharge can be stopped while the pH is adjusted.

•     Hazard analysis conducted on the coating area identified two
      critical systems:

            The EDC storage and distribution system, particularly
            aboveground piping; barriers to soil contamination;  loading.
            unloading, and transfer procedures; and alarms  (the entire
            EDC storage and handling system has been upgraded);  and

            The carbon bed adsorption system (the pneumatic control
            systems was replaced with PLC control).

Chemical Accident Prevention

•     The plate facility reports directly to management in Rochester,
      New York.  Local management provides support services, allowing
      the plate management more direct access to corporate management.

•     Eliminating underground storage  tanks is a very high priority with
      the Eastman-Kodak Company.  Kodak has budgeted $100 million for
      the elimination or upgrading of all underground tanks.  KCD
                                320

-------
estimates the cost to upgrade and/or  eliminate  its  underground
storage tanks to be $1.2 million.

The Kodak corporate Health and Environmental  Laboratory  (HAEL)
performs chemical compatibility studies,  design studies  for  new
chemicals and equipment, laboratory testing of  exposure  to new
chemical compounds, chemical handling, employee chemical  safety
procedures, and basic physical property data.

There are no guard stations or security checkpoints at the
entrances to the facility -- access to the site is  open.  Magnetic
cards must be used to access any building; there is no sign  in or
sign out procedure.  Patrols of the grounds are made periodically
by the Plant Protection department.

The Plant Protection department consists  of 23  employees who
provide round-the-clock coverage in crews of  five.  The plant
protection department is responsible  for:

      fire prevention and fire response and training;
      medical and spill emergency response;
      security and monitoring of 700  alarms and cameras;
      upkeep of all plant personnel respirators;
      coordinating building tests and drills;
      operational aspects of the waste storage  pad; and
      operation of the internal chemical  safety database;

In 1985, the plant first aid team system was eliminated to reduce
costs, and there has recently been a  significant reduction in the
personnel in the plant protection department.    It would be
difficult for the department to respond to multiple emergencies.

A potential problem analysis team,  consisting of hourly and exempt
employees from various department and the plate unit manager,
meets weekly to discuss process safety related  issues.

The plant is working toward certification under the International
Standards for Organization (ISO)  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 standards.

There is a safety representative  in each department/process unit.
Plating unit audits are performed by the safety coordinator every
other month.

Standard operating procedures are available in all  process areas.
In the plate manufacturing division,  there are three types of
procedures -- equipment, startup  and shutdown, and  routine
operations and troubleshooting.

                         3'21

-------
Currently, one person in each of the plate operations  is
responsible for document control and can issue a procedure without
any other approvals.   Under a new system being developed,  three
signatures will be necessary before a procedure is  issued.

The plate facility has implemented the DuPont STOP  safety  program,
under which any worker can stop an activity from proceeding  if  the
activity is considered unsafe.  KCD has been very successful  with
this program, primarily in the finishing area, and  other plate
operations will implement it as necessary.

A series of hazard communication video tapes are shown to
employees periodically for initial and refresher training.

The plate manufacturing division primarily uses on-the-job
training with its standard operating procedures.   An orientation
checklist is used to verify all new empl /ee training is
completed; each operation area maintains a tracking system and job
skills inventory for all their personnel.

Employees who are out of their particular plate operations area
for more than 90 days must be recertified to work in that area.

Training competence at KCD is documented and certified using  the
Analytical Methods for Training (AMI) system.

The maintenance department uses a formal Planning and Control
System (PACS) to organize their work.  This computer system keeps
track of preventive maintenance and inspection,  equipment and
instrument history, and repair cost history,  and  issues preventive
maintenance, inspection, and trouble call  work orders.

All of the test instruments and tools used by the maintenance
department can be calibrated by an onsite  metrology laboratory.

To maintain electrical classification (separation of explosion-
proof electrical devices from non-explosion proof devices), the
control room for the solvent chemical mix  is maintained under
positive air pressure to prevent the potential introduction of
flammable vapors from a release in the chemical mix area.

In the chemical mix area where EDC is used,  the  floor is  swept by
exhaust ventilation and the EDC concentration is  monitored by a
hydrocarbon analyzer.

Each operations area within the plate facility has  evaluated  their
process for critical systems.  Most of the  evaluations  were done
using "What If" failure analysis.

The corporate office has provided modelling assistance  for a
complete breakthrough of the carbon bed system and  a release  of
                          322

-------
      the entire contents of an EDC  tanker  trailer.   In both  cases  there
      was no impact beyond the KCD property  line.

•     Release prevention systems include:

            Construction of acid and caustic  sewer lines and  drainage
            trenches inside the plate building of stainless steel;
            Continuous monitoring of pH of  the waste  water treatment
            plant influent and effluent;
            Indoor bulk chemical storage areas are diked or have drains
            at the entrance to prevent spills escaping containment;
            A more durable liner containment  system has been  installed
            around the EDC storage tanks to  route leaks, spills,"or
            overflows to the existing sump;
            The leak collection sump at the  EDC storage area  and the EDC.
            storage tanks have primary and secondary  level indicators
            and alarms that sound in three separate areas;
            Ventilation systems for  all chemical mix  tanks to control
            dust when adding solid materials; and
            The facility tests the integrity of their underground
            storage tanks on a periodic basis.

Accidental Release Incident Investigation

•     The facility has a formal spill and release notification and
      response policy based on corporate procedures.   Incident reports
      are issued following any occurrence.

Facility Emergency Preparedness and  Planning Activities

•     The facility has an extensive written emergency .response plan
      based on corporate procedures.   Incidents are classified into
      three category based on the potential for off-site impact.

•     Building evacuations are held once annually for each shift.
      Designated searchers inspect the buildings and are the  only  means
      of ensuring a complete evacuation;  no head count is  taken.

•     Powered air purifying respirators are used in the chemical mix
      area due to the low Threshold Limit Value for EDC. .

•     The plant protection department has a fully staffed  fire and
      hazmat operation, including a hazmat truck with SCBAs,  a portable
      decontamination pool, overpak drums,  portable shower, absorbents,
      protective gear, pumps,  a generator,  and other  equipment.  All
      portable equipment and vehicles are inspected weekly.

•     Two members of each Plant Protection crew are trained emergency
      medical technicians, and at least two members are first  responder
      trained; in the future,  all members of each crew will receive  all
      training.
                                323

-------
Community and Facility Emergency Response Planning Activities

•     KCD is an active member and regular attendee at both  the  Colorado
      SERC and the Weld County LEPC, and supported the  former Emergency
      Management Advisory Board prior to SARA Title  III.

•     KCD sponsors an annual Earth Day fair on health and safety  in
      conjunction with Weld and Larimer counties and nearby  towns.

•     The facility response plan is coordinated with the county and
      local emergency agencies.  The facility performs  regular  internal
      as well as community exercises throughout the  year.  In 1991,
      approximately four exercises will be coordinated  with  authorities
      in Windsor.

•     KCD has offered to provide equipment and technical expertise to
      the LEPC for non-KCD hazardous materials incidents.  The  facility
      and Windsor fire departments work closely together and have
      jointly sponsored numerous training classes.

Public Alert and Notification Procedures

•     The emergency response plan contains procedures and guidelines for
      communicating with the nearby community, the local "hospital, and
      dealing with media interaction.
Recommendations:

Process Information

•     A roof should be placed over the hazardous waste storage area.

Chemical Accident Prevention

•     Manpower in the Plant Protection department should be increased.

•     To improve the equipment predictive maintenance system,  a
      subroutine should be written for the PACS program to tell the
      maintenance department how many times a piece of equipment has
      been repaired.  This would allow the facility to identify trends
      of potential hazard areas.

Accidental Release Incident Investigation

•     KCD should expand the scope of existing release investigati T
      programs to track near-misses and small-scale releases,  i.e.,
      those which do not require environmental regulatory reporting.
                                324

-------
      Facility Emergency Preparedness and Planning Activities

      •     A per-building head count system should be instituted to account
            for personnel during emergency situations.
Audit Team Member Composition:

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Due Nguyen
US EPA Region 8
Team Leader
Chemical Engineer

Carol Way
US EPA Region 8
Emergency Preparedness and Planning
EPCRA Enforcement

Doug Hamilton
TAT, US EPA Region 8
Technical Reviewer
Chemical Engineer

Susan Walker
TAT, US EPA Region 8
Non-technical Reviewer
Toxicologist

Ed Herring,  LEPC Chairman
Weld County Sheriff's Office
Observer
OEM Coordinator
Follow-up Activities:

      By the facility:

      By the Regional office:

      By State and local authorities:

Regional Contact:             Due Nguyen
                                      325 .

-------
326

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Columbia Falls Aluminum Company  (CFAC)
Facility Location:
Columbia Falls, Montana, Region 8
Date(s) Audit Conducted:
April 30 - May 3, 1991
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:

      Proximity to
      sensitive populations:
3334 -- primary aluminum production

50 south of the US/Canada border and 17
miles west of Glacier National Park along
the Flathead River in northwest Montana.
Aluminum ingots
Aluminum City and Columbia Falls City
(total population 3,000) are within 2
miles.
Reason for Facility Selection:
      ARIP Reports:
The facility was chosen because of a
release of 7,700 pounds of hydrogen
fluoride to the air on September 12,  1989.

9/12/89 release of hydrogen fluoride
Focus of Audit:
      Hazardous Substances(s)
      Examined:
Aluminum Fluoride
Carbon Monoxide
Chlorine
Coal Tar Pitch
Hydrogen Fluoride
                                      327

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      Alumina ore and petroleum coke are stored  in  large  silos  --  the
      plant consumes 2 million pound of alumina  ore daily.   Coal  car
      pitch, chlorine, liquid oxygen, and propane are  stored in tanks.
      Hazardous waste (cleaning solvent) is stored  in  drum  garage.

•     Shipping/Receiving

      Alumina, coal tar pitch, and petroleum coke are  delivered by
      train; other supplies and raw materials are delivered  by  truck.
      Finished aluminum ingots are shipped out by train.

•     Material Transfer

      Vacuum crucibles on "fork trucks are used to transfer molten
      aluminum metal from the production area to the casting room in
      order to prevent potentially explosive reactions with  water.

Process Area(si

Anodes for the electrolytic reduction cells are produced in  the paste
plant area.  Petroleum coke and coal tar pitch are mixed, heated, and
extruded into circular briquets.   The briquets are cooled and then
transferred, as necessary, to the pot line rooms to replenish consumed
anodes.  Steel pins are placed in the anode to provide structural
strength and a path for electrical flow.

The production of aluminum takes place in an electrolytic cell  (pot) --
CFAC has five pot lines with a total of 600 pots.  There is an anode at
the top of the cell and a cathode at the bottom of the cell.  The
cathode is actually the bottom and sides of the cell,  with a carbon
lining supported by a steel outside shell.   Electrical conductors are
connected to the anode and cathode.  The current is carried through a
bus bar to the anode, through the liquid portion of the cathode, and
back out to the collector bars to the main bus bar system.

Alumina is added periodically to the cell and dissolved in molten
cryolite solution (NaAlF).  The electrochemical reaction in the cell
involves the combination of oxygen from the alumina with carbon at the
anode.  Carbon dioxide and some carbon monoxide is generated.  Free
aluminum falls to the bottom of the pot where it accumulates and is
removed using a mobile collection truck and vacuum crucible.

Molten aluminum metal is transferred to the casting room,  poured into a
mold, and placed in a casting furnace.   Ingots are cooled by water as
                                328

-------
      they are formed.  Finished ingots are  inventoried  in  the casting  room
      and loaded on train cars for transport  to  the  customer.

      Fan towers collect the gases from around the outside  of the cell  and
      transport them to the air pollution control equipment.  CFAC  licenses
      the control technology (Alcoa fluidized bed dry  scrubbers), which use
      the alumina coming into the plant, prior to ore  reduction, to  adsorb
      hydrogen fluoride off-gases from the pots.
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     The facility was purchased by an employee from Atlantic Richfield
            in 1985 and is the largest employer in Flathead County.

      •     The only public access is by a road to the west of the plant.

      •     The facility is located in an potential earthquake and flood zone.

      Chemical Hazards

      •     Chemical hazards include gaseous hydrogen fluoride, coal tar pitch
            volatiles, carbon monoxide from the dry scrubber, gaseous
            chlorine, and liquid oxygen.  Pot crusts, containing very high
            temperature substances, could be contacted by facility visitors.

      •     Contractors are provided MSDS sheets for the area in which they
            are working.

      •     Operators are monitored for fluoride exposure and annual physicals
            are performed on employees working with asbestos removal.

      Process Information

      •     Housekeeping practices in the plant are effective in handling the
            volume of fine particle material present on-site.  Non-hazardous
            waste is dumped in a landfill behind the facility that is  subject
            to disturbance by high winds.

      •     The plant is highly dependent on a reliable electrical power feed
            to maintain ore reduction, and consequently has made arrangements
            to insure a secondary source of power.

      •     Due to increased efficiency and operating changes implemented by
            the new management, the plant can be operated at the same  rate of
            production with less personnel.

      •     The gate house alarm system has a battery backup.

                                      329

-------
•     Important parameters for th'e scrubber system are monitored by  a
      computer and controlled by an operator -- the operator  reviews
      printouts from the computer to detect upset conditions.

•     The facility maintains constant, but not real-time, hydrogen
      fluoride emission monitoring in the roof ventilators and at the
      exhaust gas stacks.   Ambient air monitoring is performed in
      Glacier National Park together with the National Park Service.

•     Process hazards include the potential for steam explosions from
      the reaction between water and molten aluminum, and the potential
      explosivity of carbon and other metal dusts present.

•     Noise levels in the casting room are very high, and have not been
      measured for compliance with OSHA standards in ten years.

Chemical Accident Prevention

•     The facility receives aluminum safety and incident information as
      a result of its membership in the Aluminum Association and the
      International Primary Aluminum Institute.  There is extensive open
      technology exchanges between the plant and others in the industry.

•     The facility believes that the streamlining of the management
      structure, including having the safety supervisor reporting to the
      plant manager, has improved the communication flow, and that the
      new profit-sharing plan has had a positive influence on safety.

•     There is a formal safety committee composed of representatives
      from management, union, and exempt employees from every
      department.  Meeting minutes are sent to management for response.
      In addition, an executive safety committee composed of the  plant
      manager, union president, area manager,  and one hourly employee
      addresses concerns unsolved by the safety committee.

•     CFAC publishes a company newsletter which includes important
      safety and chemical hazard information.   All employees take an
      annual safety refresher course.   In addition,  each work crew holds
      a monthly safety meeting.

•     All workers and visitors must enter through one security gate;
      contractors must pass through a separate contractor security gate.
      Periodic site patrols are performed by one plant security guard.

•     Safety inspections are conducted on a monthly or quarterly  basis
      and simulated OSHA inspections are held 2-3 times per  year.

•     A job safety analysis is done before any process changes are  made,
      including a meeting of engineering and.production department
      representatives for a safety review.
                                330

-------
None of the workers in the casting room were observed  wearing  ear
protection.  Although the noise level may be within OSHA
standards, it is constant over a 24-hour period.

Operating logs are used to transfer  information between shifts.

CFAC has a new employee training program, which includes  one week
of classroom instruction; on-the-job training for  3-4  weeks; and
evaluations after 2, 4, 6, and 9 weeks.  There is  no pre- or post-
training testing to determine its effectiveness.

Contractors must go through a safety orientation and abide by  CFAC
safety rules.  Safety information is included in contracts, and
CFAC has discharged contractors for not following  procedures.

Refresher training is given to employees who have  been out of  a
particular job for 90 days, but there is no cross-training between
departments.

A hew computerized maintenance recordkeeping system is being
implemented to track equipment history (including  costs) and
preventive maintenance.  Preventive maintenance work orders are
now computer-generated.

The maintenance department processes both written  and verbal work
order requests; verbal requests,  however,  are not  documented.

CFAC has a large, well-equipped mechanical shop with 30 staff to
assure rapid equipment repairs.

Instruments are not routinely calibrated or maintained and are
repaired only after they fail.  The rectifier control room is  the
only area with scheduled maintenance.

Hazard evaluation is an informal process at CFAC  and no air
modeling is performed.

Since installation of the new dry scrubbers,  fluoride emissions
have been reduced from 3,000-5,000 pounds  per day  to 800-900
pounds per day, bringing CFAC into compliance with State  of
Montana emission standards.

Computer-controlled feed rate equipment is being  installed for  the
dry scrubbers to reduce the potential for  error arising from the
current practice of manual feed control.   In addition,  an  alarm
system notifies the operator if the alumina feed  is interrupted.

The visual and audio alarm system is  monitored from the security
gate house and oversees smoke detectors, boilers,  air compressors,
computer room temperature, and intrusion alarms.   There are
written response procedures for each  alarm.
                          331

-------
•     The company has implemented several environmental  initiatives:

            A used oil burner was purchased which  consumes  10,000
            gallons a year of waste oil;

            Sweeping the basements underneath  the  pot  lines  has  returned
            200,000 pounds of alumina to production; and

            A new scrubber was installed in the paste  plant.

•     All areas containing flammable materials are equipped  with
      overhead sprinklers.

Accidental Release Incident Investigation

•     Only one release has occurred.  On 09/12/89, approximately 7,700
      pounds of fluoride was released due to a failure in the alumina
      feed system on one of the dry scrubbers.  Mis-communication
      complicated the incident and allowed the release to continue over
      an eight-hour period.  The facility has several  different
      operating procedure documents covering dry scrubber operation.

•     CFAC has a formal environmental incident report  form.  Front-line
      supervisors are primarily responsible for the investigation and
      reporting of near misses and accidents,  although hourly employees
      are also involved in the investigations.  Lessons  learned are
      presented at safety meetings for applicable work crews.

Facility Emergency Preparedness and Planning Activities

•     The facility has an extensive written emergency response plan,
      which is maintained by the medical and security supervisor.  The
      plan is reviewed annually to insure phone numbers and procedures
      are accurate.

•     A simulated chlorine leak drill was scheduled and performed by the
      casting department, but no exercises have been developed for other
      hazards at the facility.

•     The facility has a formal evacuation plan showing evacuation
      routes and exits.  Evacuation drills are conducted for the
      maintenance and casting department, and are critiqued £./ the
      medical and security supervisor.   There  is no head count system
      for evacuations in emergency situations.

•     The fire water system --  the.two 230,000 gallon on-site water
      tanks used to cool ingots,  has two electric and one diesel purp.

•     The facility has a 350 gpm fire truck and an ambulance and is
      currently stocking a hazmat trailer with response gear.
                                332

-------
•     A portable disaster pack, prepared by the security department,
      contains all manuals and reference materials necessary to handle
      emergencies, including a facility call-out sheet.

•     In an emergency situation, the plant security officers (eight
      full-time and two part-time) would manage the response, assisted
      by other plant personnel.  They also inspect fire doors, fire
      extinguishers, and post indicator valves.

•     The facility, concerned about the effectiveness of its public
      address system, is installing an upgraded speaker system.  This
      will eliminate potential confusion arising from using the same
      siren for lunch, quitting time,  and emergencies.

•     All security officers are trained emergency medical technicians
      and members of either a local fire department or ambulance
      service.  They participate in firefighting training as well as
      other response training at least once a month.

Community and Facility Emergency Response Planning Activities

•     The'emergency plans have been coordinated with the Columbia Falls
      fire department, and the facility has coordinated annual training
      sessions on-site with area fire  departments and ambulances.

•     A CFAC representative is a member of the LEPC,  but the company has
      not conducted any training or exercises with the LEPC.

•     Facility security staff participate in an annual disaster drill
      with Flathead County and training with the Kalispell  medical
      helicopter service.

Public Alert and Notification Procedures

•     The emergency response plan contains procedures  and guidelines  for
      interacting with the media.
Recommendations:

Process Information

•     Housekeeping at the sanitary landfill should be improved.

•     Noise measurements should be made in the casting room to insure
      compliance with OSHA standards.

Chemical Accident Prevention

•     The facility should consider implementing employee  incentive
      programs to reward good safety practices.
                                333

-------
      •      The facility should install warning signs alerting visitors to
            avoid stepping on pot crust.

      •      CFAC should consider updating detailed operating procedures for
            the dry scrubber area.

      •      An instrument calibration program for process instrumentation,
            controls,  and interlocks should be instituted.  Existing
            maintenance should be expanded to include more frequent
            calibration of controls and detectors.

      •      The facility should evaluate the most commonly handled dusts to
            determine the degree of explosion hazard posed,  and implement
            preventive measures such as open^circuit dust collection systems,
            explosion/fire suppression systems,  or "epitropic" filter fabric
            to disperse the buildup of static charges on bag houses or dust
            collector systems.

      •      CFAC should conduct formal hazard analysis to define and identify
            all credible process hazards that could endanger employees or the
            public, harm the environment,  or cause serious equipment damage.

      Facility Emergency Preparedness and Planning Activities

      •      The facility should implement a head count system for personnel
            evacuations during an emergency situation.

      •      The facility should consider using separate siren signals for
            indicating emergencies  and lunch/quitting time.

      •      Training and exercises  should be conducted for the appropriate
            response to both a chlorine and a propane release.

      Community and Facility Emergency Response  Planning Activities

      •      CFAC should consider working more closely with local  authorities
            and conduct regular table top exercises to simulate  a response  in
            the event of a natural  disaster.
Audit Team Member Composition:

Name and Title                Due Nguyen
Affiliation                   US EPA Region 8
Area of Responsibility        Team Leader
Expertise                     Chemical Engineer

Name and Title                John McCambridge,  AARP
Affiliation                   US EPA Region 8
Area of Responsibility        Technical Reviewer
Expertise                     Chemist
                                     334

-------
Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Doug Hamilton
TAT, US EPA Region 8
Technical Reviewer
Chemical Engineer

Jerry Goedert
TAT, US EPA Region 8
Technical Reviewer
Chemical Engineer

Kim Potter, Chairman
Flathead County LEPC
Observer
Emergency Planning
Follow-up Activities:

      By the facility:

      By the Regional office:

      By State and local authorities:.
Regional Contact:
Due Nguyen
                                      335

-------
336

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:


Facility Location:
Syncom Technologies, Inc.
Mitchell, South Dakota, Region 8
Date(s) Audit Conducted:
May 29 - 31, 1991
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:

      Proximity to
      sensitive populations:
3695 -- magnetic recording media

A light industrial area southeast of
residential Mitchell
Computer diskettes and computer tape
None
Reason for Facility Selection:
      ARIP Reports:
The facility was chosen because of a 57
gallon release of cyclohexanone in 1987,  a
referral from the South Dakota SERC, and
use of hazardous chemicals.

None
Focus of Audit:
      Hazardous Substances(s)
      Examined:
Cyclohexanone
Methyl Ethyl Ketone (MEK)
Toluene Diisocyanate/Xylene (CB-60 PMA)
                                      337

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      The three 10,000-gallon steel underground  storage  tanks  in the
      northern part of the facility contain cyclohexanone,  recovered
      solvent, and fresh methyl ethyl ketone.  An adjacent  1,000-gallon
      underground storage tank provides  interim  containment  for
      recovered cyclohexanone.

•     Shipping/Receiving

      A 5,000-gallon truck shipment of cyclohexanone is  received every
      other month; MEK shipments are less frequent.  Solvent for
      recycling is stored on-site until  a sufficient quantity  is present
      for shipment to a recycling facility.

•     Material Transfer

      Gear and diaphragm pumps are used  to bring fresh solvent from the
      storage tanks to the mill mix room.  Pumps are also used for
      material transfer between process vessels.  Color  coding of
      process lines is used for identification purposes.

Process Area(5)

Resin preparation used to coat mylar is performed in 200 to 300  gallon
batches.  The recipe of ingredients varies depending on  the product
being made, but the process equipment is the same.  A batch record
outlining ingredient additions is used to guide batch preparation.
Blending and  filtering steps are used in each batch preparation.

Once a batch  of mylar is prepared and quality checking performed, the
batch is sent to the coating bath where resin solution is pumped on
demand.  Resin coating thickness is in the micron range, and depends
upon the specific product.  Mylar sheeting approximately 13 inches wide
is conveyed through the resin bath and then through a closed system
heated dryer  to remove solvent.  The coated mylar is rerolled in
preparation for additional mechanical processing.  Air from the  closed
system dryer  goes to an adjacent building for solvent recovery.  The air
is cooled using R-22 refrigerant to condense cyclohexanone.   •

Since any failure in the solvent recovery process would result in poor
drying efficiency of the coated mylar,  the solvent recovery process is
equipped with process alarms.  The alarms are connected to lower
explosive limit (LEL) monitors for the air returned to the coating
dryer; the coating line is shut down if the LEL is reached:
                                338

-------
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     The work force is composed of some  long-time  employees,  part-
            timers, college students, and others.  Employee  turnover in  some
            jobs is quite high.

      •     Syncom experienced a change in ownership  in 1987,  leading  to
            reduced staffing in non-product ion  positions  but  increases in
            overall plant- employment and production.  There  is very  little
            funding available to support facility safety  programs.

      Chemical Hazards

      •     MSDSs are located in the lab adjacent to  the  processing  area, but
            some are more than five years old.

      •     The audit team observed non-compliance with posted safety rules
            regarding use of safety masks and gloves  while handling  hazardous
            chemicals.

      •     The facility does not attempt to document suspected acute or
            chronic toxic effects of chemical exposure.

      •     Although audit team personnel experienced headaches and  light-
            headedness during the audit, facility personnel seemed unaware
            that solvent concentrations might be above OSHA Permissible
            Exposure Levels.

      Process Information

      •     The facility is considering replacing its underground storage
            tanks with aboveground storage tanks by 1995.

      •     There are no written procedures for receiving fresh solvent
            shipments.

      •     There is no labeling or protective barriers for tank piping,  and
            the pumps for these tanks were inaccurately labeled.

      •     Backup process equipment is not available.

      •     The only environmental monitoring performed by the facility is on
            water collected in a sump near the underground storage tanks.

      •     The facility has not performed air quality monitoring.
                                      339

-------
Chemical Accident Prevention

•     The combination of competition and  the  ownership  change  have  led
      to management and support staff reductions while  plant operations
      staff has increased.  Present staffing  and ownership  commitment
      may be severely compromising worker health and  safety, as
      exemplified by the cyclohexanone odor throughout  the  facility.

•     Since the ownership change, internal audits,  safety goals,  and
      safety objectives are not used by the facility, no safety meetings
      are held, and formal recordkeeping on training  and maintenance is
      not followed.  The safety coordinator has many  additional
      responsibilities, and spends little time on safety concerns.

•     Managers conduct a monthly plant tour to identify safety concerns,
      although follow-up to identified concerns is  not documented.

•     Although an SOP manual for mill mix operations  exists, it appears
      to have been written under the previous facility owners and not  to
      be a working document.  The batch record is the primary process
      document.  Shift turnover logs are also used  since the facility
      operates 24 hours a day, seven days a week.

•     Employee turnover is characterized as high by the facility.

•     New employee orientation covers a variety of  safety-related
      subjects and takes 1.5 hours to a half-day to complete.

•     Procedure performance is passed from experienced operators to new
      operators through on-the-job training.  No means to determine the
      effectiveness of company training programs exist and refresher
      training and cross-training are not used.

•     The facility uses an "as needed" maintenance policy for  both
      equipment and instruments; formal work order procedures  are  not
      used.  Diagnosis of chronic and persistent equipment failure is
      dependent upon operator or maintenance worker memory.

•     No formal hazard evaluation practices are conducted,  and  the
      limited chemical use makes air modeling unnecessary.

•     Sump monitoring near the underground storage tanks is  used to
      detect leaks from the tanks or transfer lines.

•     Recent efficiency improvements have allowed the coating  line to be
      idled for 3 weeks to support maintenance.   Prior to the efficiency
      improvement, preparations were being made to install a second
      coating line to allow the facility to switch over production.

•     No post-release mitigation systems were observed.  The  mill mix
      room does have explosion-proof features to offset the  explosive
      hazards posed by the solvents.

                                340

-------
Accidental Release Incident Investigation

•     A release of 57 gallons of cyclohexanone occurred  in  1987 when  a
      transfer line between the recovery building and the underground
      storage tank failed.  The release was detected by  the groundwater
      sampling conducted at the nearby sump.  Another incident involved
      a fire in the mill mix room that occurred as a result of improper
      maintenance procedures.  No documentation of either incident was
      available for review by the audit team.

•     The facility has a formal spill report form, but there are no
      formal procedures for investigating accidents or for implementing
      corrective actions.

Facility Emergency Preparedness and Planning Activities

•     The facility emergency response plan -- containing evacuation
      routes, shelter areas, and safety rules for each operation area --
      has not been revised since 1986.

•     A review of personnel responsibilities and assignments is part of
      the training orientation materials.   This document is not dated,
      and there is no mechanism for updating personnel information.

•     Fire drills are conducted every six months.

•     A 1982 evacuation map also indicates fire extinguishers,  pull
      stations, alarm bell systems,  first aid stations,  and blankets.

Community and Facility Emergency Response Planning Activities

•     Annual exercises are held in cooperation with the  LEPC.   Syncom
      personnel have conducted a disaster drill with the Mitchell  Fire
      Department in 1988 and 1989.

•     The Mitchell Fire Department has been provided with a plant  tour,
      a layout of the plant, and a listing of hazardous  chemical
      information, and has conducted a Title III inspection.

•     The facility would rely on the Davison County Hazmat unit in case
      of a serious incident at the facility.

Public Alert and Notification Procedures

•     Syncom has no provisions for notifying the public.
Recommendations:

Chemical Hazards

•     Updated versions of the older MSDSs should be  obtained.

                                341-

-------
•     To identify immediate health and safety concerns, the  facility
      should contact the state-coordinated Occupational Health and
      Safety Consultation Program for guidance in  improving  overall
      worker health and safety.   In addition, an industrial  hygienist
      should be contacted to investigate facility  operations.

•     The facility should immediately initiate a study of the
      cyclohexanone vapor level in the air within  the facility.

Process Information

•     The facility is encouraged to replace  the underground  storage
      tanks with aboveground storage tanks.

•     The audit team recommends that labeling for  tank piping and pumps
      and rail guards for tank piping should be installed.

•     The audit team strongly recommends that the  facility initiate a
      routine or constant air monitoring program.  If high solvent
      levels are detected, three potential solutions are:

            A professional air balance study which could lead to a more
            efficient vapor removal from die building;

            Better vapor containment in process equipment; and

            Procedural changes may decrease solvent evaporation.

Chemical Accident Prevention

•     Staff additions or adjustments, relating to the safety coordinator
      and inspection and maintenance programs, should be made to improve
      workplace safety and health.

•     The facility should document employee training, inspection
      reports, and corrective actions.

•     Safety training for personnel should be implemented along with an
      enforcement program to insure compliance.

•     SOPs should be updated and used as working documents.

•     Formal process hazard assessments should be conducted  to identify
      potential problems.

Accidental Release Incident Information

•     The facility should expand its use of incident documentation to
      areas such as operator training,  equipment changes,  and revise i
      operating procedures.
                                342

-------
      Facility Emergency Preparedness and Planning Activities

      •     The facility should update the emergency plan and evacuation map
            and provide descriptions for responses to specific  incidents to
            support employee training.
Audit Team Member Composition:

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Due Nguyen
US EPA Region 8
Team Leader
Chemical Engineer

John McCambridge
US EPA Region 8
Technical Reviewer
Chemist

Jerry Goedert
TAT, US EPA Region 8
Technical Reviewer
Chemical Engineer

Doug Hamilton
TAT, US EPA Region 8
Technical Reviewer
Chemical Engineer

Don Herrick,  Chairman
Davison County LEPC
Observer
Emergency Management Director

Kathy Shroyer
Davison County LEPC
Observer
Title III Coordinator
                                      343

-------
Follow-up Activities:




      By the facility:




      By the Regional office:




      By State and local authorities:




Regional Contact:             Due Nguyen
                                      344

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Unocal Chemicals, Inc.
Facility Location:
Brea, California, Region 9
Date(s) Audit Conducted:
July 25-27, 1989
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
2873 -- nitrogenous fertilizers

The facility is located in the city of
Brea, in northern Orange County,
California, along Imperial Highway, about
one mile east of Route 57.
Nitrogen-based products primarily for
agricultural use
Residential areas and two schools are
located within 1/2 mile of the facility.
Reason for Facility Selection:
      ARIP Reports:
Focus of Audit:

      Hazardous Substances(s)
      Examined:
The facility was chosen because of
reported releases of ammonia during the
month of December, 1988.

4/12/90, 6/30/88 releases of ammonia.

      \
Ammonia
                                      345

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      All ammonia at the Brea Plant is stored as anhydrous  liquid in
      three major tank systems, not including material  distributed in
      the various piping systems in the plant.  These systems,  including
      the associated cooling and condensing equipment to maintain the
      ammonia in liquid form, consist of two spherical  tanks  capable of
      holding 1,500 tons each, and one large circular tank  capable  of
      holding 20,000 tons.

      In addition to ammonia, other chemicals stored in the ammonia
      plant are sulfuric acid (93% solution, maximum amount in  tank  is
      10,000 gallons), and sodium hydroxide (50% solution,  maximum
      amount in the tank is 15,000 gallons).  Typically, the  facility
      has four, one-ton cylinders of chloride in use and two  spare
      cylinders.  These chemicals are used  -;>r water treatment  in  the
      plant steam and cooling water system.

•     Shipping/Receiving

      All transp   ; of ammonia into or out of the ammonia plant is by
      either true.-: or railcar.  Natural gas and ammonia are supplied  to
      the nitric acid and ammonium nitrate plants by pipeline.  The
      loading and unloading for shipment are done at the loading rack
      area just north of the ammonia plant.

Process Area(s)

The Haber process for ammonia production is used in this facility.   In
this process, three parts of hydrogen are reacted with one part of
nitrogen (from air) to obtain ammonia.

The ammonia formation process has seven main steps:
            Reaction of natural gas and steam and the addition of air
            (reforming) for the production of hydrogen;
            Shift reaction to minimize the production of hydrogen and
            reduce the emission of carbon monoxide;
            Removal of carbon dioxide;
            Gas compression;
            Methanation of residual carbon monoxide and dioxide;
            Ammonia synthesis from hydrogen and nitrogen;
            Separation and refrigeration to condense the ammonia for
            storage and transport.
                                346

-------
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     The site location is within a very  active  seismic  zone.

      Chemical Hazards

      •     Ammonia is flammable within certain vapor  pressure concentration
            limits, and the fire hazard will  increase  in  the presence of other
            flammable materials.  Ammonia vapors are toxic.

      •     The greatest hazard potential reviewed by  the audit team at the
            Brea Plant is the 20,000 ton storage tank  of  liquid ammonia.  This
            tank is not as large as many in this industry, but represents a
            hazard to the surrounding community if it  were to rupture.

      Process Information

      •     The plant has dual electrical feeds with automatic transfer of
            power to respond to temporary power outages, which are seldom
            experienced by the Brea Plant.  The plant  contracts to have a
            supply of emergency generators available when needed,  not
            maintaining any emergency generators or lighting on site except
            for the package boilers.  Backup nitrogen  supply for instrument
            air is maintained for instruments to fail  safe in the  event of a
            power supply failure.

      •     Ammonia plant operations are monitored from a central  control room
            containing instrumentation typical  of its  1966 vintage
            construction.  The plant has a system of interlocked alarms and
            automatic shutdown systems designed for plant safety.   A plant
            siren alarm system is in place and  is frequently tested along with
            the instrumentation alarm systems.

      •     The plant has 11 active ammonia monitors around the plant.

      Chemical Accident Prevention

      •     Unocal's corporate staff have developed an internal environmental
            audit process to ensure regulatory compliance at facilities.   This
            audit program exists corporate-wide but is not fully implemented
            at the plant level.

      •     Unocal Chemicals has prepared extensive documentation  on operating
            procedures.  These include individual,  detailed plant  startup  and
            shutdown procedures, operating procedures,  and plant technical
            operating profiles to assist the technical plant staff in day-to-
            day operation.  The facility has a very complete set of

                                      347

-------
engineering documentation consisting of detailed mechanical,
process, and instrumentation drawings, specific equipment,  and
general equipment specifications.  In addition, a  set of plant
operator training manuals were prepared to give all necessary
information, covering the many facets of plant operation.   These
employee/operator manuals integrate job definitions,
responsibilities, instructions for emergency response, and
training information for plant operations.  The result is that  the
manuals are constantly used as operator's reference manuals.

The Brea plant uses the 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 appropriate equipment and check sheets are
used for common, repetitive maintenance work.  The Brea Plant also
maintains a separate group for instrument maintenance, due  to the
specialized nature of this work.   Typically, this plant is  taken
down annually for a maintenance turnarcand when all equipment is
inspected for integrity and operability.   The plant has all relief
valves certified annually per boiler codes.   There are no similar
codes for process relief valves,  so it is left up  to the plant or
corporate guidelines on how often to inspect, rebuild, or certify
these safety devices.

Unocal offers either a two-hour or an eight-hour class on plant
procedures and safety,  depending on whether the contractor  is to
be on the site more or less than three days.

Hazards in the Brea Plant have been evaluated in three separate
studies: "Report of Engineering Risk Analysis...",  Assessment of
Air Quality Impacts for Pollutant Emissions  from the Union
Chemicals Division/Brea Facility", and "Environmental Risk
Assessment, Brea Plant".  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.

In the event of an emergency in the ammonia  plant,  the plant is
equipped with a water spray system to help knock down ammonia
vapors.  If ammonia must be vented from the  process,  there  is a
system of vent scrubbers to capture the ammonia before release  to
the atmosphere.  In the event of emergency shutdown,  the  process
system vents fail open to protect the equipment from exceeding
pressure ratings and subsequent damage,  and  a flare system  is in
place in addition to the scrubbers.

All the chemical storage tanks in the facility are  diked  and
bermed  to retain spilled liquids  and are  fully labelled (NFPA Fire

                         .348

-------
      Diamond) as to  their contents and  the  associated  chemical  and fire
      hazards.  The facility evaluated the ammonia  storage  tanks for
      earthquake stability and opted  to  derate  the  maximum  storage
      capacity of these  tanks to  500  tons for the spherical tanks and
      19,000 tons for  the large circular tank.

Accidental Release Incident Investigation

•     An action request  system for process changes  from incident audits
      is internally mandatory for OSHA incidents; it  is not required for
      near misses, non-OSHA, or property damage  incidents.   No
      investigation is internally required for an accidental release of
      chemicals.  However, according  to  Unocal,  internal  investigations
      are often conducted following a chemical release.

Facility Emergency Preparedness and Planning Activities

•     Water and monitors for fire, command post  equipment,  safety
      showers, air packs, respirators, and personnel protective
      equipment is checked weekly and monthly.   The protective equipment
      was very organized and easily available for immediate use.

•     The safety/loss prevention officer at the  Brea plant  is the fire
      and safety supervisor.  In an emergency, a Fire & Safety
      Specialist, as primary or alternate emergency coordinator, and  the
      disaster captains  (shift supervisors) also work to manage  the
      emergency.

•     Unocal has a fully equipped emergency response command post set up
      with communications and derailed instructions for the operators.

•     Unocal management conducts eight drills per year in the plant such
      that every employee participates in two drills.   Employees
      critiqued the drills and provided  recommendations to change the
      emergency response system.   Drills often identify inadequacies in
      the system that are not noticed under normal working conditions
      (such as poor radio batteries in the backup communication
      systems).

Community and Facility Emergency Response Planning Activities

•     Unocal includes the cooperation of the City of Brea Fire
      Department in their exercises and notification drills.
Recommendations:

Chemical Accident Prevention

•     All process relief valves should be removed from service and
      tested on an annual basis to verify that they are set and that
      they operate correctly.

                                349 .

-------
            Unocal should complete its internal audit protocol and  formalize
            an internal audit program at the plant  level.
Audit Team Member Composition:

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Edward Snyder
US EPA Region 9
Team Leader
Certified Hazmat Emergency Planning and
Preparedness Instructor
Sandra Carroll
US EPA Region 9
Deputy Team Leader
Emergency Preparedness

William Blank
AARP, US EPA Region 9
Engineering
Certified Civil Engineer

Russell Schilling
TAT, US EPA Region 4
Engineering
Process Safety
Follow-up Activities:

       By the facility:

       Unocal evaluated the economic viability of this facility on a long-term
       basis and determined that other locations are more appropriate for
       manufacturing  the same products.  Therefore, this facility was
       permanently shut down on July 27, 1989.

       By the Regional office:

       By State and local authorities:
 Regional  Contact:
Gordon Woodrow
                                      350

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Coronado Generating Station
Facility Location:
St. Johns, Arizona, Region 9
Date(s) Audit Conducted:
September 7-8, 1989
Description of Facility:

      SIC Code(s):


      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
4911 -- electric gas,  and sanitary
services

138 acre site 10 miles northeast of St.
Johns,  AZ,  elevation 5,800 feet, located
10 miles from the border of New Mexico.
The plant produces electricity from steam
generated by burning coal.
The city of St.  Johns,  AZ,  is  seven miles
away.
Reason for Facility Selection:
      ARIP Reports:
The facility was chosen because  of a
release of 1,600 gallons of sulfuric acid
on August 16,  1988.

Report completed January 10,  1989
Focus of Audit:
      Hazardous Substances(s)
      Examined:
Chlorine
Sulfuric Acid
                                      351

-------
Physical Area(s) Examined:
at the Facility:

Storage and Handling

•     Storage Systems

      There are three commercial grade sulfuric  acid,  one  technical
      grade sulfuric acid, and one sodium hydroxide  holding  tanks  (with
      capacities from 5,000 to 7,000 gallons)  in the water acidification
      area.  The areas beneath the tanks are termed  and  constructed  of
      concrete and there is a sump located at  the  filling  site.

      The chlorination building contains 21 one-ton  chlorine  tanks,
      although only six are on-line at one time;  the rest  are either
      empty or awaiting use.

•     Shipping/Receiving

      Four shipments of 3,500 gallons of technical purity  sulfuric acid
      is delivered by truck each month.

Process Area(s)

The commercial grade sulfuric acid is used for adjusting the pH of the
coolrng tower water in the water acidification area.  This is
accomplished automatically by adding concentrated sulfuric acid to the
canal water as it returns from the towers.  The  acid is pumped from
holding tanks through pipes to the canals where  the  acid is mixed with
an approximately equal volume of water before simply spilling into the
canal.

In the water chlorination area,  chlorine is used to  inhibit the growth
of algae in the canals and on the cooling towers which are exposed to
sunlight.  Both liquid and gaseous chlorine are used, although the
latrer is preferred because it is cleaner and less likely  to foul the
system.  A double pipe manifold extends down the row of tanks in front
of the tank valves; one side for liquid chlorine and the other for
gaseous chlorine.  Chlorine is taken from the storage containers,  mixed
with  an appropriate amount of water,  and added as a  "slug" to the
cooling tower water.  The chlorine is dispensed automatically to the
water stream from a room adjacent to the tank area.  The system was
designed using guidelines from the Chlorine Institute.
                                352

-------
Summary of Audit Findings and Recommendations:

      Conclusions:

      Chemical Hazards

      •     The company developed the CHEMSAFE computerized  chemical
            information system to store MSDS  information.

      Process Information

      •     The chlorination building is equipped with chlorine  detectors  that
            trigger warning lights at the entrance when a release occurs.


      •     All alarms (chlorine leaks, fires, and hazardous substances
            emergencies) are electrically powered; emergency backup power
            comes from a diesel engine and batteries located within the
            facility.

      •     The sodium hydroxide tank is located in close proximity to the
            sulfuric acid tanks.  A violent reaction, possibly resulting in a
            rupture of some tanks, could occur if the acid and base are
            inadvertently mixed.

      •     During the spill at the facility, hydrostatic pressure and the
            slight positive pressure of the instrument air caused a spray of
            acid across the berm.  Because the nearby sodium hydroxide tank is
            only partially shielded wi~h insulation, spray from adjacent acid
            tanks poses a significant risk.   In addition,  the piping around
            the sodium hydroxide tank is completely exposed to acid spray.

      •     There is no splash guard around the cooling water tower.   During
            the process of introducing acid into the cooling water,  high winds
            could blow acid around,  contacting personnel in the area.

      •     According to facility personnel,  the inlet valve for the acid
            tanks automatically closes when the acid reaches the fill line.

      •     Facility personnel and truck drivers are required to be  at a safe
            distance away while the acid is being unloaded into the  storage
            tanks.  The only way for anyone to know when unloading is
            completed is to listen for the sound of air venting from the
            relief valve on the truck tank.  The venting sound, (i.e., the
            release of air from the relief valve) may not be audible  to all
            truck drivers and facility personnel.
                                      353

-------
Chemical Accident Prevention
      Training is conducted annually  for maintenance and operations
      personnel involved in handling  or managing hazardous substances.
      New employees receive this training within six months.
•     The main facility grounds are surrounded by a fence; guards  staff
      the main entrance on a 24-hour schedule.  Trucks entering  the
      facility with supplies are escorted to their site destination.
      Visitors are identified, confirmed, signed in, and given
      directions.  Additional sign-in is required at the visitor's
      destination within the facility.

•     The facility has performed hazard evaluations and modelling  for
      worst-case chlorine releases.

•     Formal training - - four to five weeks for operators, and up  to
      twenty weeks for foremen -- is given to all employees on general
      and job-specific safety procedures.  An accident prevention rule
      book is given to each new employee.

•     A safety committee has been formed to meet with management and
      labor union officials to establish safety objectives and ensure
      the objectives are met.  The committee distributes a monthly
      safety report to employees.

•     A safety suggestion system has been e;-ablished.   Employee
      suggestions are reviewed by the first -ine supervisor and the
      safety committee.

•     The Safety Training Observation Program (STOP) has been
      instituted, under which supervisors report hazardous conditions
      which they observe to the superintendent of operations.

•     Management has supported training programs and has hired a new
      safety and security coordinator who spends 80 percent of his time
      on safety issues.

•     The facility manager reviews accident reports,  safety suggestions,
      and the recommendations of the safety committee.   These  reviews
      include "near misses" as well as problems experienced.

Accident Release Incident Investigation

•     The sulfuric acid spill was caused by the introduction of moisture
      laden air into the pipe connected to the acid tank.   The moisture,
      trapped in the flange cavities of the pipe fittings,  ionized the
      acid, resulting in the corrosion of the steel pipe.
                                354

-------
•     As a result of the spill and ensuing investigation:

            Steel piping was replaced and flange cavities were  filled;
            Isolation valves were relocated to improve the ability  to
            shutoff acid flow from the tank in the event of a leak;
            The drain in the acid berm was sealed -- collected  rain
            water will now be pumped out to the drainage ditch;  and
            Only dry, instrument air will be used in the acid tanks.

Facility Emergency Preparedness and Planning Activities

•     No emergency exercises have been conducted within the facility.

•     One of the revisions to the emergency plan is an expanded
      hazardous substance incident report form that incorporates all
      Title III reporting requirements.   This form will enable emergency
      managers to collect and report information to the various agencies
      involved in emergency response and recordkeeping.

•     The facility prepared an emergency plan dated September 1988,  and
      at the time of the audit was in the process of reviewing and
      revising this document.  The plan is reviewed and revised yearly
      or when a significant design,  construction, operation,  or
      maintenance change occurs.

•     Specialized training in various response functions  has  been made
      available to individuals -- e.g.,  fire suppression,  asbestos
      removal, hazardous materials -- and respirator,  SCBA,  and CPR
      training are given to those personnel required to have  it.  The
      company also gives trainir3 as required by the OSHA HCS.

•     Because the facility is somewhat isolated,  staff  is  trained to
      handle most emergency situations.   The core staff of five
      specialists and ten assistants also-address facility emergency
      planning and safety activities.  The company also has a  40-member
      fire brigade, an ambulance, and a  trained medical staff.

Community and Facility Emergency Response Planning Activities

•     According to the Apache County LEPC,  the facility has complied
      with all Title III reporting requirements and the plant  has been a
      good neighbor.  The lead environmental engineer at  the  facility is
      a member of the LEPC.

•     Because Apache County has no fire  department  to cover its
      unincorporated areas, the facility has developed  its own fire  and
      hazardous materials response capability.   The  facility has also
      agreed to support the town of  St.  Johns,  if needed,  although no
      formal document has been prepared.
                               355

-------
      Recommendations:

      Process Information

      •     To prevent the chance that acid and sodium hydroxide could
            accidentally  mix, the facility should consider relocating  the
            sodium hydroxide tank away from the acid tanks.

      •     An audible alarm system should be established to alert  truck
            drivers and facility personnel when acid tanker unloading is
            completed.

      •     An alarm should also be triggered in the event the fill line is
            passed by the acid or the inlet acid valve closes automatically.

      •     The facility should set up acid resistant (fiberglass)  shields
            between the hydroxide tank and the adjacent acid tanks  on each
            side to prevent any spray from those tanks from impinging on the
            hydroxide tank.

      •     The facility should install a splash guard around the system for
            introduction of acid Lnto the cooling water to insure that no acid
            is blown by high winds, contacting personnel in the area.

      Community and Facility Emergency Response Planning Activities

      •     The facility should establish a program and yearly schedule of
            hazardous materials exercises.  These exercises should be
            coordinated with local response agencies that might be  involved.

      •     The facility should make the CHEMSAFE database available to the
            SERC, LEPC, and local fire departments and emergency management
            agencies because sharing information will help these groups in
            planning and response activities.
Audit Team Member Composition:

Name and Title                Edward Snyder
Affiliation                   US EPA Region 9
Area of Responsibility        Team Leader
Expertise                     Environmental Protection Specialist

Name and Title                Sandra Carroll
Affiliation                   US EPA Region 9
Area of Responsibility        Deputy Team Leader
Expertise                     Environmental Planner

Name and Title                William Davis
Affiliation                   AARP, US EPA Region 9
Area of Responsibility        Lead Technical Reviewer
Expertise                     Chemistry and Toxicology

                                      3.56

-------
Name and Title                William Blank
Affiliation                   AARP, US EPA Region 9
Area of Responsibility        Supporting Technical Reviewer
Expertise                     Civil Engineering

Name and Title                Monty Stansbury
Affiliation                   Apache County Emergency Services
Area of Responsibility        Observer
Expertise                     Deputy County Administrator

Name and Title                Jess Broadbent
Affiliation                   Chair,. Apache County LEPC
Area of Responsibility   •     Observer
Expertise                     LEPC Representative

Name and Title                Daniel Roe
Affiliation                   Arizona Division of Emergency Services
Area of Responsibility        Observer
Expertise                     SERC Representative
Follow-up Activities:

      By the facility:

      By the Regional office:

      By State and local authorities:

Regional Contact:             William Blank
                                      357

-------
358

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:.
Ultramar, Incorporated
Facility Location:
Wilmington, California, Region  9
Date(s) Audit Conducted:
April 17 -20, 1990
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
2911 -- petroleum refining

The facility is located in an industrial
area of southern Los Angeles, CA, one mile
from the Cerritos Channel, an estuarial
arm of San Pedro Bay.
Gasoline and associated petroleum products
and sulfur
The closest residential areas are located
approximately one mile east and northeast
of the facility.  Two schools are within
on° mile of the refinery,  a hospital is
located two and a half miles from the
facility,  and commercial and industrial
sites are  located within one mile.
Reason for Facility Selection:
      ARIP Reports:
Focus of Audit:

      Hazardous Substances(s)
      Examined:
The facility was chosen because of a
series of releases of sulfur dioxide that
occurred in 1989,  particularly from June
30 - July 6, 1989, and a request from the
facility to examine the hydrogen fluoride
operations -- the Alkylation Unit.

3/3/89.  6/24/89, 6/30/89,  7/3/89,  7/4/89,
7/5/89,  7/20/89, and 8/30/89 releases of
sulfur dioxide
Sulfur Dioxide
Hydrogen Fluoride
                                     359

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      Ultramar stores a maximum of  200,000 pounds  of  hydrogen fluoride
      during the year in dedicated  storage tanks,  of  which  approximately
      38,000 pounds is stored in a  tank adjacent to the  alkylation unit.
      Ammonia, hydrogen peroxide, sulfuric acid, and  vanadium pentoxide
      are also stored on-site.  Wastes are contained  in  dedicated tanks
      and treated before trucking to an appropriate disposal  site.

•     Shipping/Receiving

      The facility is totally dependent upon pipeline  facilities  for  the
      receipt of incoming crude petroleum and the  bulk shipment of
      outgoing refined petroleum products.  The facility has  a marine
      terminal within the San Pedro Bay Harbor area, with pipeline
      connections to and from the refinery.

      All hydrogen fluoride is brought to the plant by truck  at a rate
      of sixteen 3,000 gallon trucks per year.  The trucks  are met  at
      the gate and are escorted to  the transfer site.

Process Area(s)

In the sulfur recovery unit, the facility currently uses the  Bevin
Stretford procedure for the recovery of sulfur from H2S.   The sulfur
recovery unit is composed of a series of furnaces  and  liquid  sulfur
holding tanks.  This procedure will be replaced shortly by  a
hydrodesulferation process using hydrogen, which Ultramar believes  to be
an improved, cleaner system, and will not require  the  use of  vanadium
pentoxide, which becomes a hazardous waste problem when spent.

H2S produced in various process  units is  absorbed in the  amine treating
unit.  When this unit becomes rich with H2S,  it is  heated with steam to
release the  H2S,  which is then  routed to  the Glaus reactor  and sulfur
tailgas recovery units.  The Glaus reactor is a multistage  process  in
which any ammonium and sulfur containing compounds present  are converted
to water vapor, nitrogen, and elemental sulfur.  Hydrogen sulfide is
oxidized to sulfur dioxide in a furnace.   Then the sulfur dioxide is
reacted wit.i remaining hydrogen sulfide to form elemental sulfur.   Any
unreacted H2S and S02  are  converted  to  elemental sulfur.

The Alkylation Unit combines light olefins with isobutane to make
alkylate, used as a gasoline blending material for the high octane
unleaded gasolines sold at gas stations.   The hydrogen fluoride
alkylation process is used to make gasoline additives.  Hydrogen
fluoride, present in liquid form and slightly soluble   in hydrocarbons.
is used as a catalyst .in the alkylation reaction.

                                360

-------
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     At the time of the audit, the  facility had  been  in  operation for
            1,234 days without a lost-time accident.

      •     The Terminal Island Freeway  (Interstate Highway  110)  cuts  through
            the facility as close as 150 yards  from the  reactors,  storage
            drum, and settlers, and is the principle vulnerable zone.  A
            marshalling yard for the1 Union Pacific Railroad  separates  the
            refinery from heavily traveled Anaheim Street  to  the  north!

      Chemical Hazards

      •     Ultramar has met all OSHA requirements for hazard communication.

      Process Information

      •     Personnel in the alkylation unit wear standard work clothes, and
            personal protective equipment  (at a minimum, rubber gloves and
            boots,  an impervious jacket, and a  full face shield),  all of which
            are left in the unit at the end of  each work shift for on-site
            washing.  The wash solutions are neutralized before disposal.

      •     Presently, there are two sulfur processing units and both ooerate
            normally.  If one fails, through-put is reduced so that the
            remaining unit can handle the volume.  Upon installation of the
            new sulfur recovery unit, the current system will serve as the
            backup sulfur recovery process.

      •     A number of hydrogen sulfide detectors are located throughout the
            facility that trigger audible alarms at concentrations in excess
            of 10 ppm.  There is continuous monitoring of sulfur dioxide,
            carbon dioxide, and NOX.   There are  also  15  on-site  wells  for
            monitoring groundwater.

      •     All instrumentation in the alkylation unit is in duplicate,
            including 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 facility employs a steam cleaning service to clean up small
            oil spills as they occur and potential points for HF leaks are
            painted with materials which change color in the presence of HF.
                                      361

-------
Chemical Accident Prevention

•     There are no procedures for following up on audit  findings  and
      recommendations by management; therefore,  internal audit  results
      may not be followed up on and implementation of recommendations
      may never occur.

•     The facility has completed a HAZOP study for hydrogen  fluoride
      operations, and HAZOPs are planned or in progress  for  other
      chemicals used in refinery operations -- ammonia,  sulfur
      dioxide/hydrogen sulfide, sulfuric acid, hydrogen  peroxide,  and
      vanadium pentoxide.

•     The site is completely enclosed by a chain link fence, and  has
      contracted a 24-hour security force.  The four entrance gates  are
      locked when not staffed by a security guard.

•     Flares are used to control hydrocarbon emissions to the atmosphere
      when operations are being suspended.  When such an upset condition
      occurs, flow of petroleum stock continues until the processing can
      be shut down in a controlled and systematic manner.

•     Annual insurance audits are conducted by outside auditors
      assessing risk and safety control.

•     Inspection personnel meet with operators daily -- the operators
      keep a log containing daily observations and operating data, which
      can alert inspectors to problem areas.   The log also alerts newly
      arriving personnel of safety precautions.   Weekly unit inspections
      are conducted by area superintendents,  unit supervisors,  and
      operators, focusing on housekeeping and fire safety equipment.
      Quarterly safety program reviews are conducted by the management
      safety committee.

•     Most training is conducted by individual departments.   Monthly
      safety meetings are held for all employees, and there is  annual
      training on the facility's response plan.   Training practices
      include classroom, hands-on, and equipment simulators,  as well as
      technology workshops,  skills enhancement seminars,  and literacy
      courses.  Cross-training is typically optional,  although  it is
      mandatory in certain departments to provide backup  coverage.

•     No set inspection schedule exists.  Except for the  turnaround that
      occurs every three years at which time  all equipment  undergoes a
      complete inspection and needed repairs,  the inspection rate is a
      function of the past history of the equipment,  any  changes in the
      specifications, and the hazards involved.   Historical  data is kept
      on a computer to identify trends and potential problems.

•     Work orders are generated by the operators,  received  by the
      maintenance section, and prioritized by the shift operations
      supervisor.  They are tracked weekly, and those  not completed are

                                362

-------
      sent co the maintenance manager for reevaluation or rescheduling.
      Work orders also control the rotation of equipment and instrument
      calibration.

•     A contractor was used to develop air models depicting the most
      likely release scenarios.

•     Ultramar has recently refitted certain burners to reduce the
      emission of nitrogen oxides.

•     The refinery is investigating the use of safer substitutes for
      hazardous chemicals, e.g., the use of sodium hypochlorite instead
      of chlorine.  This could result in increase operating expenses,
      but will reduce the inventory of hazardous chemicals.

•     Although sulfuric acid is used in place of HF in the alkylation
      process at a number of refineries, Ultramar stated that making
      this change would require 300 additional hazardous substances
      shipments and deliveries every month.

•     The refinery's deluge system, capable of delivering up to 9000
      gallons per minute of water, is tested quarterly.   The facility
      response team has a foam tanker and trailer;  foam equipment is
      inspected weekly.

•     Ultramar has secondary containment for all storage tanks, a
      dedicated sewer system,  and water diversion capability which  would
      handle excess acidic water during an incident.

•     Ultramar has completed a Risk Management Prevention Plan, as
      required by the State of California.

Accident Release Incident Investigation

•     Eleven incidents involving releases of small  quantities of
      hydrogen fluoride have occurred over the past three  years.  None
      affected the surrounding community, and only  two  resulted in
      exposure of facility employees.

•     The release from sulfur dioxide between June  30 and July  6, 1989,
      are believed to be the result of maintenance  work  performed on
      blisters in the walls of the absorber.   Sandblasting of the new
      welds may have enabled sand to plug tubing on a level  detector.

••    Refinery policy requires completing an internal incident
      investigation and report for releases  reported to  the  NRC.  Copies
      of the report are provided to corporate and facility senior
      management.
                                363

-------
•     As a result of the release of sulfur dioxide:

            The level detector loop was redesigned and refitted  to
            prevent particulates from entering the tubing during
            absorber maintenance;
            The level indicators in the sight glasses of the knock-out
            pots have been equipped with instruments that record in  the
            operator's control room;
            Procedures have been changed to increase the water rinse  in
            the primary absorber to reduce the amount of cyanide on  the
            surface of the absorber, and resultant blistering; and
            The HAZOP team is researching a plan to redesign the amine
            recovery system with a new horizontal surge tank that would
            allow for longer residence time and larger surface area for
            the off-gassing of light hydrocarbons.

Facility Emergency Preparedness and Planning Activities

•     The facility emergency response plan is scheduled to be completed
      by January 1991.  The plan will be maintained by the safety
      department, and will be reviewed annually.

•     During a release,  the refinery directly contacts all appropriate
      outside agencies using a notification list posted on the wall by
      the telephone in each security gate station.   The senior safety
      representative is responsible for updating emergency contact
      lists.  During the audit, a. security guard was asked for the phone
      number of one of the response agencies,  but was uncertain where
      the number could be located.   No formal schedule for testing the
      notification procedures has been implemented.

•     Small-scale emergency exercises are conducted monthly by the
      safety department, which performs a review and critique.   The last
      full-scale hazardous materials exercise,  which involved the
      surrounding community,  was held in June 1988.

•     Evacuation routes and collection points are posted in each
      building.

•     The facility uses the Incident Command System to operate its
      emergency res-ronse system.  The shift supervisor is  responsible
      for emergenc  response, including notification of the  security
      department,  :.ie 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.

•     The facility maintains a trained and fully-equipped  emergency
      response team consisting of 72 members,  18  per shift,  with  a
      minimum of 108 hours of training.   The emergency response  team
      annual training budget is $330,000,  and finances  in-house  training
                                364

-------
      as well as attendance at advanced fire protection training courses
      given at Texas A&M or the University of Nevada-Reno.

•     Most of Ultramar's response equipment is stored and maintained  at
      the safety storage area, although essential equipment such as fire
      extinguishers, flash suits, and SCBAs are located throughout the
      facility.  Equipment is inspected on a weekly or monthly basis.

•     When an alarm sounds, emergency response personnel switch to a
      special radio channel for information and instructions.

Community and Facility Emergency Response Planning Activities

•     In a major incident, Ultramar can call on the response resources
      of nine other refinery members of the Inter-Refinery Mutual Aid
      Assistance group.

•     The refinery has formally agreed to assist local officials in
      developing plans for evacuating the neighborhood should such a
      step ever be considered necessary or desirable.

•     The refinery is a member of the local CAER group,  and,  until
      recently, provided the industry representative on the LEPC.

Public Alert and Notification Procedures

•     The emergency response plan includes a list of community contacts,
      including a list of nearby hospitals.

•     The plant general manager handles media calls  routinely.   If there
      is a scheduled media interview, he assigns the most  knowledgeable
      employee to participate.  In an emergency,  the human resources
      manager and the plant manager interact with the  media under  the
      incident command system.  The governmental  affairs person also
      serves as media liaison during emergency response.
Recommendations:

Process Information

•     The facility should examine the redundancies and backup  systems
      within the processes involving hydrogen sulfide as  discussed in
      the exit briefing.

Chemical Accident Prevention

•     The refinery should establish a tracking system to  ensure  that
      action is taken on the findings and recommendations of internal
      audits.
                                365

-------
      •     Ultramar should stress a management program for their
            Communication Center staff, especially for the board operators.

      •     Keeping with the tone established by upper management, safety,
            particularly with HF operations, should be continually stressed
            with all employees.

      •     The facility should establish positive incentives to enhance the
            quality and safety of work for excellence in training and
            qualifying for skilled positions in plant operations.

      Facility Emergency Preparedness and Planning Activities

      •     The facility should establish a schedule of annual emergency
            exercises.  A table-top exercise for managers,  and an inter-
            refinery mutual aid exercise should also be considered.

      •     The facility should consider holding unannounced notification
            exercises with security,  all APS,  and especially Security
            Department Post #1,  responsible for notification of local
            authorities in the event of an incident.
Audit Team Member Composition:

Name and Title                Sandra Carroll
Affiliation                   US EPA Region 9
Area of Responsibility        Team Leader
Expertise                     Environmental Planning

Name and Title                Gordon Woodrow
Affiliation                   US EPA Region 9
Area of Responsibility        Deputy Team Leader
Expertise                     Environmental Scientist

Name and Title                William Davis, AARP
Affiliation                   US EPA Region 9
Area of Responsibility        Lead Technical Reviewer
Expertise                     Biochemistry/Toxicology

Name and Title                William Blank, AARP
Affiliation                   US EPA Region 9
Area of Responsibility        Supporting Technical Reviewer
Expertise                     Civil Engineering
Name and Title                Ed Kwong
Affiliation                   TAT, US EPA Region 9
Area of Responsibilitv        Supporting Technical Reviewer
Expertise                     Chemical Engineer
                                      366

-------
Name and Title                Julie Lee
Affiliation                   Los Angeles City Fire Department
Area of Responsibility        Observer
Expertise                     Industrial Hygienist
Follow-up Activities:

      By the facility:

      Ultramar gave presentations to multi-refinery organizations in the area
      about the benefits of the Chemical Safety Audit program.

      By the Regional office:

      By State and local authorities:

Regional Contact:             William Blank
                                      367

-------
368

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Magma Copper Company
Facility Location:
San Manuel, Arizona, Region 9
Date(s) Audit Conducted:
June 19-22, 1990
Description of Facility:

      SIC Code(s):


      Location:
      Products manufactured,
      produced, or distributed:

      Proximity to
      sensitive populations:
Reason for Facility Selection:
      ARIP Reports:
3331 -- primary smelting and refining of
copper

The facility is located approximately 45
miles northeast of Tucson, Arizona,  on the
southwest side of the San Pedro Valley.
The plant site occupies approximately 20
acres in a sparsely populated area.
Copper and sulfuric acid.
Magma is approximately one-half mile from
the nearest residential neighborhood.

The facility was chosen because of a
series of accidental releases of sulfuric
acid which have occurred over the past two
years.

8/16/89, 3/2/89, 3/37/89,  9/6/89,  2/21/90,
2/18/90, 8/9/89, 7/27/89,  7/9/89 releases
of sulfuric acid.
Focus of Audit:
      Hazardous Substances(s)
      Examined:
Sulfuric acid
                                      369'

-------
      Physical  Area(s)  Examined
      at  the  Facility:

      Storage and Handling

      •     Storage  Systems

           Acid products are stored in either of two groups of steel storage
           tanks.

      •     Shipping/Receiving

           Acid is  shipped from Magma in railroad tankcars or by tanker
           trucks.   There is one railroad tankcar loading station and two
           tanker truck loading stations.   Acid is loaded into railroad
           tankcars by Magma employees and into tanker trucks by truck
           drivers.

      •     Material Transfer

           The Magma company-owned railroad is utilized to transport sulfuric
           acid between the plant and the mine site.

      Process Area(s)

      The ^lant site consists of a concentrator,  a 3,000 ton per day oxygen
      flash smelting furnace, copper converters and anode furnaces,
      electrolytic refinery and rod plant,  and related maintenance facilities.

      The sulfuric acid facility receives smelter gas  in a single,  gas-
      cleaning section consisting of an open humidifying tower,  packed gas
      cooling tower,  and four parallel trains of two-mist precipitators  in
      series.  Weak acid circulated over the gas cooling tower is  cooled in
      plate-type weak acid coolers,  operating in parallel.

      Gas from the gas cleaning section splits into two main compressors which
      move the gas througn two acid plant trains to two separate stacks.   Each
      acid plant consists of a four-pass converter.   Sulfuric acid product at
      93% or  98X purity is pumped from each plant by separate product acid
      pumps,  through separate product acid coolers to  storage.
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     The facility can be accessed from either the main gate,  off
            Arizona State Highway 76,  or from the railroad spur.   However,  the
                                     370

-------
      acid plant is a restricted area with access  limited  to  staff and
      authorized visitors.

Chemical Hazards

•     Sulfuric acid produces highly toxic fumes when heated and may
      cause combustible materials to ignite on contact.  It is also
      extremely corrosive and can undergo violent  chemical change  at
      elevated temperature or pressure.

•     A significant array of other chemical and physical hazards are
      present at Magma which have the potential to cause or be impacted
      by an uncontrolled sulfuric acid release.

Process Information

•     The average daily amount of sulfuric acid on-site can be up  to
      one-million pounds, and the maximum daily amount can be as high as
      ten-million pounds.  Acid production design basis rates for
      various modes of operation range from 1,954 to 3,542 short tons
      per day.  The operational.mode depends on whether one or both acid
      plant trains are operating, and on the sulfur dioxide (S02)
      concentration in the inlet gas.   S02 concentration varies
      depending on the proportion of gas from the flash furnace
      operation and from the converter portion.

•     Acid storage tanks Al through A4 have a capacity of 710,000
      gallons each.  Tanks A5 and A6 have a gross capacity of 1,000,000
      gallons each.  Another tank,  A7,  also used for acid storage,  has
      an unknown capacity.

•     The railroad tankcar loading station and tanker truck loading
      station have adequate lighting for night operations,  although
      spill containment capability is lacking.  In the number  one  tanker
      truck loading station, truck maneuvering space is limited and
      sloping.  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 sulfuric acid as a hazardous substance.

•     There is no corrosion monitoring system to predict the useful life
      of tankage and piping.

•     Chemical leaks, other than sulfur dioxide emissions,  are largely
      detected by visual observation.   Operators inspect sulfuric acid
      storage facilities and transfer areas each day as part of  their
      routine operational procedures.   To measure the  presence and
      concentration in the soil of spilled sulfuric acid, Magma
      personnel collect composite samples of surficial  soils.   The
      samples are generally analyzed for the following:   EPA toxic
                                371

-------
      metals (Ba, Cd, Pb only), soil pH, halogenated volatile  organics,
      and total copper.

•     There were no in-place overflow-protection devices.  However,
      Magma has begun designing and installing spill and overflow
      protection devices on all chemical and petroleum tanks,  filling
      devices,  and mobile equipment.

•     A Gaussian diffusion model was employed in 1973 by Magma to
      identify key locations for the installation of sulfur dioxide
      monitors, meteorological equipment, and sulfation plate  sites
      necessary for Magma's Environmental Monitoring and Meteorological
      Network.   The Network is specific to sulfur dioxide emissions.  In
      1977, a new Environmental Control Center (EC Center) was  erected
      about 2 kilometers from the smelter, and, in 1980, Climet
      research-grade wind and temperature sensors were mounted.  In
      1984, upgraded wind equipment went into service at the EC Center.
      Magma now monitors sulfur dioxide emissions via seven permanent,
      continuous, remote air monitor.ng stations and one mobile unit.

Chemical Accident Prevention

•     Magma enacted an Acid Spills Prevention Group in April 1989.   This
      group includes active inter-disciplinary participation of plant
      management and the environmental affairs department and appears to
      have made major programmatic and engineering revisions.   There
      were no examples available.

•     The corporate Director of Environmental Affairs is responsible for
      environmental regulatory compliance and reports directly to
      corporate general counsel.  The Corporate Director of Safety is
      responsible for worker safety and health issues and reports
      directly to Magma's president and chief executive officer.

•     All work areas are inspected weekly by the safety division, and
      response to items noted on each inspection report is required
      within two weeks.  Division managers are responsible for
      inspection follow-up and reporting to the safety director.  In the
      past year, the Corporate Environmental Affairs  office has
      established a program of internal environmental audits,  auditing
      one facility per quarter.  According to environmental staff,  about
      75 per cent of the audit recommendations have been implemented and
      environmental affairs management plans to continue this  as an
      ongoing program.

•     Risk assessment audits are conducted yearly in  order to  renew the
      company's pollution liability insurance.

•     Recent union negotiations resulted in increased union involvement
      in safety issues, including establishing safety training for
      managers, monthly safety meetings, a six-point  safety checklist,
                                372

-------
and a safety training observation program  (STOP)  for  investigating
and preventing lost-time accidents.

Process/operations training of employees is not under  centralized
control; equipment operation training is done at  the  subdivision
level.  There are no formal training manuals or up-to-date written
SOPs for operations, although written tests are given  to  operators
for troubleshooting, gas flow, and system  failure questions.  The
human resources department does conduct safety training under the
MSHA and OSHA guidlines.  Courses include  lead and arsenic
hazards, hearing conservation, and hazard  identification  training.

New employees are trained and supervised in a specific department
by the department foreman.  They are shown the locations  of the
emergency showers and eye washes, and trained on  the hazards of
sulfuric acid.  Further training for the safe handling of
hazardous materials is done by the specific department.   Training
on new equipment for new procedures is done classroom-style and
hands-on by the department foreman.  A log book of all new changes
in parts or procedures is kept for the employees to review.

Training for environmental and safety issues is coordinated by a
Senior Environmental Engineer.  Training courses include waste
cleanup procedures and proper handling and storage of hazardous
materials.  The shop hazardous waste procedures manual has been
distributed to all Magma departments and is used to identify and
properly handle hazardous waste.

Equipment maintenance is on a work-order system.   Work orders are
usually written by operato-s and are then sent to maintenance.
Emergency situations, which get first priority,  are initiated by a
phone call to maintenance and the work order is written on the
spot.

Maintenance and inspection of emergency equipment is  conducted by
Magma.  However, a preventive maintenance system is lacking.   A
"breakthrough" group is addressing this by developing a preventive
maintenance plan.

Suboperators,  who assist operators, conduct instrument and gauge.
inspections, check pressure gauges, and routinely collect  product
samples.  Only the critical meters and gauges have assigned
regular inspection schedules.   Conductivity meters are checked
weekly.  The alarm systems had not been tested recently at the
time of the audit.

There remains an absence of a comprehensive risk management
program which is based on information available  from  the use  of
hazard and operability (HAZOP) studies and hazards analysis.   The
facility has not conducted modeling for evaluation of the
consequences of releases of sulfuric acid or other chemicals
present.

                          373

-------
•     SOPs for the acid plant are maintained in the superintendent's
      office along with equipment manufacturers catalogs and manuals.
      At present, the written operating procedures are not up  to  date,
      and, according to the superintendent, are only worked on when  time
      is available.   Operating shift turnover procedures, reporting
      requirements,  check lists, emergency evacuation plans, and  job
      descriptions are prepared by the acid plant staff.

•     An acid neutralization facility was installed with the original
      acid plant.  However, it has not been used because Magma has been
      able to sell all of their acid production since commencing
      operation of the acid plant.

•     Curbs, drains, and sumps in all areas of the acid plant and in the
      acid plant loading area are not paved.

Accidental Release Incident Investigation

•     Chemical spill incident reports are filed with both Environmental
      Affairs and Safety,  and senior managers discuss all accidents and
      spill reports in their regular senior management meeting.

•     Monthly spill reports with recommendations are sent to the
      president and the executive committee;  from committee they are
      sent to area managers for follow-up.  However,  an information
      feedback loop, appears not to exist because follow-up is not
      reported to, or tracked by, the executive committee.

•     About 200,000 gallons of sulfuric acid was spilled in 27 separate
      incidents at the San Manuel Plant in 1989.   Of this amount,  62,066
      gallons or 930,000 pounds in 7 incidents were due to  "operator
      error".  The response to these incidents was reported to the
      National Response Center and the State  of Arizona Emergency
      Response Commission.

•     Magma has detailed spill reporting procedures.   Management and
      staff are to inform the Environmental Affairs Department of spills
      of more than one pound of any hazardous waste.   The only exception
      from immediate reporting is for sulfuric acid;  acid spills below
      65 gallons of 100X H2SOA  (i.e., 1,000 pounds) should be reported
      only during business hours.

•     A full "post mortem" is conducted for any significant  spill  and is
      intended to determine the true causes of the spill,  the  clean  up
      costs involved, and to implement preventive procedures.   These
      meetings are summarized and distributed to the  appropriate
      departments and individuals.

Facility Emergency Preparedness and Planning  Activities

•     Magma has prepared a two-volume set of  all their prevention,
      preparedness,  emergency response, and contingency planning

                                374

-------
      material called Preparedness, Prevention Contingency  Plan.   It
      includes an emergency plan  for hazardous materials, a site
      disaster plan, acid handling procedures, emergency  equipment
      section and the spill prevention control and  countermeasure  plan.
      Magma's emergency phone numbers, and emergency coordinator
      information are located in  the beginning of the plan.
•     Fire drill exercises are conducted every Tuesday night with
      participation of the San Manuel fire department.  In the  future,
      the facility and fire department plan to test the evacuation and
      emergency response plan of the facility.  The San Manuel  fire
      department has six members with eight hours of hazmat training and
      two members with 40 hours of training.

•     A senior environmental engineer conducts training of some
      personnel for spill response and waste clean up.  The San Manuel
      fire department also trains interested Magma employees in using
      SCBAs.

Community and Facility Emergency Response Planning Activities

•     Magma has been an active member on the Pinal County Local
      Emergency Planning committee (LEPC).   The Director of the
      Environmental Department and a senior member of his staff are both
      on the LEPC.

•     At the time of the audit, the San Manuel community had not been
      involved in drills or exercises.   In the event of a major
      incident, the fire department would coordinate community response
      or evacuation.

•     Magma has sponsored a facility open house as part of their
      outreach efforts.  The facility also publishes "Update",  a monthly
      newspaper for company employees and their families.   This is  a
      potential community-right-to-know outreach vehicle,  although  a
      facility manager expressed concern about "scaring the community"
      with information -on chemicals produced and used at the  facility.

Public Alert and Notification Procedures

•     Magma and the San Manuel community have a thorough system of
      alerting and notifying the public in the event of a major release,
      explosion, or fire. . When an incident occurs at Magma,  an operator
      or foreman calls the emergency number which connects directly with
      the se.curity guard at the main gate.   A two-way radio and paging
      system backs-up the regular telephone system.   The security guard
      calls the San Manuel fire department  and (in a major incident)  the
      sheriff's office, using the command conference phone,  and reports
      the incident.  All San Manuel residents have access  to  the command
      conference system through their'residential telephones  and the
                                375

-------
      fire department can phone all residents  simultaneously  to  share
      information or order evacuations.

      Community and facility contact lists are updated  by  the  facility
      on an "as needed" basis, but there  is no periodic review and
      update.
Recommendations:

Chemical Hazards

•     Magma should provide hazardous substance fact sheets  to workers
      and to community residents through outreach efforts.  Fact  sheets
      describe specific chemical information, chemical hazards, safe
      handling, and emergency procedures in easy to understand terms.

Process Information

•     Magma should limit acid loading at truck loading station number
      one to daylight hours and require a Magma operator to be in
      attendance and to be responsible for the loading operation.

•     An experienced process piping designer should review all acid
      lines from the limits of the acid plant battery to the storage
      tanks, and from the storage tanks through the loadout racks.  This
      review should include routing, supports, materials, and
      connections to tanks and equipment.   "Field-run" piping should not
      be used for hazardous materials as discussed in the exit briefing.
•     Facility staff recommended more in-depth sampling to allow for a
      better assessment of acid permeation in soil over time to ensure
      that the entire depth of acid-permeated soils would be adequately
      removed.

Chemical Accident Prevention

•     Magma should formally incorporate risk management as a
      responsibility of the corporate Director of Environmental Affairs.
      In order to identify, understand and control process hazards, an
      on-going system of management checks and balances and an internal
      risk reduction strategy are needed.

•     Magma should complete the preparation of written procedures for
      acid plant operation, and should include qualification
      requirements for hauling contractors at acid loading stations.

•     Magma should conduct a Hazard and Operability (HAZOP) study to
      systematically identify hazards or operability problems for the
      entire fa-il:zy, including hazards which may result in or be
      affected by -.n uncontrolled acid release.   This study should

                                376

-------
            evaluate deviations from normal operation (i.e., operator error,
            equipment failure, and external events) and how they might occur
            in order to identify which hazardous events or operability
            problems might occur and what consequences they may have.
            Designing and/or conducting a HAZOP takes considerable training,
            and expert assistance is advised.

      •      Magma should use a variety of respected methods to identify off-
            site hazards.   For most likely hazards, this must assume worst
            case scenarios and consider Magma's proximity to sensitive
            populations. A specific aspect analysis may also be beneficial
            (Fault Tree or Event Tree Analysis).

      •      Magma should develop and implement a formal,  trackable, overall
            schedule for implementing additional steps to be taken to reduce
            risks.  This should include installing alarm, detection,
            monitoring, or automatic control devices,  equipment modifications,
            repairs, changes in operations,  procedures,  maintenance schedules
            or facility design, internal audits and inspections to confirm
            effective risk management and protection program implementation.

      •      Magma should implement recommendations of the spill prevention
            "breakthrough" committee.   Magma should also initiate a corrosion
            monitoring system which would enable  prediction of useful life of
            tankage and piping.

      •      Magma should develop methods (in addition to visual observation)
            for detecting the release or presence of hazardous chemicals,  when
            a release has occurred,  and the  probable area and population  that
            could be at risk.

      •      Magma should consider paving with curbs,  drains,  and  sumps  in  all
            areas in the acid plant,  and in  the acid loading stations,  subject
            to acid spills.

      Facility Emergency Preparedness and Planning Activities

      •      Magma should set up a schedule for periodic  review and update  of
            the Preparedness and Prevention  Plan.

      •      Magma is encouraged to exercise  plans for  the evacuation  of the
            facility and potentially affected area.
Audit Team Member Composition:

Name and Title                Sandra Carroll,  Team Leader
Affiliation                 '  US EPA Region 9
Area of Responsibility        Management Activities,  Public  Alert  and
                              Notification
Expertise                     Environmental Planner
                                      377

-------
Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title

Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation     *
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Gordon Woodrow, Deputy Team Leader
US EPA Region 9
Emergency Preparedness & Planning Activities
Environmental Scientist

Lauren Gillen, Emergency Management Reviewer
US EPA Region 9
Chemical Accident Prevention Activities
Chemical Emergency Preparedness Coordinator

Donald Robertson, Lead Process Engineering
Reviewer
AARP, US EPA Region 9
Process Operation & Maintenance
Professional Engineer (Mining)

William Blank, Supporting Engineering Reviewer
AARP, US EPA Region 9
Process Information
Professional Engineer (Civil)

Daniel Roe,  Observer
Arizona Division of Emergency Services (SERC)
Emergency Management Activities
Emergency Management

Jay Bateman, Observer
Final County LEPC
Emergency Planning Activities
Emergency Planning
 Follow-up Activities:

       By the facility:

       By the Regional office:

       EPA will be  sending  requests  to the facility for a report on the
       implementations of EPA audit  team recommendations.

       By State and local authorities:
 Regional  Contact:
Gordon Woodrow
                                      378

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Pioneer Chlor Alkali
Facility Location:
Henderson, Nevada, Region 9
Date(s) Audit Conducted:
July 17 - 20, 1990
Description of Facility:

      SIC Codes(s):

      Location:
      Products manufactured
      or produced:

      Proximity to
      sensitive populations:
2812 -- alkalies and chlorine

Within the Basic Management, Inc. (BMI)
industrial complex in an arid region ten
miles south of Las Vegas, NV.
Chlor-alkali
Information not available to audit team.
Reason for Facility Selection:
      ARIP Reports:
The decision to audit the facility was
based on consultation with the State of
Nevada and a January 16,  1990, release of
an estimated 68 pounds of chlorine due to
operator error.

1/16/90 chlorine release
Focus of Audit:
      Hazardous Substance(s)
      Examined:
Liquid chlorine
Hydrochloric acid
Liquid caustic
Hydrogen chloride
Sodium hydroxide
Sulfuric acid
                                      379'

-------
      Physical Area(s)  Examined
      at  the  Facility:

      Storage and Handling

      •     Storage Systems:

           Liquified chlorine is stored in eight pressurized steel vessels
           with a total storage capacity of 2,480,000 pounds.  Concentrated
           sodium hydroxide  is stored in five closed top storage tanks that
           are vented to the atmosphere.  The total volume of the tanks is
           1,342,600 gallons.

           Hydrochloric acid is stored in rubber lined tanks with a total
           capacity of 413,600 gallons.   The tanks are vented to a water
           scrubbing system.

      •     Shipping/Receiving:

           Rock salt is received from Utah by railroad in hopper cars.
           Liquid chlorine is shipped to customers by railroad car or
           directly to an adjacent BMI Complex plant via pipeline.   Liquid
           caustic is  shipped by truck and by railroad tank car.   Only
           drivers and trucking contractors approved by Pioneer are allowed
           to transport the  liquid caustic.

      •     Material Transfer:

           Rock salt is dumped into track hoppers from the rail cars,  and
           then conveyed to  three brine  saturator tanks.   The material
            transfer process  is continuous from the brine storage  tanks,  and
           all transfers are by pipeline.

      Process Area(s)

      Pioneer is an electrochemical facility which produces caustic,  chlorine,
      and muriatic acid using salt, electricity,  and natural gas.   The  three
      technological processes involved are Diamond Shamrock's modified
      asbestos diaphragm cell for making  caustic  and chlorine,  Union Carbide's
      graphite equipment train for making muriatic acid,  and Swenson's Quad
      Effect  Evaporator unit  for making fifty percent caustic product.
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     As a result of former chemical production  units  that have since
            been discontinued, the groundwater  beneath the plant was
                                     380

-------
      contaminated.  A groundwater intercept and treatment  system  has
      been in operation since 1983.

•     None of the documents reviewed revealed that Pioneer  has
      considered off-site consequences of a release or has  identified
      vulnerable zones.

Process Information

•     Although the processing areas are outdoors, including the
      electrolytic cell area, cell renewal is done within the facility.
      Hazards inherent in this operation include electrical shorts,
      hydrogen fires at rubber hose connections, and magnetic field
      effects on equipment.

•     The chlorine plant is designed for 24-hour operation.  The cell
      line capacity contains provision for cell downtime for anode
      replacement and normal maintenance.  Spare pumps and valves for
      all critical product and utilities are available.  There are also
      spare process and storage tanks on site to allow for maintenance.
      During down time, the chlorine cell line operation would be
      limited by evaporator feed tank capacity.   Despite these spare
      parts, there are no spare principal components (i.e., critical
      parts) at the facility and no spare caustic evaporators in the
      Caustic Plant.

•     A diesel generator is provided for emergency power to safely shut
      down the plant in the event of power failure of the primary
      electrical system.

•     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.

• .    At the time of the audit,  the facility did not have environmental
      monitoring systems for chlorine or HC1.   A monitoring station in
      the railroad tank car loading area is  planned.   The station will
      automatically shut off loading pumps when a release is detected.

•     Pioneer uses AIMEX Plus, a monitoring and supervisory control
      software system that includes displays;  alarms,  which sound when
      detectors exceed the set levels;  historical data retention;  and
      trending, logging, and reporting of data.   Only a few upper level
      mangers are familiar with the system and the  full extent  of its
      capabilities.

Chemical Accident Prevention

•     Partially in response to an explosion at a nearby facility,
      Pioneer has developed written corporate  policies  on worker  safety,
                               381

-------
produce safety, environmental management, and pollution  abatement
and air toxics control.

The corporate vice president in charge of environmental  and
regulatory affairs has confirmed that all proposed  capital
authorizations at the facility must be reviewed and approved by
the facility's environmental and industrial hygiene staff.

Pioneer has initiated Total Quality Management training  for
managers.

Job analyses are training procedures used to train  operators.
These include the job step (i.e., how a function or task is
performed), procedures for a job step, and key points of the
procedures.  They are reviewed by the safety and training
supervisor and revisions are recommended by area supervisors.  The
facility uses a comprehensive and up-to-date computer program to
track employee training, including course titles,  date of course,
and course credit hours.  Pioneer plans to develop  certification
training,  a standardized program of training and testing, for some
operations to improve overall quality and reduce the potential for
operator error.  Although it was not stated in the  audit report,
Pioneer did not have a system of reviewing,  developing, or
revising SOPs (job analyses).

The Safety and Training Supervisor trains new employees on general
safety rules, and the foreman evaluates the employee throughout
their first six weeks, but no written testing procedures exist to
evaluate the effectiveness of the training.   After  this initial
training,  weekly training and safety meetings are  conducted to
discuss changes in policy, accident reports,  new vendors'
products,  and safety issues.

The level of training for maintenance department employees  varies
with the skills required.

Operators write work orders,  which are submitted to the foreman
who forwards them to the planners.   In an emergency, the  planner
receives immediate approval from a manager or supervisor.
Predictive maintenance is conducted on rotational  equipment,
including weekly vibration readings,  computer-generated list  flags
which identify when testing should be done,  and oil analysis  of
some equipment.  Preventive maintenance schedules  are  computer-
generated.  The maintenance department has four instrument
specialists available to conduct inspections.

In-plant hazard operability evaluations are  conducted,  but  the
audit team was not able to review the format or content of  these
evaluations.  The facility has not yet.considered  potential off-
site consequences.
                          382

-------
•     A computerized modelling  system has been  installed  in the  chlorine
      cell control room to print  and display  area maps  with projected
      impact boundaries.  It also provides  the  operator with an
      emergency response checklist  including  notification telephone
      numbers.

Accidental Release Incident Investigation

•     The January 16, 1990, incident, involved  an electrical problem
      that shut down the hydrochloric acid  plant, which uses chlorine
      tail gas from chlorine liquefaction.  During  the  shutdown,  the
      tail gas was sent through a scrubber.   Upon restarting the  acid
      plant, the operator failed  to reset the scrubber  vent control
      point -- the operator was unaware  that  chlorine, was  still being
      scrubbed.  The scrubber solution was  then consumed,  allowing the
      chlorine to be released.

•     Under the direction of Safety and  Training Supervisor,  the  plant
      manager ensures that follow-up on  all accidents,  near  misses, and
      releases occurs.

Facility Emergency Preparedness and Planning  Activities

•     The draft facility emergency plan  describes general  emergency
      actions.  This plan offers  general emergency actions which  may be
      required both from incidents due to operations at Pioneer and
      incidents from adjacent facilities which  could impact  Pioneer.
      The plan is very generic.   Although additional emergency
      preparedness information  is available in memorandums and policy
      statements, this information is not included as part of the plan.

•     Evacuation procedures and an alarm response guide are  included in
      the plan.

•     Pioneer conducts quarterly  drills  to test emergency response
      procedures.  The shift foreman conducts and critiques the drills
      and incorporates any recommendations received from participants.

•     A wallet-sized Emergency  Telephone List has been printed for
      distribution to facilitate  quick communication among management
      and staff in case of a chemical release.

•     Pioneer's Chemtrec chlorine response team, consisting of seven
      trained emergency spill respoiders, responds to spills in NV, UT,
      AZ, WY, CO, and NM;  drills  are conducted semiannually.  Team
      members must have five years experience at the facility and
      knowledge of the product.  Members are trained in personal
      protection and safety,  specific chemical hazards,  chlorine  kit
      use, cardiopulmonary resuscitation, and tank car response.
                                383

-------
•     The audit team reviewed Pioneer's SPCC plan and found  that  it  is
      in need of revision.

Community and Facility Emergency Response Planning Activities

•     Pioneer participates in Chlorep, Chemtrec, and the manufacturing
      committee of the Clark County LEPC.  The company environmental
      control specialist chairs the local CAER group.

•     The Chemtrec Team has trained Clark County Fire Department  in
      chlorine response procedures, and the fire department  participates
      in some drills.

•     No schedule for testing of community evacuation or response
      procedures exists.

•     Although emergency communication among facilities within the BMI
      complex could be critical in an emergency, exercises have not been
      conducted with neighboring facilities.

Public Alert and Notification Procedures

•     Pioneer notifies public response agencies in the event of an
      emergency.  These agencies notify and alert the community.
Recommendations:

Facility Background Information

•     Pioneer should consider conducting a study to identify vulnerable
      areas in the nearby, off-site environment, which would ine.ude
      risks from seismic activity, to better characterize potential
      impacts from a release at the facility.

Process Information

•     Color schemes for painting piping should be coordinated with other
      facilities in the BMI complex to minimize confusion to outside
      emergency responders as discussed in the exit briefing.

Chemical Accident Prevention

•     The facility should maintain a log of standard operating
      procedures, indicating dates of latest revisions and the status of
      incomplete items.

•     Pioneer should consider using corrosion resistant materials  or
      coatings for walkways and handrails in the brine saturator tank
      area to prevent accidents as discussed in the exit briefing.
                                384

-------
      •     In light of the releases in 1989, which were attributed to
            operator error, the facility should develop a formal system to
            test new operators, including written testing procedures, and
            periodically retest' experienced operators.

      •     The facility should expand its use of the data generated by the
            AIMEX system.   Projects might include emergency response planning
            and preparedness (real-time and historical trends), identifying
            problem areas and taking corrective action, and conducting actual
            and worst case hazard assessments.

      •     Standard operating procedures should be prepared for users of the
            AIMEX system.

      •     Hazard operability evaluations should consider potential off-site
            consequences of a release.

      Facility Emergency Preparedness and Planning Activities

      •     Pioneer's oil spill control and countermeasure plan (SPCC)  was
            last revised in mid-1989 and needs revisions to meet minimum EPA
            requirements.   The facility might want review the American
            Petroleum Institute's guidance in preparing an acceptable plan.

      •     Pioneer should review and revise the Emergency Action Plan
            regularly.   The revisions should incorporate the following:
            incident reporting and notification schemes,  identification of
            vulnerable areas,  organizational roles,  warning systems,  emergency
            communication system,  personnel protection and safety,  containment
            and cleanup measures,  and -esource capabilities.   The  plan  should
            be dated and signed,  and exercised during all operating shifts.

      Community and Facility Emergency Response Planning Activities

      •     Pioneer should take the lead in establishing backup communication
            systems with neighboring facilities and  scheduling multi-facility
            training, coordination and communications exercises.

      •     Pioneer should share  information on its  response  resources with
            local fire and hazmat officials.   This information exchange policy
            could be formalized in the  Emergency Action Plan.
Audit Team Member Composition:

Name and Title    .            Sandra Carroll
Affiliation                   USEPA Region 9
Area of Responsibility        Team Leader
Expertise                     Environmental Specialist
                                      385

-------
Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and I ..tie
Affiliation
Area of Responsibility
Expertise
Gordon Woodrow
USEPA, Region 9
Deputy Team Leader
Environmental Scientist

Lauren Gillen
USEPA Region 9
State Coordinator
Emergency Preparedness

Donald Robertson, AARP
USEPA Region 9
Civil Engineering
Mining Engineer  - design and supervision of
industrial projects

William Blank, AARP
USEPA Region 9
Civil Engineering
Civil Engineer,  petro-chemical plants

Michael S. Cyphers
Clark County Fire Department
Observer
Fire Safety, Emergency Response

Bill Langley
Nevada Division of Emergency Management
Observer
Emergency Preparedness
Follow-up Activities:

      By the Facility:

      Pioneer has implemented some of the recommendations from the audit.

      By the Regional Office:

      The regional office conducted a follow-up audit August 20,  1991.

      By State and local authorities:

      State authorities attended the follow-up audit.  State and local
      authorities have been following Pioneer's implementation of EPA, Nevada
      Division of Occupational Safety and Health (NOSH),  and Air Pollution
      Control District recommendations following the May 6,  1991 chlorine
      release.
 Regional Contact:
Bill Blank
                                      386

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Dole Packaged Food Co.
Facility Location:
Honolulu, Hawaii, Region  9
Date(s) Audit Conducted:
September 11-13, 1990
Description of Facility:

      SIC Code(s):


      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
Reason for Facility Selection:




      ARIP Reports:

Focus of Audit:

      Hazardous Substances(s)
      Examined:
2033 -- canned fruits, vegetables,
presevres, jams, and jellies

30 acre facility is located in heavily
industrialized area in Honolulu
approximately 0.5 miles from Honolulu
Harbor.
Pineapple products such as pineapple
juice, essence, and bran as well as canned
pineapples.  Cans are also manufactured
on-site.
Approximately 30,000 persons live and/or
work within a 0.5 mile radius of the
facility and includes a community college,
an elementary school, and a Salvation Army
office.

The facility was chosen because of a crack
in a tubing header allowing the release  of
approximately 1,000 pounds ammonia on May
10, 1989.

May 10, 1989 release of ammonia
Ammonia
Chloride
Sulfuric Acid
Sodium Hydroxide
                                      387

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      Ammonia is stored in 150 Ib. vertical bottle type  steel  cylinders
      in a warehouse next to a compressor room in a building near  the
      center of the facility.  The bottles are secured from overturning
      by a single strand of steel chain.  Previously, aqueous  ammonia
      was stored in tanks outside of building 1925.  Tanks, pumps  and
      piping are presently on site but are not in use.

•     Shipping/Receiving

      The Ammonia is shipped by truck to the facility where the
      cylinders are unloaded and stored in the warehouse.

•     Material Transfer

      Ammonia bottles are transported from the storage area to point of
      use by forklift or dolly.   At the time of the audit, ammonia was
      used only in the compressor room.

Process Area(s)

The cannery was constructed in 1907 and by the 1920's it covered 57
acres.  In 1980, Dole began leasing and selling portions of the facility
reducing the cannery's size to approximately 30 acres.

At present, the site includes a cannery, a can manufacturing plant, six
warehouses, and office buildings.   Other ancillary operations include a
steam generation plant, and vehicle and plant equipment repair
facilities.

Ammonia is used in a vapor compression systems as a refrigerant to
maintain temperature in the cold storage room.   The system causes the
refrigerant to absorb heat at low temperatures and to give up this heat
at higher temperatures by condensation.   The system includes condenser
units located on the roof of building holding the compressor system.

Dole has a conventional mechanical refrigeration system using ammonia
for a refrigerant to maintain temperature in the cold storage room.
Some spare compressor capacity is available due to present capacity
operation of the cannery.
                                388

-------
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     The only public access to the facility  is  through  a  guarded lobby
            entrance at 801 Billingham Blvd.

      •     The facility is both an operational  facility  and a tourist
            attraction.  Tourist facilities  (including a  tasting room,  dining
            areas,  retail shops, and historical  exhibits) are  located adjacent
            to the cannery.  Tour groups of  ten  to  thirty people are led
            through the Dole plant on a designated  route  and are accompanied
            by tour guides.  The tourist groups  are separated  from  the
            processing and canning areas by  guard rails or transparent
            partitions.  Although other areas of the Dole plant  are cordoned
            off from the tour groups with movable barriers or  by signing or
            tape, an audit team member observed  unescorted tourists beyond the
            signed area.

      Chemical Hazards

      •     Chemical hazards include ammonia, chlorine, sulfuric  acid,  and
            sodium hydroxide in addition to numerous paints, degreasing
            solvents, cutting oils, and general  greases and lubricants.

      •     An operator was observed not wearing respiratory protection,
            although the mechanical utilities supervisor stated  that some
            personnel have been fit-te~ted by outside  contracts.   SOPs  state
            that "No one shall enter the contaminated  area without respiratory
            protection."

      •     All current chemical hazard data is maintained in the office of
            the environmental director.   Data is also kept in the plant
            engineer's office.

      Process Information

      •     Environmental monitoring for ammonia began approximately five
            years ago, with six operational ammonia sensors relaying signals
            to the refrigeration compressor room.  The sensor system is
            responsive to gases other than ammonia,  ambient temperature, and
            humidity.  Since the time of the audit,  Dole has reduced the
            number of .sensors to four.   Two additional sensors  were  no  longer
            needed around the ground floor storage area and the second  floor
            can labeling area when the ion exchange (IONEX)  operation was
            discontinued in 1990.

      •     Process parameter monitoring is visually accomplished by reading
            pressure gauges, temperature indicators, and oil level sight
            gauges at the equipment.

                                     389

-------
•     Ammonia leak detection is conducted with the use of a  sulfur
      candle which, when lit and in the presence of ammonia, produces  a
      white smoke.  The candle is used when there is suspicion of a
      release, usually identified initially.through odor, of ammonia.
      There is a substantial loss of ammonia  (approximately  9,000 pounds
      annually).   This may partially be the result of small  system  leaks
      not detectable by the current sulfur candle detection  method.

Chemical Accident Prevention

•     Both facility and corporate management  activities  in chemical
      accident prevention are based on written corporate policy.
      Corporate management responsible for implementing  and monitoring
      this policy include:  directors of environmental compliance and
      materials management; director of materials management; safety
      engineer; medical director; legal counsel; and director of
      internal audits.  Management initiated  the DuPont  safety training
      observation program (STOP) program in 1988 in an effort to reduce
      and prevent accidents.

•     Facility management has established "walk throughs" and weekly
      "walk arounds" in which they look at and comment on process safety
      and sanitation, utilizing a checklist.

•     Management has offered economic incentives in an effort to reduce
      accidents.

•     The maintenance department has recently introduced a computerized
      work order system along with equipment  inventory and numbering
      system.

•     SOPs for chemical hazards processes are written in the document
      entitled "safe operation of ammonia refrigeration systems," office
      correspondence and distribution to personnel,  and checklist fOPs
      such as the ammonia daily checklist.   These SOPs are reviewed and
      approved by the area supervisors.   Documents for the operations of
      the ammonia refrigeration system appear to be  applicable to Dole's
      systems and are available to the operators.

•     Department managers are responsible for safety training and
      instruction of chemical hazard data to their employees.  Training
      available includes safety, operations, and emergency procedures
      training.  Training for ammonia operations is  performed by the
      mechanical utilities superintendent or an appointed operator.
      Training includes review of SOPs and hands on training.  Testing
      of the SOPs is written and all operators review practices  every
      four months.  Personnel also receive safety training from
      interactive videotapes, such as videos describing emergency
      procedures for ammonia spills.   Further operational training  is
      conducted at Honolulu Community College.
                                390

-------
•     Dole conductors yearly audits conducted by  the vice  president  of
      quality assurance, director of operations,  quality assurance
      directors and corporate and division  staff.

•     In 1990, the IONEX unit used for extracting fructose from
      pineapple juice was decommissioned.   The  IONEX required  large
      quantities of both ammonia and sulfuric acid for  resin
      regeneration.  Concurrent to the IONEX decommissioning,  a juice
      concentrator using ammonia as its refrigerant was replaced with  a
      new system using freon.  Both modifications  greatly  reduced the
      quantities of hazardous chemicals used at the site.

•     For economic reasons, Dole has made a concerted effort to
      eliminate all chlorinated solvents.   With the exception  of the
      motor-pool parts dip tank, almost all chlorinated solvents have
      been removed from the Dole facility.

Accident Release Incident Investigation

•     Procedures and protocols in the even  of a accident release are
      described in detail in the SOPs in the event of anhydrous ammonia
      spills  (Revised July 4, 1990).

•     Dole has a house rule, tied-in with the union contract,  requiring
      workers to report all accidents and report  to the dispensary to
      ensure employee safety and, if needed, for  treatment.

Facility Emergency Preparedness and Planning Activities

•     Manuals and SOPs for emergency response guidance are located in
      the SOP for safe operation of ammonia refrigeration systems.
      Components include:

            Alarms;
            Emergency Notification;
            Action;
            Health and Fire;
            Large Spill (> 100 pounds) notification list;  and
            Personal protective equipment.

•     Incidents involving the chlorine tanks are handled by Dole's
      neighbor, Brewer Chemical, supplier of chlorine to Dole.   Gas
      masks with chlorine canisters are in  the emergency response
      cabinet.  By observation there is no SCBA gear immediately
      available for emergency response and no one  is certified  to wear
      SCBA.  Most emergency equipment is stored in a yellow emergency
      response cabinet located near the operator's desk in the  ammonia
      compressor room.  Contents in the cabinet include equipment  for
      level C response, confined space entry equipment,  barricade  tape,
      and first aid'equipment.   The cabinet is locked and  keys  are
      supplied to the operators and supervisors.  Fire  extinguishers,
      eye washers, and showers are located throughout the  facility.

                                391

-------
      Equipment in the IONEX area include air movers, ammonia detectors,
      and gas masks.

•     Dole maintains an index document which provides a selection  of
      documents relating to hazardous substances and emergency
      management.   The index document indicates whereabouts of specific
      information of a particular plan.   The index to plans document
      lists that a fire emergency plan/evacuation plan exists but  this
      document was not reviewed by the audit team.  Other safety
      documents were also available but were not in the index, such as
      hazardous substance release and emergency notification guidelines,
      in addition to other types of information including spill response
      and clean up steps, emergency communications, inspection
      checklists,  SOPs in the event of chemical specific spills and a
      corporate policy hand-out on toxic and hazardous substances.  A
      drafted spill prevention control and countermeasure plan was
      available for the audit but had not yet received management
      approval.

•     Emergency response exercise focusing on the ammonia systems are
      held quarterly and are coordinate by the ammonia mechanic.   These
      exercises do not include outside agencies.  A written report on
      the exercise goes to management for review.

•     Emergency response chain of command is described in Appendix E of
      the facilities SOPs for the safe operation of ammonia
      refrigeration systems.  The appendix lists personnel to be
      contacted, communications protocol and notification guidelines for
      a release.

•     The environmental affairs director wears a pager at all times, and
      the facility plans to install a radio in his car for back-up
      communications.

Community and Facility Emergency Planning Activities

•     Facility emergency planning/preparedness does not include  an
      outreach component with neighboring facilities,  residents  or with
      the emergency response community.

•     An understanding between Dole and Brewer Chemical for    rgency
      response assistance is in effect.   No oth^r  coordinate.  with
      industrial neighbors or state and local emergency planning
      officials are in effect.

•     At the time of the audit, no plans, protocols,  or communication
      system linking the facility with the tour guide  company that  runs
      tours at the Dole facility were in effect.

•     According to SERC and LEPC representatives,  facility management
      has provided all information required under  Title III.   They  have
                                392

-------
      also cooperated with  the LEPC and City of Honolulu Fire  Department
      on a facility walk through.

Public Alert and Notification Procedures

•     Facility procedures for emergency response notification  are
      •detailed in the spill prevention control and countermeasures  plan.

•     The environmental affairs director stated that  if a release
      resulted in exposure beyond facility boundaries, he would contact
      Oahu County Civil Defense, City of Honolulu Fire Department,
      Hawaii Department of Health and the U.S. Coast  Guard or  the
      National Response Center.

•     If needed, the facility plans to contact public agencies and
      notify the public through those agencies.

•     Notification lists in the SPCC plan and the plant phone book  are
      updated yearly.

•     Communications with the media take place at top management levels.
      Normally, the general manager, acting general manager, or
      appropriate senior manager is the facility spokesperson for media
      interactions.  During hazmat emergency response, the general
      manager, environmental affairs manager, production manager,  and
      personnel manager would be expected to handle media calls or
      interviews.
Recommendations:

•     Emergency response equipment in the yellow storage locker should
      not be in an area where it is inaccessible during an emergency.
      The storage locker should be located in an area near the ammonia
      unit- for quick access, yet be far enough away to be out of the
      direct contaminated area.

•     Operators and response personnel should be trained and certified
      for SCBA use and should have protective gas masks.
                                                      *
•     Ammonia detectors might need to be recalibrated.  Because the
      sensor is located just inside the freezer door, the concentration
      of ammonia in the air around the sensor may be diluted by the'
      opening and closing of the door.  Placement of the sensor away
      from the door and closer to the cooling coils in the back of the
      freezer might provide more accurate readings and provide better
      information on possible cooling coil leaks.

•     It might be advantages to cross check the calibration of ammonia
      sensors with calibration gas.  Useful information fro.m this
      exercise may be gained specifically for sensors located in the
      freezer where humidity would not be a problem.

                                393

-------
            Investment in a more sensitive hand held detection meter might
            facilitate detection of smaller leaks and ultimately reduce
            losses.

            The facility should consider coordinating with the Oahu LEPC and
            look for ways to open regular communication lines with neighboring
            facilities,  residents and the emergency response community.
            Topics of mutual benefit would include risk communication  -
            informing the community of potential hazards,  as well as methods
            for treating victims of ammonia (and other hazardous chemical)
            exposure; ensuring that local hospitals are properly trained and
            prepared to treat victims of ammonia exposure; mutual aid;  joint
            training; etc.

            The facility should evaluate the different methods of conducting
            hazard evaluations in order to begin identifying potentially
            injuries accidents and estimating their likely consequences to the
            health and safety of the public and the environment.   Investigate
            use of AlChE Guidelines, the EPA Technical Guidance,  or other
            recently developed resources (i.e.,  computer software or
            contractor assistance).

            A review and consolidation of the facility's emergency response
            planning documents would reduce duplicative guidance  and
            procedures and make things easier to track and keep updated.   A
            "working" emergency response plan should be kept separate  and
            available for easy reference.

            The facility should expand their community outreach program to
            include emergency notification training (based on written
            procedures)  for tour guides, joint hazmat exercises with the  City
            of Honolulu Fire Department and joint training with Honolulu
            Community College, University of Hawaii and hazmat response
            agencies.
Audit Team Member Composition:

Name and Title                Sandra Carroll
Affiliation                   US EPA Region 9
Area of Responsibility        Team Leader
Expertise                     Environmental Specialist

Name and Title                Gordon Woodrow
Affiliation                   US EPA Region 9
Area of Responsibility        Emergency Preparedness
Expertise                     Environmental Scientist

Name and Title                Lauren Gillen
Affiliation                   US EPA Region 9
Area of Responsibility        Emergency Preparedness
Expertise                     Chemical Emergency Preparedness  Coordinator

                                      394

-------
Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Donald Robertson
AARP, US EPA Region 9
Leading Technician
Mining Engineer

William Blank
AARP, US EPA Region 9
Supporting Technical Reviewer
Registered Civil Engineer

Dave Tomlinson
US EPA Region 9
Technical Assistance
Chemist

Chris Takeno
State of Hawaii Civil Defense
Representative/Observer
Emergency Preparedness

Jeff Klien
Hawaii Dept. of Health
Representative/Observer
Emergency Preparedness
Follow-up Activities:

      By the facility:

      By the Regional office:

      EPA will be sending requests to the facility for a report on the
      implementations of EPA audit team recommendations.

      By State and local authorities:

Regional Contact:             Sandra Carroll
                                      395

-------
396

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Motorola, Inc., Discrete and Materials
Technology Group
Facility Location:
Phoenix, Arizona, Region 9
Date(s) Audit Conducted:
April 9-12, 1991
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:

      Proximity to
      sensitive populations:
3674 -- semiconductors and related devices

The facility is located in the Phoenix
metropolitan area.
Semiconductors for electronic equipment.
Two elementary schools are within one mile
of the facility and approximately 7,000
residents are within a one-mile radius of
the facility.
Reason for Facility Selection:
      ARIP Reports:
The facility was chosen because of its
physical location within the densely
populated, metropolitan area of Phoenix,
Arizona, and because of the large number
and quantity of extremely hazardous
substances used and stored on site,
including hydrogen fluoride (HF).

None
Focus of Audit:
      Hazardous Substances(s)
      Examined:
Hydrofluoric acid
                                      397

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      Hydrofluoric acid and other chemicals  are  stored in the A-D
      building  in one-gallon containers or 55-gallon  drums for later
      process usage.

•     Shipping/Receiving

      The HF is delivered to the Motorola facility by trailer truck to
      the A-D building.  The HF truck  is then attached to a hose  that
      leads to  the facility's storage  system.  A quality  control  sample
      is taken  to the facility's lab before  the  truck is  allowed  to
      discharge the load of acid.  Once the  acid's quality has  been
      confirmed, both a manual valve and a computerized process control
      valve mast be opened before on-site storage tanks can begin to be
      filled.

•     Material  Transfer

      The one-gallon bottles are mechanically filled  in cabinets.   An
      operator  sets a bottle on the filling  platform  in the  cabinet.  A
      bar-code  on the bottle's label is instantly read by a  cabinet-
      mounted device.  If the bottle's label is  HF (as  verified by  the
      bar code), a valve is opened and the bottle is  filled.   The  filled
      bottles are then stored on shelving units  nearby.

      The 55-gallon drums of HF are carted to a  separate  building  for
      use.  The drums are off-loaded onto another specialized roller-
      lined floor in the lowest floor of the water processing area.  The
      drums are slid into specially designed cabinets  and attached  to
      pump-effluent hosing.

Process Area(si

HF is pumped from the drums by nitrogen pressure, passed  through a  surge
tank in the cabinet, and finally sent through a manifold  whicv  iirects
its flow to the etching basins upstairs.  The wafers which are to be
etched are set  into trays fastened to automatic dipping arms.  A
technician loads the waters into the trays,  and  then closes a protective
lid over the basin while the arm dips the tray of wafers  into the bath.
The wafers are  then automatically dipped into a rinse water basin of low
conductivity deionized (DI) water.  The spent DI water  is pumped through
a wastewater header to the acid treatment plant.  At the  treatment
plant, the water is pH-adjusted with magnesium hydroxide  before being
released to the Phoenix city sewer system.
                                398

-------
Summary of Audit Findings arid Recommendations:

      Conclusions:

      Facility Background Information

      •     The facility has two entrances, a primary  entrance  to  the  north,
            and a secondary entrance to the east.

      •     An AIRCO Corporation facility  is physically  located within the
            fenceline of the Motorola facility, and also stores hazardous
            materials.

      Chemical Hazards

      •     Motorola distributes a booklet to new employees providing  general
            information on evacuation, lifting, housekeeping, hazards  of
            compressed gases, solvents, and HF.

      •     MSDS sets are maintained in the safety, health service, security,
            and environmental offices.  Although Motorola trains each  new
            employee on the availability,  location and how to get help  in
            understanding the content of MSDSs, workers  have had to take the
            initiative to seek out and request specific  MSDS information from
            the safety office.  A new mainframe system is currently being
            tested which will allow MSDSs  to be available in nearly all areas
            of the plant.

      •     The Motorola health services department maintains a MEDS (the
            acronym for the health ser-'ices program) health tracking system as
            part of its pilot program at this Motorola facility site.   This
            system is a computerized data  system of work/environmental effects
            on employees.  Accident/injury reports and industrial hygiene data
            are entered for statistical review.  General health surveillance
            and health risk assessment are performed on  sample groups  of
            employees.

      Process Information

      •     The transfer piping lines within the storage facility are  of PVDF
            chemical-resistant construction.   All hoses and pipes which
            contain HF are contained within clear PVC pipe.   The nitrogen feed
            line has both a check valve and a feedback diaphragm in line.

      •     Each HF pumping cabinet contains two separate 55-gallon drums
            whose contents are driven to the surge tank by a nitrogen  purge.
            A nitrogen sensor is thus used to indicate a low level in  a drum,
            which begins the use of the adjacent HF drum in the  pumping
            cabinet.  In the case of total system failure, one-gallon
            containers of acid could still be used.to fill the HF etching
            basins.
                                      399

-------
•     The storage tank has a nitrogen purge and a 1/2 psig pressure-
      relief valve.

•     Two back-up computers stay on-line and operate seconds behind  the
      main computer in case of power failure, a backup generator  is  on-
      site which can supply power to the computer-driven system.  When
      the system operates on backup power, the HF mixing processes are
      discontinued,  and the system is shut-down.

•     The acid arrives as 49Z acid by weight and is processed to  5%  and
      11X concentrations.

•     Pressurized nitrogen cylinders are available to pressure open
      fail-closed valves on the magnesium hydroxide storage tank  in  case
      of power failure.

•     Vapor releases fr^m eight areas around the processing area  are
      detected through the use of a "Telos" infrared monitoring system.
      Vapors are sucked through tubes from the sample locations into the
      Telos manifold of ports.  The Telos monitors a multitude of gases,
      including hydrofluoric acid.  A warning alarm is activated  at one
      half the threshold limit value (TLV) of a specific gas,  and an
      evacuation is sounded if vapors are measured at the TLV.

Chemical Accident Prevention

•     HF wastewater is isolated and pumped to the acid treatment plant.
      The "fab's" sewer system is isolated from any chemical process
      usage system.

•     Motorola uses TARGET, a model of groundwater flow and solute
      transport model, to predict plumes.  Motorola has undertaken air
      dispersion modeling efforts as well.  The study predicted the
      source concentrations of acids and solvents that were being
      reingested at the intake locations at the plant and compared them
      with acceptable human exposure thresholds and odor detection
      thresholds.  After conducting a detailed investigation of the
      types of emissions identified in Phase I of the exhaust  gas
      dispersion study, Phase II of the study identified the  locations
      for a new scrubber and intakes.   No additional monitoring has been
      conducted to determine whether the actions taken have reduced the
      previously recorded contaminant levels to acceptable  sta-dards.

•     Storage and process systems have manual block valves  in-line,  as
      well as block and bleed configurations for in-line servicing of
      control valves.  In case of instrument air loss,  all  control
      valves fail to positions which would assure safe  containment of
      process chemicals.

•     The pumping room has a containment basin,  and the  floors  are
      graded so that any spilled materials would flow toward  this  basin.
      Secondary containment tubing empties to containment basins  so chat

                                400

-------
      piping leaks can be visually detected.  Any spilled acid  or waste
      water is pumped or vacuum-trucked to the acid treatment plant.
      Any acid spills in the etching/wafer processing area are  contained
      and cleaned with absorbent rolls.  Doorjambs and process  equipment
      are raised more than a foot above the floor for safety and
      containment purposes.  The truck unloading area is completely
      contained and graded such that any spilled materials will collect
      in a catch basin centered under the pad.  A storm drain inlet port
      is situated within 20 feet of the acid truck loading pad.  This
      inlet is not monitored and does not have block valves or
      containment.  The 55-gallon drum-filling area is also inside a
      containment basin, and it is surrounded with layered sheets of
      plastic dropped from an overhead fixture.

•     All employees corporate-wide 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,  and department.

•     An operators manual on plant processes and daily maintenance does
      exist in draft form.  The manual is in the office of the plant's
      operations manager and is not distributed to the shift workers.

•     Management safety activities include a safety performance program,
      departmental safety audits and meetings,  safety awareness/audit
      committees, and job safety analyses (JSA).   Every 2-3  years,  a
      team of experts from other Motorola facilities and the legal
      department conduct a health,  fire,  and safety audit to determine
      where future resources and actions  are needed,  as well as  to
      evaluate a given facility's performance in these  areas.   The
      facility's environmental affairs department conducted  its  first
      environmental self-audit in 1990, based on self audit  protocol
      received from corporate headquarters.

•     There are no incentives to supervisors and managers to seek  out
      and suggest new and revised ways of preventing hazardous  material
      releases.

•     No hazard analysis has taken place  to identify the  potential
      consequences to Motorola of an explosion or chemical release  at
      AIRCO or of the Motorola facility on AIRCO.

Accidental Release Incident Investigation

•     According to the Disaster and Emergency (D&E)  plan's section  on
      incident information documentation,  a form is  to  be used  for
      collecting information about incidents,  but this  form  has  not  been
      used to date.  However, other forms not part of the plan are

                               401

-------
      systematically used to document hazardous material  incidents.
      These are kept in a binder maintained by the  facility  fire  chief
      and any follow-up material received or generated  is  then  attached
      to the original report.

•     Motorola's Disaster and Emergency Contingency Plan's response
      policy on after-incident evaluation requires  a detailed evaluation
      of all incidents, "no matter how small," to be performed  and
      reported to management with recommendations for improvement, if
      any.   It has not yet been used.  At present,  follow-up to releases
      appears to be limited to the fire brigade and the specific  sector
      that is responsible for the failure of the particular
      equipment/process/operator error.

•     Motorola's reporting plan has apparently not been activated, as no
      "operating log" was available to document incidents.  Incidents
      are,  however, logged by security and the fire brigade.  The D&E
      plan also contains a hazardous chemical spill follow-up
      report/analysis form but it is unclear as to when, to whom,  and
      how this form is to be utilized and how it relates to the response
      policy.

Facility Emergency Preparedness and Planning Activities

•     Motorola's primary document of emergency policy and procedures is
      their "Disaster and Emergency Plan".   Section II requires plan
      implementation whenever a fire or explosion involves hazardous
      materials, but states that spills,  leaks or other releases "may
      leave room for judgment on the part of the emergency coordinator."
      AIRCO is not included as part of the plan but an unsigned, undated
      document from AIRCO describing the training,  equipment, and
      responsibilities of their Hazardous Incident Response Team (HIRT)
      was included.  This document states that the HIRT is available to
      respond only to leaking AIRCO cylinders.   The name and number of
      the AIRCO plant manager is listed.

•     The most recent call list or emergency contact list was revised in
      February 1991, but other outdated lists appeared attached to
      various documents such as a stand-alone "Facilities Emergency
      Contact List," which was dated November 1990.   No listings for
      AIRCO or other nearby facilities were in the plan or contact list.

•     The manager of environmental compliance is  to be contacted cor
      technical assistance to the fire brigade in handling spill
      neutralizing action and removal procedures.   Environmental
      guidelines to be used for this technical assistance were  not
      available.  The facility emergency response coordinator is the
      senior safety manager to whom the chief of the brigade  reports.

•     Response actions detailed under section 3 of the plan provides
      action checklists which guide the emergency coordinator through
      the correct sequence of response actions to the contingency  plan.

                                402

-------
      This section does include notification to the NRG and  the  SERC  and
      notes the need for follow-up reports.

•     Motorola has a flow chart for hazmat response protocol for  the
      fire brigade for spills of less than 50 gallons and for those
      greater than 50 gallons.  These are independent of the D&E  plan.

•     A D&E conference room serves as the center for emergency
      operations.  It contains a Motorola Intrac 2000 radio
      communications system on an FCC repeater frequency (internal to
      Motorola only), the facility's primary security frequency.  It
      also has a "public" address system (in-house) and emergency
      lighting.

•     Identification and location of hazardous materials discussed in
      section IV of the D&E plan has narration and maps with clear coded
      symbols of outside compressed gases,  hazardous material and waste
      storage, the cyanide treatment area,  waste solvent/nickel plate
      waste collection, acid waste treatment area,  the dock area and
      bulk flammable liquid storage tanks and the safety equipment
      pertinent to each area.  Fire, evacuation,  and rescue corridors
     • are well documented in the D&E plan with designations,  symbols,
      and reference maps.  Emergency equipment provisions are also well
      documented in the D&E plan.   Policy and practice of distribution,
      outreach, and exercises are not included or apparent in the D&E
      plan but are separately distributed via the engineering and
      supervisory safety manual.

•     The fire brigade regularly schedules  drills and exercises  as part
      of its training program.  rome exercises are  creative and
      impromptu on-the-job training.

•     All members of the fire brigade carry pagers  when on site;  the.
      fire chief, two members of the safety department and the
      environmental compliance manager carry 24-hour pagers.  The
      remainder of the safety and environmental departments carry pagers
      when on site.

Community and Facility Emergency Response Planning  Activities

•     Upon request of the Phoenix Fire Department,  Motorola has  assisted
      them in purchasing CAMEO software and equipping the  fire trucks
      with Macintosh computers.   Neither CAMEO nor  any other  hazard
      analysis method for off-site consequences is  used by  Motorola  or
      Phoenix Fire for pre-planning and for identifying vulnerable zone
      areas in worst-case or other scenarios based  on the  types  and
      quantities of Motorola's chemical inventory.

•     Motorola has conducted joint training and exercises with local
      first responders.
                                403

-------
Public Alert and Notification Procedures

•     The facility's fire brigade uses  the  incident-command  system  in
      response to major hazardous materials  releases.   If  off-site
      impacts are occurring or likely to  occur,  the  incident commander
      contacts Phoenix fire and police  departments and  local emergency
      medical services.  Motorola expects that  fire  and police  agencies
      will alert, notify, and interact  with  the  community.   Any public
      or media interaction with the  facility would go through  the sector
      headquarters public relations  department;  this nine-member
      department serves five facilities
Recommendations:

Chemical Accident Prevention

•     SOPs should be distributed to all technicians in the HF usage and
      process areas.

•     The continued efforts to engineer fail-safe mechanisms and
      parameters into their storm drain system, as in all components of
      their process facility, would aid Motorola in preventive
      environmental disaster planning.

•     Motorola should explore additional ways to impress upon new and
      current employees that informing themselves about chemical hazards
      with which they work is not .only a matter of personal protection
      and safety, but is essential in preventing any incidents which
      could endanger the community and the environment.  Motorola should
      also provide incentives to supervisors and managers to seek out
      and suggest new and revised ways of preventing hazardous material
      releases.

•     Motorola is encouraged to create an environmental office which
      reports directly and independently to the general manager to
      complement the current management matrix of health and safety,
      community relations, and public affairs.

•     Annual environmental goals and objectives should be established i..
      much the same way as outlined in the corporate protocol for the
      health, fire, and safety audit.  This could then be expanded to
      monitor and evaluate Motorola's progress in reaching the stated
      environmental goals.  It would be advantageous for Motoro^ and
      the community to undertake activities, research,  and studies to
      better understand the consequences of potential hazardous .r.acerial
      releases on the public health and the environment - beyond the
      fence line.  Motorola should also consider going beyond mere
      requirements in certain areas; for example,  expanding the log for
      entering environmental control capital and expense costs to
      include specific entries for:
                                404

-------
                  - Participating in state-and local emergency planning
                  activities
                  - Community outreach for education and risk communication
                  - Identification,  analysis, and evaluation of off-site
                  consequences in the event of a major chemical incident
                  - Training and awareness education of managers and staff on
                  environmental issues

      Community and Facility Emergency Response Planning Activities

      •     A more active interest and level of participation by Motorola with
            the activities of the LEPC and Phoenix Fire Department in the area
            of hazards analysis is encouraged.  CAMEO and the Technical
            Guidance for Hazards Analysis are a couple of the models available
            to begin understanding the facility's potential off-site risk in a
            worst case or more realistic scenario under differing conditions.

      •     Motorola should be advised to meet with the Phoenix Fire
            Department and work together with them to run CAMEO prior to an
            emergency situation based on types and quantities of all hazardous
            materials on site.

      •     It seems critical that Motorola achieve' a better understanding of
            the hazards posed to and from AIRCO,  Inc.,  and develop an
            agreement to coordinate  response procedures and mutual aid.
Audit Team Member Composition:

Name and Title                Sandra Carroll,
Affiliation                   US EPA Region 9
Area of Responsibility        Team Leader
Expertise                     Environmental Specialist

Name and Title                Lauren Gillen
Affiliation                   US EPA Region 9
Area of Responsibility        Deputy Team Leader
Expertise                    . Environmental Specialist

Name and Title                William Blank
Affiliation                   AARP, US EPA Region 9
Area of Responsibility        Process Safety
Expertise                     Civil Engineer

Name and Title                Frank Wehr
Affiliation                   TAT, US EPA Region 9
Area of Responsibility        Process Safety
Expertise                     Chemical Engineer
                                     405

-------
Name and Title                Dan Roe
Affiliation                   Arizona Division of Emergency Services
Area of Responsibility        Observer
Expertise                     Emergency Preparedness

Name and Title                John Stewart
Affiliation                   Maricopa County LEPC
Area of Responsibility        Observer
Expertise                     N/A

Name and Title                Bob Moody
Affiliation                   City of Phoenix Fire Department
Area of Responsibility        Observer
Expertise                     N/A
Follow-up Activities:

      By the facility:

      By the Regional office:

      EPA will be sending requests to the facility for a report on the
      implementations of EPA audit team recommendations.

      By State and local authorities:


Regional Contact:             Gordon Woodrow
                                      406

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
ITT Rayonier, Pulp and Paper Division
Facility Location:
Port Angeles, Washington, Region 10
Date(s) Audit Conducted:


Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
August 15 - 18, 1989, September 28  - 28,
1989, and October 2-6, 1989
262 -- paper and pulp mill

Along the south coast of the Strait of
Juan de Fuca (the US/Canada border), 60
miles west of Seattle and 30 miles south
of Victoria, British Columbia.
Pulp products, primarily acetate,
specialty paper, fluff, and viscose.
The Olympic Memorial Hospital is located
directly southwest of the facility atop a
bluff.  Nine schools, a library, a senior
center, and various churches and temples
are within three miles to the south.
Reason for Facility Selection:
      ARIP Reports:
The facility was chosen because of its
history of releases of extremely hazardous
substances (EHSs),  especially seven
releases of sulfur dioxide and two
releases of chlorine in the past year.

2/23/89, 3/17/89,  7/5/89,  7/29/89,  8/4/89,
10/5/89, 10/10/89,  and 12/21/89 releases
of sulfur dioxide;  5/26/89 and 8/25/89
releases of chlorine;  and 10/26/89 release
of ammonia.
                                      407

-------
Focus of Audit:
      Hazardous Substances(s)
      Examined:                     Ammonia
                                    Chlorine
                                    Chlorine  Dioxide
                                    Fuel  Oil
                                    Hydrogen  Peroxide
                                    Sodium Hydroxide
                                   ' Sulfur Dioxide
                                    Sulfuric  Acid
      Physical Area(s) Examined
      at the Facility:

      Storage and Handling

      •     Storage Systems

            Rail chemical cars and permanent  storage  tanks  scattered  about  the
            site are used as storage containers  for ammonia,  sulfur dioxide,
            fuel oil, vehicle fuel, and chlorine.  Of particular  interest are
            ammonia and sulfur dioxide storage in  the rail  cars on lengths  of
            rail from tb-•• abandoned Seattle and  Northcoast  Railroad,  and a
            720-ton car   f chlorine located  adjacent to  the  shoreline.

            Sodium hydroxide is stored in a small  above ..round tank farm, which
            consists of three large tanks with a combined capacity of 240,000
            gallons which hold SOX sodium hydroxide and two smaller tanks
            which hold dilute sodium hydroxide.  Sodium chlorate  is stored  in
            two 16,000-gallon tanks near Ennis Creek.  Sulfuric acid  is stored
            in an adjacent 12,000-gallon tank.

            Chlorine dioxide is stored in two large fiberglass tanks  with a
            combined capacity of 100,000 gallons,  and hydrogen peroxide is
            stored in a 10,000-gallon aluminum tank.   Both areas  are
            adequately maintained and have secondary  containment.

            Fuel oil is stored in two large aboveground tanks within  30 feet
            of the shoreline, one with a capacity  of  nearly 1.6 million
            gallons and another with a capacity  of almost 300,000 gallons.

      •     Shipping/Receiving

            Both sodium hydroxide and liquid  chlorine  arrive  by barge  in two
            monthly 600-ton shipments.  Anhydrous  ammonia is  delivered on a
            daily basis in 28-ton truckloads.  Liquid sulfur  dioxide  is
            supplied by truck on an as-needed basis.   Hydrogen peroxide,
            sulfuric acid, sodium chlorate solution,  and nitric acid  are also
            delivered by truck.  Fuel oil is  delivered by tanker  ship, at a
                                      408

-------
            rate of three 35,000-barrel shipments per year, or by truck.

      Process Area(s)

      Pulp Production.   The mill uses an ammonia-based acid sulfite process
      for the production of dissolving grade pulps.  The process consists of
      the following major stages:   acid plant, digesters, blowpits, red stock
      washers,  pulp screens, bleach plant,  fourdiner machine, pulp dryer, and
      finishing.

      Pollution Control.   Wastewater pollution control consists of capturing
      and burning the spent sulfite liquor from the cooking process for the
      recovery of S02 and heat,  and an extensive  sewer collection system has
      been installed to divert effluent streams to primary and secondary
      treatment systems.   Solid debris is settled in the primary clarifier,
      then pumped to a  new sludge  screw press installation where it is mixed
      with waste biomass from the  secondary treatment system.   The dewatered
      mixture is then burned in the waste wood boiler to recover the fuel
      value.   The clarified effluent from the secondary treatment is
      discharged through a submerged outfall in the Strait of Juan de Fuca.

      Before  gases are  exhausted to the atmosphere from the recovery boiler,
      they are first passed through a cooling and absorbing filter system to
      recover sulfur dioxide as ammonium bisulfite.   Fine parti'culate material
      is removed by glass fiber filters before emission to the atmosphere.
      Hot blowdown gases from the  digesters are relieved to high, and low
      pressure accumulators.  The  overgases and steam associated with blowing
      to the  blow pits  are ducted  to a water condenser.   The condenser stream
      is steam-stripped to recover dissolved sulfur dioxide,  which is used in
      the acid plant for cooking acid makeup.   The stripped condensate is
      recycled to the water condenser.  The blow  gases are then passed through
      an absorption tower to recover sulfur dioxide for reuse  in the  acid
      plant.   Non-condensable blowpit overgases are finally scrubbed  in a
      limerock tower scrubber before emission to  the atmosphere.   Gases from
      washer  hoods and filtrate tanks in the Red  Stock Washer  system  are
      ducted to the limerock tower scrubber for removal of sulfur dioxide
      before  being emitted to the  atmosphere.
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     The plant is located in an area of  high seismic  activity  and  is
            susceptible to storms along the Strait  of  Juan de  Fuca.

      •     EPA dispersion calculations indicate  that  if  the contents  of  the
            720-ton chlorine tank was released,  the chlorine concentration  in
            Seattle, WA, or Victoria, BC,  could reach  Immediately  Dangerous  to
            Life and Health (IDLH) levels.

                                     409

-------
•     The primary ammonia storage area  is at  the base of  a bluff,  only
      1/8 mile from the Olympic Memorial Hospital atop  the bluff.

•     The proximity of the sodium chlorate and sulfuric acid  tanks  to
      Ennis Creek, the lack of secondary containment, and the potential
      for fire or explosion if the contents mix, are potential hazards.

Process Information

•     There are potholes in the roads and walks, standing pools of
      liquids, poor signage, leaky pipes and valves, holes in the dock,
      unopenable fire station doors, residue  from releases and spills,
      slippery and worn surfaces on stairs, liquids dripping on ladders,
      unlabeled barrels and transfer pipes, and piping resting on wooden
      beams with bases submerged in standing  liquids.  In addition, many
      storage vessels are blistering, leaking, or corroding.

•     Employees were observed without hard hats and eye protection when
      and where necessary.

•     The facility obtains off-site air monitoring data from a device
      operated by the state of Washington; the facility indicated that
      the state intends to discontinue offering this information to ITT.
      The facility naintains no monitors on-site.

•     The major =• _rces of sulfur dioxide emissions are leaking blowpit
      lids during digester blow events and the auxiliary power boilers
      not equipped with S02 scrubbers.

•     The audit team identified the differences in design and use of the
      blowgas S02 stripper system as a potential  cause  of  releases.

•     The caustic area tanks are corroded and exhibit signs of
      overfilling, and the associated pumps and piping are corroded and
      leaking.  In addition, caution tape has been haphazardly applied
      to the perimeter, there are standing pools of sodium hydroxide,
      and there is no secondary containment.

•     The storage of over one million pounds of pressurized chlorine in
      a single shore-side tank with minimal security or physical
      protection creates the potential for a catastrophic  release.
      Although the tank is emptied and inspected every two years,  the
      potential for a release is exacerbated by facility maintenance,
      security, and safety practices, and its location.

•     The chlorine tank overpressure alarm has not been operational for
      many years, and few personnel even were aware of its existence.

•     Aspects of the design and maintenance of the chlorine, system are
      not in accordance with Chlorine -Institute standards, including
      reliance on excess flow valves as emergency shutoff  devices  and

                                410

-------
lack of external corrosion protection  for piping  and  valves.
The capacity of the chlorine tank  is substantially  greater  than
that of its associated emergency scrubber,  indicating that  a
rupture disk failure could overload the scrubber  and  result in a
catastrophic release.

The structural support for chlorine transfer piping is  susceptible
to failure under a variety of conditions, including seismic
activity,  on-site vehicular traffic, and corrosion.

During chlorine transfer from the barge, chlorine is  vented to the
split tank in the caustic area.  Chlorine releases  are  common
during these activities and have been  caused by piping  corrosion;
inadequate sodium hydroxide in the split tank; lack of  scrubber
efficiency due to saturation of the sodium hydroxide  in the' split
tank; and excessive venting of the chlorine pump  tank.

The primary ammonia storage area is composed of two 30-ton  and one
90-ton railcar; liquid sulfur dioxide  is stored in  two  1,000-
gallon railcars.  The use of abandoned railcars as  permanent high
pressure storage vessels is not recommended by the  U.S. Department
of Transportation (DOT) or the American Institute of  Chemical
Engineers (AIChE).

Both the ammonia and sulfur dioxide railcar storage areas are
susceptible to storms, leakage due to corrosion and general
deterioration, and vandalism.   There are no alarm systems.

Although the mill is in the process of replacing ammonia railcar
storage with permanent tanks,  no progress was observed during  the
audit.  In addition, the storage area under construction is
adjacent to the gasoline storage area,  which presents  additional
potential for an accidental release.

Nitric acid is stored in a 1,000-gallon tank with no secondary
containment, although a stout concrete wall protects the tank  from
the adjacent main mill thoroughfare.

Some hazardous materials storage facilities were not placarded
according to National Fire Protection Association (NFPA)
standards.  In addition, in many cases the associated  piping was
incorrectly labeled as to contents or direction of flow.

The oil storage tanks' trough and culvert secondary containment
system is not large enough to contain a catastrophic oil spill.
The remote surface impoundment that provides the majority of the
required secondary containment capacity was filled with water.

The large fuel oil tank is being considered for replacement due  to
its age and deteriorating condition.

With a few exceptions, automated process control has not been

                          411

-------
      applied Co the chemical processes examined.   Even  in  cases  where
      process control was applied, proper manual  operation  is  required
      to ensure safe operation due to the limited scope  of  the
      automation; these automated controls emphasize process efficiency
      and are not specifically oriented toward process safety.

•     Many storage facilities did not have high-level alarms or high-
      level pump shutoff relays.

Chemical Accident Prevention

•     The ITT paper and pulp division quality manual makes  little
      mention of employees, safety, and training,  and no reference to
      the community or the environment.

•     Observations and conversations with employees indicate a
      m nagement style heavily weighted toward production concerns.  One
      e .iployee said that "preventive maintenance was almost non-existent
      due to a lack of funding and experienced maintenance personnel."

•     Critical instrumentation is inspected once  or twice a week,  but
      other instrumentation receives less attention.  Instrument
      maintenance supervisory personnel acknowledge that alarms are not
      a high priority and that the mill lacks a comprehensive
      maintenance, inspection, and calibration program.

•     Security ic provided by one supervisor and  four watchpersons;
      coverage ij usually provided by one watchperson per shift
      stationed at the south entrance gate.   The watchperson's duties do
      not allow time for a physical check of the facility.

•     While there is some fencing in the area of the pump station atop
      the bluff, the main production areas are not secure to the east,
      west, and north.  Many of the storage tanks and rail cars do not
      have any security measures to prevent tampering or vandalism;  the
      valves are readily accessible,  unlocked, and may be operated by
      any passer-by.

•     The plant safety committee, consisting of five management and five
      union members, meets weekly to discuss releases and near-misses,
      general safety issues, and specific concerns and problems areas.

•     The safety supervisor/training manager is a respected member .of
      the management team with a high level of credibility among the
      work force, but he has no professional training credentials.

•     A weekly newsletter notifies employees of personnel changes  within
      the plant, serves as a formal media channel, and contains a
      regular feature by the safety supervisor.

•     The audit team noted that the operating manuals used by  process
      operators were extensively and informally updated.   Although most

                                412

-------
      of the information contained in the operating manuals was  not
      dated, the dated information ranged from 1953 to 1986.  No
      information was provided on when the manuals were updated, who  was
      responsible for the update, or whether manuals were reviewed by
      management.

•     Non-process/administrative employees receive little or no  training
      in emergency response.  Their ability to respond to, and be of
      assistance in, an emergency is minimal or restricted to
      evacuation.

•     Employee training is directed only toward the first days of new or
      transfer employees, rather than the existing workforce.  Employees
      reported varying levels of training and testing, such as one to
      three weeks of on-the-job training, verbal or written tests of
      differing degrees,  and very little classroom training.

•     Management encourages employees to attend scheduled training
      films, but does not mandate attendance or test knowledge.   This
      had led to an uneven level of training across the workforce,
      dependent on the priorities of the individual supervisors.

•     Management training gives priority to areas that informal  feedback
      indicates need attention, which has led to an imbalance in the
      subjects targeted for training.  No evidence of management
      involvement in emergency response training was offered and there
      was no indication that exercises involving management personnel
      had been scheduled or would be scheduled in the future.

•     The mill recently installed a computerized maintenance  tracking
      and documentation system; this data will be used to develop a
      preventive maintenance and routine inspection schedule.   The  data
      contained in the equipment description and extent of maintenance
      fields, however, are insufficient to develop such a schedule,  and
      the pace of this process will prevent the timely implementation of
      the maintenance and inspection program.

•     ITT corporate management conducted an internal audit of operations
      at the mill prior to the EPA chemical safety audit.   EPA access  to
      these records was denied by the facility,  and the matter has been
      referred to the EPA Office of Regional Counsel.

Accidental Release Incident Investigation

•     There is no indication that ITT Rayonier has any written
      procedures for the investigation of accidents,  incidents,
      accidental releases, or near, misses.

•     While accidental releases are investigated by the environmental
      superintendent or the shift supervisor,  near misses  are  not
      investigated regularly.   The extent of the investigation usually
      depends on the investigator and the seriousness  of  the  incident.

-------
•     Reports on releases are reviewed and evaluated by  management  and
      may be passed on to corporate headquarters depending  on  the nature
      of the incident.  Corporate feedback does not include  release
      prevention or training recommendations.

•     Information on incidents and near misses in other  parts  of  the
      facility or on other work shifts is passed by workers  informally,
      rather than through a formal communication process.

•     The number of releases over the reportable quantity has  grown from
      three during 1988 to nine in the first nine months of  1989.

Facility Emergency Preparedness and Planning Activities

•     The ITT Rayonier emergency procedures manual was published in July
      1981; it was last reviewed and revised during August 1989.

•     Eiployees contacted by the audit team were either unaware of the
      existence of the emergency procedures manual or where  a copy could
      be located.  Manual distribution and availability  to on-site
      personnel, as well as training of personnel in emergency
      procedures are clearly lacking.

•     The manual designates the mill's ranking supervisor as the
      responsible supervisor and the person in charge in all but a
      firefighting capacity when off-site responders are required.

•     The manual provides adequate written directions but is unfamiliar
      to the general workforce and outside agencies due to a failure to
      conduct emergency procedures training.

•     The emergency procedures manual does not address strategies or
      tactics to be used in providing off-site assistance should a major
      release or spill occur.

•     On-site plans are available to track a toxic plume.  Maps and
      plans of the community are available through the emergency
      management office, but no maps or information relating to
      underground water conduits in the vicinity are available.

•     ITT maintains an emergency response team for on-site emergencies,
      but the facility plan provides for little interaction with other
      than fire department first response personnel (cross - training).

•     Off-site first responder notification is the responsibility of the
      mill watchperson and the 911 operator,  but no exercises or tests
      of the linkage have been conducted or are planned.

•     A listing of the chain-of-command is contained in the  emergency
      procedures manual, which also sets forth lines of authority for
      various incidents each shift.
                                414

-------
•     The Regional EPA telephone number provided  in  the manual  is  a
      general business number, not the 24-hour emergency response  line.

•     Plant communication systems include radio pagers  (for management
      personnel) and two-way radios  (for process  line workers and
      maintenance personnel).  In some cases, the only communication
      between employees on process lines was a system of hand signals.

•     Plant emergencies are indicated by a series of complicated whistle
      signals to alert the entire complex or by telephone to alert a
      specific person or group.  Approximately 50 percent of the workers
      whom the audit team asked could not consistently and accurately
      interpret the alarm signals.

•     There is a full-time safety equipment maintenance person
      responsible for ensuring that  equipment is safe, sanitary, and
      workable.  Equipment utilized  at an incident scene is replenished
      or refurbished on an ASAP schedule; all other safety equipment is
      serviced based upon manufacturer's recommendations.   Records for
      the safety equipment were available and well-maintained.

•     The plant clinic is open 45 hours a week Monday through Friday,
      and is staffed by a full-time  nurse.

•     Simulation exercises of emergency procedures are conducted on a
      monthly basis.  Fire drills are conducted on a weekly basis.

•     Problems identified during training exercises are discussed in a
      team critique, and if deemed serious enough are referred to the
      safety committee.  Due to the  lack of management participation in
      these exercises, the flow of information on safety concerns is
      primarily lateral, denying both local and corporate  management
      access to critical feedback.

•     Training critiques provided to the audit team indicated that  some
      fire equipment, SCBA gear,  and protective clothing are not in good
      working order and should be updated or replacing.

•     The facility stores oil spill containment equipment,  including
      absorbent booms and a motor boat,  on the pier.   However,  access  to
      this equipment is restricted by the configuration of the  guard
      rails on the pier near the oil transfer station.

Community and Facility Emergency Response Planning Activities

•     There have been a lack of field exercises involving  other  than
      fire situations where outside participation was invited.

•     The environmental superintendent is the designated facility
      emergency coordinator and a member of the LEPC,  although  it
      appears that the LEPC has not been active in scheduling events
      involving the chemical users in the community.

                               415

-------
•     ITT corporate headquarters, concerned  about  civil  liability
      issues, has instructed the facility not  to participate  in the
      Chemical Manufacturers Association's CAER program.

Public Alert and Notification Procedures

•     Extensive guidelines on how the media  will be  kept  informed during
      emergency incidents are contained in the procedures  manual.

•     There is no off-site warning capability beyond calling  911  in  the
      event of a .Tiajor release.

•     Prior to the audit, both the LEPC and  SERC expressed concern with
      the tardiness in release notification  by the facility.
Recommendations:

Facility Background Information

•     ITT should evaluate its hazardous materials storage supports and
      foundations for compliance with the uniform building code for
      seismic design.  This evaluation and necessary corrective actions
      should be carried out immediately for the chlorine tank.

Process Information

•     The facility should install and monitor an on-site ambient air
      monitoring system independent of the device operated by the
      Washington Department of Ecology.

•     The mill should install S02 scrubbers on all of the mill boilers
      and comprehensively evaluate the blowgas sulfur dioxide stripper
      system for design compatibility with its current application.  The
      system should be modified to ensure that sulfur dioxide recovery
      is effec-Lve throughout the range of possible loadings and that
      emissior.j are within regulatory standards.

•     The facility should upgrade all storage tanks, mountings, and
      containments to meet industry standards and appropriate
      regulations.  Instrumentation, alarms, and other safety-oriented
      devices should be installed on all storage facilities.

•     The facility should seriously consider a single storage area for
      bulk pressurized gases in accordance with NFPA and industry
      standards.

•     Secondary containment should be installed in the caustic area and
      around the individual tanks associated with the chlorine dioxide
      generator,  the ammonia storage tank, and the nitric acid tank.
                                416

-------
•     The facility should consider replacing the chlorine  tank  with
      multiple units to reduce the potential for a catastrophic release.

•     Pipelines connecting the chlorine tank to the mill and  the
      chlorine lines on the pier should be rerouted to minimize the
      potential for vehicular traffic damage.

•     The facility should transfer materials presently stored in
      railcars to permanent storage vessels meeting applicable  codes  and
      standards within 90 days.

•     The design of the fuel oil storage area should be reviewed for
      compliance with applicable EPA regulations and NFPA guidelines.
      This may include installation of high-level alarms and  high-level
      pump shutoff relays,  and secondary containment capable  of .
      containing the contents of the largest tank without adversely
      impacting other tanks or the environment.

•     The facility should install safety-oriented automated process
      controls, which provide at least one level of control redundancy,
      on mill chemical processes.

•     The facility should review the instrumentation associated with
      mill chemical processes for adequacy in terms of safety, and
      install additional instrumentation and alarms as required to
      conform with AIChE and Chlorine Institute  standards.   These
      modifications should ensure that readouts  from isolated or remote
      processes or storage facilities are forwarded to appropriate
      process control centers.

•     The maintenance department should retune  the automated process
      control system and restrict access to control adjustments.

Chemical Accident Prevention

•     Plant supervisors should take measures to  ensure operator
      compliance with standard operating procedures and annually update
      process operating manuals.

•     ITT should immediately implement a. comprehensive instrument
      inspection and repair program,  and expeditiously develop and
      implement a formal,  comprehensive routine  inspection,  calibration,
      and preventive maintenance program for mill  instrumentation.

•     The facility should undertake an immediate security audit  of  the
      mill and address areas that are vulnerable to accidents,
      vandalism, or natural disasters.   Appropriate fencing,  alarms,
      valve locks, guard barriers,  more security personnel,  and  other
      physical security measures should be put  in  place  for  hazardous
      materials storage facilities and associated  piping and throughout
      the entire facility.
                               417

-------
•     The mill should initiate an immediate cleanup and repair program
      in conjunction with a tightening of facility safety rules.

•     ITT Rayonier should enable its training manager to participate  in
      basic and advanced teaching skills programs.

•     ITT should draft and implement a policy to conduct hazard
      evaluations on an annual basis, with the first to be scheduled
      within 90 days.  The facility should follow up each evaluation
      with a schedule for mitigating problem areas.

•     The facility should undertake a professional analysis of the
      entire training program, priorities, personnel, and equipment, and
      develop a reasonable time frame for addressing concerns.  The
      facility should design and implement a process to test and
      evaluate information and instruction being afforded new hires or
      transfers as part of the on-the-job training.

•     ITT should schedule formal, documented training programs for all
      process employees addressing routine operations,  contingency
      operations, general process design, and safety.  The program
      -hould include training methods such as written testing and at
      ^east two weeks of on-the-job training prior to process operation.
      The date and contents of all training should be recorded in the
      individual's personnel folder.

•     Using the local school district,  ITT should provide management and
      supervisory personnel with the training tools and techniques
      necessary to participate as qualified instructors in the on-the-
      job training program.  In addition, management training programs
      in emergency response, first aid,  CPR,  and state  and federal
      reporting requirements should be conducted.

Accidental Release Incident Investigation

•     The facility should draft an SOP with guidelines  for conducting
      investigations of incidents, releases,  and near mi-^es  to elicit
      maximum information for future accident prevention training.

•     ITT should establish formal communication channels to  relay
      incident, release, and near miss information to the  workforce.

Facility Emergency Preparedness and Planning Activities

•     The facility should conduct a plume study for incorporation into
      the LEPC emergency response plan,  addressing seasonal wind
      direction changes through a series of modeling tests on a
      quarterly basis during 1990.
                               418

-------
•     The facility should schedule administrative management  personnel
      to participate in emergency response exercises  as  observers  and
      evaluators,  attend after-action critiques, and  put  feedback  into
      the management pipeline.

•     The mill should initiate a training program that provides  all  new
      hires with a plant and safety orientation and a copy of the
      emergency response plan..  The facility should schedule  classes in
      emergency response for all employees.

•     ITT should procure site maps locating underground  aquifers,  water
      channels, manmade conduits, and areas adjacent  to  the facility
      that could be impacted by a release or spill. .

•     The facility should initiate a program of cross-training involving
      all local emergency responders and other interested agencies.

•     The facility should conduct an evaluation of communication
      capability on- and off-site, and address needs, (equipment
      purchase and installation) within a reasonable  time frame.

•     The emergency procedures manual should include  the EPA Region X
      24-hour emergency response telephone number.

•     The plant should provide mandatory training in  the use and
      application of the various emergency breathing  devices for all ITT
      employees and non-ITT employees who are regular visitors to the
      facility.

•     The radio communication system currently used by some isolated
      operators should be expanded to include all process control
      centers to improve emergency communication.   The mill should
      implement a formal operator training program emphasizing the
      potential significance of the system and providing instructions
      for proper radio operation.

•     The facility should design and implement a simplified alarm scheme
      easily distinguished from other communications systems  to
      eliminate employee identification and interpretation problems.

•     The mill should undertake an immediate inventory and inspection of
      all emergency response and safety equipment on-site, and repair or
      replace equipment as necessary.

•.    The facility should design and schedule at least one major
      training exercise (of a magnitude to involve all facets  of
      community response) within the next six months.

Community and Facility Emergency Response Planning Activities

•     The facility should utilize the LEPC as a catalyst  f<3r  a broad-
      based public relations effort in the neighboring communities.

                                419

-------
      •     The facility should schedule an annual exercise involving  police,
            fire, schools,  hospitals, media, and other involved segments  of
            the neighboring communities.

      •     ITT should participate in the emergency planning process directed
            toward the areas and communities which could be impacted.

      Public Alert and Notification Procedures

      •     The facility should commence a cooperative effort with the LEPC  to
            address the need for a community-wide warning system and an
            education program outlining community response procedures  should
            the system be activated.
Audit Team Member Composition:

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Gordon Goff
US EPA Region 10
Team Leader
Title III Coordinator/Toxicologist/Health

Pat Lowery, AARP
US EPA Region 10
Training and Safety
Emergency Management and Business Administration

Danforth Bodien
US EPA Region 10
Monitoring
Air Quality

Rick Horner
US EPA Headquarters
Process Safety Systems
Chemical Engineer

Tom Ashley
TAT, US EPA Region 10
Process Safety Systems
Chemical Engineer

Noah Myers
TAT, US EPA Region 10
Process Safety Systems
Chemical Engineer

Marc Crooks
WA Department of the Environment and Ecology
Process Safety Systems
Chemical Engineer
                                      420

-------
Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
                              Don Nelson
                              WA Department of the Environment and Ecology
                              Process Safety Systems
                              Chemical Engineer

                              Edward Bonollo
                              Port Angeles Fire Department
                              LEPC Representative
                              Hazmat Coordinator
Follow-up Activities:

      By the facility:

      The emergency release notification process has been conducted in a much
      more timely fashion by the facility since the visit of the audit team.

      By the Regional office:

      Initially, the technical scope of the audit was to be limited to
      evaluations of the liquor generation and pulp digestion processes,  and a
      brief inspection of the sulfur dioxide storage and transfer vessels.
      However, due to the number of deficiencies encountered during the
      initial site four-day visit, the audit scope was expanded to include
      evaluations of the mill boilers, bleach plant, chlorine dioxide
      generator, and chlorine and ammonia storage and transfer facilities by a
      subsequent two week visit.

      By State and local authorities:

      An audit/inspection of the site was conducted by the Washington
      Department of Labor and Industry at the request of EPA following the
      chemical safety audit, and resulted in the issuance of two citation and
      notice documents.
Regional Contact:
                            •  Pat Lowery
                                      421

-------
422

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
British Petroleum Company
Facility Location:
Ferndale, Washington, Region  10
Date(s) Audit Conducted:
March 19 - 23, 1990
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
2911 -- petroleum refining

850 acre site in a rural area fronting on
the Georgia Strait -- twelve miles
northwest of Bellingham, WA, five miles
west of Ferndale, WA, and less than 20
miles south of the Canadian border.
Gasoline, liquified petroleum gas, jet
fuel diesel, heating oil, fuel oil, and
sulfur.
The facility is adjacent to the Lummi
tribal reservation with a population of
3,200.  There are six schools with a
population of 3,700 students in the
vicinity; one hospital with two campuses
within 10-12 miles; two nursing homes,  two
group homes for the handicapped, one
health clinic,  and one day care center.
Reason for Facility Selection:
      ARIP Reports:
The facility was chosen because of its
history of frequent releases of hazardous
substances.  Nine releases occurred during
1989 according to NRC records;  three
involved oil products,  five involved
sulfur dioxide, and one involved chlorine.

None
                                      423

-------
Focus of Audit:
      Hazardous Substances(s)
      Examined:                     There  are  65  hazardous  chemicals on-sice
                                    requiring  reporting under SARA Title III
                                    section  312.   The  chemicals  of most
                                    concern  are sulfur dioxide,  chlorine,  and
                                    hydrogen fluoride.

      Physical Area(s) Examined
      at the Facility:

      Storage and Handling

      •     Storage Systems

            Tank farms are located in the  northeast sector  of the  facility  and
            individual tanks are placed throughout the  facility.

      •     Shipping/Receiving

            Product delivery to the site is  60X pipeline, 35% barge,  and 5%
            truck.  Tanker ships approach  by way  of the  Strait of  Georgia and
            load or offload at a pier on the western edge of  the facility.
            Crude oil is unloaded from tankers at  the  dock  at the  shoreline  of
            the facility and pumped to storage tanks.

      Process Area(s)

      In the crude unit, crude oil is desalted and routed through  a  flash
      vaporization column to separate a portion of the gaseous hydrocarbons
      from the liquid crude stream.  Both  streams  are  routed  to an atmospheric
      distillation column which separates  the components of the crude  into six
      streams according to their respective  boiling points.   The six  streams
      are:  a gaseous stream, straight run gasoline, naphtha,  kerosene,
      straight run diesel, and topped crude.  The kerosene and diesel  streams
      are subjected to a variety of treatment steps, primarily treating  and
      blending, before being stored as final product.

      The gaseous stream is compressed into  a liquid and routed to the gas
      plant which consists of a series of  columns designed to  separate the
      stream into gasoline, fuel gas, propane, isobutane, and normal butane.
      The normal propane and butane are sold and  the isobutane is  routed to
      the alkylation unit.  Hydrogen sulfide from fuel gas treating, and
      hydrogen sulfide and ammonia from sour water treating are routed to the
      sulfur recovery unit.

      Hydrogen fluoride (HF) is used as the  catalyst in the alkylation unit.
      The alkylation process maximizes the octane content of  refinery products
      through the selective reaction of olefins from cracker unit  (isobutylene
      and propylene), isobutane from gas plant, recycling stream from  the #1
                                      424

-------
 deproponizer,  and hydrofluoric acid at sufficient pressure to form
 higher molecular weight isoparaffins.   The desired product, termed
 alkylate,  is a high octane branched paraffin (isoparaffin) such as
 isoheptane or isooctane.   The HF used in the alkylation unit is recycled
 in the continuous process with make-up HF addition from an HF feed-tank
 adjacent to the HF accumulator/settler.

 The  hydrosulfurization (HDF) unit remove sulfur compounds from the
 kerosene stream by hydrotreating and removes sulfur in the light gas oil
 from the thermal catalytic converter.   The light gas oil is
 hydrotreated,  and the gaseous stream is  separated and routed through an
 amine tower to absorb the hydrogen sulfide which is converted to sulfur
 in the sulfur plant.

 The  naphtha stream is sent from the crude unit to an HDF unit to remove
 unwanted sulfur and ammonia to prevent damage to the reformer catalyst.
 The  clean naphtha passes  through the reformer unit where it is converted
 from a. low octane product to liquified petroleum gas and high octane
 gasoline components.   This is accomplished by combining the naphtha with
 hydrogen,  heating the mixture and passing it through a series of
 reactors,  each of which contains a platinum catalyst.   The reformer
 generates an excess amount of hydrogen which is recycled to the  start of
 the  reformer process  and  utilized in the HDF unit.   The effluent stream
 from the reactors is  stabilized in a tower before storage'.

 The  topped crude from the atmospheric  column in the crude unit is  heated
 up and flashed in the tar separator.   The vapor product is  sent  to the
 thermal catalytic cracker (TCC),  and the bottom product is  sent  to a
 vacuum distillation column,  where the  subsequent bottom product  is heavy
 fuel oil.   The top product from the vacuum distillation column is  mixed
 with the top product  from the tar separator and is  routed to  the top of
.the  TCC where it is mixed with hot aluminum silicate catalyst  and
 reacted in a moving bed reactor.   The  goal of thermal  cracking is  to
 split large, low value hydrocarbon molecules into smaller,  more  valuable
 molecules.  The cracked product is distilled into gaseous hydrocarbons,
 LPG,  diesel, and heavy fuel oil streams.

 The  sulfur recovery unit  (SRU) converts  hydrogen sulfide  into  elemental
 sulfur, and ammonia into  nitrogen gas  and water.   This  process reduces
 harmful emissions to  the  atmosphere and  recovers marketable elemental
 sulfur.
                                425'

-------
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     The refinery is in an area defined at  an  earthquake  vulnerability
            ranking of 3.5 out of a possible 5.  In a two week period,  there
            was a series of tremors registering between  3.5 and  5.4  on  the
            Richter scale, with an epicenter 21 miles east of the  refinery.

      •     Physical barriers were lacking at some critical points,  i.e.,
            major road intersections, areas where vehicles were  operating in
            reverse, loading docks, and platforms.

      Chemical Hazards

      •     The facility has identified hydrofluoric  acid and sulfur dioxide
            releases as the major chemicals of concern.

      •     Areas of catastrophic vulnerability for this site would be  a majo
            spill from an oil tanker along the wharf,  an earthquake of
            sufficient magnitude to destroy or disrupt the process and/or
            storage area (particularly hydrogen fluoride from the alkylation
            unit),  or an uncontrolled LPG release.

      •     BP maintains a medical record tracking system.  A pre-employment
            physical examination is required, and all  employees must submit t
            a reexamination every two or three years  depending on their age.

      Process Information

      •     There is considerable buildup of litter (e.g., flammable litter,
            paper,  rags) in areas acting as windstops.

      •     The tanks have a numerical code, but no indication of their exact
            contents or its flammability.

      •     Piping systems within 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.

      •     There is haphazard storage of unused new  and old piping,  valves,
            hoses, and other impediments to movement which could pose a threai
            to responders during an emergency under reduced vision conditions

      •     Sulfur powder was observed on approximately 200 square feet of
            pavement in the SRU, mostly in the vicinity of the sulfur
            condensers and the sulfur loading facility.  Sulfur is an easily
            ignitable and combustible solid.


                                      426

-------
Chemical Accident Prevention

•     Facility security is provided by security  guards  (who  receive  a
      five-hour training course), fencing, and lighting.   Corporate
      personnel conduct a security review annually.

•-     Valves on the seven individual crude storage  tanks  in  the
      northeast corner of the facility were not  provided  with  padlocks,
      although the area is fenced and the fence  is  locked.

•     Critical valves within the refinery (e.g., pressure relief bypass
      valves) are locked with plastic chains.

•     An on-going problem analysis program is currently studying the
      power supply system, whose recent failure  has resulted in several
      releases.

•     Facility safety audits are conducted on a  twice yearly basis by an
      independent consultant and recent audits have addressed
      fire/safety, maintenance engineering, and  operations engineering.

•     The audit team observed that no system was in place  to prevent
      persons other than instrument personnel from readjusting or
      disengaging alarms.  The alarm panels could be easily opened with
      the turn of a handle to access the system's circuit boards.

•     BP does not verify whether outside contractors who routinely load
      and offload their vehicles and drive on-site without BP assistance
      or direction receive required health and safety training.

•     The facility has established the Armadillo Club, a group whose
      members have gone one-year without taking  injury sick leave
      through the use of proper personal protective equipment.

•     The joint labor-management health and safety committee meets
      monthly to consider, inspect,  investigate',  and review health and
      safety conditions and practices in the refinery.

•     The Plant Safety Rules, developed by the health and safety
      committee, and the Safe Practices and Procedures Manual are
      reviewed twice each year and updated as necessary.

•     The 200-page operating manual for the SRU  is an excellent learning
      tool and reference guide,  but it does not provide easy-to-find,
      concise instructions on managing process upsets.
                                                            *
•     The facility has two full-time staff dedicated to training,
      including courses developed by the State of Washington and
      refinery equipment vendors.

•     There is a twelve day, ninety-six hour basic operator training
      program which includes fire and safety training, presented in a

                                427

-------
classroom mode and involving sufficient  testing  of  skills.   The
facility has a dedicated training building with  classrooms  stocked
with all relevant equipment for hands-on training.

Matrices track employee training and a computer  program provides
detailed information on attendance at corporate  training courses.

Corporate policy allows for reimbursement of  training expenses up
to 90X for job-oriented courses and 100%  for  job-mandated courses.

The facility does not have a formal inspection program for  the
waste water treatment equipment or the storage tanks for
petroleum, hydrogen fluoride, and other  hazardous materials.

Weekly, informal hazard evaluation are performed as part of  the
fire/hazop drill in a "What If?" style.

The last formal Hazard Evaluation at the  facility was on the
alkylation unit in 1987, as a result of which, numerous safety
modifications were made, including the addition  of relief valves,
monitoring instruments, and release mitigation systems.

The facility has not conducted any modeling for  accidental
releases or spills of hazardous substances.

Most employees are cross-trained in 3 or 4 different units,  and
supervisors can usually operate and maintain all units within a
process.

The audit team's evaluation of the instrument preventive
maintenance system indicates that the current system is rendered
less effective by its complexity,  the low priority placed on the
program by previous management,  and a possible shortage of
instrument technicians.

Operators are able to tamper with instruments without detection.

Instrument systems are only inspected during refinery shutdowns
which occur every three years.

Only a few components within the emergency system are tested.

The instrument reliability engineer has limited accountability of
the condition of the instruments due to a poor preventive
maintenance system and the constraints of other responsibilities.

The audit team noted that eight of the alarm lights  at  the  SRU
control room panel remained lit continuously;  a similar situation
was found at the outside SRU alarm panel.  With the  exception of
the compressor shutdown system,  most of these alarms are not
critical to refinery safety.
                          428

-------
•     The following release prevention equipment and procedures  are
      utilized in the handling of HF:

            Level indicators were added to acid settler  (upper and lower
            portion) and deproponizer accumulator to control the amount
            of hydrogen fluoride;

            Water content of the HF recycle is monitored by analyzing a
            daily sample using a vacuum cup;

            HF storage tank was upgraded by adding the magnetic  floating
            level since this is a closed system; and

            HF leaks are detected visually by a visible vapor wisp or by
            discoloration of the orange paint on flanges.

•     After the chlorine release, the amount of chlorine on-site was
      reduced to what was needed for the site drinking water system.
      Other processes that in the past used chlorine were switched to
      alternative resources -- 1,1,1-trichloroethane as a chlorine
      source for reformer catalyst regeneration and sodium hypochlorite
      to control biological growth in the cooling water.

•     The refinery undertook significant capital expenditure to design
      and construct an enclosed, smokeless ground-level flare which
      eliminates the traditional flare.

•     All tanks farms were diked to  prevent runoff of leaked liquids.
      The dikes were equipped with splash guards to prevent liquids from
      flowing over the dike during a catastrophic tank failure.

•     The tank farms were constructed with intermediate dikes to  lessen
      the possibility of liquid from one failed tank damaging a second.

•     There are four tower-mounted water cannons with foam-spraying
      capability, with additional permanent mounted and mobile  mounted
      cannons and five-gallon foam containers throughout the site.

Accidental Release Incident Investigation

•     The sulfur dioxide releases occurred as a result of shutdowns of
      the sulfur recovery unit -- several of which were the  result  of
      electrical failures -- which elevated stack gas concentrations
      above permitted levels

•     The chlorine release resulted  from a ruptured pipe which  was
      connected to a one-ton chlorine container.

•     The system of release investigation includes an evaluation  and
      review of current training and work practices  to identify the
      cause(s) and .factor(s) involved in the release.
                               429

-------
•     SOPs require an investigatory report in  the event of  accidental
      releases or near misses.  A team of department heads  or  their
      designees conduct the investigation of actual releases and  present
      their findings to upper management as well as the health  and
      safety committee and the two facility trainers.

•     A monthly report is prepared for BP Headquarters on release
      occurring at the facility.  A separate report is prepared
      immediately for all significant or unique releases.

Facility Emergency Preparedness and Planning Activities

•     The refinery has an emergency plan that  addresses most foreseeable
      contingencies.  The last review of this  plan took place under the
      previous management between 1983 and 1988.

•     Emergency response personnel drill weekly, in cooperation with the
      management personnel directly responsible for that section of the
      emergency plan or process being tested.

•     General fire drills and evacuation drills are held annually.
      There is one assembly point for BP employees and one point for
      contractor employees in the evacuation drills.

•     BP maintains a full-time Fire Chief.   Response equipment includes
      three pumpers, an aerial boom truck,  a bulk foam trailer with
      spray devices, 60 SCBA units, and sufficient fire suppression
      clothing and communication gear to outfit both the first responder
      shift brigade and the call-out support fire brigade.

•     Members of the fire brigade are chosen from among BP employees who
      submit a written application and appear before a selection panel.

•     Response training is provided by the  Western States Petroleum
      Association Fire School in Reno, Nevada,  on-site supervisors,
      consultants, and members of other refinery fire  brigades.

•     In addition to training regular employees for oil spill response,
      the refinery has a more highly trained employee  oil spill team
      which can be reached 24 hours a day by pagers.

•     On-site communication is provided by  telephone,  two-way radio,  and
      pager.  Emergency communication drills are held  twice  annually.

Community and Facility Emergency Response Planning Activities

•     BP maintains a mutual assistance agreement with  other  industrial
      companies in the vicinity and in the  area.

•     BP conducts regularly scheduled tours for visitors  to  the
      facility.
                                430

-------
•     BP has conducted exercises with the  local  EMS  group,  but  has  not
      scheduled or conducted any exercises with  the  neighboring Ferndale
      Fire District or-the Lummi Tribal Reservation.

•     There is currently no contractual agreement between  the refinery
      and the Ferndale Fire District, the  closest first  responder for
      fire emergencies.   BP relies on its  on-site response  force and
      mutual assistance agreements with nearby industrial  facilities.

•     While the City of Ferndale and Whatcom County  have emergency
      response plans in place, the Lummi Tribal  Reservation directly
      south of the refinery has no plan at this  time.

•     The NRC, Washington SERC, and EPA Region X emergency  notification
      telephone numbers were not listed in the BP safe practices and
      procedures manual or the emergency response plan.

Public Alert and Notification Procedures

•     There is no public notification capacity at the refinery  in the
      event of an emergency.   The facility is seeking consulting
      assistance in developing a public notification system for all
      industrial complexes in the vicinity.
Recommendations:

Process Information

•     The facility should insure all the valves, pipes, and pumps are
      labeled for easier operation during periods of reduced visibility
      or emergency situations.

•     The facility should initiate a check and balance system to insure
      process operators do not change,  retard, or bypass calibrated-
      control equipment.

•     The facility should install a rail guard or fluorescent tape to
      protect piping near the vehicle loading and unloading area.

Chemical Accident Prevention

•     The facility should undertake 'an immediate hazard evaluation of
      the entire site with mitigating procedures to start in a timely
      manner.  Of particular concern should be an evaluation of a major
      spill .from a tanker along the wharf, and a major earthquake.

•     The facility should install case-hardened padlocks on all vessel
      discharge valves in the facility.

•     The facility should require all' vendors/contractors to supply
      documentation attesting to the health and training of their

                                431

-------
            employees assigned to the refinery,.

      •      The facility should complete implementation of the British
            Petroleum emergency shutdown and interlock maintenance program and
            the recording system.

      •      BP should implement an instrument inspection program and evaluate
            the personnel requirements for the reliability program and
            reorganize personnel as necessary.

      •      BP should review the alarm system and testing procedures.

      •      The facility should develop and publish a schedule for the
            inspection and maintenance of the waste water treatment equipment
            and storage tanks.

      •      The facility should perform a comparative review of the mechanical
            maintenance system to determine if deficiencies similar to those
            identified for the instrument maintenance program exist.

      •      The facility should initiate a modeling exercise involving air
            releases and a ground spill.

      Facility Emergency Preparedness and Planning Activities

      •      The facility should undertake an immediate review of the  emergency
            response plan, updating those sections which have not been
            recently reviewed or revised.

      Community and Facility Emergency Response Planning Activities

      •      The facility should participate with the local emergency
            management team in at least one major training exercise in the
            next six months.

      Public Alert and Notification Procedures

      •      The facility should install a public notification system  and
            initiate an appropriate training.program :o insure effective
            warning to neighboring communities.
Audit Team Member Composition:

Name and Title                Walter Jaspers
Affiliation                   US EPA Region 10
Area of Responsibility        Team Leader
Expertise                     Title II  Coordinator
                                     432

-------
Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Patrick Lowery
US EPA Region" 10
Safety/Training/Emergency Response
Emergency Management and Business Administration

Rick Horner
US EPA Headquarters
Process Safety Systems
Chemical Engineer

Due Nguyen
US EPA Region 8
Process Safety Systems
Chemical Engineer

Noah Meyers
TAT, US EPA Region 10
Process Safety Systems
Chemical Engineer

Bruce Jensen
TAT, US EPA Region 10
Process Safety Systems
Environmental Engineer

Jessie Clark, Operations Coordinator
Whatcom County Dept.  of Emergency Services
LEPC Representative
Emergency Management
Follow-up Activities:

      By the facility:

      The facility addressed the housekeeping concerns of the audit team in
      relation to litter buildup, haphazard storage practices,  and the
      presence of sulfur powder on the SRU floor.

      By the Regional office:

      By State and local authorities:
 Regional Contact:
Pat Lowerv
                                      433

-------
434

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Neste Resins Corporation
Facility Location:
Springfield, Oregon, Region  10
Date(s) Audit Conducted:
May 14 - 18, 1990
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
2821 -- synthetic resins

7 acre site in an industrial area of
eastern Springfield, OR
Thermosetting resins for use by the wood
products industry in insulation,
fiberglass, and adhesives.
There are residential areas to the west
and northwest, and one-half mile to the
northeast, of the facility.
Reason for Facility Selection:
      ARIP Reports:
The facility was chosen because of the
high volume of chemicals (including 60,000
pounds of formaldehyde) stored on-site
adjacent to a densely populated
residential community, and the 11/10/87
release of approximately 1,200 gallons of
resin reactants including phenol,
formaldehyde, and sodium hydroxide.

None
Focus of Audit:
      Hazardous Substances(s)
      Examined:
Formaldehyde
Phenol
Methanol
                                      435

-------
      Physical Area(s) Examined
      at  the  Facility:

      Storage and Handling

      •      Storage Systems

            Neste stores approximately 4 million pounds of hazardous
            chemicals, both liquids and solids, in indoor and outdoor
            locations; no underground storage tanks are currently used.
            Product resin is also stored in large amounts before shipment.
            There are several tank farms containing a total of about 85 tanks.

      •      Shipping/Receiving

            Incoming raw materials arrive 60% by railway and 40% by truck,
            while finished product leaves 98% by truck and 2% by rail.

      Process Area(s)

      The plant manufactures thermosetting resins for use by the wood products
      industry.  Formaldehyde, a major component of all on-site products,  is
      manufactured in three separate plants, by the oxidation of methanol  in
      the presence of a metal catalyst.   Five different types of resins are
      manufactured in kettles in the resin plant -- phenol formaldehyde,  urea
      formaldehyde, melamine formaldehyde,  resorcinol formaldehyde,  and phenol
      resorcinol formaldehyde-- and are typically produced in a batch process.

      Initially, formaldehyde is combined with phenol inside the kettle.
      Sodium hydroxide is added to initiate the reaction.   Once the  reaction
      begins the temperature in the kettle rises.   The rate of increase is
      controlled by manually adjusting the quantity of cooling water which
      passes through the coils within the kettle.   At a specified set point,
      cooling is manually increased to maintain a constant temperature  while
      sodium hydroxide is added.  Next,  the cooling water is shutoff to allow
      the temperature to increase again, increasing the viscosity of the resin
      to the next predetermined level where the temperature is once  again  held
      constant by applying cooling to the system.   Kettle contents are  cooled
      in steps as the viscosity increases to the desired level.
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     Prevailing southwest winds would carry potential  air releases  away
            from the heaviest concentrations of population --  Springfield  and
            Eugene, Oregon.  The area of highest vulnerability is the
            residential community to the northeast of the plant.


                                      436

-------
•     There is a propane storage or distribution  facility  --  the  propane
      tanks are surrounded by weeds, and have unknown  contents  - -  and a
      dynamite storage building adjacent to  the plant's  southern
      boundary, which presents a serious potential  fire  hazard.

•     Railroad tracks are separated from the plant  by  a  fence,  but the
      tracks themselves are not fenced and are accessible  to  the  public.

Chemical Hazards

•     Notebooks containing complete sets of Material Safety Data  Sheets
      are available to employees in the administrative office,  resin
      plant, formaldehyde plant, maintenance, and laboratory.

•     The facility does not test the concentration  of  catalysts received
      from suppliers.  Excessively high concentration  levels  could
      result in a process upset.

•     The facility believes that the accident which could potentially
      cause the greatest impact to the community would be an  explosion
      or rupture (e.g., pressurized liquid ammonia  tank  rupture).

Process Information

•     General housekeeping was above the average of other facilities
      visited.  Traffic lanes and other open areas appeared to be swept;
      auditors observed employees routinely picking up litter and
      depositing it in trash barrels.

•     The valves and piping associated with the reactor cooling water
      and stream system are unlabeled,  a potential source of confusion
      in an emergency situation.

•     There is no measuring device available at truckside when the resin
      bags are filled; instead, employees rely on the footage  content
      gauge on the side of the tank.

•     There are several redundancies to the alarm systems to assure
      shutdown in the event of a high emission release.  These systems
      have been tested effectively during past releases and near misses
      and regular preventive maintenance shutdowns.

•     A fire at the•outdoor phenol tank might present difficulties to
      responders due to limited access.   A catastrophic spill  from the
      indoor phenol tank would exceed the capacity of the diked  area.

•     Drums of acids and bases --  hydrochloric acid, sodium hydroxide.,
      formic acid, and triethanolamine  -- are stored in the same area,
      and sodium hydroxide and formaldehyde are stored  in close
      proximity in one tank farm.
                                437

-------
•     Tanks containing resin •- which contains hazardous constituents  --
      as well as nonhazardous substances were not  labelled.

•     The most hazardous period of resin production  is during  the
      exothermal portion of the process.

•     The configuration of the flammable liquid storage areas  is of
      concern due to potential ignition sources, proximity of  the
      methanol containment area and the drum storage area drainage,  and
      limited access to the phenol tank due to the presence of  storage
      drums, the methanol tank, and railroad cars.

•     Pipelines and tanks containing hazardous materials were clearly
      labelled.  The resin tank farm does not have NFPA labels  visible
      in all directions from which first responders might approach.

•     With the exception of the remote water dump for kettles 2 and  3,
      all important valves and gauges are located on or adjacent to  the
      kettles.  Vapors, smoke,  heat,  or hot liquids could prevent an
      operator from reaching the controls in an emergency.

•     Alarm panels and instrument calibration knobs may be adjusted by
      operators under abnormal conditions,  but there is no method for
      documenting these changes.

•     Process documentation reviewed by the audit team was  in pencil and
      often difficult to read;  any revisions were not readily apparent.

•     The resin plant has no centralized control room,  isolated from the
      kettles, from which all systems can be monitored or controlled.

•     Indoor storage tanks and key pipes along forklift pathways are
      unprotected from damage by vehicles.

•     The "no smoking" signs in the vicinity of the phenol  tank and
      flammable liquid storage areas  are not easily visible.

Chemical Accident Prevention

•     Air emissions are controlled by assorted scrubbers,  absorbers,  or
      catalytic converters, and are regulated by permit.

•     Medical personnel document suspected toxic exposures  in each
      worker's folder.  New hires are subject to a physical  and drug
      screening, and any employee suffering a work-related  injury is
      subject to a follow-up physical.

•     Neste does not monitor the training standards practiced by outside
      contractors whose vehicles and drivers are regularly on-site.

•     During vehicle loading and off-loading by contractor employees,  a
      Neste employee oversees the process when possible.  New drivers

                               438

-------
are instructed in the proper procedures, but  the  extent  of  this
instruction is a matter of concern  to  the audit team.  Neste  could
not provide emergency procedures  training documentation  for an
Neste employee observed overseeing  such an  operation  .

Neste does not have a plant safety  committee.  There  are monthly
meetings for managers/supervisors,  lead operators, and shift
workers where safety issues are prominently placed on^the agenda.
                                                      r
There is a regular channel for information  exchange between the
plant and Neste corporate offices.  Upsets  are investigated and
reported to corporate, and, if applicable,  corporate  relates  this
information to other facilities through a training bulletin.

The last internal audit of safety and  operating procedures was
conducted in 1984, prior to the purchase of the facility by Neste.

Some safety and operating procedure documents were not dated;
procedures policy requires that all entries be dated  and have
space for listing review and revision  dates.

There is limited documentation of emergency procedures in the
event of upsets due to power outage or cooling water  loss.

Most training is on-the-job, although  some  formal training
programs are included in the training  ager.da and other training
and materials are obtained from a variety of sources.

Specific chemical hazards present at Neste  are not covered in the
new employee orientation.  Instead, imparting such knowledge is
relegated to on-the-job training.

Refresher training for operators is regularly scheduled as  an
adjunct to any process or major equipment change.

Shifts are set up with an overlap period during which  operators
exchange information and update process procedures for the
oncoming shift.

Equipment maintenance is on a scheduled,  budgeted rotation;
overtime or even isolated shutdowns may be authorized  in some
instances.

Relative to other plants audited by the team,  the  plant appeared
to have a smaller backlog of work orders,  a large  proportion of
work orders devoted to preventive maintenance and  improvements,
and fewer visually-apparent maintenance problems.

There are no written SOPs for routine kettle operations,  although
Neste is in the process of generating a formal document.

Instrument maintenance is usually accomplished by  outside

                          439

-------
contractors.  Gauges and alarms are bench  tested prior  to  being
placed back into service.

The most recent hazard evaluation was conducted by  the  Neste
Corporate Manager of Safety and Environment  in 1989, but no
documentation was available.  No formal hazard analyses have  been
performed at the facility.

The facility has not conducted any air modeling for potential
releases from the formaldehyde tank.

The STOP safety awareness program developed by Dupont has  been
adopted.  Under this program, unsafe procedures observed are
brought to the worker's attention for discussion and adjudication,
with the supervisor providing final resolution if necessary.

Recent prevention activities include changes in equipment  siting,
increased operator training, increased safety reviews,  initiation
of the CMA Responsible Care program, expanded process training,
and simulation training exercises.

Most employees are cross-trained in several positions.  Lead
operators can usually operate and maintain all process units.

There are no specific site security personnel.   Prior to the
audit, a member of the team gained access to the plant through an
open gate, and was not questioned as to his presence on-site,
which raises serious security concerns.

Five formaldehyde tanks are not bermed individually, but
collectively, thus increasing the risk of a catastrophic incident.

The distance between tanks and the toe of interior dike walls  in
several locations is less than that required by the National Fire
Protection Code; thus, a spill could breach containment.

Any large spill in the western side of the property •- such as
from the unbermed resin storage tanks --  could easily drain to the
perimeter of the facility if it was not contained.

The cooling water system has only one water pump downstream from
the holding tank, and the system does not have  sufficient  capacity
to suppress a worst-case exothermic reaction at the facility.

Because of the lack of written SOPs, formalized training,  and  a
lack of instrumentation, there is a real  possibility for operator
error to result in an accident in the resin manufacturing  process.
                          440

-------
Accidental Release Incident  Investigation

•     Phenol formaldehyde  resin  is  transported by  truck  in  large  rubber
      bags.  In two recent incidents  involving ruptures  of  these  bags,
      investigation revealed error  by the  trucking firm  employee.

•     A spill of phenol formaldehyde  resin on 11/10/87 resulted from  an
      exothermic reaction  that caused the  liquid to become  overheated;
      the reason for inadequate  cooling has not been  determined.  As  a
      result of this spill,  an emergency water dump was  installed for
      the kettle at which  the incident occurred.

•     Neste provides employees with written directions for  spill
      response and reporting --  all spills, releases, and near misses
      are investigated and documented.  The facility  does not conduct
      investigations of near-miss incidents.

Facility Emergency Preparedness  and Planning Activities

•     The facility emergency plan is  being developed, incorporating
      existing emergency response directives.  As  segments  are completed
      by management, they will be passed on to other  employees for
      review and will be incorporated into a training program.

•     Firefighting equipment is  readily available  throughout the site.

•     All shift supervisors  and  team  leaders have  attended or plan to
      attend a three-day, CMA emergency response team workshop.   The
      facility emergency response team, and most other employees,  have
      been trained in and are certified in First Aid.

•     Fire extinguishers, emergency showers, and eye wash stations are
      strategically located  throughout the facility.  The facility is in
      the process of installing  an  automatic sprinkler system in the
      resin building.

•     Plant alarms, using electrical  sensing devices, consist of horns
      on process equipment.  There  is no standby power available.
      Alarms are tested every six months.

•     No alarms serve as redundancies for.human error or mechanical
      failure within the resin plant;  the system relies on the operator
      to discover potential  problems.

•     Senior maintenance personnel  carry .a pager,  allowing them.to be
      contacted in the event of  a problem at odd hours.

•     Operations personnel have  full-face respirators and cartridges for
      formaldehyde and organic gases  in their lockers.
                                441

-------
•     There is only a single SCBA near the resin plane, preventing  che
      utilization of the buddy system in a response situation, and  there
      is no protective clothing in the vicinity of the SCBA  gear.

•     No chemical spill kits (i.e., absorbent) were at the facility.

•     Fire monitors line the eastern border of the facility, and can be
      helpful in fighting fires or preventing off-site exposure.

•     The plant public address system can be used for internal emergency
      communication, and is audible throughout the facility.

Community and Facility Emergency Response Planning Activities

•     Neste has two representatives on the Oregon State LEPC and
      participates in the Springfield task force on chemical awareness.

•     A firefighting exercise with the local fire department is
      scheduled on an annual basis.  No documentation and/or critiques
      of past drills or exercises was available.

•     The consensus of the audit team was that facility personnel could
      handle an emergency situation of limited impact.  However,  since
      the nearest hazardous materials spill responders are approximately
      12 to 15 minutes away, a major incident that required outside
      assistance would be a problem.

•     Neste personnel participate in meeting of the local ALERT Group
      (the planning group for this district,  with members from public
      and private organizations),  which meets monthly to discuss  issues
      of interest to members of the chemical industry.  An ALERT  meeting
      conducted during the audit discussed the 1987 incident at the
      Neste facility.

Public Alert and Notification Procedures

•     The current public notification system relies upon public address
      systems operated by local first responders.

•     Emergency procedures designate a Neste corporate official as  the
      media contact in the event of a release,  which could create a
      credibility problem since the corporate offices  are  miles away.
Recommendations:

Chemical Hazards

•     Neste should test the concentration of catalysts,  such as  sodium
      hydroxide, received from suppliers before using them.
                                442

-------
Process Information

•     The facility should install a meter, gauge, or other measuring
      device in the vicinity of the resin delivery nozzle to measure  the
      .product entering the rubber bags and the rate of flow.

•     Neste should label valves and piping of the cooling water  and
      steam systems, including descriptive identifications such  as "city
      water inlet" and direction flow arrows.

•     Neste should permanently install a backup cooling water pump
      downstream of the cold well.

•     Neste should consider installing a centralized system to monitor
      and/or control the flow rates and temperatures of the cooling
      water system to distribute cooling water more efficiently. The
      facility should also install flow meters and pressure gauges on
      all incoming city water lines upstream of each kettle.

•     Neste should evaluate the flammable liquid drum storage area to
      eliminate ignition sources,  prevent a fire from exposing the
      methanol and phenol tanks, and increase accessibility to the area.

•     Neste should evaluate the storage locations of all chemicals in
      terms of material compatibilities,  and separate incompatible
      materials such as acids and bases.

•     Neste should evaluate whether certain materials,  such as phenol
      and triethanolamine,  should be stored outside for fire  hazard or
      toxicological reasons.

•     Neste should label tanks containing hazardous materials with
      highly visible NFPA labels and specific contents  identification,
      and label tanks with nonhazardous materials as well.

•     Neste should install alarms  to alert operators to high  kettle
      temperature, and to excessive kettle temperature  increases or high
      kettle liquid levels, if possible,  to compensate  for  human error.

•     Neste should protect indoor  storage tanks  and key pipes from
      damage by motor vehicles such as forklifts.

•     Neste should improve the visibility of "no smoking" signs  in the
      vicinity of the phenol tank and flammable  liquid  storage  areas.

Chemical Accident Prevention

•     Neste should consider including a monthly  safety  or training tip,
      when possible based on an actual event,  in the monthly  Neste Resin
      News provided to employees.
                               443

-------
Neste should undertake:

      an immediate hazard evaluation of  the entire  site  with
      mitigation procedures  to  start in  a  timely manner  (a  fire  in
      the loading area while  loading was underway would  be  o-f
      particular interest);
      a HAZOP study of the resin and formaldehyde processes,
      emphasizing systems which could potentially cause  the
      greatest harm if an accident were  to occur; and
      a formal hazard assessment of the  cooling water  system.

Neste should require all vendors and contractors to supply
documentation attesting to the  health and safety training of their
employees assigned to service the facility.

Neste should undertake a review of the procedures, directives, and
guides manual, updating those sections which have not been
reviewed or revised within the  last twelve months.

Neste should initiate a modeling exercise for air releases.

Neste should document credentials of persons responsible for
instructing trainees and- supervising loading/unloading operations.

Neste should request a security survey of the site by the local
policy department or an accredited private security vendor.

Neste should reinforce the need to keep man-hole covers closed
during resin cooking operations to prevent bubbling over.

Neste should provide emergency water dumps for each kettle  in
which cooling is required, and  place the controls a safe distance
from the kettles near a doorway.

Neste should install controls to secure hazardous materials
systems and initiate emergency water dumping to enable an operator
to shutdown the resin-making process from a safe distance.

Neste should install a secondary containment system around the
resin storage tanks and the formaldehyde processing units.

Neste should place seals on the alarm panels -- perhaps signed
paper strips -- and instrument  calibration knobs to help prevent
these systems from being adjusted and to allow personnel to know
when instruments have been adjusted.

Neste should formalize SOPs for all routine activities related to
the handling and processing of hazardous materials.

Neste should expand the introductory safety training to include
specific information concerning proper handling and the hazards
associated with specific chemicals used on site.

                          444

-------
 •      Neste  should conduct all process documentation in pen, rather than
       pencil,  and require operators to line out and initial
       documentation errors rather than erase them.

 •      Neste  should provide instructions for process upsets such as-power
       outages,  cooling water loss,  etc.

 •      Neste  should conduct periodic formalized "What If" drills with the
       operators involving a theoretical process upset,  and modify the
       system accordingly if weaknesses are discovered.

 Accident Release Incident Investigation

 •      Neste  should initiate a positive approach program toward the
       reporting of near misses,  and incorporate the information gathered
       from near miss reporting forms into the training  agenda.

 Facility Emergency Preparedness  and Planning Activities

 •      Neste  should complete the  installation of an automatic sprinkler
       system in the resin building.

 •      Neste  should complete the'  emergency response plan being drafted.

 •      Neste  should develop a chemical spill kit,  including materials
       which  can be used to dike  and absorb spills and block drains.

 •      Neste  should store appropriate dermal protective  clothing with  the
       SCBA gear,  and conduct periodic drills to familiarize personnel
       with the  equipment and check  its condition.

• Community and Facility Emergency Response Planning Activities

 •      Neste  should participate with the local emergency management  team
       in designing at least one  major exercise in the next six  months.
       This exercise should involve  all facets of  community response.

 Public Alert and Notification Procedures

 •      Neste  should install a public  notification  system and initiate an
       appropriate training program  to insure adequate warning to the
       neighboring communities in the event of an  upset  or  release.

 •      Neste  should designate an  on-site management person  as  the media
       contact to. enhance local credibility.

-------
Audit Team Member Composition:
Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Rosemary DiCandillo
US EPA Region 10
Emergency Preparedness
Geologist

Patrick J. Lowery
US EPA Region 10
Safety/Training/Emergency Response
Emergency Management/Business Administration

Noah Myers
TAT, US EPA Region 10
Process Maintenance and Safety
Chemical Engineer

John Erve
TAT, US EPA Region 10
Process Maintenance and Safety
Chemical Engineer

Bob Albers
State of Oregon Fire Marshall
SERC Representative
Fire Prevention

Bob Anderson
State of Oregon Fire Marshal
SERC Representative
Fire Prevention
Follow-up Activities:

      By the facility:

      By the Regional office:

      By State and  local authorities:
 Regional  Contact:
Pat Lowery
                                      446

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Unocal Chemicals Division  (UCD)
Facility Location:
Kenai, Alaska, Region  10
Date(s) Audit Conducted:
September 24-28, 1990
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:

      Proximity to
      sensitive populations:
2873 -- nitrogenous fertilizers

150 acre site approximately 10 miles north
of Kenai along the east side of Cook Inlet
Anhydrous ammonia and urea as fertilizer
Residential subdivisions are located
approximately 2 miles east of the
facility, and 2,565 people live within a
three mile radius of the plant.  Nikisi
Elementary School and a recreational
area/swimming pool are located within two
miles of the plant. Two other schools are
within 5 miles of the plant.
Reason for Facility Selection:
      ARIP Reports:
The facility was chosen because of a
series of nine reportable releases of
ammonia during 1990.

02/10/90, 02/28/90, 03/01/90,  05/03/90,
and three 05/28/90 releases of ammonia

03/05/90 release of sulfuric acid
Focus of Audit:
      Hazardous Substances(s)
      Examined:
Ammonia

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      Two large tanks capable of containing  30,000  and  50,000  tons  of
      ammonia are located in the southwestern part  of the  facility.
      There are also two tanks with 30,000 and 40,000 gallons  of urea
      formaldehyde, as well as smaller storage quantities  of  sulfuric
      acid and sodium hydroxide.

•     Shipping/Receiving

      The finished urea prills and granules  are stored  in  separate
      warehouses prior to export via ship.

•     Material Transfer

      Liquid ammonia is transferred from storage to the urea reactor  by
      the ammonia feed pumps.  The incoming  pressure is 260 psig; the
      outgoing pressure is 3,400 psig.

Process Area(s)

The Unocal plant is a large, nitrogen-based  fertilizer production
complex consisting of two ammonia plants, two urea plants, and two
associated utility plants.  Average daily production of anhydrous
ammonia and urea is 3,600 and 3,200 tons per day,  respectively.

In the ammonia plants, natural gas is converted to ammonia through a
four-stage process.  During sulfur removal,  hydrogen sulfide and organic
sulfides are absorbed by activated carbon.  Next,  steam is introduced
and the resulting mixture is reformed into hydrogen, nitrogen, carbon
monoxide, and carbon dioxide.  In the third step,  the gas mixture is
purified to produce nitrogen and hydrogen in a one-to-three ratio,
called synthesis gas, or syngas.  Finally, the hydrogen and nitrogen
react catalytically to form ammonia during ammonia synthesis.

In the urea plants, the anhydrous ammonia and   .bon dioxide produced in
the ammonia plants are reacted to form urea in a four-stage process.
First, the ammonia and carbon dioxide are compressed prior to
introduction into the urea reactors.   Next,  the compressed gases are
reacted at elevated temperatures and pressures to  form ammonium
carbamate, and subsequently, urea.   In the third step -- separation and
recycling -- the unreacted raw materials and intermediates are fed back
into the reactor to form urea.   Finally,  the urea  process stream is
either crystallized and prilled, or concentrated ar.d granulated.   The
utility plants generate electricity,  steam,  and dry compressed air for
use in the ammonia and urea plants.  Well water is deminefalized and
treated for use in the steam boilers  or as process cooling water.  The

                                448

-------
      electricity  is produced  in  the  power plants  using  a  natural  gas-fired
      piston and turbine  generators.


Summary of Audit Findings and  Recommendations:

      Conclusions:

      Facility Background Information

      •     UCD is located  in  an  area rated seismic  zone 4 by  the  uniform
            building code.  Zone  4  is defined as areas within  zone 3  (the
            potential  for major damage) determined to be at even greater  risk
            because of the  proximity  to a major fault system.  Mt.  Redoubt,  a
            volcano in the  eruption cycle, is located 50 miles to  the west.

      •     The facility operates 24  hours a day,  seven days a week with  two,
            twelve-hour shifts each day.  Operators  work in two shifts of
            seven, 12-hour  days,  with a week off after each 84 hour work  week.
            The audit  team  questioned the ability  of the plant operations
            employees  to function at  full capacity during  the  latter portion
            of this work week.

      Chemical Hazards

      •     The facility has implemented a safety  clothing program  that
            requires all operators  to wear fire-resistant  clothing  on duty.

      Process Information

      •     There  was  a lack of thorough and consistent chemical hazard
            labelling  on process  piping and storage  tanks.

      •     The ammonia storage tanks are covered with glass foam  insulation
            to maintain the ammonia in liquid form.  Vapors are collected,
            liquefied, and  recycled back to the storage tanks.

      •     The audit  team  found  the  facility to be  clean  and tidy; equipment
            not in use was  properly stored, and very little refuse or debris
            was encountered.   The only exception was the discarded maintenance
            tag-out tags near  the electric control panel;  disposal procedures
            are not included in the facility safe practices standards.

      •     Urea plant #2 process control instrumentation  consisted of relays
            and simple controllers.   As may be expected in a facility of its
            age (constructed between  1966-68),  modern integrated process
            control is not  applied.   The current process control scheme
            exhibits no supervisory process control redundancy to  minimize or
            preclude releases  as  a  result of operator error.

      •     The original design capacity of plant #2 was 1,000 short tons  per
            day; production records indicate that daily rates have  frequently

                                      449

-------
      approached 1,400 short cons.  Conversations with operators ar.d
      review of internal correspondence reveal that many of  the adverse
      signs associated with operation at excessive rates have been
      observed.  The increased flow rates result in increased turbulence
      in the first absorber bottoms, making accurate level measurement
      and,  therefore,  level control, difficult; the overall  impact of
      increased throughput rates is a decrease in overall process
      efficiency.   As  the first absorber was the source of the majority
      of the ammonia released in 1990, the audit team considers the rate
      of production to be the most likely primary cause of the releases.

•     Among proposed process modifications for the next (1992) facility
      turnaround are:

            an ammonia vent recovery system for ammonia plant #4;

            a new, larger reactor for plant #2 to increase the degree of
            conversion (and thereby reduce the load on the plant f/2
            separation and recycle processes); and

            installation of scrubbers on selected unit process vents.

      Unocal estimates that these modifications will reduce chronic
      ammonia emissions from the facility by five tons per day.

•     The level of urea particulate emissions from the urea prill  tower
      is of concern to the Alaska Department of Environmental
      Conservation (ADEC).   Substitution of this unit process with a
      more modern and efficient unit, such as the granulator, would
      reduce urea emissions from this step by an order of magnitude.
      There are, however, no plans to replace or retrofit either the
      plant #2 first absorber or the prill tower.

•     The ammonia tanks have integral tops that are protected by
      pressure and vacuum relief valves and electronic level  monitoring
      devices and differential pressure audible alarms to indicate high
      liquid levels.  Pipelines and pumps associated with the storage
      tanks are monitored routinely by operators to detect leaks and
      ensure proper operation of the equipment.

•     Air monitoring is conducted at three sites north and northeast of
      the facility, two by Unocal and one .by the state of Alaska.

Chemical Accident Prevention

•     The Unocal corporate office provides guidance to the facility in
      the form of training, safety, emergency response and environmental
      compliance bulletins and manuals, as well as  technical  and
      professional support from corporate teams as  needed.

•     The facility gives an annual safety award to  one employee  selected
      from within a group that has been accident free  for one year.

                                450

-------
The consolidation of the plant health and safety departments,
whose director reports to the plant manager, and the  increase  in
staffing over the past two years is commendable.

An executive safety committee composed of management  personnel
meet every two weeks to discuss plant problems and corporate
input.   The plant safety committee, consisting of two management
and two union employees, meets monthly to discuss safety  issues
and plant inspections.

Audits are conducted bi-annually.  Areas of concern are identified
as items for immediate attention or for correction during routine
maintenance.

The facility maintains an on-going program for development and
revision of operator training and standard operating procedures.
It is standard procedure for an upgrade in training to follow any
change in process, instrumentation, or equipment.  Training is
conducted in both a formal classroom setting and at the specific
job site.  New hires receive 2.5 weeks of basic operator training,
including chemical awareness orientation.   There is no scheduled
retraining program, but employees may make use of a large body of
technical information in document and video format that is
maintained by the training group.  The facility also provides
HAZOP training for all supervisors and engineers.

Plant #2 operators interviewed displayed an in-depth knowledge of
processes, instrumentation,  and procedures -- reflecting a sound
knowledge of plant operations and a genuine emphasis on safety --
and even provided recommendations to the audit team concerning
process modifications,  health and safety,  and training.

If a maintenance request involves a process modification,  the
request must be routed through the process engineering department
and HAZOP group prior to authorization.   On weekends,  a skeleton
crew is assigned maintenance responsibility;  emergency off-hour
maintenance requests are handled by a call-out procedure.   Every
thirty months, there is a month-long plant shutdowns for major
overhaul and complete maintenance.

A computerized maintenance management system is presently being
implemented to replace a system of handwritten records.

A review of maintenance files for both the facility and plant #2
indicated an increasing trend in the percentage of  unscheduled
versus planned maintenance required during the period from August
1988 to January 1989.  The unscheduled maintenance  rate  for plant
#2 during this period is a concern, and may indicate  inadequate
preventive maintenance.
                          451

-------
•     Although no modeling program  is currently  in  place,  Unocal
      corporate environmental staff are designing a program  for use  at
      the facility.

•     Release prevention measures include  improvements  in  process  design
      resulting in reductions in measurable ammonia emissions, inventory
      control to reduce on-site storage, and  redundancy in alarms  and
      emission control systems.

•     The ammonia storage tanks are located within  a diked area large
      enough to contain the contents of either, but not both,  tanks.
      UCD recognizes the potential  for simultaneous failure  and is
      aggressively pursuing options to address this problem.

Accidental Release Incident Investigation

•     The facility reported nine releases  of  ammonia during  1990,
      ranging from 150 pounds to 30 tons.  The majority of these
      releases were located in urea plant  #2.

•     UCD provides employees with written  directions to address
      incidents of spill response and reporting covering reporting and
      investigation of all spills, releases,  and near-misses.

•     An investigation team -- consisting  of  supervisory and management
      personnel and other staff, as appropriate --  prepares a report on
      the cause and extent of incidents, injuries and damage,
      containment, clean-up, and an overall critique.   Incidents are
      then discussed at the next safety meeting.

Facility Emergency Preparedness and Planning Activities

•     Facility accident prevention,  safety, and emergency response
      guidelines are contained in the Release Prevention, Control and
      Countermeasures (RPCC) Plan, available at a number of locations
      throughout the facility.  Key emergency response personnel have
      been provided with a second copy to keep at home.   The plan
      addresses equipment provisions,  chain of authority, management
      procedures, internal communications network,  response personnel
      training, monitoring stations, and follow-up procedures.

•     The RPCC plan was issued in June 1988 and has been revised on two
      occasions.  The health and safety supervisor and the safety and
      environmental superintendent review  the plan whenever the facility
      permit is revised; the plan "fails"  in an emergency;  significant
      design or operational changes are implemented  key emergency
      personnel change; or available emergency equipment changes.

•     Emergency response simulations are held frequently throughout the
      year -- two were held in July 1990.   Reports are prepared by the
      participants, and are analyzed by the safety  :nd environmental
      staff and discussed at the next safety meeting.

                                452

-------
•     Maps displaying fire, evacuation, and rescue corridors are  readily
      available in the RPCC and at numerous locations in the plant.

•     UCD maintains fire extinguishers, emergency showers, and eye wash
      stations throughout the site, and all operators are trained in
      their proper use during their orientation.

•     Control rooms,  offices, and works stations are equipped with
      telephones and hand-held radios are located in the control  rooms
      and are carried by operations personnel outside of the control
      room.  Critical emergency response personnel have full-time
      pagers; other staff members are equipped with on-site pagers.
      Crew working in the wharf area are equipped with VHF radios.  The
      facility also has an emergency fire phone call-up tied into a
      conference call circuit, which is activated by dialing 60 and
      immediately rings emergency phones located in all the control
      rooms and various supervisor's offices.

•     The facility has a trained and outfitted 64-man hazardous
      materials team.  The facility is using training modules developed
      by Texas A & M University and the University of Nevada-Reno to
      provide a 40-hour emergency response training program.

Community and Facility Emergency Response Planning Activities

•     A Family Day is held annually in which employee families are
      encouraged to participate in basic fire  extinguisher training.

•     The superintendent of safety and environmental affairs  is the
      chair of the Kenai Peninsula Borough LEPC, and actively
      participates in the activities of the Alaska SERC.

Public Alert and Notification Procedures

•     The Kenai Peninsula Borough Office of Emergency Management  has
      installed a public warning system operated through  strategically
      located local radio stations,  as well as high-powered voice and
      siren systems.   These radio stations have also been provided with
      back-up electrical generators for use in an emergency when  local
      power supplies are disrupted.

•     The RPCC plan contains a community evacuation plan  directive that
      outlines steps to be taken by the incident commander should some
      action on the part of the surrounding community be  necessary.  It
      includes telephone numbers for local notification.
                               453

-------
Recommendations:

Process Information

•     At the time of the audit, much of  the facility's piping was  being
      stripped and repainted.  Upon completion,  the  facility should
      label process piping with contents name and direction of  flow  and
      provide storage tanks with applicable NFPA labels.

•     The facility should review historical records  to see if a
      correlation between process throughput and frequency or magnitude
      of ammonia releases exists.

            If so, Unocal should reduce  throughput to the point that no
            statistically significant increase in frequency or  magnitude
            of accidental ammonia releases is anticipated.

            If the correlation cannot be developed,  Unocal should  reduce
            throughput to design levels.

            If plant #2 production rates are to be maintained above
            design levels, Unocal should comprehensively re-evaluate the
            design of plant processes for compatibility with the desired
            rate and modify or replace unit processes as-required.

•     The facility should.re-evaluate the design of the first absorber
      in terms of the desired production rate and resize,  replace, or
      retrofit as required.

•     Unocal should replace the prill tower with another unit process
      that emits less particulate and vapor (e.g.,  a granulator),  or
      install appropriate emission control devices (e.g.,  scrubber or
      baghouse).

•     The facility should evaluate the feasibility of installing
      supervisory process control in plant #2 and install  such  controls
      to the extent feasible.

Chemical Accident Prevention

•     During the next review and revision process,  procedures  for
      returning maintenance tag-out tags to the issuing party  at the
      completion of the work assignment should be considered  for
      inclusion into the facility safe practices  standards.

•     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.

•     Unocal should input historical maintenance  data to  the
      computerized maintenance management system  to  facilitate  the rapid
                                454

-------
            development of preventive maintenance schedules based on the
            history of existing equipment.

      •     Plant and corporate management are encouraged to continue their
            efforts to address the potential for a catastrophic release.of
            ammonia due to a failure of both large storage tanks.

      Accidental Release Incident Investigation

      •     The facility should undertake a study of incidents during the last
            year focusing on whether incidents occur more frequently at any
            point during the regular 84-hour work week.
Audit Team Member Composition:

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Pat Lowery
US EPA Region 10
Team Leader
Emergency Management and Business Administration

Carl Lautenberger,  OSC
US EPA Region 10, Alaska Operations Office
Emergency Response
Biologist

Frank Onkamoto
TAT, US EPA Region 10
Technical Reviewer
Chemical Engineer

Tom Ashley
TAT, US EPA Region 10
Technical Reviewer
Chemical Engineer

Donald R. Seagren
Alaska Dept. of Environmental Conservation
Observer
N/A
Follow-up Activities:

      By the facility:

      By the Regional office:

      By State and local authorities:
Regional. Contact:
Pat Lowery
                                     •455

-------
456

-------
                         CHEMICAL SAFETY AUDIT PROFILE
Facility Name:


Facility Location:
Chevron USA
Richmond Beach, Washington, Region 10
Date(s) Audit Conducted:
January 15 - 18, 1991
Description of Facility:

      SIC Code(s):

      Location:
      Products manufactured,
      produced, or distributed:
      Proximity to
      sensitive populations:
2951 -- asphalt paving mixtures nad blocks

10 miles north of central Seattle, WA, on
the eastern shore of Puget Sound and along
the border of King and Snohomish counties.
Petroleum products storage terminal and an
asphalt refinery.
There are residences and schools directly
to the north, south, and east.
Reason for Facility Selection:
      ARIP Reports:
The facility was chosen because of an
asphalt spill on August 30,  1990.

None
Focus of Audit:
      Hazardous Substances(s)
      Examined:
Ferric Chloride
Hydrochloric Acid
                                      457

-------
Physical Area(s) Examined
at the Facility:

Storage and Handling

•     Storage Systems

      The terminal and refinery have 145 operational storage  tanks  with
      capacities ranging from 16,000 to 125,000 barrels.  Most  of  the
      large tanks were constructed between 1912 and 1949.  The  tanks are
      located in two tank farms and are diked and/or bermed.  The
      terminal is converting all large storage tanks to double  bottoms.

      Hydrochloric acid for pH modification is stored in a fiberglass -
      reinforced, plastic storage tank.  The tank has level-indicator
      gauges and secondary containment and is appropriately labeled.

•     Shipping/Receiving

      Products for the refinery and terminal are received primarily by
      ship or barge,  with some rail traffic on the adjacent Burlington
      Northern tracks.  Finished product leaves the site by truck.

Process Area(s)

Petroleum Terminal.  The Point Wells terminal stores gasolines,  jet
fuel, lubricating oils, and diesel fuels received by tanker ship.

Asphalt Refining.  Charge stocks are fed to the vacuum distillation
tower, where they are fractionated into four streams:   a light
distillate containing naphtha and water, two medium distillates  used for
fuel and lubricating oils, and residuum bottoms.   The bottoms may be
blended to manufacture specification paving asphalts,  air oxidized to
manufacture roofing asphalt, or sheared with surfactants and water to
manufacture emulsified asphalts.

The vacuum distillation column is operated on a continuous basis, with  a
feed rate of approximately 6,000 barrels per operating day.   Charge
stock entering the column is preheated in an oil-fired furnace.   Vacuum
is supplied to the column by steam vacuum generators.   Vapors from the
vacuum generators are sent to the furnace for burning.

Air oxidation is accomplished in batches in one of three air stills.
The still is charged with asphalt and heated with steam coils.
Compressors inject air into the bottom of the still to oxidize the
asphalt.  Air and organic vapors leave the top of the  air stills and
enter a separating tank, where condensables are removed.   The remaining
air and vapor mixture travels to an incinerator.
                                458

-------
Summary of Audit Findings and Recommendations:

      Conclusions:

      Facility Background Information

      •     The facility is  located  in  a  Seismic  Zone  3,  defined by the
            Uniform Building Code  as an earthquake  vulnerability area that has
            the potential for major  damage.

      •     The primary vulnerable zone for  a  spill is Puget Sound to the
            west; the vulnerable zones  for an  air release are the Woodway and
            Richmond Beach communities  to the  north, south,  and  east.

      Chemical Hazards

      •     Employees receive a physical  when  hired and every five years  with
            the time interval shortened with increasing age.

      Process Information

      •     Storage tanks are situated  as close as  25  feet from  the  shore  of
            Puget Sound.

      •     Within the main  tank farm were various  combustible materials and
            ignition sources which could  increase the  probability  or  severity
            of a fire.  In addition, the  storage  tanks  in the terminal  and  the
            refinery were constructed before the  current  NFPA guidelines were
            established, so  many of  the tanks  are spaced  closer  than  these
            guidelines recommend.  The  audit team believes these factors
            increase the chances of a fire spreading through  the tank farm.

      •     The facility has stored haphazardly over 2,000 five-gallon
            containers of petroleum products in the terminal warehouse,
            without a sprinkler system  and near other  combustible materials.

      •     While most tanks were equipped with NFPA signs, in some instances
            these signs were difficult  to locate or not easy to read.

      •     At the time of the 8/31/90  spill, neither  the terminal or the
            refinery had formal written procedures  to be used during transfer
            operations.  The refinery has since implemented procedures and a
            checklist, and the terminal is preparing similar procedures.

      •'     The valve numbers marked on the valves  are small and difficult to
            read and could be misread or  overlooked by operators following the
            new procedures for initiating transfer  operations, which involves
            the visual verification of  individual valve positions.

      •     Funds have been  made available to  install a continuous gauging
            system with high level alarms on all eight refinery marine
            receiving and delivery tanks  and on 33 other large refinery tanks.

                                      459

-------
•     Several issues were raised with respect to  instrumentation:

            Many of the terminal storage tanks are equipped with
            electromechanical level-sens ing devices and  remote -
            activated, manual emergency shutoff valves,  but these
            devices have been prone to false positive alarms;
            High-level alarms are not installed in the refinery tanks;
            Instrumentation has beer, added in piecemeal  fashion to  the
            control room, resulting in a somewhat disarrayed appearance;
            Some of the alarms and lights are not labeled, and some  of
            the gauges and indicators were broken;
            Although the alarm for tank 74 had been disconnected, there
            was no indication of this fact on the alarm  panel;
            During a test of the instrument panel, the alarm lights  for
            tanks 55 and 74 did not function;
            Several critical temperatures can only be indicated on one
            switchable display, making it difficult to monitor several
            variables simultaneously;  and
            At the time of the audit,  the cabinet containing the alarm
            circuit boards was unlocked and could be easily accessed.

•     No ambient air monitoring is conducted.

Chemical Accident Prevention

•     The facility conducts a monthly safety meeting and issues a
      monthly safety bulletin to all employees.

•     The facility has in recent years experienced a high level of
      turnover in plant management,  and typically there has been no
      overlap to ease the transitions.  This creates an impression among
      employees, particularly response personnel,  that persons directing
      emergency operations are the least trained.

•     The entire facility is fenced,  guarded, and in operation 24  hours
      a day.  Visitor identification passes were  not issued to the
      members of the audit team.

•     Chevron provides safety guidance through the marine terminal
      safety program and conducts corporate audits on a five  year
      rotation.  The last facility audit took place in May 1987.  ;

•     The terminal manager and the head operator  disagreed over the
      correct procedures to mitigate a dock pumping accident.   Air rams
      can be manually activated to stop the flow  of product,  but  the
      sudden pressure surge could cause a rupture  in the  transfer  hose.

•     In addition to new hire orientation,  training is provided through
      regularly scheduled programs and on-the-job  training by  immediate
      supervisors or the head operator.   Instructional tapes  on the
      principles of distillation and pumping are  also available.
                               460

-------
Employees are evaluated on an annual basis by  their  supervisor.
The inherent limitations of an evaluation conducted  by  the  person
responsible for training and the possibility of using corporate  or
outside evaluators were discussed with the facility.

Terminal operators displayed limited knowledge of operations  and
emergency procedures at the refinery, and refinery operators
showed a lack of familiarity with terminal operations.

Employees conducting a tank displacement process were observed
wearing no protective gear, and should have been equipped with
hard hats and eye protection.

There is a color-coded system of lockout tags; however, the audit
team was concerned about a number of plain locks without
identifying tags or color coding.

Routine preventive maintenance at the terminal includes regular
servicing of the fire system at both the terminal and the
refinery, periodic repacking of valves, and inspection and testing
of tanks, safety systems, and instrumentation.  According to
maintenance supervisors, nearly all of the department's resources
are used for emergency or urgent repairs; low priority-jobs may be
put off indefinitely.

A computerized preventive maintenance system has recently been
instituted at the terminal to track some individual maintenance
tasks at regularly scheduled intervals.

All piping throughout the terminal connecting the tanks farms,
truck and rail loading racks, and the dock berths are pressure
tested annually.

Instrumentation maintenance is provided by off-site contractors.

There is no maintenance schedule for the hydrocarbon sensor and
outflow trip system beyond the south separator, or for pipeline
pressure relief valves, pipeline and tank valves,  pumps,  tank
painting, and most instrumentation.   Personnel were unable  to
identify when two critical trip systems were  last checked.

As a result of the asphalt spill,  Chevron USA has undertaken a
program of reviewing all their refinery and terminal  receiving
systems to identify.all aspects of the marine delivery/receipt
system which could result in a spill incident.

No hazard evaluations or modeling have been performed in the past,
although management is currently conducting What  If analyses on
all of their operations.

In general, tanks and piping we're well-protected  from physical
damage from vehicles.  However,  in three cases  --  several pipes

                         461

-------
adjacent to the parking lot,  tank  65,  and  fuel  oil  tanks  127  and
128 -- the potential for vehicular  damage  exists.

The truck loading racks are equipped with  a  vapor recovery  system.

Secondary containment measures exist for all the storage  tanks,
the three truck loading racks, and  the yard  and process areas.

There are many instances of insufficient containment  practices:

      Containment for the railroad  loading station  does not appear
      to be sufficient for a  spill  of  an entire carload,  which
      might then pass beneath the warehouse;

      Spilled oil from the thinner  loading rack could exceed  its
      containment structure and flow beneath the roadway  trestle,
      the main route for emergency  vehicles  and evacuation;

      The protective covering of the earthen dike surrounding
      tanks 61 and 62 (currently out of service) appeared to be
      deteriorated;

      Although there are catchpans  beneath the  dock pipeline
      inlets to catch very minor spills or leaks, the catchpans
      are not large enough to catch any substantial leak  or splash
      -- oil sheens were visible on standing water on the dock;

      After visual inspection to detect oil,   rain water from the
      upper tank farm is drained to the woods without treatment;

      Several large storage tanks are located within a few feet of
      the containment dikes, so that a pressurized leak from a
      point above the adjacent dike could  travel above the wall;

      The dikes and berms to  isolate tanks within the main tank
      farm have been compromised in numerous places, primarily
      with holes made to allow passage of  piping;  and

      Several tank farms are not individually bermed,  so that a
      large spill could spread over a wide area of the facility.

The only outlet from the secondary  containment system is through
the valved drainage system to a pair of oil/water separators and
then  into Puget Sound in accordance with an NPDES permit.   As
highlighted by the events of the 8/31/90 release,  however,.there
is considerable potential for spilled oil  to reach Puget Sound:

      In the event of a large spill, the capacity of the
      separators may be overwhelmed by the quantity of oil;

      The facility depends upon-visual observation of a release  to
      close the outlet valve from the north separator, and a

                          462

-------
            hydrocarbon sensor and an outflow trip past  the  south
            separator, to prevent a spill from reaching  Puget  Sound;

            Containment on the dock is provided by a 6-inch  perimeter
            curb, with accumulated water draining directly to  Puget
            Sound through a number of small drains or  scuppers.   At  the
            time of the audit, the scuppers were open, but a dock
            operator indicated that the scuppers are closed  during
            transfer operations; and

            Although there are dike drain valves which can be  closed and
            locked to prevent a spill from reaching the  separator,
            according to the terminal manager the valves are left open
            and all tank farms are drained directly to the separators.

•     The top of the groundwater pumping wells near tanks 2  and 3  are
      approximately one foot above ground level.   In the event of  a
      large spill, oil product could flow directly down  the wells  and
      into the groundwater.   The inner walls of the wells and  the water
      table near tank 2 appeared to be coated with residual  oil.

Accidental Release Incident Investigation

•     During the year prior to the audit,  the facility experienced a 50-
      gallon spill of diesel oil,  a 176,000-gallon spill of asphalt,  and
      a spill of an unknown quantity of gasoline.

•     During the 8/31/90 incident, 176,000 gallons were spilled and
      approximately 4,000 gallons  entered Puget Sound when operators
      were off-loading a tanker of feedstock.   An operator had
      inadvertently left a valve open which directed the feedstock to
      the incorrect tank, which subsequently overflowed into  a bermed
      area as well as over the berm into Puget Sound.

•     Written directions and forms are provided.for spill and release
      incidents, but Chevron does  not provide a form or procedures for
      reporting near-misses.

Facility Emergency Preparedness and Planning Activities

•     Chevron has a Marketing Emergency Management Plan (MEMP)  --  a
      training and reference source with seventeen sections on a wide-
      range of critical emergency  issues --as well as  a Pre-Fire  Plan,
      and an Oil Spill Contingency (SPCC)  Plan.   There  were no  dates  to
      indicate the last review for any of  these plans.

•     No formal plans are in place to coordinate  terminal and the
      refinery activities during an accident.

•     The audit team was concerned about the evacuation of personnel  in
      the administrative areas should an explosion or  fire cut  them off
      from an evacuation to the east.

                               463

-------
Dock spill response equipment  includes  motorboats,  electric
cranes, almost 5,000 feet of booms,  900 feet  of  sea curtain,  and a
large pile of absorbent pads.  Most  of  the  equipment is  new  and in
very good condition.

The signs identifying  the steam  smothering  lines  for extinguishing
fires were difficult to read,  which  could present a problem  since
they must be manually  activated.

Although there are several spill  response boats  along the  dock,
deployment problems could mitigate their usefulness:

      In the event of  a power  outage, the lack of electricity
      would render the electric cranes  useless (the  terminal
      manager indicated that a ramp  was planned  to  alleviate this
      problem);

      Ladders are not  installed at all  crane  locations, making  it
      impossible for one person to deploy the spill  response boat
      at certain locations (safety rules prohibit personnel from
      sitting in the boat as it is lowered  into the  water); and

      The presence of  barges or tanker  ships  in the  certain dock
      areas could prevent the  deployment of the response boats  to
      strategic locations along the  dock.

Although flood lamps are provided on the dock, the shoreline is
not so equipped, making it difficult to detect or assess the size
and location of a nighttime spill.

A backup diesel water  pump is  located on the dock to supply water
to the fire suppression system in the event of a power outage
knocking out the two existing  electrical pumps.

A review of the fire cabinets  revealed  that some hose replacement
was due, and most cabinets required some repair.

Emergency response equipment (e.g., SCBAs)  is located in the
terminal, but not in the refinery.  Terminal personnel are trained
in its use and refinery personnel are not.

Facility telephones are equipped with annunciators and may be used
as a public address system throughout the facility.

During some shifts, the terminal and the refinery are manned by
only two people each,  making it difficult to effectively respond
to a spill into Puget  Sound.   There  is no cross-training between
employees of the refinery and  the terminal,  particularly in the
area of emergency response, and waiting for the  arrival of
trained, off-shift employees could cause response delays.
                          464

-------
•     The facility fire response team has been  trained  at  the  oil  fire
      training school-in Reno, Nevada, and  during  a  fire is  under  the
      command of refinery or terminal manager,  or  his designee.

Community and Facility Emergency Response Planning Activities

•     The refinery manager and the terminal manager  were unfamiliar with
      the CMA Chemical Awareness and Emergency  Response  (CAER) program.

•     Off-site response assistance would be provided by the  Shoreline
      and Snohomish fire departments.

•     In the past, management has not regularly exercised  the emergency
      response plan and procedures with off-site response  agencies or
      conducted any cross-training programs.  An on-site response
      exercise was conducted in December 1990,  and a real-time exercise
      involving LEPC member agencies is planned for  1991.

Public Alert and Notification Procedures

•     While the MEMP emergency manual does set  forth guidelines for the
      notification of local agencies in the event  of a major upset or
      disaster, the manual does not address notifying the public in the
      areas immediately surrounding the facility.
Recommendations:

Facility Background Information

•     The facility should include earthquake planning considerations in
      any future construction projects.

Process Information

•     In order to prevent a serious fire in the warehouse where the
      five-gallon containers are stored, the facility should segregate
      the containers from other flammable materials, install drains or
      curbs for containment, reduce the number of containers stored in
      any one location within the warehouse, and install sprinklers and
      smoke detectors.

•     The facility should install oversized NFPA tank signs to prevent
      reduced visibility from impacting on the ability of off-site
      personnel, to respond effectively.

•     The facility should upgrade the instrumentation in the refinery
      control room as planned and ensure that process information is
      being clearly and effectively communicated to the operators.

• •    Valve numbers at the terminal and the refinery should be clearly
      marked on the valves.

                               '465

-------
Chemical Accident Prevention

•     Chevron should consider providing a  transition between  management
      changes in the future so that new managers  can become fully
      familiar with operations and emergency procedures.

•-    The refinery should implement a formal, comprehensive,  routine
      inspection and preventive maintenance program, which  includes all
      storage and transfer facilities, processes, and  instrumentation.

•     The facility should identify the correct procedures for  response
      to a pumping accident, including proper use of the air  ram, and
      train employees accordingly.

•     Chevron should upgrade lockout practices and lockout equipment
      availability to a standard consistent with  the lockout policy.

•     A formal preventive maintenance/calibration program should be
      implemented for the hydrocarbon sensors and the hydrocarbon sensor
      and valve for the effluent from the north separator should be
      installed as planned.

•     The facility should expand the terminal preventive maintenance
      tracking system to include at the very least instrumentation,
      backup diesel fire pumps, and spill response equipment.

•     Guard barriers and/or other physical security measures should be
      installed where not already provided to minimize the potential for
      a release as the result of a vehicle accident.

•     The audit team suggests that a comprehensive review of potential
      ignition sources near flammable liquid storage tanks would help
      reduce the chances of fire should a major leak occur.

•     Chevron should establish a more exact procedure to compare the
      amount of oil pumped from a vessel to the amount of oil  received
      in the tank to prevent a recurrence of the asphalt spill.

•     Means to prevent unauthorized adjustments or disconnections of
      alarms should be installed,  such as locking the alarm cabinet  or
      placing paper seals over alarm panel doors.

•     Chevron should consider installing high-level alarms on  the
      remaining terminal tanks.

•     Chevron should consider installing equipment that would  improve
      its ability to trap spills,  such as redundant hydrocarbon sensors
      or a pair of retention tanks downstream of the  north separator.

•     The system of concrete dikes and berms that isolate tanks ir.to
      subgroups within the main tank farm should be repaired immediately

-------
      -- new dikes should be  installed  and many  of  the  existing  dikes
      and berms should be raised to provide additional  containment.

•     Chevron should consider raising the height of the secondary
      containment dike or installing splash guards  near the  tanks
      immediately adjacent to Puget Sound.

•     The height of the culverts on the groundwater pumping  wells  should
      be raised to a height greater than that of the secondary
      containment dike to prevent contamination.

Accidental Release Incident Investigation

•     The audit team suggests that Chevron develop  procedures for
      reporting near misses.

Facility Emergency Preparedness and Planning Activities

•     Chevron should consider placing a boom around vessels whenever a
      transfer is in progress and conditions allow  in order  to trap
      spilled oil and exercise the spill response system.

•     The facility should undertake an evacuation exercise in the very
      near future to address concerns about the  evacuation of personnel
      in the administration building.

•     Chevron should conduct routinely scheduled emergency drills for
      operations and emergency response personnel.

•     The terminal should reposition the aluminum response boat to be
      available at all times and under all dock conditions, install
      ladders at all crane locations to facilitate  launching the
      response boats, install the proposed dock boat ramp  to allow boat
      launches in the event of a power failure,  and place  response boats
      on rollers when vessels are docked in front of boat  launch areas
      so they can be moved to nearby cranes.

•     Chevron should inspect, repair, or replace all fire  equipment and
      storage areas.

•     The steam smothering lines leading to the furnace should be more
      clearly labeled.

•     Chevron should consider installing flood lamps on the shoreline to
      aid in visually monitoring the waters during  the  night.

•     Due to the small size of operations at both the refinery and the
      terminal and the fact that they share fire and communications
      systems, the operators should be made familiar with  both
      operations through an overall response training program.
                                467

-------
      Community and Facility Emergency Response Planning Activities

      •     The facility should involve off-site responders in a series of
            monthly training exercises, and schedule a full-scale response
            exercise within the calendar year.

      •     The terminal and refinery managers should become participating
            members of the nearest CAER group and the facility should also
            become more involved in training activities with the LEPC.

      Public Alert and Notification Procedures

      •     The facility should design a notification and awareness program
            for neighbors using a steam whistle or other device capable of
            immediate local notification.
Audit Team Member Composition:

Name and Title
Affil.ation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise

Name and Title
Affiliation
Area of Responsibility
Expertise
Pat Lowery
US EPA Region 10
Team Leader
Emergency Management and Business Administration

Noah Myers
TAT, US EPA Region 10
Technical Reviewer
Chemical Engineer

David Schuchardt
TAT, US EPA Region 10
Technical Reviewer
Chemical Engineer

Jim Tagart
Southwest Snohomish County Emergency Services
Observer
LEPC Representative
Follow-up Activities:

      By the facility:

      By the Regional office:

      By State and local authorities:
Regional Contact:
Pat Lowery
                                      468

-------