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 checkints. 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 theoutdoor 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 ------- |