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
------- |