United States EPA- 600 /8- 87-040
Environmental Protection
.August 1987
'&EPA Research and
Development
TECHNICAL SUPPORT
TO THE SOUTH COAST AIR QUALITY
MANAGEMENT DISTRICT TOXIC CHEMICAL
ACCIDENTAL AIR RELEASES
Prepared for
Office of Air Quality Planning and Standards
and
EPA Region 9
Prepared by
Air and Energy Engineering Research
Laboratory
Research Triangle Park NC 27711
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RESEARCH REPORTING SERIES
Research reports of the Office of Research and Development, U.S. Environmental
Protection Agency, have been grouped into nine series. These nine broad cate-
gories were established to facilitate further development and application of
environmental technology. Elimination of traditional grouping was consciously
planned to foster technology transfer and a maximum interface in related fields.
The nine series are:
1. Environmental Health Effects Research
2. Environmental Protection Technology
3. Ecological Research
4. Environmental Monitoring
5. Socioeconomic Environmental Studies
6. Scientific and Technical Assessment Reports (STAR)
7. Interagency Energy-Environment Research and Development
8. "Special" Reports
9. Miscellaneous Reports
This report has been assigned to the SPECIAL REPORTS series. This series is
reserved for reports which are intended to meet the technical information needs
of specifically targeted user groups. Reports in this series include Problem Orient-
ed Reports. Research Application Reports, and Executive Summary Documents.
Typical of these reports include state-of-the-art analyses, technology assess-
ments, reports on the results of major research and development efforts, design
manuals, and user manuals.
EPA REVIEW NOTICE
This report has been reviewed by the U.S. Environmental Protection Agency, and
approved for publication. Approval does not signify that the contents necessarily
reflect the views and policy of the Agency, nor does mention of trade names or
commercial products constitute endorsement or recommendation for use.
This document is available to the public through the National Technical Informa-
tion Service, Springfield, Virginia 22161.
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EPA-600/8-87-040
August 1987
SUMMARY REPORT
TECHNICAL SUPPORT TO THE
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT
TOXIC CHEMICAL ACCIDENTAL AIR RELEASES
By:
D.S. Davis
G.B. DeWolf
Radian Corporation
Austin, Texas 78766
Contract No. 68-02-3889
Work Assignment 84
EPA Project Officer
T. Kelly Janes
Air and Energy Engineering Research Laboratory
Research Triangle Park, North Carolina 27711
Prepared for:
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
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ABSTRACT
The South Coast Air Quality Management District requested technical
support toward developing a regulatory approach for controlling potential
accidental air releases of toxic chemicals. This report provides some of the
technical input and describes other support efforts. These efforts included
preparation of the technical contents of an example draft rule applicable to
facilities using or storing seven specific toxic chemicals and technical
reference manuals concerning hazards and their control in such facilities.
ACKNOWLEDGEMENTS
This document was prepared under the overall guidance and direction of
T. Kelly Janes, Project Officer, with the active participation of Robert P.
Hangebrauck, William J. Rhodes, and Jane M. Crum, all of U.S. EPA. In
addition, other EPA personnel served as reviewers. Sponsorship and technical
support was also provided by Robert Antonopolis of the South Coast Air Quality
Management District of Southern California, and Michael Stenberg of the U.S.
EPA, Region 9. Radian Corporation principal contributors involved in
preparing the document were Graham E. Harris (Program Manager), Glenn B.
DeWolf (Project Director), Daniel S. Davis and Lynn L. Zimmerman.
Contributions were also provided by other staff members. Secretarial support
was provided by Roberta J. Brouwer and others. Special thanks are given to
the many other people, both in government and industry, who served on the
Technical Advisory Group and as peer reviewers.
ii
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TABLE OF CONTENTS
Section Page
ABSTRACT ii
1 INTRODUCTION 1
1.1 INITIATION AND PURPOSE OF THE STUDY 1
1.2 ROLES OF U.S. EPA, RADIAN CORPORATION, AND THE SCAQMD .... 2
1.3 BACKGROUND WORK BY THE SCAQMD 3
2 DESCRIPTION OF TECHNICAL SUPPORT EFFORT 5
2. 1 MAIN ELEMENTS 5
2.1.1 Planning Meetings 5
2.1.2 Preparation of the Prevention Reference Manuals. ... 5
2.1.3 Preparation of a Draft Rule 7
2.2 SCAQMD INPUTS 7
2.3 PREVENTION REFERENCE MANUALS 8
2.4 ROLE OF PREVENTION REFERENCE MANUALS IN SCAQMD RULEMAKING
AND INSPECTION ACTIVITIES " 9
3 TECHNICAL MATERIALS PROVIDED TO SCAQMD 12
3.1 DRAFT RULE 12
3.2 TECHNICAL INPUT TO RULE 13
EXHIBITS
A - SCAQMD - South Coast Air Basin Accidental Toxic Air
Emissions Study 15
B - Example of Typical Existing SCAQMD Air Rule 105
C - Summary of Inventory Survey of Designated Chemicals in
SCAQMD 113
D - Example Draft Rule 122
E - Preliminary Tables of Contents for Prevention Reference
Manuals 146
ill
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FIGURES
Page
2-1 Overview of prevention reference manuals 6
2-2 Role of prevention reference manuals in potential SCAQMD regulatory
process 11
IV
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SECTION 1
INTRODUCTION
1.1 INITIATION AND PURPOSE OF THE STUDY
Concern for accidental toxic chemical air releases, and especially a
Bhopal type incident, has prompted considerable interest in the prevention and
mitigation of such releases. In January of 1985, the Governing Board of the
South Coast Air Quality Management District directed a study to be undertaken
concerning prevention and preparedness for a large toxic chemical air release
in the South Coast Air Basin of Southern California. The two main objectives
of the study were to assess: 1) the ability of the chemical industry to avoid
a chemical disaster of Bhopal proportions, and 2) the ability of the four
counties comprising the district (Los Angeles, Orange, San Bernandino, and
Riverside) to respond effectively if such a disaster occurred. The resultant
study was the South Coast Air Basin Accidental Toxic Air Emissions Study,
issued in September, 1985 (Exhibit A).
As a result of this study, the SCAQMD decided to develop a rule for
facilities that use or store any of several toxic chemicals above certain
quantities. The purpose of the rule would be to ensure that appropriate
technical, administrative, and operational controls existed at designated
facilities to minimize the potential for accidental toxic chemical air re-
leases. SCAQMD approached Region 9 of the U.S. Environmental Protection
Agency (EPA) for technical support.
Region 9 decided to provide technical support to SCAQMD under Section 105
State Grant Funds for the development of their rule. In their proposal, the
SCAQMD identified a task to develop "implementation guidelines" which appeared
to be similar to a series of Prevention Reference Manuals (PRM) that had been
proposed for development by the U.S. EPA. EPA felt that support to the States
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in demonstration projects, such as a Region 6 inspection project and Region
2's interest in an inspector's training course, would help EPA to increase its
own expertise. The EPA Office of Research and Development (ORD) met with
Region 9 and SCAQMD and agreed to proceed with a technical support project to
SCAQMD with funding from Region 9 for technical input into the Rule and the
PRMs and from ORD for the PRMs. The Air and Energy Engineering Research
Laboratory (AEERL) was designated as the ORD project monitor, and subsequently
contracted with Radian Corporation to do the work on the PRMs and simultane-
ously provide technical information to support the rule development. SCAQMD
decided that the rule would be similar in format and structure to their
existing air rules, an example of which is shown in Exhibit B. SCAQMD also
felt that the PRMs would be the type of technical support the rule needed,
both as a guide to industry and to the regulators and inspectors in taking
measures to reduce the probability and severity of accidental air releases of
toxic chemicals. A primary technical approach favored by the SCAQMD for
release prevention was redundancy.
1.2 ROLES OF U.S. EPA, RADIAN CORPORATION, AND THE SCAQMD
Specific roles were clearly defined for the U.S. EPA, Radian Corporation,
and the SCAQMD in this effort:
EPA was to provide technical assistance in areas identi-
fied by the SCAQMD where the SCAQMD felt they needed
support. This technical information was to be supplied to
the SCAQMD in the form of a preliminary draft of a rule.
as well as various PRMs when they were available.
The SCAQMD was to write a final draft of the rule, conduct
reviews, and follow through on their usual rulemaking
procedures. At that stage further use of EPA input is
optional.
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Radian Corporation was charged with preparing the PRMs as
well as providing an example draft of how a rule might be
configured based on the technical requirements of release
prevention through the technical information developed in
the PRMs.
These three groups were to work together with a Technical Advisory Group
(TAG) to meet the program's objectives. The TAG was to provide technical
expertise and industrial experience as well as assure the technical quality of
EPA's input to SCAQMD. Members represented industry, the States, associa-
tions, and representatives from other parts of EPA.
A fundamental principle of this program is that the rule being developed
is at the initiative and overall direction of the SCAQMD and does not repre-
sent any official policy of the EPA and is not to be perceived as EPA rec-
ommendations. There is no intent that the example draft rule developed in
this program is necessarily to be used by others. Reportable quantities of
chemicals in the draft rule have no relation to other requirements such as EPA
reportable quantities, and nothing in the rule is to take the place of any
existing or future EPA requirements, should there be any.
1.3 BACKGROUND WORK BY THE SCAQMD
In conjunction with SCAQMD study mentioned previously, a formal survey
was conducted by the SCAQMD of facilities in the District. This survey
identified facilities and their inventories of specific chemicals on the
SCAQMD list of chemicals of concern which was presented in the SCAQMD study.
A summary of the findings of the survey in terms of types of facilities and
reported inventories is presented in Exhibit C for seven specific chemicals
that, as a result of the study and survey, the SCAQMD decided might be subject
to the rule. These seven chemicals are:
chlorine (CAS NO. 7782-50-5),
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hydrogen fluoride (CAS No. 7664-39-3).
hydrogen cyanide (CAS No. 74-90-8).
ammonia (CAS No. 7664-41-7).
carbon tetrachloride (CAS No. 56-23-5).
sulfur dioxide (CAS No. 7446-09-5), and
chloropicrin (CAS No. 76-06-2).
The technical effort described in the next section focused on these seven
chemicals.
SCAQMD identified its requrements in the following general areas:
format for the rule.
the specific chemicals covered,
types of facilities,
procedures,
applicability.
registration,
hazard identification,
control plan,
risk reduction plan,
recordkeeping.
emphasis on redundancy or backup control systems, and
technical aids for hazard identification and evaluation
for permitting and inspections.
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SECTION 2
DESCRIPTION OF TECHNICAL SUPPORT EFFORT
2.1 MAIN ELEMENTS
2.1.1 Planning Meetings
The Contractor and EPA met several times with the SCAQMD to plan the
overall approach for providing technical support to the development of the
rule and to define its scope. These meetings discussed issues such as appli-
cability and the definition of a designated facility, defining threshold
quantities to trigger applicability, and the technical areas, which would be
addressed by the rule, within a designated facility. The meetings also
defined the mechanisms for transmitting information between the Contractor,
EPA, the SCAQMD, and the TAG. Some meetings were also held with the TAG for
review and comment on the program's progress.
2.1.2 Preparation of the Prevention Reference Manuals
After initiation of the technical effort, the next step was gathering
technical information on chemical release hazards and their controls for
industrial facilities of the type handling the seven designated chemicals in
the SCAQMD. This information was to be incorporated into the PRMs that would
provide technical guidance for both regulatory and industrial personnel on
hazard identification, evaluation, and remediation. This information would be
the basis for specifying appropriate control equipment, procedures, and
practices that could be incorporated into a rule. An overview of the three
manuals is shown in Figure 2-1. The structure and contents of the PRMs are
discussed in more detail in Section 2.3 of this report.
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Prevention
Reference
Manuals
o Introduction to
Accidental Releases of
Chemical Air Toxics
o Methods for
Identification of Hazards
o Guide to Evaluation of
Plants/Processes
o Decision Analysis on
Prevention Options
o Guide to Other References
o Overview of Primary
Hazards
o Technical Reference for
Process Hazards
o Approaches to Reduce
Hazards
o Good practices and control
approaches
Control
Techniques
Manual
o Applicability
o Description of Controls
o Status of Technical
Development
o Performance and
Reliability
o Advantages and
Disadvantages
o Resultant Environmental
Concerns
o Costs
Figure 2-1. Overview of prevention reference manuals,
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2.1.3 Preparation of a Draft Rule
In addition to compiling and analyzing information for the SCAQMD, the
technical support effort also involved preparation of an example draft rule to
illustrate how the technical information developed in the PRM effort could be
applied in a regulatory context specific to the SCAQMD. This draft could be
used by the SCAQMD to develop a complete rule for actual application in the
District. Various versions of the draft rule were prepared, reviewed in
meetings between the Contractor, EPA, SCAQMD, and the TAG, and revised into
the form outlined in Section 3.1 and presented in Exhibit D of this report.
2.2 SCAQMD INPUTS
Specific technical input to support this effort was obtained from the
SCAQMD. These technical inputs included:
Results of the SCAQMD background study discussed earlier
(Exhibit A),
The scope, format, overall structure used for other air
rules developed by the district, (Exhibit B),
Results of the SCAQMD facilities survey conducted in
conjunction with the study (Exhibit C), and
The scope and constraints of an accidental release rule
based on the District's jurisdiction (e.g., highway
transportation is outside the jurisdiction).
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Basic elements to be addressed by the rule included:
applicability,
administrative requirements, and
technical requirements.
These form the basis of the outline presented in Section 3.1 of this report.
2.3 PREVENTION REFERENCE MANUALS
Preparation of the Prevention Reference Manuals was a key component of
the technical effort. The PRMs consisted of three basic document efforts:
Prevention Reference Manual - User's Guide,
Prevention Reference Manuals - Chemical Specific
Information, and
Prevention Reference Manual - Control Technologies
The purpose of the User's Guide is to provide an introduction to the
overall area of accidental chemical releases, provide technical reference
methods for identification of hazards and general evaluation of control
techniques, and serve as a guide to available information in more detailed
manuals and the general technical literature. The scope of the User's Guide
is to provide historical background and an overview of accidental chemical
releases, an introduction to formal methods of hazard identification and
evaluation, an overview of the principles of control, and a guide for inspec-
tions of a chemical process facility.
Individual chemical specific information manuals are being prepared for
each of the seven chemicals listed in Section 1. The purpose of these manuals
is to provide guidance for a process hazard review of facilities using or
storing these chemicals in the SCAQMD. The manuals are to provide sufficient
summary information to enable the reader to identify primary hazards and
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corresponding control technologies specific to each chemical as it is used and
stored in the SCAQMD.
The third document is the Prevention Reference Manual - Control Technolo-
gies. This two-volume manual discusses specific technologies for the preven-
tion and mitigation of accidental chemical releases. The approach used
addresses two fundamental elements of risk reduction: prevention and protec-
tion. Within the realm of prevention three areas addressed are process
design, physical plant design, and procedures and practices. This volume
details primary hazards addressed by control technologies or practices in each
of these three areas of prevention. It also details technological options for
protection from a release once primary containment has failed. The second
volume, planned for the future, will extend this work to include mitigation
technologies which deal directly with reducing the consequences of an
accidental release that has already occurred.
2.4 ROLE OF PREVENTION REFERENCE MANUALS IN SCAQMD RULEMAKING AND INSPECTION
ACTIVITIES
Each PRM has a distinct role in the overall rulemaking and inspection
activities of the SCAQMD. Some of these activities can be inferred from the
preceding discussions. Overall, the manuals provide a basis for establishing
an inspection program and for training and guiding inspectors, provide techni-
cal material to aid in the evaluation of control plans for release prevention
or risk reduction submitted to the district under the rule, and also aid
industry in implementing, developing, and upgrading internal company programs
for release prevention.
The manuals provide the technical basis for:
Setting priorities for selecting facilities for inspec-
tions based on types of chemicals and operations at these
facilities,
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Defining what regulatory personnel should be looking for
in inspecting facilities and in reviewing emergency or
control plans for facilities,
Defining what a company should be addressing in design,
construction, and operation for minimizing the potential
for accidental releases.
Figure 2-2 illustrates the role of the PRMs in a potential SCAQMD regulatory
process. At the time this report is being issued, the draft manuals are still
in progress.
10
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DESIGNATED
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i.'- YF4 k . CflMTDni
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Figure 2-2. Role of prevention reference manuals in potential SCAQMD regulatory process.
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SECTION 3
TECHNICAL MATERIALS PROVIDED TO SCAQMD
The technical materials provided to the SCAQMD as a result of this
technical effort were primarily:
An initial outline of a draft rule for review and comment,
An example draft rule, and
Technical input to the rule, both directly in the draft
and in the Prevention Reference Manuals.
3.1 DRAFT RULE
The example rule demonstrated how the technology and practices of release
«
prevention could be incorporated into the rule format commonly used by the
SCAQMD in other areas. Major areas addressed by the rule include:
Purpose
Applicability
Definitions
Registration
Accidental Release Control Plan
Plan Requirements
Variances
Action on Plans and Variances
Risk Reduction Plan
Control Considerations
Recordkeeping and Reporting
Recordkeeping
Reportable Releases
Compliance Schedule
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Plan Amendments Approval, Transferability, and Plant
Closure
Plan Amendments
Transferability and Plant Closure
Severability
The details of these areas are contained in the example draft rule
presented in Exhibit D.
3.2 TECHNICAL INPUT TO THE RULE
Primary direct technical input to the rule included technical defini-
tions, the concepts of accidental release control plans and risk
reduction plans, and a summary of specific chemical process or storage facil-
ity areas and hazard control considerations which could be addressed in these
plans. This input was incorporated as an exhibit contained in the draft rule
and is included with the draft rule in Exhibit D of this report.
An outline is:
Siting and Layout Controls
Siting
Layout
Process Controls
Chemical Processes
Chemical Storage
Equipment Controls
Foundations
Structural Steel
Vessels
Pressure and Vacuum Relief Systems
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Pumps and Compressors
Heaters and Furnaces
Heat Exchangers
Turbines
Electrical Equipment
Instrumentation
Piping
Emissions Control Devices
Fire Protection and Safety
Operational Controls
Chemical Compatibility
Materials Handling
Waste Management Practices
Management Controls
Operator Practices and Training
Fire Protection and Prevention
Contingency Plan and Emergency Response Coordination
Maintenance
Additional technical input included development of a suggested registra-
tion form incorporated as part of the draft rule.
Another part of this technical input for rule development was in the form
of the PRMs discussed previously. Preliminary tables of contents for these
manuals, which are still in progress, are presented in Exhibit E.
14
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EXHIBIT A
SOUTH COAST AIR BASIN
ACCIDENTAL TOXIC AIR
EMISSIONS STUDY
15
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EXHIBIT A
SOUTH COAST AIR BASIN
ACCIDENTAL TOXIC AIR
EMISSIONS STUDY
Eugene F. Calafato, consultant (crisis management)
Robert Antonoplis, Engineering Division, SCAQMD
Dr. Ike Yen, consultant (safety systems)
September 1985
16
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TABLE OF CONTENTS
PART I
INDUSTRY SAFETY
Introduction 18
Parameters and Approach 19
Definition of Terms 20
Bhopal Analysis 21
Survey Findings 24
Chemical Inventory 24
Proximity to Population 26
Safety 26
Earthquake 28
Sabotage 28
Human Error 23
Regulation of Toxic Substances 29
Comparison of SCAB Environment to Bhopal 31
Liability Insurance 32
Industry Initiatives 33
Transport of Hazardous Materials 35
Conclusions 36
Recommendations 37
PART II
COMMUNITY PREPAREDNESS
Introduction 41
Approach 42
Preparedness Climate and Perceptions 42
Community Disaster Planning ... 43
Vertical Linkages 46
Specialized/Compartmentalized Planning 46
Communication 43
Warning Systems 49
Emergency Operating Center 52
Emergency Broadcast System 52
Evacuation 54
Emergency Medical System 56
Assessment by Response Scenario 58
Integrated Planning 60
Findings 61
Recommendations 61
Conclusion 65
References 66
Acknowledgements 67
Appendices A through J 68-104
17
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PARTI
INDUSTRY SAFETY
INTRODUCTION
Early in the morning of December 3,1984, an accidental release of methyl
isocyanate (MIC), a toxic gas, occurred in Bhopal, India, resulting in the
deaths of more than 2,500 people. This incident focused world attention on
the potential for calamity from the accidental release of toxic emissions into
the atmosphere.
On January 4,1982, the Governing Board of the South Coast Air Quality
Management District, concerned about* the possibility of a Bhopal-type
disaster occurring in the South Coast Air Basin (SCAB), directed that a study
be undertaken to assess: (a) the ability of the petrochemical industry to avoid
a chemical disaster of Bhopal proportions; and (b) the ability of the four
counties (Los Angeles, Orange, Riverside and San Bernardino) to respond, in
a timely and effective manner, if such a disaster did occur.
Three principals were selected by the SCAQMD Executive Officer to conduct
the study. They are: Mr. Robert Antonoplis, Engineering Division; Mr.
Eugene Calafato, consultant (crisis management); and Dr. Ike Yen,
consultant (safety systems). In addition, the resources of the SCAQMD staff
were made available on an as-needed basis. The study was a six-month effort
with a final report due by July 15,1985.
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PARTI
Part I of this study addresses the ability of the petrochemical industry in the
SCAB to avoid a chemical disaster of Bhopal proportions.
PARAMETERS AND APPROACH
1. This aspect of the study addressed itself to accidental toxic air emissions
from stationary sites that have the potential of resulting in widespread injury
and damage, i.e., casualties in the thousands and property damage in the
millions. Manufacturing, processing and storage facilities, and waste
treatment storage and disposal sites were included in the survey.
2. The accidental release of toxic materials during transport, whether by ship,
truck or railcar, was not examined as part of this study. However, since there
is such direct relevance between community preparedness and the threat
posed by the transport of hazardous materials interstate and intrastate, some
comments and observations are included herein with regard to mobile
systems.
3. After consultation with the Office of Emergency Services (OES) in
Sacramento, it was decided to focus the study primarily on approximately
100 chemicals listed in a publication on chemical hazards issued by the
National Institute for Occupational Safety and by the Occupational Safety
and Health Administration. These chemicals have an immediately dangerous
to life and health (IDLH) value of 2,000 ppm or less, and a vapor pressure of
10 mm Hg or higher at ambient conditions. This list was supplemented from
three other sources: (a) the Department of Transportation (DOT) Emergency
Response Guidebook listing those chemicals that, if spilled, are likely to result
in evacuation; (b) the DOT Poisons A List; and (c) the legal carcinogens that
are gaseous or have a vapor pressure of approximately 10 mm Hg or higher
under ambient conditions (Attachment 1).
4. A mail survey was conducted of 197 companies in the SCAB. The
questionnaire requested detailed data regarding types and quantities of
hazardous chemicals processed or stored and concentrated exclusively on
safety practices, procedures and technology. The companies were selected for
participation based on SCAQMD records and with substantial input from
the District staff. The criteria for selection included company type, size.
19
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location, product and other factors that would constitute a representative
sampling of the petrochemical industry. Attachments 2 and 3 provide a listing
of these companies, and a copy of the survey questionnaire with the District
cover letter.
5. Information obtained from the mail survey was reviewed to determine the
types and quantities of toxic substances stored, processed, or otherwise used
by the various companies. Based on this, the companies were ranked
according to the following index:
Quantity of Toxic Substance (Ibs)
EDLH Value of Substance (ppm)
A total of nineteen companies (Attachment 4) were then selected for on-site
audit based on the inventory of chemicals (type and quantity), the type of
industry, size of operation, location, inputs from local fire department
personnel and the subjective judgment of the project staff.
The on-site audits focused on the procedures and equipment used for the
handling, storage, and use of the toxic substances; the overall safety policies
and procedures of the companies; the attitude of management toward safety
and a visual inspection of those areas of the plant where toxic materials are
stored or processed. The latter included discussion with personnel responsible
for the processing operation. The checklist for these audits is included as
(Attachment 5).
6. In parallel to the surveys, an analysis was made of the Bhopal incident in
order to establish a basis for assessing the degree to which the SCAB may be
at risk in terms of an incident of similar gravity.
DEFINITION OF TERMS
Risk AsMsunent
Historically, the absence of an adequate data base has brought into
controversy the exactness and limitations of risk analysis. In regard to this
study, it is noted at the outset that chemical hazards pose an inherent
uncertainty in their identification and in estimating the probability and the
consequence of events. It is not uncommon that for some risks of very low
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probability there may be uncertainty by a factor of ten. However, even a
rough estimate may draw attention to hazards which may not previously have
been recognized or mistakenly dismissed as trivial. While acknowledging this
lack of preciseness, due in great part to imperfect and incomplete
technical/scientific information, we have proceeded on the assumption that
decisions impacting safety must nevertheless be made, and measures must be
taken, even when the lack of an experience factor or comprehensive data base
leave some margin for discussion and dissent It is further noted that risk
assessment, taken in its broadest sense, would also consider factors, such as
public attitude, which not only vary with time, but often rapidly.
Whereas risk assessment is basically an analytical process, firmly based on
scientific consideration, it inevitably requires judgments to be made when the
available information is incomplete or necessarily subject to interpretation.
For the purposes of this report, there has been some quantification of risk, but
the findings are also based on qualitative judgments. Certain value judgments
have been made regarding the acceptability of risk evaluated in terms of cost
and other factors associated with control and safety.
Risk Acceptability
Here again, different interpretations are taken of what acceptable or
unacceptable risk really means. For purposes of this report, it is noted that
there is no simple relationship between the acceptance of risk and its
detriment, or indeed between acceptance and acceptability. The fact that a
risk is accepted is by no means a guarantee of its acceptability. In addition, the
acceptability of the risk of a rare but serious event, i.e., a major chemical
disaster, may be dramatically altered if the reality of the hazard is
demonstrated by the occurrence of such an event, even if the occurrence
confirms the realism of the previous estimate of the risk. We do not speak of
risk as acceptable or unacceptable in isolation, but only in combination with
the costs and benefits that are attendant to that risk. Considered in isolation,
no risk is acceptable.
BHOPAL ANALYSIS
Background
Due to litigation currently in progress, definitive information on certain
aspects of the Bhopal incident remains, at least publicly, unknown. The
following review and analysis is based on the Union Carbide Corporation
Bhopal Methyl Isocyanate Incident Report dated March 198S and on a series
of investigative reports published in the New York Times.
21
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Pint, some background considerations that bear on the Bhopal incident.
Western technology came to Bhopal, but not necessarily the infrastructure for
that technology. Although positive evidence has not been surfaced in this
regard, there are strong indications of deficiencies such as the non-availability
of competent personnel, lack of training of plant personnel, and inadequate
upkeep and maintenance of the operating equipment and the backup safety
systems. Workers, operating by rote, may not have been aware of the
consequences of their actions and inactions. Industrial countries exhibit a
sense of urgency with regard to safety problems and the attention given to
worst-case possibilities is relatively routine. Not so in most developing
countries where machinery often becomes quickly outdated, availability of
spare parts is limited, and maintenance is, at best, marginal. Another factor in
Bhopal is that the population grew rapidly and without zoning laws. No
buffers were established around high risk factories, notwithstanding the
attendant danger to overcrowded areas.
An important factor impacting the Bhopal incident is the lack of emphasis on
preventive maintenance. Dr. Shrivastava, Assistant Professor of Manage-
ment at the NYU Graduate School of Business Administration, and a native
of Bhopal, noted that just because the technology arrives on the premises of a
subsidiary doesn't mean that it is transferred and assimilated into the
workforce as a whole. Part of the transfer is the consideration given to
operating errors, design flaws, maintenance failures, training deficiencies,
and economy measures that combine to endanger safety. All these factors are
far more likely to occur in an environment where there has not been a
preconceived orientation toward safety at the grass-roots level.
Methyl Isocyuute Release
Union Carbide India, Ltd., operated an insecticide plant in Bhopal, India.
Methyl Isocyanate (MIC) was used as an intermediate in the insecticide
manufacturing process. It was stored in two partially buried 15,000 gallon
tanks. A third 15,000 gallon spare tank was available for emergency storage or
for temporarily storing "off-specification" MIC. The storage tanks were
equipped with a refrigeration system to hold the MIC temperature at 0°C. In
addition, there were a vent gas scrubber and a flare tower to absorb or burn
any gases vented from the MIC tanks.
Late in the evening of December 2,1984, MIC odors were reported in the area.
An earlier test had shown that the MIC storage tank that eventually leaked
could not hold pressure. Later, it was also noted that the pressure in the tank
rose from 2 psi to 10 psi during a 40-minute period. Notwithstanding these
indications of possible trouble, no remedial action was taken.
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Later in this report a comparison will be made between the safety assessment
of the petrochemical industry in the South Coast Air Basin and the Union
Carbide Bhopal incident.
At 12:13 a.m. on December 3, the field operator reported a release of MIC.
Apparently, there was an effort to start the vent gas scrubber, to cool the MIC
tanks, and knock down the gases by directing water at the MIC leak. The
effect and duration of these remedial actions are unknown. Union Carbide
India Ltd. reported that the safety vent valve reseated itself sometime between
1:30 a.m. and 2:30 a.m. It has been estimated that a maximum of 90,000 Ibs. of
MIC may have been released.
Factors Impactful the Release:
A review of the reports on the Bhopal incident indicates that it occurred due
to a confluence of events and circumstances:
1. Disregard of Safety System Indicators
Apparently, the plant continued its operation in spite of the fact that the
refrigeration system, the vent gas scrubber, and the vent gas flare tower were
out of commission. (Several hours before the massive leak, there were
indications of malfunction of the equipment. No corrective action was taken.)
2. MIC Storage
The MIC was stored in large tanks near densely populated areas. Also, the
span tank was being used for the temporary storage of "off-specification'*
MIC, and thus it was unavailable for transfer of MIC from the leaking tank.
3. In-Plant Response
After the massive leak occurred, the plant response was poorly coordinated.
It is not clear that the plant had an emergency plan or that any practice drills
had been held simulating response to a MIC leak.
4. Community Response
Communication between the plant and the community was poor. It is not
known how the community was notified or how it responded during the
critical hours after the leak was first discovered.
5. Medical Response
There was confusion regarding the determination of appropriate treatment of
the exposed victims.
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6. Time
The leak occurred around midnight when the community was asleep.
7. Weather
The weather was reported as brisk, temperature was 57° F and the wind was
from the northwest blowing toward a densely populated area.
This confluence of events resulting from human errors, equipment failures,
time of day, and meteorological conditions led to a worst-case scenario and
casualties into the thousands.
SURVEY FINDINGS
Chemical Inventory
Based on the survey data provided by 197 petrochemical companies, a list of
toxic chemicals was compiled which are present in the SCAB in sufficient
quantities to potentially cause a major incident if accidentally released into
the atmosphere under certain conditions. These are: chlorine, hydrogen
fluoride, hydrogen chloride, anhydrous ammonia, chloropicrin, gasoline lead
additive, vinyl chloride, and benzene.
1. Chlorine
This is the most prevalent toxic chemical present in the SCAB. It is used for
water disinfection and the manufacture of many different chemicals including
household bleach and detergents. The maximum amount found stored at one
location was 540 tons; the maximum stored in one container was 90 tons.
2. Hydrogen Fluoride
This chemical is used in the manufacture of refrigerants and the production of
gasoline. It is transported to the SCAB by railroad or tank trucks, and then it
is transferred to large on-site storage tanks with capacities of up to 22,000
gallons.
These tanks are usually elevated ten feet or more above ground level to
prevent vehicles from accidentally damaging the tanks. Also, the tank area is
diked to contain any spills. Some tanks are equipped with water sprays and
others have fire monitors in their proximity so that water can be used to
knock down any leaking gases. One user has taken the added precaution of
dedicating one spare tank as backup for draining the hydrogen fluoride in
case of leaks in the main storage tank. This type of redundancy is not the rule
today, however, it reflects a standard that other companies should emulate.
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3. Hydrogen Chloride
This chemical, usually present as a 31 percent water solution, is used in many
chemical manufacturing processes, and it is also a by-product of many
processes using chlorine.
Hydrogen chloride solutions are generally stored in large tanks of up to
100,000 gallon capacity. These tanks are always diked to catch any spills and
some are further protected by foam sprays or water sprays to prevent
vaporization of the hydrogen chloride in case of a leak.
4. Anhydrous Ammonia
Anhydrous ammonia is used in many chemical processes and is also a
fertilizer. It is usually stored in liquid form in large tanks of up to 22,000
gallon capacity. As a rule, these tanks are protected in the same manner as the
hydrogen fluoride storage tanks, i.e., elevated, diked, and with water sprays
or fire monitors to knock down leaked gases.
5. Chloropicrin
This chemical, used as a fumigant, is the only toxic chemical of special
significance in this study that is manufactured in the SCAB. It has a relatively
low IDLH value of 4 ppm and a vapor pressure of about 20 mm Hg under
ambient conditions. The chloropicrin located in the SCAB is stored in two
32,000 Ib. holding tanks and in many DOT approved containers at the
manufacturing plant.
6. Gasoline Lead Additive
This is a chemical mixture containing tetraethyl lead, tetramethyl lead,
ethylene dibromide, and other chemicals. It is used as an additive in gasoline
to increase its octane rating.
Gasoline lead additive is present in significant quantities in gasoline
refineries. It is stored in tanks with capacities of up to 160,000 Ibs. The two
major manufacturers of this chemical mixture are the Du Pont and Ethyl
Corporations, and each imposes stringent handling and storage procedures.
7. Vinyl Chloride and Benzene
Vinyl chloride is used in the making of PVC plastics. It is transported to the
SCAB in railroad tank cars and is then transferred to large storage tanks. The
largest storage tank in the SCAB has a capacity of 6,000,000 Ibs.
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Benzene is used in the making of many chemicals. It arrives in the SCAB by
sea and is stored in a 1,000,000 gallon storage tank. From here it is then
transported by tank trucks to various locations.
Both chemical compounds have relatively high IDLH values but are classified
as carcinogens. In the event of a major release, the immediate death toll may
not be high, but the long-term effect of such exposure is debatable.
8. Bromine, Phosgene, Phosphorous
These additional chemicals merit mention. Bromine and phosgene, used in
the manufacture of pesticides and specialty chemicals, would ordinarily
warrant inclusion in the above list due to their high toxicity. However, the
known inventory in the SCAB is of such small quantity as to effectively rule
out the possibility of a Bhopal-type disaster. Phosphorus is both toxic and
combustible and is used to make sodium tripolyphosphate, an ingredient
often used in detergents. Although the inventory is substantial, its toxicity is
mitigated by the fact that it spontaneously combusts when it comes in contact
with air. Whereas phosphorous oxide reacts with water to form phosphoric
acid, the latter, although a strong and corrosive acid, is aot toxic.
The aforementioned listing of chemicals is not all-inclusive in terms of those
that pose a potential threat to the basin. It reflects an inventory keyed to 197
companies that, of themselves, are a representative sampling of the
petrochemical industry located in this basin.
Proximity to Population
The industry phase of this study focused primarily on those areas of the
SCAB that have the highest percentage of hazardous materials processed or
stored in proximity to populated areas. Hence, most of the industry data was
drawn from Los Angeles and Orange counties. However, San Bernardino and
Riverside counties are rapidly inheriting many of the same disaster
preparedness problems as industry continues its move from the more
congested areas of the basin.
Safety
Information from the industry survey and the on-site audits indicates a wide
variance among companies in their respective safety policies, procedures and
practices, as well as in the safety attitudes reflected by management. As a rule,
the major corporations took a more systematic, comprehensive, and closely
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monitored approach toward employee safety training. This is reflected in the
regularity with which safety meetings are held, the agenda for these sessions,
the active participation of supervisors and top level management personnel,
and the quality of formal training given to the employees. Also there is, in
general, a more deliberate and positive approach taken toward developing a
dialogue with the outside community. An example is the Union Oil
Company's efforts at its Brea plant to foster a more comfortable relationship
with the City Council and with the community based on a freer exchange of
information.
This is not to say that none of the mid-size or small companies are moving in
these same directions. However, the survey generally indicates that the
smaller the company the less structure one will find in the safety program, and
the less attention being given to actively promoting better community
relations. There are, of course, always exceptionsand at both ends of the
spectrum. For example, at the Paramount facility of the Paramount
Petroleum Corporation, management is taking a major initiative, with
attendant costs, to develop ways of reaching out to the local community in an
effort to enhance its relationships. In this case, the limited number of plant
personnel (approximately 142 employees) has not been a deterrent to forward
thinking. Conversely, some of the major corporations which continue to
pollute the air through small, periodic emissions, suggest by this behavior a
safety program that may be more cosmetic than effective. And certainly there
are some major corporations which continue to adhere closely to a policy of
almost total insulation from community interactionuntil a problem actually
surfaces.
It is also a fact that the size and financial resources of a company often will
dictate the amount of redundancy found in mechanical safety systems, even in
cases where additional systems may be virtually a necessity. In the latter
instances it is not unusual for companies to rationalize that the lack of any
serious safety mishap in the past is justification for complacency regarding the
future. Yet, an objective assessment would strongly suggest that time does not
run in their favor. For example, one company, small at its local site but
medium-sized nationwide, with a poor safety record, and currently under
litigation with the EPA and DHS, has been storing dichlorobenzene in a tank
with no containing dikes, and using chlorine with almost complete
dependence on the safety systems that come with the railroad tank car. The
risk here, and in the case of other companies following either questionable
safety practices or maintaining marginal safety standards, is not of a Bhopal-
type disaster. However, there is the real and ever-present danger of serious
injury to plant personnel, with the potential for at least moderate adverse
impact on the immediate surrounding community.
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Earthquake
The likelihood and severity of toxic emissions caused by earthquake damage
to toxic substance containers cannot be accurately addressed in this report
due to insufficient relevant data.
We do know, however, the following: Since mid-1982, the Federal Emergency
Management Agency (FEMA) is on record with a finding that the probability
has doubled of an earthquake in California of 7.0 magnitude or greater, the
California state geologist reports that California has entered a period of
greater seismicity than experienced during the previous 25 years; some
authoritative sources state unequivocally that an earthquake of 8.0 to 8.5
magnitude is a virtual certainty within the next 20 years; and it is generally
conceded within industry and among preparedness officials that although
progress is being made, the SCAB is not today adequately prepared for a
catastrophic earthquake of the magnitude indicated above.
Our disaster preparedness study confirms that only the smallest percentage of
companies have included an earthquake contingency in their emergency
plans. They have placed total reliance on the local fire and police/ sheriff
departments. The details of this reliance are at best nebulous. A worst case,
though not unlikely, scenario postulates severe, simultaneous toxic chemical
emissions across a broad spectrum of plants. Given such a situation, today's
planning is almost totally inadequate and this would be reflected in the
execution of these plans.
Sabotage
Planning for this contingency among petrochemical companies in the basin is
virtually nonexistent. Total reliance is placed on state and federal authorities.
Although this report does not address the likelihood of such an occurrence, if
it should occur the potential for a major catastrophe is high.
Human Error
This factor will always be a consideration. However, due to the effectiveness
of company training programs, the degree of safety consciousness permeating
the workforce and the investment being made in mechanical safety systems,
the likelihood of human error resulting in a catastrophic occurrence of
Bhopal proportions is negligible.
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REGULATION OF TOXIC SUBSTANCES
Bob Griffith, who heads Orange County's hazardous material program, and
other authorities in this business, have repeatedly pointed out that one of the
anomalies of today's health and environmental regulations is the lack of an
infrastructure and the ambiguity of certain regulations which inhibit more
stringent control of toxic substances. Yet, once a toxic substance is declared a
waste, the control requirements are clearly spelled out and lead agency
responsibility is well-defined. However, if the toxic substance is not declared a
waste, it can be moved and handled with significantly fewer control
requirements. In a most incisive article dated 3 July 1985 (subject: Toxic Fires
Can Be Anywhere) Kim Murphy and Ronald B. Taylor of the L.A. Times
reinforced this and similar points. They note that the Uniform Fire Code and
the Uniform Building Code provide some protection, but often local
government and their fire departments do not have the manpower or
expertise to fully enforce toxic substance control requirements.
Murphy and Taylor surface certain other relevancies as well For instance,
there is a natural reluctance among enforcement agencies to become involved
with the manufacturing processes of private industry. Similarly, private
industry jealously protects these processes from outside scrutiny by shielding
them under the cloak of "proprietary interest." Both positions are under-
standable, but they also complicate regulation of toxic substances and
sometimes result in conditions of less than acceptable safety.
Recently, increased emphasis has been placed on the need to exercise more
control over toxic substances, both to protect the safety of emergency
response personnel and that of the general public. The key to this is
identifying the substances and knowing where they are located. Accordingly,
some local jurisdictions have enacted so-called "right-to-know" laws. This
reflects progress. However, enforcement of these laws has been made difficult
due to limited resources, both money and manpower. Nevertheless, the laws
remain an important tool without which effective emergency response will be
severely handicapped. (See Ref. #1).
Size of Containers
In terms of economy, it is often more economical to use a single large storage
tank than several smaller tanks. From the point of guarding against a large
catastrophic toxic release, multiple smaller tanks are by far preferable.
Toward this end, guidelines should be developed to limit the maximum size of
containers allowable for different toxic substances.
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Cradle-to-Grave Monitoring
The control of toxic waste is based on the use of a manifest system that tracks
the waste from the point of its generation to its final point of disposal.
Consideration should be given to developing a similar system for tracking and
control of toxic substances within the SCAB.
Coordination Amonf Agencies
At present there are innumerable agencies with jurisdiction over various
aspects of toxic substance control. Even assuming that each role can be
legitimized, better liaison and communication among this team of players is
imperative. (More about this will be said in Section 2 under Community
Preparedness.)
Precautions During Abnormal Periods
It was noted during the survey that accident rates sometimes increase during
periods of corporate stress. Regulatory agencies should consider this and
exercise particularly close scrutiny over companies being operated under the
provisions of Chapter 11 or during the early periods of a plant strike.
Facility Retrofit
In recent yean, a number of chemical plant disasters have resulted from
phenomena where a certain set of conditions or sequence of events occurred
for the first time, even though the process had been in use successfully and
safely for many years. In some of these instances the problem, directly or
indirectly, was one of an aging chemical producing or consuming plant
operating with few, if any, mechanical safety systems. Many of these plants
will be in use for decades to come. The price of remaining alert to the
improvement of accident prevention features, safety techniques and
safeguards may, in some instances, require expenditures that will adversely
impact the company's competitiveness in the marketplace. It is unrealistic to
anticipate, in all instances, initiatives by management that result in burden-
some expenditures, unless the retrofitting of designated facilities is mandated
by law. This would require not only the passage of legislation, but also further
appropriations to fund the resources that will be needed to make enforcement
practical
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COMPARISON OF SCAB ENVIRONMENT TO BHOPAL
There is a high degree of safety consciousness among industry in the SCAB.
Even in those companies where we have noted considerable room for
improvement in safety practices, attitudes, procedures and safety precautions
still rate very favorably when compared to the conditions that reportedly led
to, and were operative during, the Bhopal crisis. Safety awareness in the
United States among the major petrochemical companies having the type of
chemical inventory most susceptible to large scale toxic emissions, did not
begin with Bhopal. Other pressures, over the years, have been driving the
companies toward better preparedness. Bhopal, however, accelerated the
pace. Protracted and costly litigation on environmental and safety matters,
spiralling insurance costs (to be discussed in more detail later in this report),
rising community indignation over real and perceived environmental
malpractices by industry, the exercise of ever-tightening legislative control
(federal, state and local), and the development of a more pronounced moral
consciousness toward safety matters in corporate board rooms had motivated
industry to take note and respond favorably long before world attention was
focused on Bhopal. Hence, most of the negative factors that were operative in
the'Bhopal incident are not relevant in the SCAB.
The equipment used in the SCAB for the storage and handling of toxic
substances is, generally, of excellent quality and well maintained, even though
the degree of redundancy in mechanical safety systems should be improved in
some instances.
One of the main factors contributing to the severity of the Bhopai disaster was
the exceptionally close proximity of highly populated areas to the plant site
where MIC was processed and stored. While population density may seem
high in the SCAB, and notwithstanding the location of certain housing tracts
close to our industrial sites, there is-no comparability to the situation that
prevailed in BhopaL
Furthermore, our local fire and police agencies know the hazards in their
jurisdictions. They are prepared, well trained, and highly motivated; in effect,
an exceptionally professional force able to respond, in most instances,
quickly and effectively. Given these capabilities, a localized incident would
not be permitted to degenerate into a Bhopal situation. Also, from a medical
standpoint, we would not have the same dearth of knowledge regarding
casualty treatment that existed in Bhopal.
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Based on the above, one can conclude with reasonable assurance that the
factors which contributed to the Bhopal disaster-including the confluence of
events and circumstancesare not factors in the SCAB. This by no means
rules out the possibility of periodic accidental toxic releases which may result
in some deaths and consequential damage. The aging of plants and equipment
(referred to later in this report) certainly heightens this possibility, but the
severity of such incidents would not approach Bhopal.
LIABILITY INSURANCE
An authoritative and insightful source recently discussed the insurance
industry's changing attitude toward underwriting industrial risks, and the
impact this is having on safety policies and practices in the petrochemical
community. It was noted that the Bhopal incident came after three of some of
the worst years, financially, in the history of the insurance industry. Insurers
are today taking a very hard look at what types of risks they will cover, how
much of that risk they will cover, and what they will charge for the coverage.
The Bhopal disaster is not the spark for this tough approach, but coinciding
as it does with the insurance industry's effort to raise itself out of a three-year
slump, it certainly has served to accelerate the trend.
The point was made that along with other industrial firms, chemical
companies are facing far more expensive and restrictive liability insurance
policies. Already there is evidence that rates are skyrocketing; knowledgeable
sources predict that in the relatively near term we may expect to see rate
increases of some 150 to 200 percent for lower-layer coverage, i.e., coverage
less than 550,000,000 per occurrence. For upper-layer insurance, the rate
increases will probably be greater.
Concurrently, insurance companies are taking advantage of the market
turnaround to change or eliminate many of the provisions of old policies that
have become onerous to them. Most significantly, they are pushing hard to
change commercial general liability policies from "basis of occurrence,"
under which coverage is provided for injury and damage occurring during the
policy period, to "claims made," under which coverage is provided if the claim
for damages is first made during the policy period. It is anticipated that by
January 1, 1986, restrictions of this type will have become prevalent in the
marketplace.
According to this source, the particular target of the changes in this
commercial general liability program, and one that especially affects the
chemical industry, is pollution coverage. Chemical companies are especially
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vulnerable to the occurrence issues arising under the existing policy
provisions because pollution-related damage or injury is often latent. There
can be many causes of injury and there may be no aggregate limit on the
coverage. Under the existing policy provisions, pollution liability is not
covered except when due to sudden and accidental emissions. This
terminology meant to exclude coverage for latent-injury causes, but was not
always interpreted that way in the courts. As a result, the new provisions
being promulgated in the insurance industry will eliminate coverage for most
pollution liability. Therefore, to insure against this liability, most chemical
companies will be forced to turn to environmental impairment liability
policies. The problem here is that such policies are not generally available.
Hence, the overall impact on the chemical producers is likely to be greater
resort to self-insurance.
All of this has heightened industry's attention to safety and accident
prevention. In-house recommendations to implement certain safety measures
are finding a more receptive ear. And this bodes well for the future. Here in
the basin, industry is commissioning more outside studies to assess its state of
safety and these include the application of relatively sophisticated analytic
techniques. From industry's standpoint this is an investment toward
preserving assets. From the vantage point of the community, better safety is
the product.
INDUSTRY INITIATIVES
Industry efforts in the preparedness area have not been limited to unilateral
actions directed by and affecting only individual corporations. The need for
cooperative efforts has been recognized and some segments of the industry
are moving ahead aggressively. The following examples are cited:
Chemical Manufacturers Association (CMA) is implementing two major
programs aimed at enhancing emergency response and improving the flow of
chemical hazard information to the public. They are the Community
Awareness and Emergency Response (CAER) and the National Chemical
Response and Information Center (NCRIQ.
The CAER is a coordinated effort to establish or revitalize chemical industry
emergency response plans and to integrate them with community plans. It
relies heavily on the chemical plant manager to act as a catalyst, i.e., to work
with emergency response officials of neighboring industries and local
community members. Additionally, the new program will make the hazard
information now available to chemical workers and emergency services also
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available to the public. It will help plants communicate with their
communities on chemical emergency plans; integrate them into overall
emergency networks; and assure that all steps in the critical planning process
are considered.
The intent of CAER is to individually tailor each community program to
meet its specific local needs. In general, the program would respond to these
types of questions: (1) Who are the key people concerned with community
emergency response and what are their roles?; (2) What are the risks, and how
great are they?; (3) What plans already exist?; (4) What changes are needed to
improve existing plans and to coordinate individual plans with the overall
community plan, thereby assuring a truly integrated effort in the event of an
emergency?; (5) Is the coordinated plan in writing?; (6) Are emergency
responden trained, and concerned community members educated in the
planning process?; (7) Are procedures established for periodic testing,
reviewing, and updating of the plan?; and (8) Is the public-at-large involved in
the total community emergency plan?.
The role of the NCRIC is to establish a clearing house for chemical emergency
help and hazard information, and for the training and response activities
associated with the use and distribution of chemical products. A key feature is
an expanded Chemical Transportation Emergency Center. Under this
program, the Center will provide information for all major chemical
emergencies, not just transportation-related accidents.
Another feature is implementation of CHEMNET, a mutual aid network of
company and "for-hire" emergency response teams whose purpose it is to
place chemical experts at the scene of a serious accident in a minimum
amount of time. It will also provide training for personnel, such as those in
police and fire departments, who usually respond first during a chemical
emergency.
A related service is provided by the Chemical Referral Center (CRC) for
nonemergency information regarding a chemical product. CRC will serve as a
referral agency, taking requests for information from the public on its "800"
telephone number; matching the inquiry to a company that can answer it; and
providing the caller with the company's name, address, and phone number.
Also, the American Institute of Chemical Engineers has established a Center
For Chemical Plant Safety to address four issues: hazardous evaluation
procedures, bulk storage and handling of toxic or reactive materials, plant
operating procedures, and safety training.
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All of this reflects a meaningful beginning and points in the right direction.
However, these programs represent initiatives (and reasonably so) by the
large corporations. Much will need to be done to get the attention,
participation, and commitment of the medium-size, and, particularly, the
small-size companies, who may not immediately recognize the need or the
potential benefits accruing to them. In addition, these efforts must become a
two-way street; Le., both the communities and the local preparedness
organizations must reach out and take similar initiatives if all this is to be
anything more than a knee-jerk reaction that quickly loses its priority and
long-term value.
TRANSPORT OF HAZARDOUS MATERIALS
At the beginning of this report it was noted that the transport of hazardous
materials by truck and railcar was not within the charter of this study.
However, in our discussions with both industry and community officials the
"mobile issue" repeatedly surfaced. This issue is briefly addressed due to its
general relevance to the overall preparedness aspect.
It is estimated that over a thousand new chemicals enter the United States'
commercial market annually; and, at any given time, 70,000 trucks carrying
hazardous materials are on the road. In addition, extensive railroad, barge,
pipeline and air cargo transportation is regularly undertaken in this country.
It is further estimated that 4 billion tons of hazardous materials are
transported annually in the United States, and this is probably a conservative
figure.
A recent article in The National Journal has pointed out that "under federal
packaging and marketing regulations MIC can be transported in railroad or
truck tank cars with minimum protectionsides of the containers simply
market flammable liquid'and yet remain in compliance. The liquid MIC
released in Bhopal vaporized and did not ignite; its toxicity, not fire, doing the
killing. In this country, Union Carbidethe only United States' manufacturer
of MIC-voluntarily ships the chemical in its own specially designed, double-
walled railcars. That is not unusual, Le., the big chemical companies generally
provide more protection for their dangerous cargoes than the law requires.
However, the small chemical companies and other shippers and carriers of
hazardous loads, as a rule, do no more than the regulations make them do."
The enforcement aspect is also a likely problem. It is estimated that there are
only 57 full-time federal inspectors for the 1,300,000 vehicles that carry
hazardous materials.
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The author, RocheUe Stanfield, makes the further point that despite the
heavy volume of hazardous cargo, communities have remained relatively
untroubled from transportation accidents involving hazardous material.
Also, of the thousands of incidents reported to the Transportation
Department each year, only 2 percent have been labeled severe, i.e., causing
death, injury, or requiring evacuation. However, the potential for catastrophe
is also clear. The author cites the derailment of 42 chemical cars in a 101-car
train near Livingston, Louisiana in 1982. This forced the evacuation of 2,000
people and caused extensive property damage, though no one was killed or
injured. In 1978, a derailment near Waverly, Tennessee killed 16 firefighters.
There were eight deaths, 138 injuries, and several million dollars in property
damage from a derailment near Youngstown, Florida in the same year. And
the business district of Crescent City, Illinois was leveled in the explosive
aftermath of a 1970 derailment. Given these incidents, we might ponder the
consequences if similar accidents were to happen in the SCAB. Although we
tend to read more about train wrecks than truck accidents, Ms. Stanfield
notes that 85 percent of the hazardous cargo incidents reported to the
Transportation Department occur on the highway, and all the deaths since
1981 from mobile sources have come on the road. One might attribute this to
the fact that where hazardous materials are concerned, trucks make by far the
most trips even though railroads carry the greater volume. (See Ref. #2.)
CONCLUSIONS
1. The Bhopal disaster was caused by a confluence of events and
circumstances virtually unique to the localized situation existing at that
location. The likelihood of a disaster of similar magnitude in the SCAB is
minimal. This study could not accurately assess the threat from either
earthquake or sabotage; however, both clearly pose the possibility of
catastrophic disaster, even exceeding Bhopal proportions.
2. Accidental toxic air emissions resulting in death and injury to personnel
within plant boundaries, and having adverse impact on adjacent com-
munities, (generally within a two-mile radius) are a distinct possibility. These
will be (hopefully) infrequent, without pattern, but an inevitable consequence
of having such vast quantities of highly toxic substances in an environment
where safety standards vary significantly; regulatory legislation has
loopholes; enforcement of existing legislation is hampered by budgetary
considerations; and population centers are located in such close proximity.
3. Emergency planning by industry is moving ahead at an accelerated pace,
particularly among the major corporations. However, much remains to be
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done, especially with regard to preparedness for earthquake and sabotage
contingencies. Also, closer coordination is imperative among industries in
geographic proximity to each other, and between industry and local agencies
charged with disaster preparedness responsibility.
4. Industry/ Community communication is improving, but remains sporadic
and ad hoc. Few companies are according this matter the priority it merits.
RECOMMENDATIONS
1. Require all companies handling toxic substances to adhere to a
prescribed safety standard tailored to specific chemicals and type of
operation. This would include a sufficiency of mechanical safety systems
to provide satisfactory insurance against equipment failure and human
error. Based on deficiencies noted in the recent study, the following are
some examples of the type of precautions that would be mandated
under certain cucumstat
a. Pressurized gas or liquid storage cylinders, storing toxic materials
with an IDHL value of 2,000 ppm or less, and 'equipped with pressure
relief valves and/or rupture disks must not vent directly into the
atmosphere. The vented gases must be contained, absorbed, or
destroyed.
b. Tanks storing liquid toxic materials, whose vapors have an IDHL
value of 2,000 ppm or less, and are heavier than air, must have leak-tight
secondary containment. If the secondary containment is a diked area,
then the atmospheric vent must open at the bottom of the dike and
provision must be made to cover the vented vapors or liquid with a
foam or other means, such that these will not emit uncontrolled vapors
into the atmosphere. In addition, these tanks should be nitrogen
blanketed.
c. For plants handling toxic materials with an IDHL value of 2,000
ppm or less, the safe handling of which requires a constant supply of
electricity, water, or other utility, a back-up supply source must be
provided for the utility needed.
d. The maximum size of storage containers should be limited depending
on the toxicity of the material being stored.
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It should be noted that the 2,000 ppm or less threshold was selected because it
is consistent with the guideline recommended by the OES and adopted for
this study. However, for purposes of any regulatory action, this threshold
should be further reviewed.
If these tighter safety controls were enacted, it means concurrent funding of a
suitably staffed (both in numbers and technical know-how) enforcement
activity. It also means coordination among the myriad agencies of
government involved in environmental protection to be sure industry is not
burdened with needless and costly duplication or contradictory directives.
The responsibility for implementing this recommendation
would more appropriately be with the State Legislature if standardization
throughout California is a factor. However, one can readily foresee the
difficulty of achieving the necessary political consensus. Two alternatives as
stop-gap possibilities are: (a) add the new safety requirements to the current
AQMD permitting system; or (b) add a licensing provision to the
"right-to-know" ordinances which would link safety system requirements to
what is reflected in the inventory. Under option (b), the responsibility could
become that of city, county, or state government.
2. The District should rcexamine its policy on the subject of Airborne
Hazardous Material Incidents, dated September 10, 1982, and its Imple-
mentation Plan, dated August 5, 1982.
This review is timely as a result of the experience gained in the two recent
pesticide warehouse fires. In both instances, the SCAQMD provided
technical assistance on a 24-hour, multi-day basis. This is the first
opportunity that the District has had to provide such assistance over an
extended period since implementation of the policy. From the lessons learned
here there may evolve recommendations for policy and procedural changes
that would enhance responsiveness.
It is recommended that this reexamination include notification procedures,
on-scene responsibilities, personnel equipment and training requirements,
and cost recovery. Also it should address the appropriateness of providing
this technical assistance automatically under certain pre-determined
conditions, rather than by invitation only.
The automatic aspect is not meant to suggest that an SCAQMD presence be
imposed on the counties. The intent of this recommendation is that there be
an agreement negotiated with county authorities spelling out the cir-
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cumstances under which the AQMD team would be automatically
dispatched, and recognizing this service as an opportunity to have a valuable
resource more expeditiously available to the scene manager.
We know time is a key factor in responding to incidents of accidental toxic air
emissions. District expertise with regard to air monitoring, meteorological
monitoring, and dispersion modeling is not readily duplicated in the SCAB.
We know that the precision and accuracy of the measurements taken in the
course of an emergency are necessarily subordinated to the need for quick
answers. Hence, even if occasionally there is duplication in these resources,
the double-check that a backup SCAQMD team might provide has merit of
itself. But the case for District involvement actually stems from the Lewis Air
Quality Management Act, which states that "...the SCAQMD is the sole and
exclusive local agency within the SCAB, with responsibility for compre-
hensive air pollution control." Even though the SCAQMD was not intended
to be an emergency response organization per se, it can be argued that there is
a logical, even necessary, continuum between its day-to-day control
responsibilities and being at the scene when air quality is out of control.
A further consideration is that the SCAQMD has high visibility in the SCAB
and is recognized for its competency in air quality matters. Accordingly, its
lack of presence, or late arrival, at the scene during a severe toxic air emissions
emergency could be viewed by the affected community with disfavor, and
erroneously suggest lack of interest by District management. Our citizenry
could argue that, especially during an emergency, the community should not
have to accept anything less than full and timely support; and that SCAQMD
participation is not an issue over which there should be any vacillation, for
while decisions are held in abeyance awaiting further developments, valuable
response time is lost.
3. The SCAQMD has a special expertise in the measurement and
identification of air contaminants; in the measurement and intrepretation of
meteorological data; and in projecting airborne contaminant dispersion.
Training in the use, and in the limitations, of measuring equipment should be
made available to city and county H AZMAT teams, as appropriate. Also, the
SCAQMD should be a prime participant in all exercises built around field
simulation of hazardous releases.
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4. HAZMAT Personnel Training
Training of HAZMAT personnel should be monitored by a single source to
assure uniform standards and adequate capability. This could be a joint
responsibility shared by the fire departments with assistance from the
SCAQMD. However, the single point preparedness authority, that will be
recommended in Part II of this report, should make this determination.
5. Toxic Chemical Traininf
More training, particularly for first responders, is required in: (a) the
identification of the nature of the chemical threat; (b) the procedures for
stabilization and neutralization of a chemical incident; and (c) the effective
allocation of specialized resources. Since this training must come from several
sources, there is a need for centralized management to ensure that the training
is properly coordinated.
6. Availability of complete and current data on type, quantity and location of
toxic chemicals is an urgent requirement. Comprehensive community
chemical disclosure ordinances are the most direct and expeditious means of
inventorying this information. Any such legislation should also take into
consideration the resources needed to maintain the inventory system current.
(Due to the relevance of these ordinances to community prepardness,
reference will be made to them in Part II of this study under the
Recommendations section.)
An example of the information to be included in these ordinances is as
follows:
Chemical composition
Chemical reactivity
Handling and storage data
First aid data
Health hazard data
Special protection data
Fire/ explosion hazard data
Spill and leak containment procedures
Fire and Emergency Medical System (EMS) response data
Emergency medical treatment data
Decontamination procedures
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PARTD
Community Preparedness
INTRODUCTION
This section focuses on an assessment of community preparedness in the
South Coast Air Basin (SCAB); i.e., the ability of emergency preparedness
agencies to respond, in a timely and effective manner, to a chemical disaster of
Bhopal proportions.
Similar to the approach taken with industry, a questionnaire was sent to the
director of each of the four county offices (Attachment 6) responsible for
disaster preparedness in the SCAB, and to the mayors of 34 selected cities,
(Attachment 7) requesting data relevant to community preparedness.
Interviews were held with a broad cross section of officials, including fire
department, sheriff, medical, communications and administrative personnel,
at the policy, planning and implementation levels, who share in the
responsibility for community preparedness. Also, reflected here is the
substance of discussions held with many of the company officials who
participated in the industry survey, and who surfaced thoughts and concerns
regarding community interface and disaster preparedness. Finally, we drew
from a vast data bank consisting of research studies and technical papers,
particularly those sponsored by the Disaster Research Center at the
University of Delaware and by the Nuclear Regulatory Commission, relating
to natural and man-made disasters of the past. This information, in its
totality, provides the basis for Part 2 of this report. There is ample evidence in
each county that disaster preparedness is, indeed, a matter of concern and is
receiving significant attention. However, although progress is being made,
the pace of this progress varies both among the counties and with regard to
specific aspects of the preparedness equation. For purposes of this study, we
have selected key areas of community preparedness and examined these with
regard to the SCAB as a totality, rather than relating them to individual
counties or cities. There are two reasons for this approach. First, in the event
of a major disaster, the key to effective response is integrated effort and
cooperation across county lines. Hence, an assessment of overall pre-
paredness is more relevant than the status of any particular jurisdiction taken
in isolation. The second reason is to avoid the possibility that observations
made in this report, however material, could be misconstrued and interpreted
as critical of an individual agency or official charged with preparedness
responsibility. This would be divisive and a disservice to those who simply see
preparedness in a different light.
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All personnel with whom discussions were held evidenced a high degree of
dedication and professionalism, and a commitment to the preparedness
function, there were, and remain, some differences of opinion as to the
approach to be taken, and perhaps even the priority even the priority to be
given, to certain aspects of disaster preparedness. But it is important to
reaffirm at the outset the broad base of agreement that exists, and not
magnify any disagreements out of proportion to their merit. This study
recognizes the autonomy of city and county governments and the need to
foster a cooperative, rather than competitive, relationship between these
governments and other public agencies which share preparedness re-
sponsibility. Only in this context can there be an effective integrated planning.
APPROACH
Disaster preparedness has been the subject of study for many years by a
concentration of multi-disciplined professionals. Through their efforts we
have available to us a vast data bank of research information that has been
quantified with an academic detachment which enhances its credibility. As
noted earlier, we have drawn substantially from this material, using it as a
yardstick to measure community preparedness. The philosophies outlined in
the section on preparedness climate and perceptions, community disaster
planning, vertical linkages, specialized/compartmentalized planning, eva-
cuation and the emergency medical system are, in effect, extracts from
previous relevant research. These tenets have withstood the test of time. In
each case, authorship is attributed in the reference section of the report.
Certain other references have also been listed. These have been invaluable as
general background, even though the content does not appear in the report.
PREPAREDNESS CLIMATE AND PERCEPTIONS
Much lip service is lent to the need for community preparedness. However,
even the acknowledgment that a threat truly exists is often not sufficient to
mobilize planners into action. Today we have a situation where the local
community in general has not yet accepted the imminence of an earthquake
disaster. And this is notwithstanding the two or more yean of focused effort
toward raising the threshold of public awareness. Is it surprising, therefore,
that the chemical emergency is not viewed with appropriate concern-
particularly in the light of the shallow understanding of this many faceted and
complex threat? It is a fact that localized incidents do draw attention and even
the immediate ire of a small affected community. But seldom, and only by a
very few, is there an outlook beyond the immediate to what might occur,
should the sudden confluence of circumstances and events trigger the
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unexpected. All this is not to say that perceptions are necessarily in concrete.
They can be changed. But if this is the intent, the re-education must begin at
the level of the policy makers and planners, where today there is no unanimity
of thought regarding the need for additional and accelerated chemical
disaster preparedness.
Ironically, the petrochemical companies do have a sense of urgency regarding
safety, although it is generally in the context of rendering the plant
environment safe for their employees. This points in the right direction but it
also ends at the perimeter of the facility's property line. The major
petrochemical companies tend to reflect more safety awareness than those in
the smaller companies. However, this is a rule that is not universally
applicable.
COMMUNITY DISASTER PLANNING
Community disaster planning is a continuous process but the continuance
aspect must not be a shield behind which plans are permitted to become
outdated and non-responsive to changing situations. Furthermore, the
purpose of the plan is not to fuel the papermill but to convey relevant
information and direction, educating both the planner and the recipients of
the plan in the process. To the extent practical this means developing
alternative scenarios clued to a spectrum of possible contingencies.
Public involvement in disaster planning is crucial, especially in terms of
developing an awareness and knowledge of the planning being undertaken.
Feedback from the public is necessary at ail stages of the planning process.
This requires that the public be kept fully informed about what is planned,
especially with regard to those aspects which one foresees as potentially
questionable. For a disaster plan to be effective, the community residents
must know, understand and accept it.
The key element in implementing total community planning is the
development of effective links between the various organizations within the
cities and counties which would become involved in case of a widespread
disaster. This does not mean simply a listing of tacit agreements for mutual
assistance that are pegged to the lowest order of emergency. It means
confronting in advance the harsh realities of a major disaster, however
unlikely but still within the realm of possibility. One must bear in mind that if
such a disaster should occur it will not be the result of ordinary circumstances.
Planners should foresee such contingencies, set aside their concerns over
competing domains and establish the framework for an effective operational
response to whatever the situation.
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As a rule, preparedness for natural disasters is generally the major
responsibility of one organizationusually whatever is constituted to be the
civil defense agency or the largest governmental entity in that geographical
area. This responsibility means that the organization is the lead agency in
calling attention to the range of hazards in the area; in coordinating the
activities of other planning groups addressing these problems; and in
prioritizing these efforts.
In the case of technological disasters generally, and more specifically sudden
chemical disasters, we have been unable to identify any single organization
which actively takes responsibility for coordinating these efforts in the SCAB.
To all intents, there is none. Various government agencies are peripherally
involved in preparations for disasters resulting from chemical incidents, but
to have the authority to assess overall preparedness across county lines and
enforce a rigorous standard of compliance with agreed standards. The local
fire departments have a special interest in chemical hazards, and often a
special competence, but they do not necessarily serve as the lead coordinating
group in their own city, let alone in their county or the SCAB. Some local
chemical plants, reflecting recent corporate direction, are becoming more
involved in community disaster preparedness activities but, as noted
previously, this involvement does not include the assumption of a lead role
beyond their immediate plant boundaries. Thus, in the SCAB there is no
single Czar-type organization with the responsibility and the authority to
direct overall preparedness planning for potential chemical disasters.
In its various studies the Disaster Research Center found continuing evidence
of what it termed "mutual ignorance" between organizations in the private
and public sectors regarding their respective activities. The Center notes that
the local fire departments are the major, and virtually the only, point of
contact between local emergency organizations and chemical companies
within an area. The narrowness of this linkage between the two sectors causes
chemical companies to remain generally uninformed concerning community
disaster planning. Similarly, most public safety agencies know very little
about what the neighboring companies are prepared to do in a major
chemical emergency.
A further serious complication is that often in-plant accidents are not viewed
by the petrochemical companies as a legitimate concern until there is direct
and visible impact on the community. Sometimes this is too late...or at least
later than it should be. The recent Fiberite plant incident certainly points in
this direction.
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The lack of coordinated planning effort between the private sector and public
organizations in chemical disaster preparedness is changing-but not rapidly.
A fact brought out by the ORC studies is that "when chemical disasters occur
in areas for which jurisdictional responsibility is unclear or complicated, (e.g.,
port or river areas) the pre-planning often has failed to reflect a clear
delineation of responsibility. Even when there is disaster preparedness, there
still will be gaps in coverage unless coordination is very tight. Whereas it is
desirable to have petrochemical companies located away from built-up
residential areas, these sparsely populated zones are sometimes meagerly
serviced by the emergency organization in the community. Here you have a
situation where the risk is low of an emergency occurring. But if it should
occur, the response often is less effective than it should be." The reason for
raising these issues is to highlight their complexity and make clear why there
are no easy answers to the problem of coordination.
Professor E. L. Quarantelli of the Disaster Research Center brought to light
some interesting paradoxes in the planning for chemical threats and dangers.
Among the major ones, confirmed by our findings in the basin, are the
following: "(1) Chemical facilities that engage the most in planning are not
necessarily the ones that most need to plan." An example is the large safety-
minded corporations who are becoming extremely sophisticated in their
safety measures, as opposed to the smaller local companies. The latter often
cannot afford elaborate safety planning and plant modernization, not-
withstanding the need for both. "(2) Chemical companies tend to see
accidents and catastrophic* as points on a continuum and thus to see disaster
planning as an extension of everyday safety planning. One consequence is
that when an in-piant accident occurs, ail energy is directed to containing and
reducing the threat, and little to informing the community of the attendant
hazards should the threat not be contained. In the event the containment
efforts are not successful, the community suffers due to lost warning time.
Also, lack of reporting tends to give a community a false sense of security. (3)
The fire department, the most likely local organization to be the prime
responder to a chemical disaster, is usually not involved in comprehensive
planning beyond its own immediate role. (4) Planning for plant safety
incidents or planning for disasters tends to be viewed as the same thing in
most chemical companies. It is often unrecognized that there might be a
qualitative difference in the planning necessary, and response required, for
the two kinds of situations. Accordingly, preparedness which is excellent for
accidents may lead to a mistaken belief of being prepared for disasters. (5)
While pre-plan mechanisms exist for obtaining information and expertise, as
well as mobilizing specialized personnel and equipment, the initial and prime
responders to a chemical incident usually have major difficulty in simply
identifying what, if any, hazardous materials are involved. This is especially
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true in transportation accidents where multiple chemical substances often are
involved." Even with a manifest in hand, the first responder on the scene often
is at a loss as to what remedial actions should be taken. Meanwhile, precious
time is wasted. From all of this one can conclude that disaster preparedness
for chemical emergencies has quite a few gaps that are perhaps tolerable in
terms of localized incidents, but necessarily of serious concern if there should
occur a major disaster impacting a large fraction of the SCAB. (See Reference
#3.)
VERTICAL LINKAGES
We noted previously the problem of competing domains and loyalties which
tend to hinder cooperative efforts across jurisdictional lines. Further to this
point, K. J. Tierney, Ph.DM Department of Sociology, University of
California at Los Angeles and Institute of Safety and Systems Management,
University of Southern California, makes the point that "vertical linkages are
extremely advantageous in terms of the resources they can mobilize in times
of emergencies. However, from the standpoint of local organizations,
instituting and maintaining these linkages for planning purposes can be costly
in both time and effort." And this relates directly to the ever-tightening
budgets...a consideration that is usually key to the availability of resources.
Tierney further notes that "there is a tendency for organizations to resist any
dilution of autonomy and control. The prospect of losing it to some outside
entity at the time of a serious chemical incident is unweicomed by most local
organizations who see themselves as the ones who will bear the brunt of public
indignation if an incident is mishandled. As a result, despite the availability of
outside resources, there often is a tendency for organizational personnel to
hope rather than to plan adequately. The rationalization is that money is
being saved and autonomy is being preserved." One can appreciate the
concern of local officials regarding any dilution of authority that is needed to
effectively discharge responsibilities. However, the history of government, at
its various levels, reflects precisely such accommodations, without which little
would ever be accomplished. (See Reference #4.)
SPECIALIZED/COMPARTMENTALIZED PLANNING
In the SCAB, the petrochemical companies and the fire departments who
serve them are the two best qualified organizations to cope with a chemical
emergency and these are the organizations that do most of the planning. And
this is not peculiar to the basin. Tierney confirms from her research that this is
generally the rule. However, her study also notes that "most of this
information and expertise is localized and remains within organizational
sectors, not readily accessible to the larger community disaster preparedness
subsystem."
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According to Tierney, "specialization and compartmentalization have several
ramifications for overall community disaster preparedness and response.
First, white the specialized organizations know a great deal about the
particular tasks on which they focus (neutralization of chemical agents, for
example), there is a lack of mutual understanding about how other important
tasks (such as evacuation) will be handled and who will carry them out This
lack of general pre-planning and consensus will make working together in an
acute chemical disaster very difficult. Also, due to the jurisdictionally
complex and compartmentalized nature of chemical emergency prepared-
ness, gaps occur in planning. For example, communities with chemical
facilities may have organizations with the knowledge, expertise and resources
to handle emergencies at local chemical production facilities, yet there is no
such clear cut delineation of responsibility for chemical transportation
emergencies within the same jurisdiction. Or, certain disaster-related tasks,
such as emergency medical care in a mass casualty incident, may either have
been glossed-over or not adequately coordinated as part of chemical
emergency planning. These deficiencies are unlikely to come to light during
non-emergency times in communities where personnel charged with
specialized preparedness responsibilities do not communicate regularly. A
disaster drill involving the simulation of a major chemical emergency would
surface these oversights. However, such drills'are seldom conducted on a
community-wide basis."The latter point is particularly relevant to the basin.
Even when the drills are conducted, the element of realism is missing from the
scenarios. Fire departments do, of course, have frequent drills and these often
simulate "real time" contingencies. But, again, this relates to the localized
incident, and not one across city and county lines of disaster proportions.
As Tierney points out: "None of this is to say that in taking an integrated
approach to disaster planning one should ignore specialization. On the
contrary, specialists are essential to an effective response. However, pre-
paredness also involves sharing information and resources so that all
potentially involved organizations cannot only anticipate the threats from the
chemical agent, but also anticipate one another's actions in disaster, thereby
avoiding conflict, duplication of effort, and inadequate response." Here in the
basin one will readily find agreement with this in principle, and the principle
works for localized incidents. Beyond these the planning and sharing are quite
remote, probably because the major chemical disaster is not viewed as a likely
occurrence. Cost inevitably is cited as a factor in not doing more along the
lines of community preparedness. And one must acknowledge that this is a
consideration. However, as Tierney indicates: "a relatively modest budget is
sufficient to promote exchange of information among disaster relevant
community groups, and to integrate preparedness for chemical emergencies
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with more general community disaster planning. Community risk assess-
ments, community preparedness meetings, training sessions, and community-
wide drills are all means to these ends." There also are some political
discussions that need to be made and these are perhaps the most difficult of
all. At the root of all this is a question as to what priority should be assigned.
This should not be done in the isolation of any single community, because
none of the communities can stand alone in the event of a truly catastrophic
chemical incident. And so once again we return to the importance of
integrated planning of a type that reflects the same realism one will confront
in the case of a truly catastrophic chemical incident (See Reference #4.)
COMMUNICATION
The two mechanical means of communication generally discussed are sirens
and radio. Particularly in regard to warning, they are clearly most relevant if
the forewarning period is relatively short There is fairly clear evidence that
use of warning sirens alone is inadequate to stimulate people to take
immediate protective action. The sirens may not be noticed. If noticed, they
may be ignored.
Radio and television are the most widely used, and potentially the most
effective and efficient means of communicating warnings. They are widely
accessible, not particularly vulnerable to environmental impact, highly
flexible, immediate, and generally given high credibility by the public.
Research data indicates that these mechanisms are frequently turned to by
people in mass emergencies. It must be noted, however, that the effectiveness
is to a considerable degree dependent on their operation being congruent with
the decisions and activities of local officials. Lack of congruence confuses and
compounds the dilemma for everyone.
In the past, an interesting dependence of local officals on radio and television
has been noted in certain types of mass emergencies. In technological
disasters, such as the Three Mile Island incident, the Louisville chlorine barge
episode and in some recent chemical disasters in other parts of the country,
important information was controlled by private or non-local government
agencies and not always given directly to local authorities. In these instances,
radio and television became the major source of information available to
those who must make the key operational decisions.
In still other situations, radio and television may function in a more
integrated role than is realized, intended, or planned. It has been reported that
in four communities along the Mississippi River that were threatened by toxic
gasesand in the absence of coordination and leadership by government
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agenciesradio stations assumed the responsibility for summoning expert
assistance, determining risks, and making decisions regarding warning and
evacuation that ordinarily would have fallen to local officials. The general
public, realizing that the station was the only dependable source of
information, listened to it extensively, believed it, and later reported high
satisfaction with it.
During this survey one county official suggested another means of warning,
i.e., the development of a telephone network whereby people could call one
another to discuss and confirm warning and evacuation information.
Experience has shown, however, that in the case of even a medium-size
disaster the phone system quickly becomes overloaded and few calls in the
later stages pass through.
We do know that the sheriff and police departments have made use of
speakers to alert populations to danger and to urge evacuation. This is more
effective during events that allow a certain amount of forewarning. However,
there are very clear limitations based on the extensiveness of the area for
which this type of warning system is intended. A related aspect of
communication that bears further study is the lack of crossover capability
among the various radio networks. This definitely hampers interagency
coordination.
WARNING SYSTEMS
Responsive warning systems are a key ingredient in disaster planning. It is
also a fact that many of our most vulnerable communities are not adequately
prepared in this regard.
To estimate the cost of an adequate outdoor warning system, the Carson area
was selected for survey due to its heavy concentration of industry harboring
hazardous toxic materials. The assistance of the Signal Division of the
Federal Signal Corporation was solicited in conducting this survey. An area
was pinpointed bordered by Del Amo Boulevard on the north, Sepulveda
Boulevard on the south, Figueroa Street on the west and Route 17 to the east.
It encompasses the southern half of the City of Carson which is not now
equipped with outdoor warning sirens. This site was selected by evaluating
such criteria as population density, rural and urban development,
geographical and topographical considerations, minimum performance
requirements, power availability and economics.
If an emergency developed today requiring evacuation, the public would be
notified by one, or a combination, of three methods: 1) mass media
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notification by either radio or television; 2) door-to-door notification by local
authorities; and/or 3) outdoor warning and notification by an emergency
vehicle driving up and down each, street. All of these options would be time
consuming and would tax local resources to the fullest. There would also be
the possibility of mass confusion for the local populace.
For purposes of this survey, two types of outdoor siren warning systems were
considered: 1) an electronic siren; and 2) an electro-mechanical siren.
The electronic siren system offers these advantages:
1. Immediate notification by day or night of all affected people that an
emergency is in progress.
2. Public address capability to provide information as to the nature of
the emergency, where to go, and what to do.
3. Seven distinct signals to distinguish the type of emergency.
4. Thirty-minute continuous operation following loss of primary power.
5. Westminster chimes signal to allow daily testing.
6. Distinctive electro-mechanical dual-tone sound to distinguish it from
an emergency vehicle siren.
7. Status feedback upgrade capability to assure local officials that all
sirens have been activated.
8. Ease of installation.
The installation would consist of electronic sirens with sound output ratings
of 1244BC at 100 feet and 115dBC at 100 feet. For purposes of depicting
anticipated coverages, an attenuation factor of lOdBC per distance doubled
was employed. This produces a signal of about 68dBC at 4,300 feet for the
124dBC Federal Signal EOWS 612 sirens and 68dBC at 2,400 feet for the 115
dBC EOWS 1212 sirens.
The recommended types and locations of these electronic sirens would be as
follows:
Siren # Type Location
1- EOWS1212 Carson City Pool
2. EOWS612 Scott Park
3. EOWS612 Carnegie Jr. H.S.
4. EOWS1212 Adams St.i Prospect Ave.
This system is priced at approximately S51,500, not including installation.
The latter generally costs between two and three thousand dollars per siren
site, depending on the siren.
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The electro-mechanical siren system is capable of two emergency signals,
"alert" and "attack.""Alert" is a steady signal and "attack" is an undulating
(wailing) signal The electro-mechanical system offers these advantages:
L Immediate notification by day or night of all affected people that an
emergency is in progress.
2. Low cost
3. Field proven long-term dependability and maintenance-free.
4. Ease of installation.
5. Cancel function.
In this case, Federal Signal's RSH10A 1224BC siren, producing a signal of
about 68dBC at 3,500 feet, and Federal's STH10A 115dBC, producing a
signal of about 68dBC at 2,400 feet are recommended.
The recommended types and locations of these electro-mechanical sirens
would be as follows:
Siren # Type Location
1. . RSH10A Carson St Elementary School
2. RSH10A Scott Park and Pool
3. RSH10A 213th and Perry St.
4. STH10A Adams St. and Prospect Ave.
The above system is priced at $32^500, plus installation. Both the electronic
and the electro-mechanical systems would utilize DTMF Radio Siren
Activation. This would allow local officials the versatility of activating one
siren, any combination of sirens, or all sirens. The possibility of accidental
radio activation of a siren (falsing) by an outside party would be small for a
DTMF radio control system. Both warning systems are designed to provide a
minimum 65dBC intensity as the minimum signal level in the coverage area.
Siren range for Carson was computed using a lOdBC per distance doubled
attenuation factor. This value takes into account all factors that affect the
signal and provides realistic coverage expectations.
The main determinant for a local agency as to which siren system to choose,
electronic or electro-mechanical, is the primary objective of the siren system
itself. The siren system is just a part of the local emergency plan. If siren
activation means that an emergency is in progress and that the local citizens
should turn on the radio, an electro-mechanical system is sufficient. However,
if one foresees many different types of emergencies, and there is a need to be
more specific as to type in terms of the appropriate response the citizens
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should take, electronic sirens would be the better choice. Other determinants
include many types of primary power available, whether the loss of primary
power is a problem, the number of visitors who frequent an area, and
economics. Nevertheless, both types of sirens would be adequate to help warn
local communities that an emergency is in progress. In sum, the key factors
driving such an expenditure are an estimate of the threat, in terms of required
warning time, and the size of the geographic area associated with the threat.
EMERGENCY OPERATING CENTER
Direction, control, and warning are key functions of emergency preparedness
and response operations. A central facility from which all emergency efforts
can be coordinated and directed is considered by the Federal Emergency
Management Agency (FEMA) as essential for emergency response and
recovery, whether the disaster stems from natural or man-made causes, or
from an act of war. Such a facility is referred to as an Emergency Operating
Center (EOQ. The EOC also has an important role when realistic simulations
of disaster situations are conducted, serving as a physical framework for
bringing the "decision-making" organization together, thereby promoting an
integrated, team-building approach to disaster management.
The design and capability criteria are somewhat stringent. However, to a
degree, these can be tailored to the needs of a specific community. Certain
cities in the SCAB have taken the initiative and established a local EOC. This
reflects, in a very tangible way, the priority that is being given to disaster
preparedness by local officials. For the SCAB, there is a minimum
requirement of one EOC per county, and it must be in conformance with the
standards prescribed by FEMA if it is to fulfill its function.
EMERGENCY BROADCAST SYSTEM
In response to a Federal Communications Commission (FCC) request, the
Los Angeles County Emergency Preparedness Commission developed an
Emergency Broadcast System (EBS) plan in 1981, and it was approved by the
Board of Supervisors in June of that year. The purpose of the plan was to
provide a communications channel between local agencies and the public in
the event of an emergency occurring in Los Angeles County. The system is
voluntary, and involves the cooperation of various county and city agencies
and the local media. It is an excellent system for Los Angeles County and
merits consideration as a model for bringing the other basin counties into the
network.
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The system utilizes 39.98 MHz frequency (which the SCAQMO uses to
broadcast smog alert information to schools and industries) which normally
ha« minimal traffic.
Emergency broadcasts can be originated by an appropriate local government
representative, by the Mayor, Chief of Police, or other designee of the City of
Los Angeles, by the Los Angeles County Sheriff, Chairman of the Board of
Supervisors, or other designated County representatives. The Sheriff is
responsible for the content and authenticity of the broadcast information.
BBS facilities are located at the Sheriffs Department Radio Center, at the
Sheriff's Information Bureau in the Hall of Justice, at L.A.P.D. head-
quarters, and at the Los Angeles Emergency Operations Center at City Hall.
An emergency must affect a significant segment of the population before
information can be broadcast over the EBS. There is no written definition of
what constitutes a "significant segment." This would be determined on an ad
hoc basis by the Sheriff's Department. At the minimum, it should affect the
citizens of several cities, or a wide portion of Los Angeles. All emergency
messages are sent by telephone to the Sheriff's Information Bureau at (213)
974-4211. The authorized city or county representative may prerecord
iges, telephone or personally deliver live messages, or have the Sheriff's
Department redeliver the message verbatim. The City of Los Angeles, after
clearing its message with the Sheriff's Department beforehand, can broadcast
its own message. The message is broadcast over the 39.98 MHz frequency to
receivers located at 22 radio stations and 8 television stations. The stations are
alerted beforehand that an EBS message will be sent. Upon receiving the
message, the stations have full discretion to broadcast verbatim or edit the
message.
The editorial discretion of the stations is crucial to the success of the EBS.
This enables the stations, all of which have news departments, to broadcast
only those messages they deem necessary. This heightens the impact of an
EBS message, better assuring it will be listened to when broadcast. It is
essential that the urgency of an EBS message be maintained; thus the media
broadcasts an EBS message only when urgency truly warrants it.
The EBS is not meant to be a "news flash" system informing the public that a
disaster has just occurred. The radio and TV stations have field reporters
which get to the scene in minutes to broadcast late-breaking stories. The EBS
is meant to be an advisory system which will inform the pubic what to do in
response to a disaster. By the time the EBS message is broadcast, the media
should have already aired the initial newsbreak. The EBS is intended to be
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broadcast shortly thereafter, as soon as the message content is verified.
Confusion or misinformation would definitely undermine the effect of the
BBS.
BBS is a rapid and effective method of disseminating advisory information to
the public with several distinct exceptions. For example, if a toxic disaster
occurred during the early morning hours, most TV's and radios would be
turned off and the message would not be heard. The BBS has no way of
alerting the public to turn on their radios or TV's to hear the message; it can
only alert them to the fact that a message will be broadcast if their sets happen
to be turned on. In Canada, the BBS automatically dials peoples' telephones
to tell them that a message will be broadcast shortly. This is facilitated by the
fact that the media and telephone companies are nationally owned there.
However, a similar system here would be impractical and expensive to
implement.
This BBS serves only Los Angeles County. The other counties do not utilize
the 39.98 MHz frequency for their emergency planning, although this
frequency ties into 30 major radio and TV stations. The Orange County plan
utilizes radio stations located within the county, but these are small and have
limited range and listening audience. Similarly, neither Riverside nor San
Bernardino Counties has quick access to the major networks to broadcast
their emergency messages. Such access would benefit each county in-
dividually, and would also provide the broader coverage to all counties in the
event a major disaster impacted across county lines.
EVACUATION
We know that a key element in emergency preparedness is the ability to
evacuate. This is a fact whether the emergency is of a localized nature or with
broad impact across city and county boundaries. Particularly in the case of a
chemical disaster, timeliness is a key consideration. According to one
authoritative source, Prof. B. L. Quarantelli, of the Disaster Research Center,
an orderly, planned evacuation can also serve to reinforce morale insofar as it
strengthens the belief among our citizenry that competent authorities have
indeed taken charge.
In his studies, Professor Quarantelli has noted that the initial withdrawal
phase of the evacuation process usually proceeds relatively well. "The
departure tends to be orderly, reasonable from the perspective of the
evacuees, and generally effective in removing people from danger. Most of the
problems with evacuation occur before and after the process takes place."
-------
Today, in the SCAB, there is no evidence of organizational preparedness for
initiating and conducting mass evacuation in the event of a major
technological disaster. We refer here to situations where large segments of a
county, or counties, are instantaneously and simultaneously threatened by
major toxic emissions caused, for example, by an earthquake or sabotage.
This is an entirely different scenario than one where even ten thousand
people, in a relatively circumscribed area, are evacuated due to a single,
localirrd incident
Today, evacuation is not treated as a major policy matter. Perhaps even more
fundamental, most disaster preparedness officials regard the possibility of a
mass evacuation under a worst-case scenario as remote. Hence the reluctance
to accord this contingency an appropriate priority. However, remoteness is
not the issue. The question more appropriately is whether this possibility,
even if remote, can be disregarded in the overall planning framework.
There are some other factors that often fail to receive proper attention in
evacuation planning. For example, little attention is given to the distinctive
features and special problems which can be involved in mass evacuations due
to a chemical emergency at varying times of the day and night in a basin where
transportation arteries are few and congested. It is not unusual to find this
situation. Professor Quarantelli, and other researchers who have studied the
evacuation phenomena, repeatedly make the point that "whether in plans or
in actual instances, link consideration is given to the fact that evacuation
involves going to some area, as well as movement from some locality, and
inevitably a return to the original point of departure. To ignore the directed
and round-trip nature of the evacuation process is to miss much of what must
be dealt with in practical terms."
Another point made in the DRC studies is that often there is a reluctance by
some to evacuatefor whatever the reason. Yet, in the event of a chemical
disaster, timing is key. And if the incident is of major proportions, affecting
widely dispersed areas, those who have not been indoctrinated beforehand in
evacuation procedures, are not about to react with speed and cooperation
during the crisis.
Based on the above, the following are some general guidelines that have been
extracted from DRC studies and which provide a basis for preparedness
planning. "First, evacuation should be approached as a proactive policy,
distinctive and important in itself." This means realism in the planning stage
and in conducting pre-emergency exercises. "Second, planning should
visualize evacuation as a flow process with different emergent stages
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involving various types of contingencies. Third, operational personnel should
consider the full range of behavior patterns involved in evacuation from the
warning, to the withdrawal, to shelter, and then to the return stage."
Management of a large scale evacuation requires considerable fine-tuning
and some of this must be thought out in advance.
\
Experience, documented in various DRC studies, emphasizes that the
evacuation plan is the only framework. Those responsible for the effective
execution of the plan must act in an informed, coordinated manner.
Otherwise, confusion will reign and the situation will readily evolve out of
control.
Another point emphasized in past research is the importance of maintaining
open lines of communication to the evacuees by responsible emergency
authorities to guard against precipitous return to the impacted area or similar
actions which complicate the evacuation process. This not only requires
planning but also the exercise of these plans under conditions that closely
approximate a true chemical disaster environment. (See Ref. #3.)
EMERGENCY MEDICAL SYSTEM
We acknowledge that some planning and operational personnel believe that
the everyday Emergency Medical System (EMS) system can simply be
extended in mass emergencies with assurance that it will perform adequately.
However, past experience, documented in DRC research findings indicate
indisputably that "mass emergencies create demands that differ qualitatively
and quantitatively from everyday EMS needs. For example, disasters can
create a large number of walking wounded who, while not necessarily
requiring the services of a hospital emergency room, may nevertheless
intensify demands by converging on hospitals." (See Tierney-Taylor Ref. #6.)
This is particularly true in the case of a large scale chemical disaster where
patients descend on hospitals without prior diagnosis.
Another difference between disaster and everyday EMS noted in the
referenced study is that "everyday EMS is designed to function with great
speed in meeting specialized problems of sick and injured individuals, e.g.,
cardiac arrest and multiple trauma. Whereas, in disasters which produce large
numbers of casualties whose medical problems exhibit different degrees of
urgency, speed of the response may not be crucial to effective operations.
Instead, the overall coordination of the response among hospitals, and
between first responders, becomes the essential task."
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The Tierney-Taylor study notes "a widespread lack of knowledge about the
EMS in most communities." Here in the basin we find adequate information
about, and satisfactory execution of, the day-to-day EMS. However, much
remains to be done with regard to coordination if these services are to be
effective in a mass casualty situation. The following quote from the referenced
study describes the basin situation perfectly: "Where mass emergencies are
concerned, attitudes of either faith or fatalism are prevalent. On the one hand,
there is faith that the necessary assistance will be forthcoming from some
quarter in situations of extremely high EMS demand; on the other, there is a
fatalistic notion that for some disasters there probably can be little effective
community response."
It is understandable why interorganizational coordination is not easy to
achieve. The same political considerations that are documented in the vast
literature of DRC studies on EMS apply, in large measure, to the basin as
well. While some will cite the vast resources available in the basin that could
be applied in the event of an emergency, this avoids the questions as to
whether or not there has been adequate planning for the effective application
of these resources. Those who recall and participated in the WATTS
emergency some yean ago will suggest that many of the same EMS problems
remain with us today.
Additionally, mass emergencies (particularly those resulting from earth-
quakes) would not necessarily be limited to a politically convenient location
in the SCAB. Any number of organizations and agencies, on a variety of
governmental levels, would have an operational role in case of a major
catastrophe. One can readily foresee how overlapping jurisdiction could lead
to confusion in the delivery of services, and to treatment of patients in less
than a satisfactory manner. Hence, the overriding need for coordinated
planning,
We know "the plan" is key. This must include coordination and also periodic
exercises simulating worst-case situations. In this regard, the referenced DRC
study makes several additional points that bear repetition here: "a) planning
must include major input from physicians and nurses experienced in
emergency treatment, b) Hospital delivery must also be based on patient
medical needs, not on the desire of the hospital to receive them and the
availability of an ambulance to bring them. Thus, professional medical input,
early in the process of determining policy and objectives, is an imperative in
MCI planning, c) The actual formulation of the logistical and operational
plan should be the responsibility of the providers. Essentially, it is the public
safety people who should develop the coordination of resources and all that
that entails."
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We know from experience and other DRC studies that an MCI response
utilizes a heterogeneous array of organizations including police, firefighters,
ambulance personnel, (sometimes) civil defense personnel, nurses, physicians
and hospital administrative people, plus other public and private organi-
zations. If these groups have not found a mechanism to work together
harmoniously in the planning stage, it is unrealistic to expect everything
coming together under the stress of emergency. Unfortunately, the approach
taken in many situations where agreement is anticipated to be difficult is to
simply ignore the problem. However, the basic differences remain only to
surface again at the most inopportune time.
In the recommendations section of the report we will note a number of the
areas that require careful study, planning and coordination. These will not be
repeated here except to stress one key area"exercises." Exercises are the
most effective method of testing logistics and coordination. They provide
opportunity to identify the gaps and solidify relationships. The latter is of
overriding importance due to the benefits that can conceivably carry over
back to the planning table. Exercises, however, must be held with some
regularity, otherwise they are relatively meaningless. And the lessons learned
must be applied to future planningotherwise the longer term benefit is nil.
As other studies have noted, the exercise scenario is key. It must be realistic
not just convenient. Also, it should anticipate the unexpected. Otherwise, we
are exercising robots with no memory beyond the original limited pro-
limited programming. There is a tendency to regard community disaster drills
as an annual or biennial event, approximating a square-filling exercise. The
hallmarks were aptly described by one researcher as no imagination, no
diversification, no enthusiasm, and only junior-level participation. Clearly
more attention must be given to this element. This means more interest from
the top of the response structure. (See Ref. #6.)
ASSESSMENT BY RESPONSE SCENARIO
In the course of our survey on EMS response, we met with Dr. Doug
Arterberry, Director of the Northridge Tox Center and with Mr. Eric
Hutchins, a systems analyst, who is working closely with Dr. Arterberry in
developing a flexible, computer-based incident reporting system. As a result
of our meeting, a step-by-step scenario was proposed that would permit a
realistic assessment of EMS response in the SCAB.
First, identify a manageable number of locations (say five to ten) where a
major incident is most likely to take place. This could probably be worked out
by cross-referencing such factors as the amounts of hazardous materials
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stored at various locations, the numbers of fixed containers in which the
materials are stored, and their respective incident histories (number and
severity). Care should be taken to insure that at least one of the sites selected is
located in each major area of concern.
Second, work with the Medical Alert Center (MAC) to develop quick
emergency response scenarios for each site. This need be nothing more than a
casualty profile in hard numbers, a list of the first tier of agencies to be called,
and a sequence of the initial things each of these agencies would do.
Third, contact the agencies listed by MAC for each of the likely incident
locations and invite them to be represented at a meeting to discuss the
scenario. At the meeting, describe the incident, the casualty profile, and
MAC'S rough idea of what would happen in the beginning of the response.
Let the discussion flow from there and carefully record the areas of consensus,
difference, and ambiguity.
Fourth, conduct whatever analysts and further interviews may be required
and send a copy of the draft report to each agency that was represented, along
with an invitation to a debriefing and further discussion.
The above approach permits a relatively quick and accurate assessment of
what should happen and what is needed in the way of preparation from a
medical standpoint Roughly the same approach could be taken in evaluating
other aspects of preparedness.
Another area identified as worthy of closer examination was how use of some
self-contained computer work stations at the MAC, and at the critical
response agencies, could shave minutes (perhaps hours) off the critical first
phase of response. For example, when the first alert notification comes into
the MAC, the area scenario checklist, that was begun in the course of the
assessment, could be brought to the screen immediately. This checklist could
include agencies to be notified and lists of contact persons to ascertain the
status of critical resources in the private sector. None of this information will
take the place of the response experts at the MAC, but it will support them
with months of preplanned information thoughtfully put together by teams of
people.
In order to positively identify the substance or substances at a given site, the
inventory record of what chemicals are stored at that location could be
brought to the screen by the local fire department. This information could be
telephoned to a central Tox Center (such as Northridge), along with the first
substance description from the scene. The Tox Center could immediately
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advise the MAC and scene commander regarding the fastest route to positive
chemical identification and to personnel protection. The Toxic Center could
download a record of the substance from its H AZM AT database to hardcopy
and have it flown to the scene commander. The Toxic Center would then go
on-line to the Chemical Information Service (CIS) and to the National
Library of Medicine (NLM) which would download their respective records
on the substance for further interpretation and advisement to MAC. The
scene commander could have a microcomputer at the scene to provide direct
communication with the Toxic Center; to act as a casualty record center; and
to serve as a displaced persons message center. This would enormously
simplify the subsequent tasks of incident tracking, damage reporting, and
reuniting separated family members. The software for everything listed above
presently exists or can be created with minimum expense. The hardware for a
reliable mobile operation also exists.
Both projects detailed above are examples of what can be beneficially
accomplished on % comparatively low budget, and in a realistic time frame.
What is needed is more centralized control over planning; the initiative and
ability to identify and integrate such efforts; and the authority and
determination to set priorities, make commitments, and follow-up to be sure
they are met.
INTEGRATED PLANNING
Integrated emergency planning need not be a difficult process. However, it
takes thought, time, and continuous updating. FEMA has spelled out the
process in its various publications. Eventually, it begins with a comprehensive
hazard assessment prepared by the community, possibly in conjunction with
state and federal regional personnel, depending on the circumstances. It then
proceeds through an analysis of capability, identifying shortfalls of resources,
and moves to the development of a generic operational plan with annexes for
the unique aspects of individual emergencies, the maintenance of capability,
mitigation activities, emergency operations, and evaluation of such
operations. The jurisdiction will then prepare a multiyear development plan,
followed by annual plan increments as the process proceeds. A very key
element is the intra- and inter-jurisdictional coordination to be certain that all
the players recognize, and are able to execute, their responsibilities if put to
the test. By following this process, a community can establish an emergency
management system, with readiness to deal with both the common elements
of preparedness and those requirements which are unique to individual
emergencies. There are a few shortcuts that perhaps are practical in certain
situations. But anything that deviates significantly from the above results in
something significantly less than integrated planning.
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FINDINGS
Community preparedness is today adequate if evaluated in terms of
capability to cope effectively with a localized chemical incident. This includes
evacuation of a major segment of population from a single designated area.
(The recent Larry Flicker Co. incident is a case in point.) The one exception
to this favorable assessment is in the area of training and equipping
HAZMAT team personnel Some improvement is needed on both counts.
The reason for this generally encouraging assessment is the exceptional
competence and esprit which characterizes the state of readiness of fire
department personnel located in the more critical areas of the basin, Le.,
critical from the standpoint of vulnerability to a major toxic chemical
incident. Wen it not for the high degree of training and professionalism
evidenced by these personnel, the overall threat would increase dramatically
and hence reduce our estimate of the community's ability to quickly and
effectively respond to a severe localized incident.
Community preparedness is today not adequate if evaluated in terms of
capability to effectively cope with a chemical disaster of Bhopal proportions,
whether caused by earthquake, sabotage or otherwise. This scenario foresees
large segments of a county or counties being simultaneously impacted by
toxic emissions causing instantaneous and widespread damage. Some
progress is being made toward adequate prepardness for a major disaster.
Considerably more remains to be done. If the timetable is to be accelerated,
preparedness priorities must be revised. In the present climate of budget
austerity and parochial thinking integrated planning, however essential, is
not a realistic possibility.
RECOMMENDATIONS
The recommendations that follow are categorized as: (a) Those actions that
appear within the purview of the SCAQMD Governing Board for imple-
mentation; and (b) Those actions that may more appropriately require county
or state level involvement.
SCAQMD Actions
1. The SCAQMD should serve as a catalyst and coordinator in facilitating a
dialogue among industry, neighboring communities, and local disaster
preparedness officials aimed at allaying concerns and fostering more
cooperation. A prime target for this assistance is small businesses which lack
the know-how and the internal organizational structure to take these
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initiatives, yet would be favorably disposed to follow the lead of an overall
coordinator. This form of cooperation -could readily carry over into the
emergency planning area and result in an integration of effort well beyond
where we are today.
2. The SCAQMD Governing Board should adopt a resolution urging each
County Board of Supervisors to enact an umbrella-type "right-to-know"
ordinance, which could then be implemented by the cities on an as-needed
basis; (b) Adopt a resolution supporting CA. Assembly Bill 2185, introduced
by Assembly Members Marine Waters and Willie Brown, particularly with
regard to the requirement for disclosure of toxic materials information. It is
fundamental that unless toxic chemicals can be identified by name and
location, their control is, at best, difficult This lack of information increases
the risk for first responders to a toxic air emission or spill, and renders more
likely adverse impact on a community due to delay in the identification of a
specific chemical agent.
Today, the environment is right to get this legislation passed. Industry may
not prefer it, but neither will it choose to risk the attendant adverse publicity
that would result from any concerted opposition. Of .the 197 companies that
we surveyed, all but one readily cooperated. Even this company eventually
provided its inventory of toxic chemicals. Two companies claimed their
information was proprietary, yet made full and prompt disclosure once given
assurance that the data would be appropriately safeguarded.
The one negative associated with this issue is the cost to cities and counties of
maintaining the inventory in a current status. However, the overriding
consideration is that the rapid retrieval of this information significantly
impacts safety. Hence, those who must respond to disasters, and the
communities that are affected by them, speak with one voice in urging the
enactment of "right-to-know" ordinances.
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County/State Level Actions
7. Single Point Preparedness Authority
Effective community preparedness for mass disaster situations requires: (a)
An outlook that views the SCAB as a totality rather than as a loose
confederacy of counties and cities; and (b) An agreement that integrated
preparedness planning move forward on an expedited basis. Hence, it is
recommended that a single point preparedness Authority be appointed
preferably a State agency with representation in the SCABwhich would
have the responsibility and the concurrent power to ensure that all
jurisdictions work together in developing, and periodically exercising,
disaster preparedness plans as they pertain to both natural and technological
disasters. The proposed Authority could operate through a small working
committee with representation from each county, from industry, and from
special agencies such as the SCAQMD. This structure would not usurp the
prerogatives of local governments, but it would bring to their attention areas
where gaps in preparedness exist, particularly those that relate to intercounty
support. This, hopefully, would also result in counties moving more
expeditiousry toward getting their own house in order.
What follows is a listing, by preparedness area, of issues to be resolved, or at
least more fully coordinated. It is proposed that these actions become part of
the charter for the recommended single point preparedness Authority.
a. Emergency Medical Response System
Remedies must be found for the following: (1) an inadequate communication
and command system to tie resources together; (2) not enough triage
personnel; (3) insufficient nurses and paramedics; (4) lack of centralized
dispatching of medical assistance; (5) insufficient emergency room, hospital,
and clinic facilities to accommodate the critically and noncriticaily injured;
(6) insufficient, and not readily available, data on the antidotes and
treatments for those injured by chemical agents; and (7) absence of periodic
and realistic full-scale mass casualty drills, simulating a Bhopal-type disaster.
b. Evacuation Plans
These plans should be revised to specifically incorporate a large scale
chemical disaster scenario and to accommodate considerations outlined
under the Evacuation section of this report. The information should then be
broadly disseminated to all communities in the SCAB.
c. Emergency Broadcast System
Counties should develop an Emergency Broadcast System for their particular
area, patterned after the L.A. County EBS. This would enable all counties to
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directly access the radio broadcasters and TV stations in Los Angeles, and
thereby air advisories simultaneously within all four counties, or within
whatever fraction of these counties that may be affected by a major disaster.
Under this proposal, the 39.98 MHz frequency is a logical candidate for use
by the counties.
d. Emergency Operating Centers
One fully operational EOC per county is a mandatory requirement based on
the multiplicity of threats in the basin under which such a resource would be
activated. An inspection authority, independent from the County, should
periodically check the emergency operating centers to insure compliance with
FEM A specifications and direct that discrepancies be corrected as a matter of
priority.
2. Industry Preparedness Plans
Each petrochemical plant should be required to prepare and submit for
review, a comprehensive disaster emergency plan for its facility. The plan
should cover a spectrum of possible contingencies, to include toxic chemical
emissions resulting from earthquake and sabotage. There should be a further
requirement for periodic update. The single point preparedness authority in
the SCAB would determine who should perform the review and standardize
the procedure.
Also, industry should expand its contacts within the disaster preparedness
community. Today, these contacts are almost exclusively limited to the fire
departments.
3. Assessment by Response Scenario
The two exercises proposed in this report (pages 41-43) are a reflection of the
vast resource of competence, ingenuity, and dedication available among the
professionals in this basin. Both Dr. Doug Arterberry and Mr. Eric Hutchins
have a realistic feel for what it takes to bridge some of the gaps in EMS
planning. It is strongly recommended that the exercises they have proposed
be undertaken as a starting point for any review of EMS activity. The
Northridge Community Hospital does not have the resources to undertake
these pilot studies in isolation. Therefore, there is need for a central Authority
to seek additional support and make the appropriate commitment
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CONCLUSION
We acknowledge that there are no easy solutions to the problems of safety and
preparedness. But neither can we lose sight of the fact that we today live in an
environment, aptly described by one journalist, as perfectly legal and
unbelievably dangerous. In this basin that potential for danger is certainly
with us in abundance. Regardless of what course is chosen regarding these
recommendations, Charles Perrow perhaps said it all and said it best when he
commented that "sensible living with risky systems means keeping the
controversies alive, listening to the public and accepting the essentially
political nature of risk assessment." Ultimately the issue is not risk, it is the
exercise of power-that same power derived from the consent of the governed.
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REFERENCES
Quoted in Report;
1, "Toxic Fires Can Be Anywhere." Kim Murphy and Ronald B.-
Taylor, LA. Times dated 07/03/85.
2. "Because It Can Happen Here, Localities Want Tougher Rules on
Dangerous Cargo." Rochelle L. Stanfield, National Journal dated
2/23/85.
3. "Chemical Disaster Preparedness at the Local Community Level." E.
L. Quarantelli, Journal of Hazardous Materials 8 (1984) 239-249.
4. "Community and Organizational Awareness of, and Preparation for
Acute Chemical Emergencies." Kathleen J. Tierney, Journal of
Hazardous Materials. 4 (1981) 331-341
5. Evacuation Behavior and Problems: Findings and Implications from
the Research Literature. E. L. Quarantelli with Barbara Baisden and
Timothy Bourdess, Book and Monograph Series #6. DRC, University
of Delaware, 1984.
6. "EMS Delivery in Mass Emergencies: Preliminary Research Find-
ings." Kathleen J. Tierney and Vera A. Taylor. Mass Emergencies. 2
(1977) 15H57.'
Background Data:
1. "Characteristic Patterns of and Variations in Community Response to
Acute Chemical Emergencies." Jane Gray, Journal of Hazardous
Materials. 4 (1981) 357-365.
2. "When Disaster Strikes (It Isnt Much Like You've Heard and Read
About)." E. L. Quarantelli and Russell R. Dynes, Psychology Today,
Feb. 1972.
3. "Community Response to Earthquake Threat in Southern California.
Part 10 Summary and Recommendations." U.S. Department of
Consumers, National Technical Information Service 198L
4. "The Assessment of Community Vulnerability to Acute Hazardous
Materials." Gabor, Thomas and Griffith, Terri K. Journal of
Hazardous Materials. 3 (1980) 323-333.
5. "The Comparative Study of Disaster": Dynes, Russell R. Mass
Emergencies 1 (1975) 21-31.
6. "Human Behavior in Disaster." Quarantelli, E.L. Proceedings of the
Conference to Survive Disaster. Chicago. ITT Research Institute
(1973) 5374.
7. Delivery of Emergency Medical Services in Disasters: Assumptions
and Realities. E. L. Quarantelli, Irvington Publishers, New York.
1983.
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ACKNOWLEDGMENTS
As noted earlier, the data reflected in this report was drawn from myriad
sources, Le. state and government agencies, local emergency response
agencies, the private and public sectors, the academic community.
We found invaluable, the research efforts and insights shared with us by such
acknowledged experts in their area of specialization as Professor E. L.
Quanntelli and Professor Russell Dynes from the Disaster Research Center,
Kathleen J. Tierney, Ph.D., Department of Sociology, University of
California at Los Angeles, and Institute of Safety and Systems Management,
University of Southern California; Ira Zimmerman, Ph.D., from New York
University; Stanley Dolins, Ph.D., from the Nuclear Regulatory Com-
mission; and John D. Arterberry, M.D., from the Northridge Community
Hospital.
We also take note of the cooperation and courtisies extended us by the
Elsevier Scientific Publishing Company, Amsterdam, the Netherlands which
publishes the Journal of Hazardous Materials.
Finally, we acknowledge as our primary source of information the practical,
day-to-day experience shared with us by those who serve "on the line"-
particularly the fire, sheriff and medical personnel with whom rests the
ultimate responsibility for translating plans into action.
To all of the above we offer our gratitude.
67
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Appendix A
COMPANIES SENT HAZARDOUS MATERIALS QUESTIONNAIRE
Aerojet Ordnance Company
Air Products & Chemicals, Inc.
Industry
Air Products & Chemicals, Inc.
Long Beach
Alflex Corporation
Allied Corporation
Allied Kelite Products Oiv.
Alpha Resins Company
American Pharmaseal Laboratories
Amoco Chemicals Corporation
Amvac Chemical Corporation
Anabolic, Inc.
Angeles Chemical Company
ARCO Battery Manufacturing Co.
Armstrong World Industries, Inc.
Ashland Chemical Company
Santa Fe Springs
Ashland Chemical Company
Montebello
Atlantic Richfield Company
Baron-Slakes lee, Inc.
Bauer Coatings & Chemical Co.
8. F. Goodrich Chemical Company
Bordon, Inc.
Boyle-Midway
Cal Compact Foods, Inc.
California Sulphur
Calsol, Inc.
Cargill, Inc.
Carny-Chemical Company
Carrasco Vacuum Truck Service
Celanese Specialty Resins
ChampUn Petroleum Company
Chase Chemical Company
Chem Lab Products
Chevron Chemical Company
Chevron USA Refinery
Chili Products Company
Ciba-Geigy Composites Division
Cine-Tech, Inc.
Cintas Uniform Corp.
City Tank Line, Inc.
Clorox Company
Coast Detergents, Inc.
Cominco American, Inc.
Consolidated Film Industries
Continental Chemical Company
Continental Graphics
Cool Transports, Inc.
Coral Chemicals, Inc.
68
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-2-
Coral Chemicals, Inc.(tank fann)
Cosden Oil & Chemical Co.
Crescent Warehouse Co.
Cyclo Products, Inc.
Data Products Corporation
Deepwater Chemical Co.
Delco Remy 01v., General Motors
Deluxe Lab., Inc.
Oexol Industries, Inc.
Diamond Tankllnes & Transportation
Douglas Aircraft Company
Dow Chemical Company
Duncan Battery Co.
Eastman Kodak Company
Economics Lab., Inc.
Edgington 011 Company
Electro Bleach Products
Emery Industries
Essex Group, Inc.
Estee Battery Co., Inc.
Ethyl Corporation
Farm-Aid, Inc.
Ferro Corporation
Fletcher Oil Company
Flo-Kern Products, Inc.
FMC Corporation
Foto-Kem Industries, Inc.
Four Corners Pipeline Co.
Four Star Chemicals, Inc.
Garden State Paper Co.
GATX Storage Terminals Corp.
General Battery Corp.
Getty Synthetic Fuels, Inc.
Golden West Refining Co.
Goodwin Chemical Co.
Grow Chemical Coatings Corp.
Harbor Terminal Service
Hatchco
Henkel Corporation
H111 Bros. Chemical Co.
H. J. Baker & Bro., Inc.
Hugh J. Resins Co., Inc.
Huntway Refining Co.
Hyperion Waste Water Treatment Plant
Industrial Bettery Engineering, Inc.
Industrial Waste Engineering
Inmont Corporation
International Paper Co.
69
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-3-
J. C.t Inc., Liquid Waste Disposal
J. C. Penney Co. Drapery Cleaning
Johnson Controls, Inc.
Jones Chemicals
Keysor-Century Corporation
Koppers Company, Inc.
Lever Bros. Company
Lilly Industrial Coatings, Inc.
Liquid Air, Inc.
Long Beach 011 Development Co.
Los Angeles County Sanitation Districts
Carson
Los Angeles Soap Company
LIN Uniform Supply Company
Lunday-Thagard Oil Company
Nalco Chemical Company
National Chemical Corporation
Neville Chemical Co., Chlorinated Products
Neville Chemical Co.
Newhall Refining Co., Inc.
Nlklor Chemical Company
North American Environmental
Northrop Corporation
Oakite Products, Inc.
Oil S Solvent Process Co.
Omega Chemical Corporation
Orange County Chemical Company
Orange County Water District
Fountain Valley
Owens-Illinois, Inc.
Ozalid Corporation
Maori 11 an Ring-Free Oil Co., Inc.
McKesson Chemical Company
Merit Group, Inc.
MGM Lab., Inc.
Micro-Biotrol, Inc.
Mobil Chemical Company
Mobil Oil Corporation
Modern Coverall 4 Uniform Supply
Monsanto Company
Movielab-Hollywood, Inc.
Paramount Petroleum Corporation
Pervo Paint Co., Inc.
Petrolane, Inc.
Petrolane Lomita Gasoline Co.
Pharmavite Pharmaceutical Corp.
Phillips Oil Company
Pilot Chemical Company
Poly Resins
PPG Industries
Proctor & Gamble Manufacturing Co.
70
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-4-
Products Research & Chamical Corp.
International Polymer
Prudential Overall Supply Co.
Riverside
Prudential Overall Supply Co.
Van Nuys
Purex Corporation
Quemtco, Inc.
Reichhold Chemicals, Inc.
Shell 011 Company
Sllmar, Oiv. of Sohio Chen. Co.
Sinclair Paint Company
Sloan's Dry Cleaners
Solder Plus
Southern California Chemical Co.
Southern California Edison, Colton
Southern California Edison, Redondo Beach
Southern California Gas Company
Space Age Chemicals
Spectra Color Lab., Inc.
Stapelton Company
Stauffer Chemical Co., South Gate
Stauffer Chemical Co., Carson
Stepan Company
Sterilization Services of California
Technicolor Corporation
Teledyne Battery Products
Texaco, Inc.
Texaco, Inc., Montebello Research Lab.
Textile Rubber & Chemical Co.
Timco
Toxo Spray Oust, Inc.
Trojan Battery Company
TRW
Union Carbide Corporation
Solvents & Coatings Materials
Union Carbide Corporation
Emulsion Systems
Union Carbide, Linde Oiv.
Fontana
Union Carbide. Linde 01v.
Ontario
Union Chemical Oiv., Union Oil
Union 011 Company of California, Wilmington
United Chemical J Supply Co.
Upjohn Company
U. S. Borax & Chemical Corp.
U. S. Industrial Chemical Co.
U. S. S. Agr1-Chem, Inc.
Waste Disposal Services, Inc.
Watson Siogas System
71
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-5-
Western Disposal Company
Western Fuel Oil Company
Western Sulphur Company
West Newport 011 Company
Whittaker Corp., Bermite Division
Wilmington Liquid Bulk Terminals
Witco Chemical Corporation
World Industries International, Inc.
Wyle Lab
72
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Appendix B
South Coast
AIR QUALITY MANAGEMENT DISTRICT
9150 FLAIR DRIVE. EL MONTE. CA 91731 (213) 572-6200
SAMPLE LETTER TO COMPANIES
February 1, 1985
Dear *
The recent disaster in Bhopal, India, focused world attention
on the potential for calamity from the accidental release of
toxic air emissions. I believe the safety record of the
American chemical and energy industries is impressive.
However, in the wake of the Dhopal tragedy, a national
priority has been aecorded--both by government and
1ndustry--to a review of the potential for similar accidents
in the United States.
Based upon a cursory review of our local situation, the South
Coast Air Quality Management district has concluded that:
* A Bhopal-type incident, though less likely here, cannot
be ruled out as a possibility.
0 Current contingency plans are oriented primarily toward
the localized emergency and may not he adequate to cope
with a disaster requiring mass civil notification and
evacuati on.
Accordingly, the District's Governing Board, with the support
from state and local authorities, has directed that a study he
undertaken addressing both th.e state of accident prevention
and the state of emergency response within the South Coast Air
Basin. The study's focus is on the major catastrophe-type
incident and will consist of two concurrent phases:
1. A prevention and response assessment of industrial
stationary sources, to include data gathering and
select on-site surveys.
2. An assessment of state and local contingency plans
relating to community preparedness in the event of
such a catastrophe.
73
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-2-
Th1s letter 1s Intended to Inform you of our study, to solicit
your assistance and support, and to stress the Importance of a
timely response to our request for data. Specifically, I am
requesting that the attached questionnaire be completed and
returned to my office by February 28, 1985. (Similar
Inquiries for data have been sent to appropriate state/local
agencies to ensure that our data base 1s adequate and truly
representative of the South Coast Air 8as1n.) We have worked
closely with Industry representatives In Its preparation to
ensure that the release of the Information to us 1n no way
compromises any trade secrets or proprietary Information that
we recognize must be protected. Also, we are aware that
agencies of the state and federal government may later conduct
separate Inquiries on a broader aspect of this subject. To
the extent practicable, we will coordinate this effort with
such agencies to avoid needless duplication and Inconvenience
to you.
I reiterate the Importance of a timely response to ensure that
your company has been appropriately represented. In making
this a cooperative effort, rather than one done In Isolation
with fragmented and possibly outdated Information, your
Interests and those of communities within the District will
best be served.
If you have any questions regarding the study or
questionnaire, please contact either Mr. Sene Calafato
(818/572-6451) or, In his absence, me at (318/572-6400).
Thank you for your cooperation.
Very truly yours,
"3. A. Stuart
Executive Officer
JAS:pmj
Attachment
74
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Appendix C
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT
HAZARDOUS MATERIALS SURVEY QUESTIONNAIRE
PART A; 6ENERAL COMPANY INFORMATION
Facility Nane: Date:
Facility location: Phone: jj J_
Company NMM:
Parent Conpany:
Type) of Plant: (I.e.. petrol em refinery. »«tjl-pl«t1nq shop, etc.)
(Picas* g1»e a brltf description of your plant. The natirlals you Mk«.
tht procnsM used, when plant was built. Please use a continuation
sheet If required.)
SIC NO.:
Nane of PrlMry Contact Person:
Address:
Phone: j ]_
Title:
Na«e of Alternate Contact Person:
Address:
Phone: _J ]_
Tftle:
75
-------
-z-
PART 8: HAZARDOUS MATERIALS INFORMATION
1. Materials Inventory
Attached Is in Inventory of nuttrlals considered Imedlately dangerous to the life and
health of the general public If present In the ataosphere at levels of 7.000 ppw or
less. Please report the MAXIMUM, AVERAGE, and MINIMUM quantities of the listed
Materials that you maintain at your site at any tlM. Indicate how you arrive at this
number. (M-*e«sured, R-Estlaate). Also check the operations 1n which you use these
aterlals. Please arid continuation sheet If required.
Chealcal NaM
CAS No.
Maxlaui
Average
Minium
Please place "x
In appropriate
Operations column
*»
w
3
U
O.
Ml
m
«
^ ^
« «
U. M
3 <«
** t-
(J 41
* e
W 41
a v
e
-------
-3-
Materlals Inventory (continued)
In addition to the specified chemicals, are there any substances at your location that
could b« (Mediately dangerous to the life and health of the general public If present
In the ataospnert at levels of 2,000 pp» or less? If so, please list the substances
and the quantities you have on site. Indicating how you arrive at this number. Also,
check the operation! In which you use these naterlals. Please add continuation sheet
If required.
Chealeal Ma«e
CAS NO.
HaxlMM
Average
H1n1au>
Please place "x
In appropriate
Operations column
4rf
W
3
O
O
k
&
IA
X
^
41
fc
a
^ ^
« «
1. 4^
3 «
*l i.
SS
iS
5U
0
^
41
a
a
77
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2. Safety Ft«tur*j
As attachment 1 to this survey, please describe the safety precautions you observe when
handling hazardous Materials of the type Identified under 'Materials Inventory.*
Please comaint specifically if these substances are under refrigeration or pressure and
ho* you prevent uncontrolled releases. For example, precautions against tank ruptures.
utility failures, earthquakes, etc.
3. Security Features
As attachment 2, please describe security precautions at your site. How do you guard
against vandalism, sabotage, and unauthorized entry? no you have fences, guards,
alarm, etc.?
4. Audits
As attachment 3, please Indicate 1f you conduct any self audit of your facility? If
so, at neat frequency? When «as the last audit? If possible. Include a synopsis or a
copy of the latest audit.
S. Incident History
As attachment 4. please provide a chronology of all safety related Incidents that have
occurred In the past 3 years that are reportable under Federal and State regulations.
S. Permits
As attachment S, please list the permits you have received from Federal, State, and
local agencies for the handling of the above listed hazardous materials.
7. Outside Inspections
As attachment S, please 11st by agency and date. Any hazardous materials related
Inspection of your site during the past 3 years.
Training
8. As Attachment 7, please describe the In-house training conducted for wjrkers and staff
related to equipment safety, noting how frequently this training Is administered.
78
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-s-
fABT C: CONTAIHMENT/EVACUATIOM INFQOHATIOM
. Emergency coaaunlcatldn, alara*. and equipment; (Pleat* us* continuation sheets «i required)
Location Description of Equipment
Internal Comnunlcation and Alanu
Eiternal Connunicatlons and Alanu
Fire fighting Equipment
Spill Control Equipment
Oecontaalnatlon Equipment
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-6-
!. Arrangements with Local Authorities
A. Please Indicate below the local authorities
(If any) with whom agreements exist
relative to alert and evacuation In the
event of a disaster. As attachment ft,
please provide a copy or synopsis af these
agreements.
Local Authorities
please Identify by organization
ind phone number)
'ollce;
Primary:
Alternate:
'Ire Department:
Primary:
Alternate:
.ocal Emergency Response Team:
Primary:
Alternate:
itate Emergency Response Team:
Primary:
Alternate:
aerqeney Response Contractors:
Primary:
Alternate:
u
M
b
» «J
1!
(please
approp
! ** ~ «.
*27
i*
< &
P- M «r
« P-
-. O J=
Itposst pu
place "
'late co
41
C
C
M O
U U
^51
t- « 0
« * C CT
P- C
fl 4» 3 t.
(h in
umn)
w» 4*
w j:
U *J
e
« c
o
L. U >,
e u
Mar with possible
jatlon routes
*» u
80
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-7-
B. Please list any hospitals or medical clinics and doctors that have specialized
knowledge concerning the properties of hazardous materials handled at your facility.
Hospitals; (please Identify by name)
Prlmry: .
Alternate:
Non«: Q
Doctors;
Pr1«»ry: __
Alternate:
None: |~|
C. Emergency Procedures;
Pleat* describe your emergency procedures for each of the following 1n the event an
Incident should require sone measure of civil alert or evacuation. (Either enclose a
plan, or a sumMry of saute, as attachment 9.)
A. Plre:
B. Explosions:
81
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-8-
C. Emergency Procedures: (continued)
C. Helenes of Hazardous Materials:
0. Evacuation;
82
-------
Appendix D
COMPANIES AUDITED (ON-S1TE)
Allied Corporacion
Amvac Chemical Corporation
B. F. Goodrich
Cargill Chemical Products
Chevron
Dow Chemical USA
GATX
Golden West Refining
Jones Chemicals, Inc.
Keysor-Cencury Corporation
Monsanto
Neville
Niklor Chemical Company
Paramount Petroleum Corporation
Procter and Gamble
Stepan
Texaco
Upjohn
Witco
83
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Appendix E
South Coast
AIR QUALITY MANAGEMENT DISTRICT
9150FLAIHORIV6. EL MONTE. CA 91731 (818)572-6200
AUDIT CHECKLIST
I. SUPPORT OPERATIONS
A. Safety Organization
1. To what level of management does the organization report?
2. What are the qualifications of the person responsible for
safety?
3. What is the size and capabilities of the safety organization?
4. What are its functions?
5. Is there a formalized safety program?
6. How is it structured?
7. Are there regular employee meetings in which safety is the
primary topic?
8. Training
1. What type of training is administered to operators of equipment
used in conjunction with hazardous materials?
2. Are there refresher courses, tests, or certifications required?
C. Maintenance
1. Is there a program of regular preventative maintenance?
2. How is safety equipment tested and maintained?
0. Checks/Audits
1. Are self-audits conducted on a scheduled basis?
2. Have any technical audits by outside parties been commissioned
within the last three years?
-------
-2-
E. Emergency Plans
1. How is the emergency response system organized for reaction
to non-work hour emergencies, such as:
a. Earthquake
b. Flood
c. Fire
d. Sabotage/terrorist
e. Hazardous materials release
II. RECORDS
A. How are plant records maintained relating to incidents/injuries/
releases related to the handling, storage, use and disposal of
hazardous material? Have there been any significant incidents?
B. When and how are these incidents reported and to whom? What are
the required actions?
C. Determine from plant records the maximum amount of hazardous
materials stored on the site for the past three years. How do
these values compare to those reported in the questionnaire?
0. Plant Construction
1. When was the plant built? By whom?
2. What are the design and construction criteria?
3. Have there been any additions or modifications?
4. When and what were these changes?
III. PROCESS OPERATIONS
A. Transfer of Hazardous Material into the Plant
1. How does material arrive at the plant?
2. Is there a check to determine if it is the correct material
before unloading?
3. How is it unloaded?
4. Is there a standby crew during-unloading?
85
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-3-
5. What safety precautions?
6. Is a supervisor present?
7. Under what circumstances will material not be unloaded?
8. Use of Hazardous Materials
1. How is hazardous material used in process?
2. How are process variables controlled to prevent overheating
or overpressuring of hazardous material?
3. How are plant operators notified of process upset?
4. Do you have redundancy of safety and warning systems?
5. Is there a safety margin in the plant design?
6. In the event of a leak, are there any control systems that
will capture or neutralize released materials?
C. Storage of Hazardous Material
1. What are the sizes of the storage vessels?
2. What are their safety features? If refrigeration, heating,
cooling or other special precaution is needed, are there
backup systems?
3. Are temperature, pressure, quantity monitored? Connected to alarms?
4. Can leaks or contamination be quickly ascertained?
5. How Is monitoring evaluated?
D. How are waste hazardous materials disposed of?
IV. LOCATION AND SETTING
A. Population
1. What 1s population within one mile radius? Within five mile radius?
2. Distance to freeways?
3. Distance to schools, hospitals, etc?
8. Meteorology
1. What are the prevailing wind directions?
2 April 1985
86
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Appendix F
South Coast
AIR QUALITY MANAGEMENT DISTRICT
91 SO FLAM DRIVE. EL MONTE. CA 31731 (213) 572-6200
SAMPLE LETTER TO COUNTIES February 11. 1985
The disaster in Bnopal. India, focused world attention on the potential
for calamity from che accidental release of toxic air emissions. In the
wake of the Bhopal tragedy, a national priority has been accordedboth
by government and Industryto a review of the potential for similar
accidents in the United States.
Based upon a cursory examination of our local situation, the South Coast
Air Quality Management District has concluded chat:
o A Bhopal-type Incident, chough less likely here, cannot be
ruled out as a possibility.
o Current contingency plans are oriented primarily coward che
localized emergency and may not be adequate to cope with a
disaster requiring mass civil notification and evacuation.
Accordingly, the District's Governing Board, with support from state
and local authorities, has directed that a study be undertaken addressing
both che state of accident prevention and the state of emergency response
within che South Coast Air Basin. The study's focus is primarily on che
major catastrophe-type incident and will consist of cwo concurrent phases.
1. A prevention and response assessment of industrial stationary
sources within che District, to include data gathering and
select on-slte surveys.
2. An assessment of state and local contingency plans relating co
community preparedness in che evenc of such a catastrophe.
87
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Mr. Arnold White -2- February 11. 1985
This letter is intended to inform you of our scudy, to solicit your
assistance and support, and to stress the importance of a timely
response to our request for data. Specifically, 1 am requesting chat
the attached questionnaire be returned to my office by March 4. 1985.
We are working closely with the appropriate state agencies in coordi-
nating this study. However, the local jurisdictions, at the county and
city levels, are the key sources from which data is needed. These also
are the sources with whom we will work closely in developing realistic
recommendations. Due to time constraints. It is unpractical to gather
data for all the cities that come under the purview of the South Coast Air
Basin. However, la your reply, we ask that you Include at least those
cities within the county which,In your judgment, could require emergency
evacuation of a large fraction of the population due to the accidental
emission Into the atmosphere of a hazardous substance from a stationary
site.
Whereas no single effort is ever a panacea for getting everything done,
we believe this study may help alleviate certain community concerns and
also place in sharper focus the additional resources that may be needed
to ensure adequate preparedness should a major disaster occur.
If you have any questions regarding the project or questionnaire, please
contact Mr. Gene Calafaro (818) 572-6451 or. in his absence, me at
(818) 572-6400.
Thank you for your cooperation.
Very truly yours.
. A. Stuart
Executive Officer
JAS:drw
Attachment
-------
Appendix G
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT
CIVIL PREPAREDNESS QUESTIONNAIRE
Nome of County:
Civil Preparedness Contact
Name:
Address:
Phone: ( )
1. ORDINANCE ("Right to Know" by a community as to which chemicals are
manufactured, stored, trans-shipped in that community)
A. Please Indicate which cities In your county have a "right to know"
ordinance and the date it became effective. Please provide a copy
of each ordinance if readily available.
City Effective Date
B. Please indicate which cities in your county are now actively
considering the adoption of a "right to know" ordinance as
described above.
39
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-2-
U. HAZARDOUS SUBSTANCE INVENTORY
A. At either the county or city level, does there currently exist
any comprehensive and currently maintained inventory of
hazardous substances manufactured and/or stored in the
county or in a city. (This includes those inventories
maintained by the respective fire departments.) Yes No
B. If the answer above is "yes", please provide the following
information for each inventory:
Location (City) Frequency
of Inventory Contact Point of Update
C. If the answer to "A" above is "no", tor which cities (if any) would
the County consider such an inventory either "essential" or "useful".
(Please check appropriate blank)
City Essential Useful
90
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-3-
111. NOTIFICATION AND EVACUATION
A. Over the past three years, has there been any toxic release
in the county that required the mass temporary evacuation
of 300 or more people? Yes No
8. If the answer to "A" is ''yes", for each incident please specify:
Location Toxic Substance No. of People
Date City & Plane Released Evacuated Injured
C. Do any county or city plans currently require the exercise of
alert or evacuation procedures at specified Intervals? Yes No
O. If the answer to "C" is "yes", please identify the plan(s) and
indicate the date
-------
E. Please specify by cicy clw cype of alert/warning system
currently in effect to notify residents of the need to evacuate.
Also, please provide a copy of any plan/procedure relating
to the implementation of this system. (Please use continua-
tion sheet, if required.)
City System Description: Manufacturer-Model Designation
F. Do you consider these systems adequate in all essential'aspects.
l.e., response time, range, etc. 7 Yea No
G. If the answer to "F' Is "no", what would be required to make it
satisfactory (to Include coat)?
IV. TRAINING
A. Please indicate for each Hazardous Material Team in your county the
following information: (Please use continuation sheet if required.)
No. of Degree of Readiness
Location Personnel Fully Qualified Partially Qualified
-------
B. Do you consider the current number of teams adequate co meet
the requirements of your county? Yes No
C. If the answer to "B" is "no", please provide the following
information for each additional team required:
Location (City) No. of Personnel Estimated Cost
O. What is the average elapsed time between incident notification and
on scene arrival for the Hazardous Material team?
E. Li the level of training for fire department personnel in each city
adequate to cope with accidental toxic air emissions? Yes No
F. If the answer to "E" la "no", please specify by city the type of
additional training required and the approximate coat. (Please
use continuation sheet if required.)
City Training Estimated Cost
93
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-6-
G. Please provide a copy of all county-issued plans/procedures
relating to community emergency evacuation.
V. OVERALL ASSESSMENT
A. Given today's resources, are the cities you have selected capable
of satisfactorily carrying out the mass evacuation of 1000 or more
residents in che event of a primary disaster, i.e.. one which strikes
suddenly and causes widespread death and injury? Yes No
B. If the answer to "A" is "no", please prioritize below the resources
that are required to achieve a satisfactory readiness standard. In
each case, please- Itemize approximate cose and relate this informa-
tion to a specific city.
City Resources Required Estimated Cost
94
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Appendix H
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT
HAZARDOUS MATERIALS INVENTORY
CHEMICAL NAME
AcROLE IN
ACRYLONITRILE
ALLYL ALCOHOL
ALLYL CHLORIDE
AMMONIA
ARSINE
BENZENE
BETA-PROPIOLACTONE
CROTONALOEHYOE
CYANOGEN
CYANOGEN CHLORIDE
DlAZOMETHANE
OlBORANE
DI ETHYLAM IN6
Dl1SOPROPYLAMINE
DlMETHYLAMINE
SIS-CHLOROMETHYL ETHER I,!-OIMETHYLHYDRAZINE
BORON TRIFLUORIDE
BROMINE
BROMOACETONE
1,3-BUTAOIENE
N-BUTYL AMI HE
CARBON OISULFIDE
CARBON MONOXIDE
CARBON TETRACHLORIDE
CHLORINE
CHLORINE DIOXIDE
CHLORINE TRIFLUORIDE
CHLOROACETALOEHYDE
CHLOROFORM
CHLOROPICRIN
CHLOROPRENE
DIOXANE
DlPHOSGENE
EPICHLOROHYDRIN
ETHYLACRYLATE
ETHYLENE CHLOROHYORIN
ETHYLENE DISROMIDE
ETHYLENE OICHLORIOE
HYDROGEN CHLORIDE
HYDROGEN CYANIDE
HYDROGEN FLOUR IDE
HYDROGEN SELENIDE
HYDROGEN SULFIDE
KETENE
METHYL ACRYLATE
METHYL BROMIDE
METHYL CHLOROFORM
METHYL CHLOROMETHYL ETHER
METHYL DICHLOROARSINE
METHYL IODIDE
METHYL ISOCYANATE
METHYL ETHYL MERCAPTAN
METHYLAMINE
MONOMETHYL HYDRAZINE
ETHYLENE DICHLOROARSINE NICKEL CARBONYL
ETHYLENE IMINE
ETHYLENE OXIDE
ETHYLENE
FLUORINE
FORMIC ACID
HYDRAZINE
HYDROGEN BROMIDE
-1-
NITRIC ACID
NITRIC OXIDE
NITROGEN DIOXIDE
NITROGEN TETROXIDE
NITROGEN TRIFLUORIOE
NlTROMETHANE
N-NlTROSODIMETHYL AMINE
95
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SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT
HAZARDOUS MATERIALS INVENTORY
CHEMICAL NAHE
OLEUM
OSMIUM TETROXIOE
OXYGEN DIFLUORIDE
OZONE
PCB's
PENTABORANE
PERCHLOROMETHYL
MERCAPTAN
PERCHLORYL FLUORIDE
PHOSGENE
PHOSPHINE
TOLUENE OIISOCYANATE
PERCHLOROETHYLENE
PENTACHLOROPHENOL
PHOSPHORUS
PENTACHLORIOE
PHOSPHORUS TRICHLORIDE
PROPYLENE OICHLORIOE
PROPYLENE IMINE
PROPYLENE OXIDE
SELENIUM HEXAFLUORIOE
STIBINE
STYRENE
SULFUR DIOXIDE
SULFUR PENTAFLUORIOE
SULFURYL FLUORIDE
TELLURIUM HEXAFLUORIDE
TETRAMETHYL LEAD
TETRAMETHYL
SUCCINONtTRILE
TITANIUM TETRACHLORIDE
TOLUENE
1 * 1,1-TRICHLOROETHANE
TRICHLOROETHYLENE
TRIETHYLAMINE
TRIMETHYLAMINE
VINYL CHLORIDE
96
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Appendix I
SAMPLE LETTER TO CITIES
March 8, 1985
In December 1984, shortly after the disaster in Bhopal, India,
the South Coast Air Quality Management District conducted a
cursory review of our preparedness In the South Coast Air
Basin area and concluded that:
* A Bhopal-type Incident, though less likely here, cannot
be ruled out as a possibility.
Current contingency plans are oriented primarily toward
the localized emergency and may not be adequate to cope
with a disaster requiring mass civil notification and
evacuation.
Accordingly, the District's Governing Board, with the support
from state and local authorities, directed that a study be
undertaken addressing both the state of accident prevention
and the state of emergency response within the South Coast Air
Basin. The study's focus 1s on the major catastrophe-type
Incident and consists of two concurrent phases:
1. A prevention and response assessment of Industrial
stationary sources, to Include data gathering and
select on-s1te surveys.
2. An assessment of state and local contingency plans
relating to community preparedness in the event of
such a catastrophe.
In the course of the December review, numerous contacts were
made with local fire department and law enforcement personnel.
From these meetings 1t became clear that additional resources
are needed at the city level, and better Integration of
support activities is required at all levels, in order to cope
with a major disaster that could impact a thousand or more
people. Hence, a prime focus of the current study Is directed
97
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-2-
toward Identifying specifics In this regard and developing a
supportable basis to justify the additional expenditures that
will be required.
Approximately one month ago a questionnaire was sent to each
county office responsible for disaster preparedness requesting
assistance In obtaining data and formulating recommendations.
Our Initial approach was to work through the County Disaster
Preparedness offices In view of their broad responsibilities
In this area and an expressed Interest by some In being the
principal coordinator for this effort. So far the general
response has been excellent and In three of the counties the
data gathering 1s proceeding well. However, Los Angeles
County because of Its size and the high concentration of
Industry poses some complexity. In a letter received from
A. A. Hearne, Environmental Management Deputy, Department
of Health Services, 1t 1s suggested that we work directly with
the cities In determining Individual problems and needs
associated with emergency response. (I am Including for your
Information a copy of Mr. Hearne's letter and of the data
provided by the County.)
Our most Immediate need Is for the Information requested 1n
the attached questionnaire. This can best be provided by
those who ultimately have the operational responsibility for
getting the job done. We have found that these also are the
Individuals who cooperate most readily, recognizing fully the
Implications of being unable to respond satisfactorily in the
case of such an emergency.
Due to the time constraints Imposed by the Governing Board, I
would appreciate having the questionnaire completed and
returned by April 5, 1985. Also, it would be helpful if we
are given a focal point for contact and coordination in your
city. In certain cases, I can foresee the desirability of a
follow-on meeting between city officials responsible for
emergency preparedness and our Study Director, Mr. Gene
Calafato.
As we noted to the county officials, no single effort of this
type Is necessarily a panacea for getting everything done.
However, 1n view of the community and government attention
that is being given to the Bhopal disaster, the timing seems
right for us to jointly make a case for the resources you
require to ensure adequate response should a major disaster
occur. Toward this end, your cooperation 1s very much
needed.
98
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-3-
If you have any questions regarding the study or
questionnaire, both Gene Calafato (313) S72-64S1 and
(818) 572-6400 are available to you.
SIncerely,
A. Stuart
'Executive Officer
JAS:praj
Enclosures
99
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Appendix J
SOUTH ('.OAST AW QUALITY MANAGEMENT DISTRICT
CIVIL 1'UEl'AKEDNESS QUESTIONNAIRE
Name of City:
Civil Preparedness Contact
Name:
Address:
Phone: ( )
I. ORDINANCE
A. Please Indicate if your city has a "right co know"* ordinance
and the date It became effective. Please provide a copy of
this ordinance if readily available.
B. If your city does not have such an ordinance, please indicate
if it is now actively considering its adoption.
II. HAZARDOUS SUBSTANCE INVENTORY
A. Does there currently exist any comprehensive inventory of
hazardous substances manufactured and/or stored in your city.
Yes No
3. If the answer above is "yes", please provide the following
information for each inventory:
Frequency
Location (Zont.icc fame of Update
T'lliglu co Know" l)y a community as to which chemicals are manufactured,
stored, trans-shipped in that community)
LOO
-------
C. If die answer to "A" above is "no1", please indicate if you
consider such an inventory "essential", "useful" or
"unnecessary".
(Please check appropriate blank)
Essential Useful Unnecessary
D. If the answer to "C" above is "essential" or "useful", please
indicate by whom the inventory should be kept and how it would
be used.
HI. NOTIFICATION AND EVACUATION
A. Over the past three years, has there been any toxic release in
your city that required toe mass temporary evacuation of 300.
or more people? Yea No
3. If the answer co "A" is "yes", for each incident please specify:
Toxic Substance No. of People
Date Location Released Evacuated Injured
C. Do any county or city plans currently require Che exercise of
evacuation procedures at specified intervals? Yes No
101
-------
D. If the answer to "C" is "yes", please identity the plan(s) and
indicate the Jace(s) that the evacuation procedure has been
exercised during the past three years. (The above is exclusive
of hospital emergency exercises.)
plan Date(3) of Exercise
E. Please specify the cype of alert/warning system currently in
effect in your city to notify residents of the need to evacuate
and estimate the anticipated response time. Also, please
provide a copy of any plan/procedure relating co the imple-
mentation of this system. (Please use continuation sheet if
required.)
Systems Description: Manufacturer-Model Designation
IV. TRAINING
A. Please indicate for each Hazardous Material Team in your city
the following information: (Please use continuation sheet if required.}
No. of Degree o( Readiness
Location Personnel Fully Qualified Partially Qualified
102
-------
-*-
B. Do you consider die current number of teams adequuie to meet
your requirements? Yes No
C. If the answer to "B" is "no", please provide the following
information for each additional team required:
No. of Personnel Estimated Cost
O. What la the average elapsed time between incident notification and
on scene arrival for the Hazardous Materials team?
E. U the level of training.for fire department personnel adequate
to cope with accidental toxic air emissions? Yes No
F. U che answer to "E" is "no", please specify the type of additional
training required and the approximate cost. (Please use continua-
tion sheet U required.)
Estimated Cost
C. 1'lease provide a copy of all city-issued plans/procedures
relating to community emergency evacuation.
103
-------
V. OVHKAI .1. ASSESSMENT
A. Given today's resources, is your city capable o( satisfactorily
carrying out tlie mass evacuation of 1000 or more residents in
die event of a primary disaster, i.e. . one which strikes suddenly
and causes widespread death and injury? Yes No
B. tf the answer to "A" is "no", please prioritize below the resources
that are required to achieve a satisfactory readiness standard.
In each case, please itemize approximate cost.
Resources Required Escimaced Cost
104
-------
EXHIBIT B
EXAMPLE OF TYPICAL EXISTING
SCAQMD AIR RULE
105
-------
EXHIBIT B
EXAMPLE OF TYPICAL EXISTING
SCAQMD AIR RULE
(Adopted June 7, 1985)(Formerly Rule 1005.1)
RULE 1163. CONTROL OF VINYL CHLORIDE EMISSIONS
(a) Applicability
(1) This rule applies to plants which produce:
(A) Ethylene dichloride by reaction of oxygen and hydrogen chlo-
ride with ethylene,
(B) Vinyl chloride by any process, and/or
(C) One or more polymers containing any fraction of polymerized
vinyl chloride.
(2) The provisions of this rule apply in addition to the provisions of
Regulation X, Subpart F.
(b) Definitions
For the purpose of this rule, the following definitions shall apply:
(1) All definitions stated in Regulation X, Subpart F.
(2) Leak means the detection of vinyl chloride from any location other
than a stack vent or designed equipment opening from which vinyl
chloride exceeds the background concentration by ten ppm. Such
determination shall be made five centimeters from the potential
source, using an analyzer employing flame ionization or photodetec-
tion methods, which may be portable, and having a sensitivity of at
least 1 ppm, or by employing any device or analyzer which the Ex-
ecutive Officer determines is equivalent.
(3) Background level means the concentration of vinyl chloride in the
atmosphere within the plant premises, which is not predominently
influenced by an specific emission point, and which is determined
at least three meters upwind of any potential source being
inspected.
(4) Designated Plant means an ethylene dichloride, vinyl chloride or
polyvinyl chloride plant.
(5) Continuous Stack Monitoring means sampling is done on a continuous
basis, with actual samples being taken at least every fifteen
minutes.
(6) Modification means a physical change in, or a change in the method
of operation of, d designated plant. For the purposes of this
definition:
(A) Routine maintenance or repair shall not be considered to be
physical changes, and
(B) A change in production rate or operating hours shall not be
considered to be a change in tne method of operation, provided
that these increases are not contrary to any existing permit
to operate conditions.
(7) Receiving Vessel is a sealed container used to receive gaseous dis-
charge from vent valves and other equipment. For the purpose of
this rule, a monomer recovery vessel shall be considered as a
receiving vessel.
106
-------
Rule 1163 (Contd.) (Adopted June 7, 1985)
(c) Control Requirements
After the effective date of this rule, a person operating a designated
plant shall vent the following equiment containing more than ten pom of
vinyl chloride to air pollution control equipment or other processes
which comply with the requirements of subparagraph (e) of this rule:
(1) Vents of or appurtenances venting:
(A) Reactors.
(B) Storage tanks or surge tanks.
(C) Purification vessels or other equipment used for purification.
(D) Stripper vessels.
(E) Combination reactor-stripper vessels.
(F) Mixing, weighing or holding tanks.
(G) Monomer recovery equipment.
(H) Receiving vessel.
(I) Other equipment as required by the Executive Officer.
(2) Exemption
The provisions of paragraph (c)(l) shall not apply to equipment
which has been purged by liquid displacement and the purged gas
vented to air pollution control equipment.
(d) Ambient Air Concentration Requirements
A person operating a designated plant shall not allow the discharge into
the atmosphere of any materials which result in ambient concentrations of
vinyl chloride which are eq'ial to or greater than ten parts per billion
of vinyl chloride, 24-hour averaoe measured at any point beyond the prop-
erty line of such plant at which persons reside or work. Such measure-
ments shall be performed using method? specified by the California Air
Resources Board or any other method approved by the Executive Officer in
establishing the Vinyl Chloride Ambient Air Quality Standard. A copy of
such methods may be obtained from tho District Executive Officer upon
request.
(e) Air Pollution Control Equipment
(1) The owner or operator of the air pollution control equipment
specified in this rule shall at all times operate such equipment at
an efficiency sufficient to limit the total amount of vinyl chlo-
ride in the discharge of all cuch control equipment to less than 50
grams per hour for polyvinyl chloride plants and less than 50 grams
per hour for both ethylene dichloride and vinyl chloride plants.
Such 50 grains per hour limit shall apply to the discharge of con-
trol equipment serving all polyvinyl chloride plants on a premise.
A separate 50 gram per hour limit shall apply to the discharge of
control equipment serving any combination of ethylene dichloride
and vinyl chloride plants on a premise.
(2) A continuous stack monitoring system, or equivalent, measuring the
flow rate, concentration, and showing the mass flow rate of vinyl
chloride discharged from the control equipment shall be installed.
Such system shall be approved by the Executive Officer prior to
installation. Violations of the standard specified in subparagraph
(e)(l), as measured by such systems, shall be reported to the Ex-
ecutive Officer within two hours of such measurements. The records
107
-------
Rule 1163 (Contd.) (Adopted June 7, 1985)
from such monitoring equipment shall be maintained for two years
and shall be summarized monthly in the form and manner specified by
the Executive Officer. Whenever the stack monitoring system is not
in proper operation or out of service, alternate methods shall be
used to monitor the vinyl chloride concentrations on an hourly
schedule. The Executive Officer may waive the requirements of this
subsection for those operations for which he deems them unneces-
sary, and shall notify the District Board of the granting of such
waivers in writing.
(3) Other methods may be employed which reduce vinyl chloride emissions
to the same degree of subparagraphs (c) and (e)(l) provided that:
(A) A control plan is submitted which details the measures which
the owner or operator intends to implement, and such plan is
approved by the Executive Officer, based on his findings that
such measures are equivalent to the measures required by sub-
paragraph (e)(l).
(B) Applications are submitted for new permits to construct or
operate both the basic and control equipment involved regard-
less of whether modifications or additions are to be made
either to the basic or control equipment, or both. Existing
permits to operate pertaining to the basic and control equip-
ment as specified above shall be surrendered and canceled at
the time such new permits to construct or operate are issued.
Such new permits shall not be effective unless surrender of
such existing permits has been made. If such new permits are
denied, such existing permits surrendered pursuant to this
section shall be re-issued and restored subject to the same
conditions which were applicable to the original permits prior
to surrender and the provisions of subparagraph (e)(l) shall
be applicable.
The Executive Officer shall impose those written conditions on
such new permits specifying emission limits or other condi-
tions which may be necessary to insure that the emission
limitations under this rule are met.
(f) Operational Requirements
(1) All vent-valves are relief devices (except emergency relief valves)
on equipment upstream of the stripping operation or post catalysis
shall be vented to a receiving vessel.
(2) Product from reactors which cannot be used in subsequent opera-
tions, such as stripping, blending or drying, shall be discharged
to a sealed container, which shall be vented to a receiving vessel;
or stripped to a degree acceptable to the Executive Officer before
discharge.
(3) Failure of the rupture disc preceding an emergency relief valve
which results in a discharge to the atmosphere of vinyl chloride
monomer from equipment upstream of a stripping operation shall be
deemed a violation of this rule, unless the gaseous discharge is
vented to a receiving vessel or air pollution control equipment.
108
-------
Rule 1163 (Contd.) (Adopted June 7, 1985)
An equivalent system which has been approved by the Executive 01-
ficer may be substituted for the requirement for venting the dis-
charge of the emergency relief valve. Any discharge to the atmo-
sphere of vinyl chloride from such an equivalent system shall be
deemed a violation of this rule.
(4) Rectors and other equipment upstream from the stripper shall be
equipped with automatic pressure reduction systems which will open
at a pressure between operating pressure and the emergency pressure
relief valve setting. The vapors from such pressure reduction sys-
tems shall be directed to a receiving vessel, vapor recovery sys-
tem, or air pollution control system. The provisions of this sub-
section shall not apply to ethylene dichloride plants.
(g) Management Plan
The owner/operator of a designated plant shall submit to the Executive
Officer for his approval, a Management Plan for the reduction of vinyl
chloride emissions.
The Management Plan for the reduction of vinyl chloride emissions must
include, but is not limited to:
(1) A plan' and schedule to locate and identify all sources of vinyl
chloride emissions which might contribute to exceedences of the
ambient concentration requirements of subsection (d).
(2) An outline of a training program to routinely instruct employees,
including supervisors, on methods to prevent vinyl chloride
emissions.
(3) A method of screening operating records or other data to detect
equipment operators who may periodically cause excessive vinyl
chloride emissions because of misoperation of equipment.
(4) An outline of a special training program or other measures to
eliminate the emissions, cited in subsection (g)(l).
After approval of the Management Plan, all applicable operations
shall be conducted according to said Plan.
(h) Leaks
(1) Except as provided in subparagraph (h)(5), a person shall not use
any compressor, flange, pump, valve, storage container, process
vessels, or other equipment containing or using vinyl chloride in a
designated plant unless such equipment is free of vinyl chloride
leaks.
(2) Except as provided in subparagraph (h)(5), a person shall not use
any rail tank cars, tank trucks or shipping containers used to
transport vinyl chloride unless such equiment is free of vinyl
chloride leaks.
(3) All flanges, pumps, valves, storage containers and process vessels
shall be inspected for leaks within 90 days after the effective
date of this subparagraph. Thereafter, all compressors, pumps and
valves shall be inspected each three months following such initial
inspections. All flanges, reactors and process equipment shall be
inspected each six months following such initial inspections. All
inspections shall be the responsibility of the plant operator, and
109
-------
Rule 1163 (Contd.) (Adopted June 7, 1985)
shall include checks for possible leakage as defined in subpara-
graph (b)(2).
(4) All detected leaks by the operator shall be recorded in an inspec-
tion record along with the date and inspector's initials. Such
records shall be maintained for two years.
(5) Any detected leaks by the operator shall be eliminated within 24
hours of detection.
(6) Ninety days after the effective date of this subparagraph, except
as provided in subsection (h)(5), any leaks detected by the Dis-
trict shall be deemed a violation of this rule and shall be re-
paired and eliminated within 24 hours of detection.
(i) Ambient Air Mentoring
A person operating a designated plant shall comply wth the following re-
quirements for ambient air monitoring facilities.
(1) Provide and operate up to four air monitoring stations to con-
tinuously measure and record ambient concentrations of vinyl chlo-
ride in the vicinity of such plants. The exact number and location
of such monitoring stations shall be approved by the Executive Of-
ficer; and
(2) Provide and operate up to four additional air monitoring stations
to continuously measure and record ambient concentrations of vinyl
chloride in populated areas near such plants. The exact number and
location of such monitoring stations shall be approved by the Ex-
ecutive Officer.
(3) Calibrate and maintain the required ambient air monitoring stations
in accordance with procedures specified in subparagraph (d);
(4) Keep the records from the required air monitoring stations for a
period of two years. The data from such records shall be sum-
marized monthly and shall be submitted in the manner and form
specified by the Executive Officer.
(5) Breakdowns of the vinyl chloride ambient air monitoring equipment
shall be reported to the Executive Officer within 12 hours after
the time such breakdowns are first found. Non-operation or faulty
operation of such equipment for longer than 96 hours shall be
deemed a violation of this rule.
(6) Measure meterorological data consisting of wind direction and wind
speed. Such data shall be summarized and submittted in the form
and manner specified by the Executive Officer. The original
records shall be retained for a period of two years.
(7) A person operating a designated plant which produces ten million
pounds or less of vinyl chloride polymer, in any year, is exempt
from the provision of subsection (i)(2).
(j) New or Modified Plants
After May 1, 1980, a person shall not build a new designated plant or
modify an existing designated plant unless that person demonstrates to
the Executive Officer that the ambient air quality will not exceed the
California Vinyl Chloride Ambient Air Standards as a result of any emis-
sions from a new plant jr any increase in emissions from a modified
plant.
110
-------
Rule 1163 (Contd.)
(Adopted June 7, 1985)
(k) Exemptions
(1) A designated plant is exempt from the provisions of this rule, ex-
cept subparagraphs (g), and (h) if the plant operator can show to
the satisfaction of the Executive Officer that the plant has not
exceeded the provisions of subparagraph (d) for a period of six
months continuously, and maintain at least one air monitoring sta-
tion as required by subsection (i)(l). A designated plant which
produces ten million pounds or less of vinyl chloride polymer, an
any one year, is exempt from the air monitoring station require-
ments of this subsection.
Such exemption will be granted in writing by the Executive Officer.
After obtaining a written exemption from the Executive Officer, if
a designated plant violates the provisons of subparagraph (d), such
written exemption from the Executive Officer shall be void, unless
it is shown that such violations are caused by minor, non-periodic
and infrequent breakdowns, as determined by the Executive Officer.
(2) This rule does not apply to equipment used in research and develop-
ment if the reactor used to polymerize the vinyl chloride processed
in the equipment has a capacity of no more than 0.19 m (50
gallons).
(1) The provisions of this rule shall
pliance schedule stated below:
(1) Subparagraph
(g) Management Plan
(h) Leaks
(c) Control Requirements
.(d) Ambient Air
Concentration Requirements
be effective according to the com-
Effective Date
90 days from the adoption
this rule.
of
60 days from the adoption of
this rule.
One year from
this rule.
One year from
this rule.
the adoption of
the adoption of
(e)
Air Pollution Control
Equipment
One year from the adoption of
this rule.
One year from the adoption of
this rule.
(i) Ambient Air Monitoring
One year from
this rule.
the adoption of
(2)
Within one year from the date of adoption of this rule, a person
operating a designated plant shall install and thereafter operate
pressure indicating and recording instruments (or equivalent as
111
-------
Rule 1163 (Contd.) (Adopted June 7, 1985)
approved by the Executive Officer) monitoring the discharge of
emergency relief valves and manual vent valves located on equipment
upstream of the stripping operation. The data from such instru-
ments shall be summarized monthly and shall be submitted to the
Executive Officer in the form and manner specified. The records
from such instruments shall be maintained for two years.
(3) The provisions of subparagraph (f)(4) shall not be applicable un-
less all of the following occurs:
(A) Twelve months have passed since the date of adoption of this
rule and thereafter, two violations per month of the ambient
air concentration requirement of subparagraph (d) have oc-
curred in two consecutive months; and
(B) The Executive Officer has determined that such violations of
the concentration requirement were caused by venting of vinyl
chloride from emergency relief valves, or manual vent valves,
located on equipment upstream of the stripping operation; and
(C) The Executive Officer gives written notice of such determina-
tion, along with a specification of the basis for his deter-
mination, and a description of the equipment to be subject- to
the requirements of subparagraph (f)(4) to the owner or opera-
tor- of the source(s) determined to be responsible for such
violations.
(4) All provisions of subparagraph (f)(4) applicable to the equipment
specified by the Executive Officer in his notice of determination
shall be complied with no later than one year from the date of the
Notice of Determination.
(m) Severability
If any portion of this rule shall be found to be unenforceable, such
finding shall have no effect on the enforceability of the remaining por-
tions of the rule, which shall continue to be in full force and effect.
112
-------
EXHIBIT C
SUMMARY OF INVENTORY SURVEY OF DESIGNATED
CHEMICALS IN SCAQMD
113
-------
EXHIBIT C
SUMMARY OF INVENTORY SURVEY OF DESIGNATED
CHEMICALS IN SCAQMD
Coioany
Chlorine
Naxnui Average flinuui
Units
Hydrogen Fluoride
.laxiiui Average Nirutui Units
Refineries:
Refinery 1
Refinery 2
Refinery 3
Refinery 4
Refinery 5
Refinery 6
Refinery 7
Refinery 8
Refinery 9
Refinery 10
Refinery 11
Refinery 12
Refinery 13
Cheiical Plants:
Cheiical Plant I
Cheiicai Plant 2
Cheiical Plant 3
Cheiical Plant 4
Cheiical Plant 5
Cheiical Plant 6
Cheiical Plant 7
Cheiicai Plant 8
Cheiical Plant 9
Cheiical Plant 10
Cheiical Plant 11
Cheiical Plant 12
Cheiical Plant 13
Cheiical Plant 14
Cheiical Plant 15
Cheiical Plant 16
Cheiical Plant 17
Cheiical Plant 18
Cheiical Plant 19
Cheiical Plant 20
Chencal Plant 21
Cheiical Plant 22
Cheiicai Plant 23
Cheiical Plant 24
Cheiical Plant 25
Cheiical Plant 26
Cheiical Plant 27
Cheiical Plant 28
Cheiical Plant 29
Cheiicai Plant 30
Cheiicai Plant 31
Cheiical Plant 32
Cheiical Plant 33
Cheiical Plant 34
Cheiical Plant 35
Cheiicai Dlant 36
Iheiicai 3lant 37
20000 10000
32
40000 16000
48 23
2000 1000
2 I
4000 2000
24000 8000
8 5
24 17
5 2
3 1.5
20000
1 1
6 4
600 300
90 45
5
2
1
540000 270000
2 1
6 3
114
6000 Ibs
2000* cylinders
4000 Ibs 650000 450000
18 2000* cylinders
0 Ibs
0 2000* cylinders
500 Ibs
4000 Ibs
4 2000* cylinders 41951
10 2000* cylinders
1 2000* cylinders 5000
1 2000* cylinders
Ibs 438
1 ton
2 150* cylinders
100 Ibs
0 tons
tons
2000* cylinders
90000 Ibs
1 2000* cylinders
3 tons
0 gal
gal
gal
NSCFH
-------
Coipany
Chlorine
Naxiiui Average Minimii
Units
Hydrogen Fluoride
Naxiiui Average Niniiui Units
Cheiical Packaging:
Chei. Packaging 1
Chei. Packaging 2
Chet. Packaging 3
Chei. Packaging 4
Chei. Packaging 5
Chei. Packaging 6
Chei. Packaging 7
Hater Treatient:
Hater Treatient 1
Hater Treatient 2
Hater Treatient 3
200 100
SO 25
2000000 1000000
5 3
180 90
25
540
4
10
20
270
2
8
<1 tons
0 2x1 gal cs.
5 1501 cylinders (gas)
800000 IDS
1 tank cars
0 tons
12 20001 cylinders
90 tons (rail car)
1 2000* cylinders
2 tons
514000 300000 180000 Ibs
250
100
50 gal (70X
Misc.:
Misc. 1
Nisc. 2
Ilisc. 3
Nisc. 4
Nisc. 5
disc. 6
disc. 7
Nisc. .8
Nisc. 9
Nisc. 10
Nisc. 11
Cheiical Shipping:
Chei. Shipping I
'Cylinder Quantities Only*
'Cylinder Quantities Only*
1 0.5 0 gal
???? quantity unspecified
5500 4500 3500 gal
115
-------
Anhydrous- Aaionia Aqueous Aiionia
Coipany Naximii Average fliniiui Units Haxinui Average Hinnui Units
Refineries:
Refinery 1 15 10 5 tons
Refinery 2 22000 gal
Refinery 3 12000 6000 0 gal
Refinery 4 532 1501 cyl.
Refinery 5 500 250 100 gal
Refinery 6 1500 700 200 gal
Refinery 7
Refinery 8 80000 51000 2BOOO gal
Refinery 9 10000 1500 gal
Refinery 10 3900 1880 820 Ibs
Refinery 11 150 100 50 Ibs
Refinery 12
Refinery 13
Cheiical Plants:
Cheiical Plant 1
Cheiical Plant 2
Cheiical Plant 3
Cheiical Plant 4
Cheiical Plant 5 24000 16000 6000 gal
Cheiical Plant & 40 25 5 tons
Cheiical Plant 7 1800 900 450 Ibs
Cheiical Plant 8 1500 1000 500 Ibs
Cheiical Plant 9 2000 1400 800 Ibs
Cheiical Plant 10
Cheiical Plant 11
Cheiical Plant 12 500 300 150 gal
Cheiical Plant 13 3000 2000 1700 Ibs
Cheiical Plant 14 45840 22920 3820 Ib (24 «t
Cheiical Plant 15 7500 3000 0 gal
Cheiical Plant 16 8000 5000 2000 gal
Cheitcil Plant 17 750 245 0 Ibs
Cheiical Plant 18 200 100 50 Ib (281)
Cheiical Plant 19 7000 2000 100 ??? 6
Cheiical Plant 20 1000 <500 0 Ibs
Cheiical Plant 21 1850 1000 740 Ibs
Cheiical Plant 22 1800 1000 100 Ibs
Cheiical Plant 23 100000 65000 20000 Ib (281)
Cheiical Plant 24 1395 400 0 Ibs
Cheiical Plant 25 100 50 30 tans 45 25 7 tans
Cheiical Plant 26 7000 7000 7000 gal
Cheucal Plant 27 330 330 0 Ibs
Chencal Plant 28 6000 3000 0 Ibs
Cheiical Plant 29 3700 2000 0 Ibs
Cheiical Plant 30 4500 3000 1350 Ibs
Cheaical Plant 31 12000 6000 0 gal
Cheiical Plant 32 900 700 0 gal
Cheiical Plant 33 2000 1000 500 gal (28Xi
Cheiical Plant 34
Cheiical Plant 35
Cheiical 3!ant lt>
Zhencai 3lant ~7 i ,--
-------
Coipany
Anhydrous Aiionia Aqueous Aiionia
Naxiiui Average diniiui Units Naxiiui Average diniiui Units
Cheiical Packaging:
Chei. Packaging 1
Chei. Packaging 2
Chef. Packaging 3
Chei. Packaging 4
Chei. Packaging 5
Chei. Packaging &
Chei. Packaging 7
Hater Treatment:
Hater Treatment 1
Mater Treatient 2
Hater Treatient 3
10200 1000 gal
27000 18000 0 Ibs
5000
gal
soln)
disc.:
disc. 1
disc. 2
disc. 3
disc. 4
disc. S
disc. &
disc. 7
disc. 8
disc. 9
disc. 10
disc. 11
Cheiical Shipping:
Chei. Shipping 1
'Cylinder Quantities Only*
210 170 140 cu.ft.
20 12 4 Ibs
10200 4000 1800 gal
5
12
gal
2.5 liters
7SOO 5000 2000 gal
117
-------
Carbon Tetracnlonde Sulfur Dioxide
Coipany flax nut Average Hiniiui Units Haxnui Average Ninnui Units
Refineries:
Refinery 1
Refinery 2
Refinery 3 11025 5000 0 Ib/hr
Refinery 4
Refinery 5
Refinery 6
Refinery 7
Refinery 8 60000 19000 7000 cu.ft./hr
Refinery 9 900 100 gal 40000 30000 12000 scfl)
Refinery 10 22000 12000 100 Ibs
Refinery 11
Refinery 12
Refinery 13 40 iscfh
Cheiical Plants:
Cheiical Plant 1 420 quarts
Cheiical Plant 2
Cheiical Plant 3
Cheiical Plant 4
Cheiical Plant 5 20000 10000 2000 gal
Cheiical Plant 6
Chetical Plant 7
Cheiical Plant 3
Cheiical Plant 9
Cheiical Plant 10
Cheiical Plant 11
Cheiical Plant 12
Cheiical Plant 13
Cheiical Plant 14 50000 35000 10000 Ibs
Cheiical Plant 15
Cheiical Plant 16
Cheiical Plant 17
Cheiical Plant 18
Cheiical Plant 19
Cheiical Plant 20
Cheiical Plant 21
Cheiical Plant 22
Cheiical Plant 23
Cheiical Plant 24
Cheiical Plant 25
Chencal Plant 26
Cheiical .Plant 27
Che»ical Plant 28
Cheiical Plant 29
Cheiical Plant 30
Chetical Plant 31
Cheiical Plant 32
Cheiical Plant 33
Cheiical Plant 34 HO 55 55 gal
Cheiical Plant 35 470 250 50 tons
Chencal Plant 36 10000 50000 0 qal
Cheiical Plant 37 350 700 0 Ib
118
-------
Carbon Tetrachloride Sulfur Dioxide
Coipany flaxiiui Average Niniiui Units Maxiiui Average diniiui Units
Cheiical Packaging:
Chei. Packaging 1
Chei. Packaging 2
Chei. Packaging 3
Chei. Packaging 4 180000 80000 4000 Ibs
Chei. Packaging S
Chei. Packaging &
Chei. Packaging 7
Hater Treatient:
Mater Treatient 1
Mater Treatient 2
Hater Treatient 3
disc.:
disc. 1 'Cylinder Quantities Only
disc. 2 8 4 1 gal
disc. 3
disc. 4
disc. 5
disc. & 4000 500 il
disc. 7
disc. 8 ??? ??? ??? ???
disc. 9
disc. 10
disc. 11 120000 65000 10000 Ibs
Cheiical Shipping:
Chei. Shipping 1 20° 50 tons
119
-------
Chloropicnn
Coipany Naxiiui Average diniiui Units
Refineries:
Refinery 1
Refinery 2
Refinery 3
Refinery 4
Refinery 5
Refinery 6
Refinery 7
Refinery 8
Refinery 9
Refinery 10
Refinery 11
Refinery 12
Refinery 13
Cheiical Plants:
Cheiical Plant 1
Cheiical Plant 2
Cheiical Plant 3
Cheiical Plant 4 ISO 75 10 tons
Cheiical Plant 5
Cheiical Plant 6
Cheiical Plant 7
Cheiical Plant 9
Cheiical Plant 9
Cheiical Plant 10
Cheiical Plant 11
Cheiical Plant 12
Cheiical Plant 13
Cheiical Plant 14
Cheiical Plant IS
Cheiical Plant 16
Cheiical Plant 17
Cheiical Plant 18
Cheiical Plant 19
Cheiical Plant 20
Cheiical Plant 21
Cheiical Plant 22
Cheiical Plant 23
Cheiical Plant 24
Cheiical Plant 25
Cheiical Plant 26
Cheiical Plant 27
Cheiical Plant 28
Cheiical Plant 29
Cheiical Plant 30
Cheiical Plant 31
Cheiical Plant 32
Cheiical Plant 33
Cheiical Plant 34
Cheiical Plant 35
Cheiical Plant 36
Chencal Plant 37
120
-------
Chloropicnn
Company Maxima Average Hiniiui Units
Cheiicil Packaging:
Chef. Packaging 1
Chei. Packaging 2
'Chei. Packaging 3
Che§. Packaging 4
Chei. Packaging 5
Che§. Packaging 6
Chei. Packaging 7
Hater Treatment:
Mater Treatment 1
Hater Treatment 2
Hater Treatient 3
Rise.:
disc. 1
Hisc. 2
disc. 3
disc. 4
Hisc. 5
disc. &
Hisc. 7
disc. 8
Hisc. ?
disc. 10
disc. 11
Oieiical Shipping:
Chei. Shipping 1
121
-------
EXHIBIT D
EXAMPLE DRAFT RULE
122
-------
EXHIBIT D
EXAMPLE DRAFT RULE
EXAMPLE OF
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT RULE
CONTROL OF TOXIC CHEMICAL RELEASES
(a) Purpose
The purpose of this rule is to prevent accidental releases of
toxic chemicals, reduce the probability of accidental releases or
reduce the consequences of accidental releases of toxic chemicals by
requiring industry to anticipate circumstances that could result in
their occurrence and take appropriate precautionary and preemptive
actions.
(b) Applicability
(1) This rule applies to plants using, manufacturing, storing, handling,
or generating at any time the following designated chemicals in
quantities equal to or exceeding the specified threshold amounts:
anhydrous ammonia (to be determined by SCAQMD) CAS No. 7664-41-7;
carbon tetrachloride (to be determined by SCAQMD) CAS No. 56-23-5;
gaseous or liquid chlorine (to be determined by SCAQMD) CAS No.
7782-50-5; chloropicrin (to be determined by SCAQMD) CAS No.
76-06-2; hydrogen cyanide, CAS No. 74-90-8, and its metal salts as
solids or in solution (to be determined by SCAQMD); anhydrous
hydrogen fluoride (to be determined by SCAQMD) CAS No. 7664-39-3;
and anhydrous sulfur dioxide (to be determined by SCAQMD) CAS No.
7446-09-5. For the purpose of determining applicability, the
threshold quantities shall include the total inventory (maximum at
any one time within the last 12 months or maximum capacity) of the
designated chemical in-process or in storage within the designated
plant boundaries, and applies to mixtures of the designated
chemicals and other chemicals when the concentration of the
designated chemical is at least 80 percent by weight or greater.
(2) Vehicular storage shall be subject only to the registration and re-
lease reporting requirements contained in Sections (d) and (h) of
this rule.
(c) Definitions
For the purposes of this rule, the following definitions shall ap-
ply:
(1) All definitions stated in Regulation I, Rule 102.
(2) "Accidental release" means the spilling, leaking, pumping, purging,
emitting, emptying, discharging, escaping, dumping, or disposing
into the environment during any one-hour period of a designated
chemical which can result in release to the atmosphere in a quantity
123
-------
equal to or exceeding the following amount: anhydrous ammonia (to
be determined by SCAQMD); carbon tetrachloride (to be determined by
SCAQMD); gaseous or liquid chlorine (to be determined by SCAQMD);
chloropicrin (to be determined by SCAQMD); hydrogen cyanide and its
metal salts as solids or in solution (to be determined by SCAQMD);
anhydrous hydrogen fluoride (to be determined by SCAQMD); and
anhydrous sulfur dioxide (to be determined by SCAQMD). Accidental
releases shall not include emissions and discharges of designated
chemicals in compliance with the plant's federal, state, or local
environmental permits.
(3) "Accidental Release Control Plan" means a written program prepared
by the owner/operator of a designated plant describing all of the
risk reduction measures used to prevent or minimize the probability
of and consequences of accidental releases of designated chemicals.
(A) "Designated chemical" means anhydrous ammonia (CAS No. 7664-41-7),
carbon tetrachloride (CAS No. 56-23-5). gaseous or liquid chlorine
(CAS No. 7782-50-5). chloropicrin (CAS No. 76-06-2). hydrogen
cyanide (CAS No. 74-90-8) and its metal salts as solids or in
solution, anhydrous hydrogen fluoride (CAS No. 7664-39-3). and
anhydrous sulfur dioxide (CAS No. 7446-09-5).
(5) "Designated plant" means any facility using, manufacturing, storing,
handling, or generating a designated chemical in quantities exceed-
ing the threshold amounts specified in Section (b) above. A desig-
nated plant includes all buildings, equipment, and contiguous areas
at a single location under the ownership or control of the same per-
son.
(6) "Equipment controls" means any process, storage, or handling equip-
ment or equipment design practices used at a designated plant for
reduction of hazardous release risks. These include prevention con-
trols which are process design and operational controls that reduce
the probability of a release and protection controls which destroy
or remove the designated chemical from the potentially released pro-
cess material.
(7) "Executive Summary" means a summary of an accidental release control
plan or risk reduction plan that provides sufficient information for
the Executive Officer of the District to make a decision that the
plans summarized are adequate or determine if more information is
required.
(8) "Hazard" means an intrinsic property of a material, operation, or
piece of equipment that causes it to represent a foreseeable danger
(e.g., toxicity and flammability are hazardous properties of H S) .
124
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(9) "Hazard evaluation" means the process of identifying potential haz-
ardous events that could result in an accidental release, evaluating
the probability of an occurrence (either qualitatively or quantita-
tively), and estimating the potential impacts of the release.
(10) "Hazardous release risk" means a potential for the accidental re-
lease of a designated chemical into the environment which could
produce a significant likelihood that persons exposed may suffer
acute or irreparable health effects resulting in significant injury
or death.
(11) "Inventory" means the maximum amount of the designated chemical
on-site at any one time, including stored and in-process materials,
and excluding mixtures of the designated chemicals and other chemi-
cals where the concentration of designated chemical is 80 percent or
greater by weight.
(12) "Layout control" means the spacing and arrangement of buildings,
equipment, and contiguous areas at a designated plant which reduce
hazardous release risks.
(13) "Management control" means any administrative measure used at a
designated plant for reduction of hazardous release risks. Admin-
istrative measures include, but are not limited to, maintenance.
operator training, accident investigation, emergency response, and
internal/external audit programs.
(14) "Operational control" means an operational program or practice used
at a designated plant for reduction of hazardous release risks.
Operational controls include, but are not limited to, chemical com-
patibility assurance, materials handling, and waste management prac-
tices.
(15) "Risk" means the potential consequences weighted by the probability
of occurrence (i.e., risk = probability x consequences).
(16) "Risk reduction" means the use of siting, layout, process,
equipment, operational, and/or management controls to prevent or
minimize the consequences of accidental releases for human health
and the environment.
(17) "Risk Reduction Plan" means a written remedial action program
prepared by the owner/operator of a designated plant describing the
measures which will be taken to correct deficiencies identified by
the District in the plant's Accidental Release Control Plan.
(18) "Siting control" means measures taken to locate a designated plant
in a manner which reduces hazardous release risks or to consider
such siting in other aspects of accidental release control.
125
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(19)
"Vehicular storage" means vehicles such as tank cars or tank
trailers while stationary on the plant property and that are used
for storage of designated chemicals.
(d) Registration
The owner/operator of any plant manufacturing, using, storing, han-
dling, or generating a designated chemical shall register with the Dis-
trict by completing and submitting the registration form provided in Ap-
pendix A to this rule.
(e) Accidental Release Control Plan
(1) Plan Requirements
The owner/operator of a designated plant shall submit for approval
of the Executive Officer of the District an executive summary of a
plan for controlling hazardous release risks from the designated
chemicals. The intent of the summary is to highlight major provi-
sions of the Accidental Release Control Plan at the plant. In pre-
paring a Accidental Release Control Plan for a designated plant, the
owner/operator should consider the control criteria listed in Sec-
tion (g). The Accidental Release Control Plan for a designated
plant should provide sufficient detail to allow the District to de-
termine in a reasonable amount of time whether the risks of acciden-
tal release are adequately controlled. The appropriate level of
detail for a Plan will vary with the potential risks associated with
the plant. Detailed data supporting the Accidental Release Control
Plan should be maintained at the plant during its operating life.
An executive summary of the Accidental Release Control Plan should
be conceptual in nature, with sufficient detail to allow meaningful
evaluation.
The following elements which should be provided in the executive
summary: (A) present inventory of designated chemicals and quanti-
ties produced, stored, or handled monthly; (B) summary descriptions
of processes and principal equipment involved in handling designated
chemicals; (C) description of the area in which the designated plant
is situated including its proximity to water supplies and populated
areas; (D) description of the extent to which the hazardous release
risks of the processes, equipment, operations, and management have
been identified, evaluated, and controlled; (E) expertise and affil-
iation of the evaluators of the plant's handling of designated chem-
icals; (F) summary description of the recordkeeping system of the
designated plant; (G) summary description of the safety maintenance
schedule for equipment and processes involving the designated
chemicals; (H) summary description of the plant's risk management
program; (I) summary description of safety review and design
procedures for new and existing equipment; (J) summary description
126
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of standard operating procedures; (K) summary description of the
accidental release related preventive maintenance program; (L)
summary description of operator training and accident investigation
procedures; (M) summary description of hazard evaluation procedures
for specific pieces of equipment or operating alternatives (examples
of some acceptable methodologies are given in Appendix B); (N)
summary description of emergency response planning; and (0) summary
description of internal or external audit procedures.
(2) Variances
The owner/operator of a designated plant may apply to the Executive
Officer of the District for a variance from some of the requirements
for a Accidental Release Control Plan listed in Subsection (1)
above. A variance may be granted by the Executive Officer of the
District upon written finding that a certain requirement is not jus-
tified on the basis of the hazardous release risks associated with
the plant. The burden-of-proof shall be on the plant owner/operator
to demonstrate the basis for variance.
(3) Action on Plans and Variances
The Executive Officer of the District shall act, within a reasonable
time, on a Risk Control Plan or variance and shall notify the own-
er/operator in writing of the approval or disapproval. Before dis-
approving a Risk Control Plan or variance request, the Executive
Officer of the District shall allow an owner/operator 30 days to
correct deficiencies, subject to a reasonable extension for good
cause.
(f) Risk Reduction Plan
If a Risk Control Plan for a designated plant is disapproved by Ex-
ecutive Officer of the District, the owner/operator shall prepare
and submit a Risk Reduction Plan for Executive Officer of the Dis-
trict approval which addresses unresolved deficiencies in the Acci-
dental Release Control Plan. The Risk Reduction Plan shall consist
of the following elements: (1) owner/operator identification; (2)
identification and quantity of designated chemicals that could be
released in the event of an equipment breakdown, human error, design
defect, procedural failure, or imposition of an external force; (3)
information concerning the nature, age, and condition of all equip-
ment involved in the handling and management of the designated chem-
icals and their testing/maintenance schedules; (4) remaining defi-
ciencies identified by the owner/operator or Executive Officer in
the operation of the plant which represent a hazardous release risk;
(5) recommended or required practices, procedures, and equipment
designed to correct deficiencies by preventing or reducing the prob-
ability of hazardous release risks; (6) recommended or required
127
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training or management practices to inform the relevant plant per
sonnel regarding the dangers posed by potential releases; and (7)
recommended or required schedule for implementation of the Risk Re-
duction Plan.
(g) Control Considerations
In preparing a Accidental Release Control Plan or Risk Reduc-
tion Plan for a designated plant as required by Sections (e) and (f)
of this Rule, an owner/operator should consider siting, layout,
equipment, operational, and management controls needed to reduce
hazardous release risks associated with plant operations. Examples
of control criteria that should be considered are described in
Appendix C. The control criteria do not supercede standards,
specifications, or requirements of other regulatory agencies ap-
plicable to the elements addressed.
(h) Recordkeeping and Reporting
(1) Recordkeeping The owner/operator of a designated plant shall
maintain at the designated plant at least the following records per-
taining to hazardous release control and reduction: (A) approved
Accidental Release Control and Risk Reduction Plans where applica-
ble; (B) written descriptions of risk assessment and reduction ef-
forts undertaken; (C) records of required operator training provided
specific to facilities for designated chemicals; (D) preventive
maintenance and inspection records for facilities specific to desig-
nated chemicals; and (E) reports of accidental releases of designat-
ed chemicals. The records shall be retained for at least five
years.
(2) Reportable Releases The owner/operator of a designated plant
shall report to the District any accidental releases of designated
chemicals, according to the definition of accidental release in Sec-
tion (c)(2). The report shall be made by telephone to the District
offices (time period to be determined by SCAQMD). The report shall
include a description of the nature and extent of the release, per-
sons potentially affected, and response actions undertaken. A writ-
ten-report of the release shall be submitted to the District within
seven days of the release.
(i) Compliance Schedule
The owner/operator of a designated plant shall comply with the require-
ments of this rule according to the following schedule: (1) registration
form submission within a time period of the effective date of this
rule to be determined by the District; (2) Accidental Release Control
Plan submission to be determined by the District on a case-by-case
basis and (3) Risk Reduction Plan submission to be determined by the
District on a case-by-case basis after Executive Officer disapproval of
the Accidental Release Control Plan,
128
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Submission deadlines may be extended for good cause by the Executive Of-
ficer of the District upon demonstration of need by the owner/operator.
(j) Plan Amendments. Approval Transferability, and Plant Closure
(1) Flan Amendments
"The owner/operator of a designated plant shall submit all proposed
amendments for changes and modifications to approved Accidental Re-
lease Control and Risk Reduction Plans for the review and approval
of the Executive Officer of the District with a specified time peri-
od to be determined by the District on a case-by-case basis. Plant
modifications requiring amendments to the plan are to be determined
by the District.
Recertification of the Plan is required every two years. Recerti-
fication requires a statement that there have been no changes in the
plant that require changes in the plan.
An updated Accidental Release Control Plan shall be submitted peri-
odically within an interval of years to be determined by the Dis-
trict on a case-by-case basis.
(2) Transferability and Plant Closure
Approvals of Accidental Release Control and Risk Reduction Plans
shall not be transferable, whether by operation of law or otherwise,
either from one location to another or from one person to another.
When a designated plant is permanently closed, changes ownership, or
will no longer be operated by the owner/operator which registered
the plant, the Accidental Release Control Plan and Risk Reduction
Plan approvals shall become void. Such Plans must be resubmitted by
the new ownership in accordancd with provisions of Section (i) of
this rule. The new owners must abide by provisions of the old Plan
until the new Plan is approved. For the purposes of this rule,
statutory mergers, name changes, or incorporations by an individual
owner or partnership composed of individuals shall not constitute a
transfer or change of ownership.
(1) Severability
If any portion of this rule shall be found to be unenforceable, such
finding shall have no effect on the enforceability of the remaining parts
of the rule, which shall continue to be in full force and effect.
129
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APPENDIX A
Registration Form
130
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SOUTH COAST AIR QUALITY MAINTENANCE DISTRICT Page 1
CONTROL OF TOXIC CHEMICAL RELEASES
REGISTRATION FORM INVENTORY
SECTION A
1. Facility Name (Full Business Name)
2. Nature of Business:
3. SIC Code Plant I.D. No.
4. Facility Location:
No. Street
City County State Zip
Lot No.Block No.
5. Facility Mailing Address:
No. Street
City County State Zip
6. Name of Contact: Telephone ( )
7. Title:
SECTION B
Does this facility use. manufacture, store, handle, or generate any of the
following designated chemicals as a raw material, intermediate, final product,
byproduct, or waste product in an amount equal to or in excess of the follow-
ing listed quantities: anhydydrous ammonia (to be determined by SCAQMD) CAS
No. 7664-41-7; carbon tetrachloride (to be determined by SCAQMD) CAS No. 56-
23-5; elemental chlorine (to be determined by SCAQMD) CAS No. 7782-50-5; chlo-
ropricin (to be determined by SCAQMD) CAS No. 76-06-2; hydrogen cyanide, CAS
No. 74-90-8, and its metal salts as solids or in solution (to be determined by
SCAQMD); anhydrous hydrogen fluoride (to be determined by SCAQMD) CAS No.
7664-39-3; and anhydrous sulfur dioxide (to be determined by SCAQMD) CAS No.
7446-09-5.
/ / Yes / / No
If "No", sign the certification below and fill out the registration form
Section D only. If "Yes", complete the remaining sections of the registration
form before signing the certification below.
SECTION C - Certification of Facility Manager
I hereby certify that all information regarding this registration form is
true, complete, and correct to the best of my knowledge. I am aware that if
any of the information provided in this registration form is willfully false,
I am subject to punishment, including fines-and/or imprisonment.
Signature: Date
Name (Print): Title:
Mail Completed South Coast Air Quality Management District
Registration Engineering Division
Forms to: 9150 Flair Avenue
El Monte. CA 91731
Attn:
For assistance or additional information, call: (818) 572-6200.
131
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REGISTRATION FORM
Page 2
SECTION D
Make additional copies of this page if necessary.
]NVENTORY - Complete the following table for every designated chemical used,manufactured, stored, handled, or generated
at this facility. Use the codes indicated below.
Quantities Stored
(pounds)
Quantities In-Process
(pounds)
Designated Chemical
1.
CAS No.
Form Use
Avg
Max
Cap
Avg
Max
Cap
Comments
2.
3.
A.
5.
U)
K>
6.
7.
8.
9.
10.
12.
Codes
Form Use
L-Liquid RM-Raw Material
G-Gas I-Intermediate
S-Solid F-Final Product
BP-By-Product
WP-Waste Product
O-Other (describe)
Quantites Stored and Quantities In-Process
Average-Monthly Average
MaximumMonthly Maximum
Capacity-Maximum Capacity
-------
U)
U)
SECTION E Page 3
Complete this section for each designated chemical listed in Section D. Make additional copies of this page if
necessary.
1. Indicate the designated chemical for which the following process description and equipment list applies:
2. Process Description - Provide a general description of the process involved in the use, manufacture, storage,
handling, or generation of the designated chemical. Indicate typical and maximum operating conditions (i.e.,
temperatures and pressures) as they relate to the designated chemical. Provide simplified process flow sheets and a
plot plan if available.
-------
APPENDIX B
Hazard Evaluation Methodologies
134
-------
In evaluating the hazardous release risks associated with processes.
equipment, and procedures, the owner/operator of a designated plant should
consider using one or more of the following methodologies, as appropriate:
(A) process/system checklists; (B) safety review; (C) relative ranking Dow
and Mond Hazard Indices; (D) preliminary hazard analysis; (E) "What If" analy-
sis; (F) hazard and operability (HazOp) studies; (G) failure modes, effects.
and criticality analysis; (H) fault tree analysis; (I) event tree analysis;
(J) cause-consequence analysis; and (K) human error analysis. An owner/
operator may use another equivalent hazard evaluation methodology in assessing
hazardous release risks» hut should provide an equivalency demonstration in
the Accidental Release Control Plan.
135
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APPENDIX C
Control Considerations
136
-------
The control considerations listed here are examples of criteria that
should be considered in Accidental Release Control Flans. These examples are
not necessarily complete, nor are all items necessarily applicable to all fa-
cilities, and are intended as guidance for preparation of the Control Plan.
(1) Siting and Layout Controls
(A) Siting The impact of a plant's location on the frequency or
severity of an accidental release should be evaluated and steps
taken to minimize potential impacts. Siting considerations
include, but are not limited to, the following: (i) drainage
systems should prevent the runoff of spilled liquid chemicals
onto adjacent properties and prevent the spread of toxic and/or
flammable liquid chemicals in a manner that minimizes adverse
impacts within and outside of the plant boundaries; (ii) equip-
ment design should be appropriate to minimize the effects of
natural calamities such as freezing, fire, floods, earthquakes,
and landslides in contributing to an accidental release; (iii)
the potential impact of accidents such as fires, explosions, or
hazardous chemical releases at adjacent industrial facilities,
roads, or railways should be considered and minimized by appro-
priate design and operating procedures; and (iv) reliable water
and power supplies should be available with backups where a
failure could cause an accidental chemical release; and (v)
traffic flow patterns within the plant and around the perimeter
should be designed to prevent congestion and allow access by
emergency response vehicles and appropriate movement of person-
nel in an emergency.
(B) Layout The layout of a plant should contribute to safe oper-
ations, be consistent with safety practices customary in the
industry, and reduce the potential for and impacts of an ac-
cidental release. Layout considerations include, but are not
limited to, the following: (i) process units and the equipment
and piping within a unit should be arranged to prevent unneces-
sary congestion; (ii) where possible, hazardous processes
should be segregated from other hazardous processes or sensi-
tive areas within the plant or plant property; (iii) adequate
spacing should be available for access by maintenance and emer-
gency response personnel and equipment; (iv) explosion barriers
should be applied where appropriate; (v) escape routes for per-
sonnel should be easily accessible; and (vi) offices, lunch-
rooms, or other support structures should be located at the
perimeter of the facility.
(2) Process Controls
(A) Chemical Processes The design of a process in which desig-
nated chemicals are used or produced should be based on
137
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sufficient data to ensure a safe operating system. Necessary
data to be considered in the design process includes, but is
not limited to, the following: (i) chemical, physical, and
toxicological properties of the individual chemical components
used or produced in the process; (ii) the process potential for
explosive reaction or detonation under normal or abnormal con-
ditions; (iii) process reactivity with water or other common
contaminants; (iv) possibility of spontaneous polymerization or
heating; (v) potential side reactions and conditions under
which they are favored; (vi) whether reactions are endothermic,
exothermic, or thermodynamically balanced; (vii) the explosive
range of volatile or gaseous components and the possibility of
explosive mixtures during storage, processing, or handling; and
(viii) the possibility of dust or mist explosions; and (ix)
interactions with materials of construction.
(B) Chemical Storage The design of storage facilities for desig-
nated chemicals should have considered the same data as for
process facilities, and should also have considered the effects
of materials transfer, the possibility of incorrect transfer,
and large inventories.
(3) Equipment Controls
(A) Foundations Foundations should assure the stability of all
vessels and nontransportable equipment containing designated
chemicals. The design should be in accordance with recognized
construction and material specification standards in the indus-
try, as a minimum. The design should consider all normal and
abnormal load and vibration conditions as well as severe condi-
tions caused by freezing, fire, wind, earthquakes, flood, or
landslides. Transportable equipment should be secured to pre-
vent upset or accidental detachment of process lines conveying
designated chemicals during use and should not be used to perma-
nently replace a stationary piece of equipment unless standard
safety practice dictates a preference or requirement for such
transportable equipment.
(B) Structural Steel Structural steel should, as a minimum, be
designed and constructed in accordance with appropriate con-
struction and material specification standards in the industry.
The design should consider all normal and abnormal dead loads
and dynamic loads resulting from wind, collision, earthquake,
or other external forces. At minimum, fireproofing should be
used for areas in which designated chemicals are mainufactured,
stored, handled, or generated and such areas should conform
with legally applicable codes and standards. More protection
should be considered for hazardous areas in which designated
chemicals are present.
138
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(C) Vessels Vessel design and construction should conform to
recognized design and material standards for the specific ap-
plication in the industry. Stricter standards and specifica-
tions may sometimes be appropriate. Design should consider the
most severe combination of conditions anticipated for quantity,
fill rate, pressure, temperature, reactivity, toxicity, and
corrosivity. As a minimum, all vessels should be equipped with
the following safety features: (i) overfill and overpressure
protection should be provided and, where appropriate, vacuum
protection; (ii) storage vessels should be surrounded by dik-
ing, firewalls, or other containment devices unless such fea-
tures are deemed to create a more severe secondary hazard;
(iii) vessels and vessel fittings should be protected from dam-
age caused by collision or vibration and should be adequately
braced to support the weight of piping. Columns should be ade-
quately supported to withstand the maximum wind loads expected
in the area; and (iv) operators should be trained concerning
the vessel's limits for pressure, temperature, fill and empty-
ing rates, and incompatible materials.
Additional items such as nitrogen blanketing, improved fire
protection, or release reduction equipment (e.g., water or
steam curtains) will be appropriate in certain situations.
(D) Pressure and Vacuum Relief Systems All pressure vessels and
vessel jackets should be fitted with adequate pressure and/or
vacuum relief. The relief systems should be designed according
to recognized design procedures and standards appropriate in
the industry as a minimum. Stricter procedures and standards
may sometimes be appropriate. Containment systems should be
designed according to recognized design procedures for contain-
ment systems. Valves upstream of pressure or vacuum relief
devices should be prevented from being closed in such a way
that the vessel will be isolated from all pressure relief or
vacuum relief. Where possible, a pressure trip system should
be used along with a pressure relief system. This will help to
minimize the frequency of releases of designated chemicals
through the pressure relief system. All pressure or vacuum
relief devices should be inspected and maintained on a regular
basis. The adequacy of a pressure or vacuum relief system
should be reevaluated when a vessel or process unit is used to
handle more material, or a different material, than that for
which it was originally designed.
(E) Pumos and Compressors Extra precautions should be taken in
the design of pumps and compressors to minimize the potential
for an accidental release of a designated chemical. Extra pre-
cautions include, but are not limited to, the following: (i)
where a pressurized hazardous material is being pumped or where
the consequence of a seal failure could result in the
139
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accidental release of designated chemical, seals should be
suitable to ensure reliable leak prevention (e.g., double me-
chanical seal with a pressurized barrier fluid); (ii) totally
enclosed pump or compressor systems may be appropriate, if
safely vented and inerted and monitored for oxygen where enclo-
sure could result in a secondary hazard such as an explosive
mixture; (iii) remotely operated emergency isolation valves and
power shutoff switches may be appropriate on the suction and
discharge sides of a pump or compressor; (iv) compressors or
positive displacement pumps should be fitted with adequate
overpressure protection; (v) instrumentation to determine when
flow into or out of a pump has ceased may be appropriate; (vi)
where overheating could result in a fire or explosion, tempera-
ture monitoring may be appropriate; (vii) a backup power supply
should be used for critical pumping systems; and (viii) pumps,
compressors, and their associated -piping should have founda-
tions and supports that protect against damage caused by vibra-
tion and any static and dynamic loads.
(F) Heaters and Furnaces Heaters and furnaces should be located
so as to minimize the possibility of bringing an open flame
and/or extreme heat too close to a hazardous area. Basic units
and controls should be designed in accordance with applicable
standards and codes as a minimum. Stricter standards may some-
times be appropriate. Examples of some of the basic require-
ments for furnaces include the following: (i) provision for
adequate draft; (ii) positive fuel ignition; (iii) automatic
water level controls; (iv) pressure relief devices; and (v)
fuel controls. Air heaters should have igniters designed to
provide positive ignition, proper safety controls on fuel
sources, sight glasses for flame observation, monitoring devic-
es for flame-out detection, and high temperature alarms. All
heaters and furnaces should be inspected on a regular basis.
Where heaters and furnaces handle hazardous process materials,
appropriate precautions should be taken to prevent releases in
the event of tube failures, such as cracking, rupture, or plug-
ging-
(G) Heat Exchangers At minimum, heat exchangers should be con-
structed in accordance with accepted industry codes and stan-
dards. Stricter standards may sometimes be appropriate. The
materials of construction should be selected to minimize corro-
sion and fouling. All exchangers should be equipped with pres-
sure relief, by-pass piping, and adequate drainage facilities.
Exchanger design should allow for thermal expansion and con-
struction without causing excessive stress on connections.
(H) Turbines Turbines, drivers, and auxiliary machinery should
be designed, constructed, and operated in accordance with ap-
plicable industry standards and codes. Stricter controls may
140
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sometimes be appropriate. The equipment should have adequate
protective devices to shut down the operation and/or inform the
operator before danger occurs.
(I) Electrical Equipment All wiring and electrical equipment
should be installed in accordance with the National Electric
Code or stricter standards, if applicable. Electrical equip-
ment for use in hazardous locations should comply with accept-
ability criteria of recognized testing organizations. All
electrical apparatus should be grounded where appropriate.
(j) Instrumentation Every reasonable effort should be made to
maximize the effectiveness of automatic process control systems
for the preventing of an accidental release. All systems and
instrumentation should be of the "fail-safe" type. Instruments
should be made of materials capable of withstanding the corro-
sive or erosive conditions to which they are subjected. Cen-
tral control rooms should be protected from fire and explosion
hazards. An owner-operator should evaluate the ability of con-
trol systems to operate on manual control and should install a
backup power supply in situations where operating on manual
control would be impractical.
A variety of miscellaneous modifications may be appropriate,
depending upon the needs of the particular process unit. Exam-
ples of these modifications include, but are not limited to the
following: (i) the addition of control systems where none are
presently employed; (ii) redundancy of key components; (iii)
replacing components to improve accuracy, reliability, repeat-
ability, or response time; (iv) the addition of a backup con-
trol system; (v) simplification of an existing control system
to improve operability; (vi) replacing a system that indirectly
controls the variable of interest with a system that directly
measures and controls the variable of interest; (vii) the addi-
tion of trip systems for emergency situations; and (viii) the
redesign of a control system to conform to acceptable design
standards.
(K) Piping As a minimum, piping, valves, and fittings should be
designed according to recognized industry codes and standards
pertaining to working pressures, structural stresses, and cor-
rosive materials to which they may be subjected. The thermal
stress of repeated heating and cooling cycles or excessive tem-
peratures, either high or low, should be considered. Some ad-
ditional considerations include, but are not limited to, the
following: (i) dead ends or unnecessary and rarely used piping
branches should be avoided; (ii) the type of pipe appropriate
for pumping a designated chemical should be selected (e.g.,
using welded or flanged pipe instead of threaded pipe or using
a suitable metal or lined metal piping instead of plastic wall
141
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piping); (iii) backflow protection should be installed where
necessary, but backflow prevention should not be relied upon as
the only means of avoiding a backflow hazard; (iv) materials of
construction suitable for the application should be selected;
and checked before installation to confirm the composition; (v)
recordkeeping or critical lines should be provided to prevent
incorrect future substitutions; (vi) a means of remotely shut-
ting off the flow in lines that carry a large volume of hazard-
ous materials should be provided; (vii) adequate structural
support should be provided to protect against vibration and
loads and to protect piping from potential collisions; (viii)
piping should be pitched to avoid unintentional trapping of
liquids; and (ix) provisions should be made to ensure that a
liquid-full condition cannot exist in a blocked section of line
unless such a section of line has pressure relief.
(L) Emissions Control Devices Emission control devices should
have the capability of warning operating personnel when emis-
sions are not being controlled. If a device is only used on an
intermittent basis, then a testing program should be in place
to ensure that the system will function when necessary.
(M) Fire Protection and Safety As a minimum, plant fire protec-
tion systems should be laid out in accordance with recognized
codes and standards, such as those prepared by the National
Fire Protection Association. A reliable water supply for all
portions of the plant should be available. Flammable gas de-
tection systems are recommended for locations where flammable
chemicals are used at elevated temperatures and pressures.
Central fire alarm systems should be in place. In addition to
water, firefighting materials such as spray foams, dry chemi-
cals, and carbon dioxide should be available, as appropri-
ate, to handle various specialized types of fires.
(4) Operational Controls
(A) Chemical Compatibility The following types of reactive mate-
rials should be stored so that the potential for mixing in the
event of an accidental release is minimized by dikes or other
physical barriers: (i) materials that react to form a desig-
nated chemical; (ii) designated chemicals that react exother-
mically and thereby contribute to the rate of evaporation in
the chemicals; and (iii) designated chemicals that will react
such that the reaction will contribute to the potential for an
accidental release.
Extra precautions may be required where there is a potential
for mixing two incompatible chemicals within a. process. Such
precautions could include backflow protection, composition mon-
itoring, and interlocks that prevent valves from being opened
-------
in combinations that allow for cross-contamination. Use of
common lines for handling such incompatible chemicals should be
avoided.
All materials of construction should be capable of withstanding
normal operating conditions and normal shutdown conditions.
Where a specialized material is required, then initial con-
struction materials and replacement parts should be tested be-
fore use to ensure that the composition is consistent with
specifications.
(B) Materials Handling Safe procedures should be established to
minimize the risk of an accidental release of a hazardous mate-
rial during filling or emptying operations for tanks, vessels,
tank trucks, or tank cars. Some considerations include, but
are not limited to, the following: (i) before material is add-
ed to a vessel, tank, tank truck, or tank car, the operator in
charge of the addition should be able to verify what material
is in the vessel or was last in the vessel; (ii) where hoses
are used, a system should be in place to ensure that the proper
type of hose is used for each application (e.g., different
types of fittings for each application); (iii) hoses should be
regularly inspected and maintained as necessary; (iv) efforts
should be made to minimize the potential for materials to be
sent to the wrong location; (v) a system should be in place to
prevent tank trucks or rail cars from moving away with a hose
still connected; (vi) when a hose is used to transfer materi-
als, it should be possible to stop the flow if the hose should
fail; (vii) equipment should be grounded and operators trained
as to the appropriate methods for chemical transfer so as to
avoid static charge accumulation.
(C) Waste Management Practices Procedures and equipment should
be in place so that every reasonable effort may be made to pre-
vent an accidental release from the storage, handling, or
treatment of wastes containing the designated chemicals.
(5) Management Controls
(A) Operator Practices and Training Programs to train operators
to handle normal operating conditions, upset conditions, emer-
gency conditions, and accidental releases should be implement-
ed. The programs should include written instruction, classroom
instruction, and field drills. Periodic review and drill exer-
cises should be part of such programs. Printed materials de-
scribing standard and emergency procedures should be provided
to employees and revised as necessary to be consistent with
accepted practices and recent plant modifications.
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(B) Fire Protection and Prevention A plant-wide fire prevention
and protection plan should be implemented. Every employee
should be instructed concerning fire prevention and fire re-
sponse. All plant personnel should be instructed in basic
first aid and fire extinguisher use. The formation and train-
ing of specialized fire fighting teams and first aid teams
should be in accordance with or exceed requirements of all fire
protection and prevention plans should be periodically reviewed
and drilled.
(C) Contingency Plan flfld Emergency Response Coordination The
owner/operator of a designated plant should formulate a compre-
hensive contingency plan to handle major plant disasters. All
plant personnel should be trained to participate in plans for
controlling plant emergencies related to accidental releases
including emergencies such as large windstorms, earthquakes,
floods, power failure, fires, explosions, and accidental re-
leases of designated chemicals.
The contingency plan should describe coordination between the
plant and local police, fire, and other emergency personnel.
The plan should be specific in designating responsibilities and
in addressing specific high-hazard situations that are possible
for the plant. Communications responsibilities and procedures
for relaying information during emergencies should also be
clearly defined. The plan should include procedures for emer-
gency notification of community and local governments. Where
an accidental release could adversely affect the local communi-
ty, the plan should include appropriate community emergency
response procedures,
Simulated emergency drills involving plant personnel should be
performed on a regular basis. Disaster drills that incorporate
local emergency response organizations should also be undertak-
en periodically.
Maip.Cen.anc5 An inspection, testing, and monitoring program
for process equipment and instrumentation should be considered
for areas of high hazard potential. Systems and components to
which this program can be applied include, but are not limited
to, the following: (i) pressure vessels; (ii) relief devices
and systems; (iii) critical process instruments; ( iv) process
safety interlocks (trips); (v) isolation, dump, and drowning
valves; (vi) process piping systems; (vii) electrical grounding
and bonding systems; (viii) fire protection systems; and ( ix)
emergency alarm and communications systems. Engineering draw-
ings and design specifications should be available for inspec-
tion, if requested.
-------
Maintenance staff qualifications, skill level, and numbers
should be consistent with the hazard potential at the specific
operation.
A process safety review consistent with the magnitude of the
modification should be made prior to the implementation of any
modification. Documentation of modifications should be made
and available for inspection, if required.
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EXHIBIT E
PRELIMINARY TABLE OF CONTENTS FOR
PREVENTION REFERENCE MANUALS
146
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Section
PRELIMINARY TABLES OF CONTENTS FOR
PREVENTION REFERENCE MANUALS
PRM - USER'S GUIDE
TABLE OF CONTENTS
1 INTRODUCTION
1.1 General Background
1.2 Historical Background and Accidental Events Overview.
1.3 Purpose of This Manual
2 HAZARDOUS CHEMICALS
2.1 Toxic Chemicals
2.2 Physical and Chemical Properties
3 HAZARDS IN PROCESS OPERATIONS
3.1 Background
3.2 Process Design Considerations . . . .
3.3 Physical Plant Design Considerations
3.4 Procedures and Practices
4 METHODS OF HAZARD IDENTIFICATION AND EVALUATION
4.1 Hazard Identification
4.2 Methods for Hazard Evaluation
5 OVERVIEW OF PRINCIPLES OF CONTROL
5.1 Background
5.2 Prevention
5.2.1 Process Design Considerations . . .
5.2.2 Physical Plant Design Considerations
5.2.3 Procedures and Practices
5.3 Protection
5.4 Mitigation
5.5 Control Technology Summary
6 GUIDE TO FACILITY INSPECTIONS
6.1 General Procedure
6.2 Specific Procedures
6.2.1 Process and Process Chemistry Evaluation . . . .
6.2.2 Facility Siting Evaluation
6.2.3 Plant Layout Evaluation
6.2.4 Pressure Relief System Evaluation
6.2.5 Maintenance and Structural Integrity Evaluation
6.2.6 Fire Protection Evaluation
6.2.7 Electrical System Evaluation
6.2.8 Transportation Practices Evaluation
6.2.9 Contingency Plan and Emergency Response
Coordination
7 REFERENCES
APPENDIX A - LIST OF ACUTELY TOXIC CHEMICALS
14'
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TABLES
Number
1-1 Major Toxic Release Incidents Between 1950 and 1980 .
1-2 Distribution of Event Locations as Reported by Kletz
2-1 Selected Properties of Some Common Hazardous Chemicals
4-1 Example Guide Words and Corresponding Deviations for HAZOP
Analysis
4-2 Summary of Key Features of Hazard Identification and Evaluation
Methods ,
5-1 Examples of Possible Releases and Controls
FIGURES
Number Page
1-1 Inplant acute hazardous events by location .
1-2 Causes of loss in the chemical and allied industries from
insurance survey .........
4-1 Example of a fault tree for process hazard evaluation
4-2 Relationship between hazard evaluation procedures and hazard
evaluation process
148
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PRM - CHLORINE
TABLE OF CONTENTS
Section
INTRODUCTION
1.1 Background
1.2 Purpose of this Manual
1.3 Uses of Chlorine . . .
1.4 Manual Overview . . . .
CHEMICAL CHARACTERISTICS
2.1 Physical Properties
2.2 Chemical Properties
2.2.1 Reaction with Metals
2.2.2 Reactions with Nonmetallic Elements
2.2.3 Reactions with Inorganic Compounds .
2.2.4 Reactions with Organic Compounds . .
2.3 Tozicological Properties
FACILITY DESCRIPTIONS AND PROCESS HAZARDS
3.1 Processing
3.1.1 Drinking Water. Wastewater. and Cooling
Tower Chlorination
3.1.2 Bleach Production
3.1.3 Photochemical Chlorination
3.2 Storage and Transfer
3.3 Potential Causes of Releases
HAZARD PREVENTION AND CONTROL
4.1 Background
4.2 Process Design Considerations
4.3 Physical Plant Design Considerations . ,
4.3.1 Materials of Construction . . . .
4.3.2 Vessels
4.3.3 Piping and Valves
4.3.4 Process Machinery
4.3.5 Miscellaneous Equipment
4.3.6 Plant Siting and Layout
4.3.7 Transfer and Transport Facilities
4.4 Operation and Maintenance Practices . . ,
4.5 Containment and Neutralization System . .
4.5.1 Enclosures
4.5.2 Diking
4.5.3 Scrubbers ,
4.6 Control Effectiveness
4.7 Costs ,
REFERENCES
149
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FIGURES
Page
3-1 Conceptual process diagram of typical water chlorination
system
3-2 Photochlorination reactors
3-3 Typical bulk chlorine storage and tank car unloading system .
3-4 Refrigerated liquid chlorine storage
4-1 Liquid chlorine expansion chamber for liquid chlorine only
150
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TABLES
Number Page
2-1 Physical Properties of Chlorine
4-1 Key Process Design Considerations for Chlorine Processes . . .
4-2 Corrosion of Metals in Dry Chlorine
f-3 Summary of Chlorine Institute Piping Material Recommendations.
4-4 Summary of Chlorine Institute Guidelines for Valves
4-5 Examples of Major Prevention and Protection Measures for
Chlorine Releases
151
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PRM - HYDROGEN FLUORIDE
TABLE OF CONTENTS
Section
INTRODUCTION
1 . 1 Background
1.2 Purpose of the Manual
1.3 Uses of Hydrogen Fluoride
CHEMICAL CHARACTERISTICS AND HAZARDS ............ 4
2.1 Physical Properties .................. 4
2.2 Chemical Properties .................. 8
2.3 Toxicity ....................... 9
FACILITY DESCRIPTIONS ................... 12
3.1 Process Facilities .................. 12
3.1.1 Hydrogen Fluoride Alky lat ion .......... 12
3.1.2 Manufacture of Chlorofluorocarbons ....... 16
3.2 Storage and Transfer Facilities ............ 19
3.3 Potential Causes of Releases ............. 20
3.4 Potential Causes of Releases ............. 23
3.4.1 Process Causes ................. 24
3.4.2 Equipment Causes ................ 25
3.4.3 Operational Causes ............... 26
HAZARDS PREVENTION AND CONTROL ............. ... 28
4.1 General Considerations ................ 28
4.2 Process Design Considerations ............. 29
4.3 Physical Plant Design Considerations ......... 31
4.3.1 Equipment ................... 31
4.3.2 Plant Siting and Layout ............ 50
4.3.3 Transfer/Transport Facilities ......... 52
4.4 Containment and Neutralization Systems ........ 53
4.4.1 Enclosures ................... 53
4.^.2 Diking ..................... 55
4.4.3 Scrubbers ................... 55
4.5 Operation and Maintenance Practices .......... 56
4.6 Control Effectiveness ................ 57
4.7 Costs ......................... 58
REFERENCES ........................ 61
152
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TABLES
Number Page
2-1 Physical Properties of Hydrogen Fluoride
2-2 Physical Properties of 70 Percent Aqueous Hydrofluoric Acid
4-1 Key Process Design Considerations and Processes Involving
Hydrogen Fluoride .
4-2 Characteristics of Materials of Construction in Hydrogen
Fluoride and Hydrofluoric Acid Service
4-3 Examples of Major Prevention and Protection Measures for
Hydrogen Fluoride Releases
FIGURES
3-1 Conceptual diagram of typical HF-alkylation process
3-2 Conceptual diagram of typical fluorochlorocarbon process ....
3-3 Conceptual process diagram of hydrogen fluoride rail tank
car unloading and tank storage facility
3-4 Conceptual process diagram hydrogen fluoride tank truck
unloading and tank storage facility
4-1 Temperature limits for materials of construction for use with
hydrofluoric acid (corrosion rate less than 0.02 inches per year)
4-2 Concept of a liquid hydrogen fluoride expansion chamber ....
153
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PRM - HYDROGEN CYANIDE
TABLE OF CONTENTS
Section
1.0 INTRODUCTION ,
1.1 Background
1.2 Purpose of This Manual
1.3 Uses of Cyanides . . .
2.0 CHEMICAL CHARACTERISTICS
2.1 Physical Properties
2.2 Chemical Properties
2.3 Toxicological and Health Effects
3.0 FACILITY DESCRIPTIONS AND PROCESS HAZARDS
3.1 Processing
3.1.1 Electrolytic Cleaning . . . .
3.1.2 Electrolytic Plating
3.2 Storage and Handling
3.3 Potential Causes of Releases . . . .
3.3.1 Process Causes
3.3.2 Equipment Causes
3.3.3 Operational Causes
4.0 HAZARD PREVENTION AND CONTROL ,
4.1 General Considerations
4.2 Process Design Considerations . . . . ,
4.3 Physical Plant Design Considerations
4.3.1 Equipment
4.3.2 Plant Siting and Layout . . . .
4.4 Containment and Neutralization Systems
4.4.1 Enclosures ,
4.4.2 Diking ,
4.4.3 Scrubbers ,
4.5 Operation and Maintenance Practices . ,
4.6 Control Effectiveness ,
4.7 Costs ,
5.0 REFERENCES
154
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TABLES
Page
2-1 Physical Properties of Hydrogen Cyanide
2-2 Physical Properties of Anhydrous Sodium Cyanide
2-3 Physical Properties of Anhydrous Potassium Cyanide
3-1 Composition and Operating Conditions for a Typical Dilute
Copper-Cyanide Plating Bath
3-2 Composition and Operating Conditions for a Typical High
Efficiency Copper-Cyanide Plating Bath
3-3 Various Compositions for Typical Cadmium-Cyanide Plating Baths.
3-4 Composition and Operating Conditions for a Typical Silver-
Cyanide Plating Bath
3-5 Composition and Operating Conditions for a Typical Brass-Cyanide
Plating Bath ....
4-1 Examples of Major Prevention and Protection Measures for
Hydrogen Cyanide Releases -. . . .
155
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FIGURES
2-1 Solubility of sodium cyanide in water
2-2 Densities of sodium cyanide solutions
2-3 Effect of pH on cyanide ionization
3-1 Flow charts of processes for preparing steels for electroplating.
3-2 Reactions in electrocleaning processes
3-3 Cut-away view of a typical plating tank
3-4 HCN vapor concentration vs. pH for 50 g/1 NaCN solution
3-5 HCN vapor concentration vs. pH for high efficiency copper plating
solution
3-6 HCN vapor concentration vs. pH for cadmium plating solution . . .
3-7 HCN vapor concentration vs. pH for brass plating solution ....
156
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PRM - CONTROL TECHNOLOGIES
TABLE OF CONTENTS
Section
1 INTRODUCTION
2 PROCESS DESIGN CONSIDERATIONS
2.1 OVERVIEW OF PROCESS CONTROL CONSIDERATIONS RELATED TO
ACCIDENTAL RELEASES
2.1.1 Process Control and Release Prevention ....
2.1.2 System Response
2.1.3 Control System Integrity
2.1.4 Control Systems
2.1.5 Effectiveness of Process Control Systems . . .
2.1.6 Summary of Considerations for Process
Modifications in Process Control Systems . . .
2.2 PROCESS CHARACTERISTICS AND CHEMISTRY . . .
2.2.1 Process Materials
2.2.2 Process Mode
2.2.3 Reaction Thermodynamics
2.2.4 Process Control System
2.2.5 Process Type
2.2.6 Severity of Process Conditions
2.2.7 Process Complexity
2.2.8 Potential Modifications
2.3 FLOW MEASUREMENT AND CONTROL
2.3.1 Flow Hazards
2.3.2 Technology of Flow Control
2.3.3 Control Effectiveness
2.3.4 Summary of Control Technologies
2.3.5 Costs
2.3.6 Case Example
2.4 PRESSURE CONTROL
2.4.1 Pressure Hazards
2.4.2 Technology of Pressure Control
2.4.3 Control Effectiveness
2.4.4 Summary of Control Technologies
2.4.5 Costs
2.4.6 Case Example
2.5 TEMPERATURE MEASUREMENT AND CONTROL
2.5.1 Temperature Hazards
2.5.2 Technology of Temperature Control
2.5.3 Control Effectiveness
2.5.4 Summary of Potential Process Modifications for
Temperature Measurement and Control
2.5.5 Costs
2.5.6 Case Example
157
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TABLE OF CONTENTS (Continued)
2.6 QUANTITY MEASUREMENT AND CONTROL
2.6.1 Quantity Measurement and Control Hazards . . . .
2.6.2 Technology of Quantity Control
2.6.3 Control Effectiveness
2.6.4 Summary of Control Technologies
2.6.5 Costs <
2.6.6 Case Examples
2.7 MIXING SYSTEMS
2.7.1 Mixing System Hazards
2.7.2 Technology of Mixing Control
2.7.3 Control Effectiveness
2.7.4 Summary of Control Technologies
2.7.5 Costs
2.7.6 Case Example
2.8 COMPOSITION DETERMINATION AND CONTROL
2.8.1 Hazards Associated With the Loss of Composition
Determination and Control
2.8.2 Technology of Composition Control
2.8.3 Control Effectiveness
2.8.4 Costs
2.8.5 Summary of Control Technologies
2.8.6 Case Examples
2.9 REFERENCES
3 PHYSICAL PLANT DESIGN CONSIDERATIONS
3.1 BACKGROUND
3.2 STANDARDS, CODES, AND RECOMMENDED PRACTICES
3.3 SITING AND LAYOUT CONSIDERATIONS
3.3.1 Siting
3.3.2 Layout
3.3.3 Storage Layout Considerations . . .
3.4 MISCELLANEOUS DESIGN CONSIDERATIONS ....
3.5 EQUIPMENT DESIGN CONSIDERATIONS
3.5.1 Materials Of Construction
3.5.2 General Equipment Failure Modes . .
3.5.3 Vessels
3.5.4 Piping
3.5.5 Process Machinery
3.6 REFERENCES
4 PROCEDURES AND PRACTICES
4.1 MANAGEMENT POLICY
4.2 OPERATOR TRAINING
4.3 MAINTENANCE AND MODIFICATION PRACTICES
4.4 OPERATING AND MAINTENANCE MANUALS . . .
A.5 REFERENCES
158
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TABLE OF CONTENTS (Continued)
5 PROTECTION TECHNOLOGIES
5.1 INTRODUCTION
5.2 FLARES
5.2.1 Process Description
5.2.2 Applicability . . . .
5.2.3 Control Effectiveness
5.2.4 Costs of Flare Systems
5.3 SCRUBBERS
5.3.1 Process Description
5.3.2 Applicability Releases
5.3.3 Control Effectiveness
5.3.4 Costs
5.4 DIKING
5.4.1 Description
5.4.2 Applicability ....
5.4.3 Control Effectiveness
5.4.4 Costs
5.5 ENCLOSURES
5.5.1 Description
5.5.2 Applicability . . . .
5.5.3 Control Effectiveness
5.5.4 Costs
5.6 REFERENCES
159
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FIGURES
1-1 The place of prevention, protection and mitigation in the overall
sequence of cause to consequence for accidental chemical releases
2-1 Generalized information flow for process control loop
2-2 Check valve types
2-3 Examples of backflow through pumps
2-4 Typical rupture disc Installation
2-5 Typical pressure relief valves
160
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TABLES
Page
2-1 Reliability of Selected Process System Components
2-2 Properties of Materials to be Considered in Chemical Process
Evaluation
2-3 Considerations for Various Process Modes . . . . ,
2-4 Unit Processes in the Chemical Process Industries .
2-5 Unit Operations in the Chemical Process Industries
2-6 Types of Check Valves ,
2-7 Flowmeter Selection Guide ,
2-8 Typical Reliability of Flow Control Components . ,
2-9 Costs of Components Associated With Process Modifications For Flow
Systems
2-10 Pressure Sensing and Measuring Devices
2-11 Typical Reliability of Pressure Control Components
2-12 Costs of Components Associated With Process Modifications for Pressure
Measurement and Control Systems
2-14 Temperature Sensor Selection Guide for Non-Severe Service Under 500°C .
2-15 Typical Reliability of Temperature Control Components
2-16 Costs of Components Associated With Process Modifications for
Temperature Measurement and Control Systems
2-17 Liquid Level Detector Selection Guide
2-19 Typical Reliability of Quantity Control Components
2-20 Costs of Components Related to Process Modifications for Quantity
Measurement and Control Systems (Excluding Flow Rate Measurement -
See Section 2.3)
2-21 Typical Reliability of Mixing System Components
2-22 Costs of Components Associated with Process Modifications for Mixing
Systems
161
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TABLES (Continued)
Page
2-23 Typical Reliability of Composition System Components
2-24 Costs of Components Associated With Process Modifications For
Composition Determination and Control
3-1 Major Organizations Providing Codes and Standards for Equipment and
Recommended Practices for Chemical and Allied Industry Process Plants .
3-2 Areas Covered by Codes, Standards, and Recommended Practices of
Designated Organizations (see Table 3-1 for Symbols Definitions). . . .
3-3 Physical Components, Design, and Fabrication Features of Vessels
Covered by ASHE Codes as Indicated
3-4 Galvanic Series of Metals and Alloys
3-5 Reliability of Vessel Components
3-6 Vessel Hazards, Control Technologies, and Costs
3-7 Design Bases for Vessel Controls
3-8 Reliability of Piping Components
3-9 Piping Hazards. Control Technologies, and Costs
3-10 Design Bases for Piping Controls
3-11 Reliability Data for Process Machinery Components
3-12 Process Machinery Hazards, Control Technologies, and Costs
3-13 Design Bases for Process Machinery Controls
4-1 Aspects of Training Programs for Routine Process Operations
4-2 Examples of Questions Asked During Procedure Reviews . . .
5-1 Important Considerations for using Flares to Prevent Accidental
Chemical Releases
5-2 Cost Comparison of Elevated and Enclosed Ground Flaring Systems
5-3 Summary of Selected Absorption Data
162
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TECHNICAL REPORT DATA
(Please read lasovctions on the reverse before completing}
REPORT NO '
EPA-600/8-87-Q4Q
2.
3. RECIPIENT'S ACCESSION1 NO.
4. TITLE AND SUBTITLE ~~
Technical Support to the South Coast Air Quality
Management District Toxic Chemical Accidental
Air Releases
5. REPORT DATE
August 1987
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
D. S. Davis and G. B. DeWolf
8. PERFORMING ORGANIZATION REPORT NO.
DCN 87-203-024-84-25
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Radian Corporation
8501 Mo-Pac Boulevard
Austin, Texas 78766
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3889, Task 84
12. SPONSORING AGENCY NAME AND ADDRESS
EPA, Office of Research and Development
Air and Energy Engineering Research Laboratory
Research Triangle Park, NC 27711
13. TYPE OF REPORT AND PERIOD COVERED
Task Final; 4-9/86
14. SPONSORING AGENCY CODE
EPA/600/13
^.SUPPLEMENTARY NOTES £EERL project officer is T.
541-2852.
Kelly Janes, Mail Drop 62B, 9197
16. ABSTRACT
The report summarizes EPA technical inputs and describes other support
provided to the South Coast Air Quality Management District (SCAQMD), responding
to requests for support toward developing a regulatory approach for controlling po-
tential accidental releases of toxic chemicals. This support included preparation
of the technical contents of an example draft rule applicable to facilities using or
storing seven toxic chemicals and technical reference manuals concerning hazards
and their control in such facilities. The chemicals are chlorine, hydrogen fluoride,
hydrogen cyanide, ammonia, carbon tetrachloride, sulfur dioxide, and chloropicrin.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Pollution
Emission
Accidents
Toxicity
Chlorine
Hydrogen Fluoride
Hydrogen Cyanide
Ammonia
Carbon Tetrachloride
Sulfur Dioxide
Chlorohydr oc arb ons
Pollution Control
Stationary Sources
Accidental Releases
Chloropicrin
13 B
14G
13 L
06T
07B
07C
3 QiSTHIHUTION STATEMEN1
Release to Public
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
167
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
£PA farm 222ff-1 (9-73)
163
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