United States Region 1 Date of Audit:
Environmental Protection Environmental Services Division April 10-14, 1989
Agency 60 Westview Street Date Of Report:
Lexington MA 02173 November 17.1989
&EPA Chemical
Safety Audit Report
W.R. Grace
Organic Chemicals Division
Nashua, New Hampshire
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&EPA Chemical
Safety Audit Report
W.R. Grace
Organic Chemicals Division
Nashua, New Hampshire
Date of Audit:
April 10-14, 1989
Date Of Report:
November 17, 1989
United States Environmental Protection Agency
Region 1 Environmental Services Divison
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TABLE OF CONTENTS
Section Page
LIST OF TABLES v
EXECUTIVE SUMMARY 1
1 INTRODUCTION 1-1
1.1 Introduction 1-1
1.2 Report Organization 1-2
2 PURPOSE AND METHODOLOGY 2-1
2.1 Purpose 2-1
2.2 Methodology 2-2
2.3 Audit Limitations 2-4
2.4 Audit Team Composition 2-4
3 FACILITY INFORMATION 3-1
3.1 Site Setting 3-1
3.2 Site Description 3-2
3.3 Production Overview 3-2
3.4 Facility Representation 3-3
4 HAZARDOUS MATERIAL RELEASES 4-1
4.1 No. 5 Reactor Release - 8/5/88 4-1
4.2 Ammonia Release - 4/6/88 4-2
4.3 Hydrocyanic Acid (HCN) Release - 3/15/88 4-2
4.4 Sodium Cyanide (NaCN) Release - 1/16/88 4-3
4.5 Nitrogen Oxide (NOx) Release - 6/6/87 4-4
5 HAZARDOUS CHEMICALS AND TOXICOLOGY 5-1
5.1 Hydrogen Cyanide (HCN) 5-1
5.2 Phosphorous Trichloride (PC1-) 5-1
5.3 Anhydrous Ammonia 5-1
5.4 Sodium Cyanide/Sodium Cyanide Solutions (NaCN) 5-2
6 HAZARDOUS CHEMICAL STORAGE AND HANDLING 6-1
6.1 Storage and Handling of Hydrogen Cyanide (HCN) 6-1
6.1.1 Storage 6-1
6.1.1.1 B HCN Storage Tank 6-1
6.1.1.2 A HCN Storage Tank 6-3
6.1.1.3 HCN Tank Cars 6-4
6.1.1.4 HCN Railcar Unloading Area 6-4
6.1.1.5 HCN Pipe Connections 6-5
6.1.1.6 HCN Product Unloading 6-5
111
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TABLE OF CONTENTS (Continued)
Section Page
6.1.2 HCN Handling and Transfer 6-6
6.1.2.1 HCN Feed System 6-6
6.1.3 General Safety Features 6-7
6.1.3.1 HCN Vapor Detectors 6-7
6.1.3.2 Integrity of Overall HCN Systems 6-8
6.1.4 First Aid and Medical Treatment for
HCN Exposure 6-8
6.2 Storage and Handling of Phosphorous Trichloride (PC1~). 6-9
6.2.1 Storage 7.. 6-10
6.2.2 Handling Observations 6-10
6.3 Storage and Handling of Ammonia 6-11
6.3.1 Storage 6-11
6.3.2 Handling 6-11
6.4 Storage and Handling of Sodium Cyanide (NaCN) 6-12
6.4.1 Storage 6-12
6.4.2 Handling 6-13
7 GENERAL PROCESS AREAS 7-1
7.1 Ketone Amino Nitrile (KAN) Process 7-1
7.2 Iminodiacetic Acid (IDA) Area 7-1
7.3 Nitrolotriacetic Acid (NTA) Area 7-2
8 RELEASE PREVENTION AND ENVIRONMENTAL COMPLIANCE 8-1
8.1 Safety Management Programs and Equipment 8-1
8.1.1 Process Hazards Review 8-1
8.1.2 Serious Incident or Near-Miss Reporting and
Accident Review 8-1
8.1.3 Unobserved Operations 8-2
8.1.4 Equipment Storage ' 8-2
8.2 Safety Management Program and Personnel 8-2
8.2.1 Communications 8-2
8.2.2 Contingency Plan and Emergency Response Teams .. 8-3
8.2.3 Training and Safety Operations 8-4
8.3 Safety Management Programs 8-5
8.3.1 Maintenance 8-5
8.3.2 Facility Control Rooms 8-5
8.3.3 Prevention of Leaks and Vapors 8-6
8.3.4 Fire Fighting and Vapor Suppression 8-7
8.4 Emergency Preparedness and Planning Activities 8-7
8.4.1 Emergency Response Systems 8-7
8.4.2 Public Alert and Notification Procedures 8-8
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TABLE OF CONTENTS (Continued)
Section
8.4.3 Title III Activities and Environmental
Compliance 8-8
8.5 Pollution Control and Waste Management 8-9
8.5.1 Air Pollution Control 8-9
8.5.2 Water Pollution Control 8-10
8.5.3 Hazardous Waste Management 8-11
8.5.4 Solid Waste Management 8-12
8.5.5 Underground Storage Tanks 8-13
8.5.6 Pesticide Use and Storage 8-13
8.5.7 PCB Inventory Management 8-13
9 SUMMARY OF MAJOR AUDIT OBSERVATIONS AND RECOMMENDATIONS 9-1
9.1 Reactor No. 5 Hydrogen Cyanide (HC1) Release 9-1
9.2 Hydrogen Cyanide (HCN) Storage and Transfer 9-1
9.3 Railcar Unloading Operation 9-2
9.4 Monitoring '. 9-2
9.5 Phosphorous Trichloride (PCI-) 9-2
9.6 Sodium Cyanide (NaCN) Storage 9-3
9.7 Emergency Backup Power 9-3
9.8 Chemical Accident Prevention 9-3
9.9 Operation and Maintenance 9-4
9.10 Emergency Venting 9-4
9.11 Environmental Compliance 9-5
9.12 Hazards Analysis 9-5
9.13 Accident Investigation and Followup 9-6
APPENDICES
A. Site Plan and USGS Survey Map
B. Photographs of the Facility Taken During the April 10-14, 1989
Audit
C. Accidental Release Information Questionnaire
D. HCN Release Profile
E. HC1 Release Profile
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LIST OF TABLES
Tables Page
2-1 CHEMICAL SAFETY AUDIT TEAM - 2-5
3-1 FACILITY REPRESENTATION 3-4
5-1 CHEMICAL STORAGE FOR THE THREE MOST HAZARDOUS CHEMICALS 5-2
8-1 W.R. GRACE UNDERGROUND STORAGE TANKS 8-14
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EXECUTIVE SUMMARY
During the week of April 10-14, 1989, the U.S. Environmental
Protection Agency, Region I (EPA) conducted an in-depth Chemical Safety
Audit of the W.R. Grace & Co. Hampshire Facility in Nashua, New
Hampshire. EPA was assisted by representatives from the Occupational
Safety & Health Administration (OSHA), Region I. The primary purpose of
the chemical safety audit was to identify imminent or potential hazards
to the community and the environment and to recommend corrective
measures for the W.R. Grace Organic Chemicals Division, Nashua, New
Hampshire. The scope of the audit did not include conducting a full
compliance evaluation for enforcement purposes. Although the Audit team
identified numerous safety problems, Grace has demonstrated a commitment
to safety and has made substantial improvements to release prevention
systems especially over the past 5 years. The Hydrogen Cyanide (HCN)
piping and storage facilities as well as the Phosphorous Trichloride
(PCI,,) storage tanks have been renewed and modernized and these
modifications have greatly reduced the possibility of a large-scale
release. The buffer zone between the facility and the neighborhood has
been increased through land purchase by the facility, and Grace has
aggressively participated in chemical emergency planning and community
awareness programs including those required under SARA Title III.
The on-site emergency response team has participated in highly
specialized training and is equipped to respond and mitigate chemical
releases on Grace property and in the community. Grace has a network of
continuous monitors to detect accidental chemical releases, and the
facility continuously monitors meteorological conditions. This
equipment, coupled with Grace's ability to model download concentrations
of accidental releases, provides the facility and community emergency
responders with the necessary tools to reduce the likelihood of a
catastrophic chemical emergency. However, the Audit team identified
several potentially serious safety problems within the plant and has
outlined recommendations in this report as a means to further reduce the
frequency and severity of chemical accidents which could impact the
community and the environment.
The most significant problems were found in the following areas:
o Reactor No. 5 Hydrochloric Acid (HC1) Release
o Hydrogen Cyanide (HCN) Storage and Transfer
o Railcar Unloading Operation
o Monitoring
o Phosphorous Trichloride (PC1-)
o Sodium Cyanide (NaCN) Storage
o Emergency Backup Power
o Chemical Accident Prevention
o Operations and Maintenance
o Emergency Venting
o Environmental Compliance
o Hazards Analysis
o Accident Investigation and Followup
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This list is not all-inclusive. W.R. Grace should consider
conducting a comprehensive plant-wide audit to identify additional
safety problems and place a high priority on rectifying all hazards that
could impact the community.
Safety is the ongoing responsibility of Federal, State, and local
government, the community, and the facility. The EPA will continue to
monitor planning, Community Right-to-Know, and release prevention
policies in Nashua, New Hampshire, through its Region I SARA Title III
program office located in Lexington, Massachusetts.
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1 INTRODUCTION
1.1 INTRODUCTION
During the week of April 10-14, 1989, the U.S. Environmental
Protection Agency, Region I (EPA) conducted an in-depth Chemical Safety
Audit of the W.R. Grace & Co. Hampshire Facility in Nashua, New
Hampshire. EPA was assisted by representatives from the Occupational
Safety & Health Administration (OSHA), Region I. The Nashua Facility is
one of four major chemical facilities operated and managed by the
Organic Chemicals Division of V.R. Grace & Co. Most of the products
manufactured at this location are based on hydrocyanic acid (HCN)
chemistry. The facility consists of four manufacturing plants, a
research lab, offices and effluent treatment facilities.
The purpose of the audit was to assess the overall environmental
and safety aspects of the site, especially in terms of potential impact
on the surrounding community and citizens. Evaluations were based upon
a review of documents provided by the facility and on information
gathered while on-site, both in conference with plant management and
through visits to the various production areas. The intent of the audit
was to thoroughly examine process equipment and storage facilities
associated with the use or handling of hazardous chemicals in order to
provide the Nashua Facility with information to enhance chemical safety
practices and reduce the likelihood of future accidents or releases.
Recommendations to minimize hazardous emissions at the facility are
included in this report. While the Audit team made certain observations
concerning compliance with environmental regulatory programs, the team
did not conduct a full enforcement inspection.
Observations represent a snapshot of conditions existing at the
facility during the audit timeframe, and do not represent planned or
anticipated changes already proposed or on-going at the facility.
Recommendations made in this report are not a substitute for a
comprehensive safety evaluation program, nor should absence of a
recommendation be used to halt any on-going evaluation or correction
programs, or affect proposed and on-going enhancement of a plant health
and safety culture, adhered to by plant management, staff, or any
visiting contractors.
The Audit team observed many toxic, corrosive and flammable
chemicals received, stored and processed at the site. The three
chemicals of most concern because of quantities, toxicities and vapor
pressures are hydrogen cyanide, ammonia, and phosphorous trichloride.
Plants working with significant quantities of such materials would
benefit from extensive plant buffer zones to reduce the possibility of
accidental releases of extremely hazardous substances migrating beyond
property lines. Because of this facility's close proximity to area
residents, the Nashua plant should have equipment, procedures, alarms,
redundancy, backup equipment, training and an attitude toward safety
that goes beyond industry standards. This is justified given the
potential for harm to health and environment if an accident of major
proportions were to occur. Strict safety procedures will reduce the
possibility of occurrence and the resulting consequences.
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This report describes existing processes observed during the audit
and provides recommendations to enhance safety through equipment and
process modifications. New techniques and practices are discussed as
veil. Major safety recommendations are outlined in the final chapters
of the report.
The Audit was conducted under the authority of the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act (SARA);
Clean Air Act (CAA); Resource Conservation and Recovery Act (RCRA); and
EPA's Accidental Release Information Program. It was coordinated with
the many State and Federal Agencies having jurisdiction over the
facility so as to minimize duplication of individual agency tasks and
maximize the use of limited resources available during the audit. This
process included a comprehensive inter-agency information sharing
effort.
The Nashua Facility cooperated in the Chemical Safety Audit,
providing knowledgeable personnel and detailed information upon request.
Management demonstrated a firm commitment to safety by fully
participating in the audit and providing sound documentation of existing
or planned safety improvements throughout the Audit period. The plant
has taken initiatives to improve health and safety, and significant
on-going safety improvements were observed at the facility which enhance
both health and safety and emergency preparedness. The Audit team
recognizes that numerous operations at the facility meet or in some
cases exceed industry standards. However, some deficiencies do exist.
The Audit team believes that an extra margin of safety is necessary at
the W.R Grace Nashua facility in view of the nature of operations and
the close proximity of the facility to the local community.
1.2 REPORT ORGANIZATION
o Section 1 - INTRODUCTION
This section includes an introduction to the Chemical Safety
Audit. It provides information on the report format, a plant
description, and an overview of the area surrounding the
facility. Some of the key concerns identified by the Audit team
are highlighted.
o Section 2 - PURPOSE AND METHODOLOGY
This section identifies and presents the goals established by
the Audit team, and includes a discussion of the methodology
used for accumulating information. The limitations of the Audit
team are also identified. A schedule of Audit team members is
presented, along with their areas of responsibility. This
section explains that a multi-disciplinary team approach was
used to provide checks and balances to validate observations and
document deficiencies as well as ensure maximum coverage of
material during the limited audit period.
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o Section 3 - FACILITY INFORMATION
Information is provided in this section as to the general
setting of the facility and the surrounding area. A facility
description and layout are provided. A brief production
overview is followed by a listing of V.R. Grace representatives
who participated in the audit, according to titles, job duties,
and assigned audit functions. Access to facility personnel not
identified in this section was limited and little information
was gathered from persons not referenced in this report.
o Section 4 - PAST HAZARDOUS MATERIALS RELEASES
A brief account is provided of major releases and incidents
experienced over the past 2 years at the facility, including a
description of the chemical releases, sequence of events,
notification procedures, chain of command, follow-up actions,
and modifications or training resulting from incident
evaluation and corrective actions applied.
o Section 5 - HAZARDOUS CHEMICALS AND TOXICOLOGY
A comprehensive analysis is provided of the most hazardous
chemicals used at the facility along with the potential for harm
associated with them as a result of existing operating
practices, accidents, or routine releases.
o Section 6 - HAZARDOUS CHEMICALS STORAGE
This section provides a comprehensive review of the chemical
storage facilities on the plant, transport, loading and
unloading facilities and practices, material transfer areas and
systems, production areas, and tank farms. The focus is on
general housekeeping, safe operating practices, containment
measures, chemical hazards, storage systems and the need to
maximize efforts to prevent chemical accidents from occurring.
o Section 7 - GENERAL PROCESS AREAS
An overview is provided of the different processes associated
with the production of speciality chemicals at the facility.
The section examines those areas of the plant that handle
hazardous or extremely hazardous chemicals.
o Section 8 - RELEASE PREVENTION AND ENVIRONMENTAL COMPLIANCE
Plant policies, plans, systems, and equipment are discussed and
evaluated in terms of their effectiveness and suitability to
prevent chemical releases from occurring. Observations on
possible health and safety enhancement measures are included.
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On- and off-plant impact from accidental releases are evaluated
in terms of quantities of material in storage and production.
Observations concerning compliance with several environmental
regulatory programs are also included.
o Section 9 - SUMMARY OF MAJOR OBSERVATIONS AND RECOMMENDATIONS
The Audit team's recommendations for enhancing chemical safety
procedures and management practices at the plant are outlined in
this section. Specific recommendations for actual changes or
modifications are included as well as recommendations to improve
general work practices.
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2 PURPOSE AND METHODOLOGY
2.1 PURPOSE
The Chemical Safety Audit program is an active outgrowth of EPA's
efforts under the Chemical Accident Prevention (CAP) program, originally
developed to address concerns regarding chemical facilities, generally
after the incidents at Bhopal, India and at Institute, West Virginia.
Audits are conducted to investigate the causes of hazardous
substance releases and to identify the particular operating practices,
process equipment, operator training, and managerial actions that can be
modified, encouraged or required so as to minimize the potential for
future releases.
The W.R. Grace facility was selected for an audit based upon the
following screening criteria:
o The plant utilizes and produces several high-hazard chemicals
which present the risk of an airborne release with significant
off-site consequences [e.g., hydrocyanic acid (HCN), phosphorous
trichloride (PCI,), and ammonia (NH,)].
o Seven accidental releases, some with potential for off-site
consequences, were reported for the period 1987-1988.
o The facility is located in a highly-populated area.
o The surrounding population is very concerned by and aware of the
potential consequences of a facility release. An example of
this sensitivity is the public and media reaction to the
hydrochloric acid (HC1) release which occurred on August 5,
1988, and is described in Section 4.1 of this report.
The Audit was conducted in order to evaluate the releases
that occurred at the plant in 1987 and 1988, and to help increase
process safety at the Grace facility through recommendations and an
exchange of information. The Audit team evaluated the following:
o Process safety equipment and personnel training;
o Internal release investigation procedures for both actual
releases and "near-misses;"
o Alert and notification procedures within the plant and outside
the facility;
o Hazardous chemical storage and handling;
o Standard operating procedures (SOPs);
o Chemical emergency prevention procedures;
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o Potential and consequences of off-site chemical releases;
o Compliance status with Federal and State environmental programs;
o Storage and handling;
o Pumping and piping;
o Flow control/metering/charging of material to reactors; and
o Pressure release venting of both reactors and storage vessels.
The Audit team concentrated its efforts on the most vulnerable
areas of the W.R. Grace facility, in terras of potential for an
accidental release, and also reviewed areas of the plant that handled
the most hazardous materials.
2.2 METHODOLOGY
W.R. Grace was notified of the EPA's intent to conduct a Chemical
Safety Audit of the facility prior to the actual audit so as to minimize
disruption to the facility. EPA also required that the plant complete
and submit an EPA Release Prevention Questionnaire for each of the seven
releases under investigation, as well as detailed replies to a series of
questions concerning the following:
o Federal and State environmental permits;
o Facility description and operations (including simple process
flow diagrams);
o Map of the facility (highlighting buffer zone size);
o Surrounding population density, distribution, and land use;
o Lists of all extremely hazardous substances present in excess of
a threshold planning quantity;
o List of all CERCLA hazardous materials in excess of 10,000 Ibs
used in any calendar year;
o Description and location for the use, treatment, storage,
disposal and handling of these chemicals;
o Hazardous material release prevention plans and procedures; and,
o Training activities at the facility related to safety and loss
prevention.
W.R. Grace - Nashua Facility - compiled the data requested and
provided the material to EPA on September 7, 1988. Following review of
this data and other material available regarding the facility, the audit
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was scheduled for February 1989. This delay was due to EPA budget
constraints. The audit was ultimately rescheduled for the week of
April 10-14, 1989.
The Audit team assembled by EPA included representatives from
numerous technical disciplines including: chemical, mechanical and •
safety engineering; industrial hygiene; and the environmental sciences.
A consulting process engineer with over 30 years experience in cyanide
processes was retained to provide observations in the area of plant
operations and cyanide chemistry. Other team members were drawn from
the EPA, OSHA and EPA contractors.
The Audit itself consisted of a series of presentations made by
facility representatives, round table discussions, and facility tours to
examine various site elements, including physical infrastructure and
safety mechanisms. After the first day's introductions, daily meetings
opened with a series of observations presented by the Audit team, based
on the previous day's findings. When these issues had been addressed by
Facility Representatives, new issues were brought up for discussion, and
specific site locations were identified for viewing.
The Audit team toured the facility as a cohesive unit, accompanied
by the facility representatives listed in this report. No other
W.R. Grace employees were questioned by the Team, or made presentations
as to their activities with the exception of the union representative
who was interviewed by OSHA.
Topics reviewed by the Audit team included the following:
Chemical Hazards
o Past hazardous materials release incidents,
o Chemical handling and storage, and
o Chemical transfer and waste management practices.
Safety Procedures and Training
o Standard operating conditions;
o Emergency spill/emissions procedures;
o Emergency response, alert, and notification procedures;
o Detectors and alarms;
o Safety programs (e.g., Respiratory Protection Program);
o Safety rules, safety equipment, and safety attitudes;
o Inspections and drills;
o W.R. Grace's Emergency Response Procedures and Contingency
Plans;
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o Training requirements and practices (new employee, contractor,
Hazmat Team, Fire Brigade, Community Relations Groups); and
o Maintenance (e.g., upkeep of personnel protection equipment,
training records, calibration of monitoring instruments).
General Information
o Environmental permits and licenses;
o Release modeling;
o Piping and Instrumentation Diagrams (PIDs), interlocks, relief
valves;
o Equipment integrity checks; and,
o General maintenance.
2.3 AUDIT LIMITATIONS
While the Chemical Safety Audit conducted at the Nashua Facility
was comprehensive given the 1-week time period allotted, several areas
were not specifically addressed, namely:
o A hazards assessment using methods comparable to What if?, Fault
Tree, Hazards and Operability Studies, or Failure Mode and
Effect and other consequences analyses. Such studies require an
extended timeframe and were not within the scope of this audit.
The Audit team did investigate the hazards assessment methods in
use by the facility. These findings are documented in the
report.
o A detailed review of the design specifications for storage
vessels, pressure vessels, reactors, scrubbers, valves, piping,
pumps, controls systems, etc. was not conducted with respect to
ASME, API, or NFPA codes and standards. The Audit team did
investigate critical systems in terms of construction material
compatibility, valve and flange gasket compatibility, reactor
pressure relief venting requirements, safety system redundancy,
storage vessel venting and scrubbing requirements, and tank
level indicators.
o A detailed review of Piping and Instrumentation Diagrams (PIDs)
was undertaken. In general, the PIDs reviewed by the Team were
process flow diagrams not containing information on mass
balance, temperature, pressure, control systems, or equipment
specifications.
2.4 AUDIT TEAM COMPOSITION
Table 2-1 depicts the Chemical Safety Audit team (all of whom
assisted in preparing the material used in this report), chosen for
their expertise in diversified environmental, chemical process, and
health and safety disciplines.
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Table 2-1
Chemical Safety Audit Team
AUDIT TEAM MEMBER
Ray DiNardo
Title III Program Mgr.
Environmental Engineer
Ken Ferber
Environmental Engineer
Paul O'Connell
Safety Engineer
Fred Malaby
Industrial Hygienist
Jeff Goodman
Environmental Scientist
William Jenks
Chemical Engineer
Tom Walsh
Industrial Hygienist
Mark Dahm
Chemical Engineer
Nermin Ahmad
Information Specialist
AFFILIATION
EPA, Region I
RESPONSIBILITY
Team Coordinator
EPA/AARP Region I Assistant Team Coordinator
OSHA, Region I
OSHA, Region I
ICF Tech., Inc.
Consultant
EPA TAT - E & E
EPA TAT - E & E
Safety Advisor
Industrial Hygiene/
Toxicology Advisor
Environmental Control/
Planning Consultant
Chemical Safety/Processes
Consultant
Response Procedures/
Containment Advisor
Chemical Systems Advisor
EPA TAT - E & E Technical Information
Controller
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3 FACILITY INFORMATION
The Nashua Facility is a batch specialty chemical plant, producing
133 products on a continuous or a seasonal basis according to product
demand. Many of the chemicals used in plant production are considered
hazardous or extremely hazardous, and their use can result in serious
safety and environmental consequences unless proper safeguards and
prevention measures are routinely implemented. It is important for a
facility of this type to have a firm commitment to safety. Excellent
construction materials and proper storage and handling procedures are
necessary to reduce the potential for and frequency of serious chemical
accidents. Plant housekeeping measures, prevention of chemical
releases, and stringent health and safety measures must be a priority
for the W.R. Grace operation in Nashua, New Hampshire.
3.1 SITE SETTING
The W.R. Grace & Co.- Conn.'s Organic Chemicals Division - Nashua
Facility is located on Poisson Avenue, adjacent to the Merrimack River,
and within the city of Nashua, New Hampshire. Local land use is
primarily commercial, although three residences are located immediately
next to the facility's western entrance. To the east lies the Merrimack
River, separated from the facility by the tracks of the Guilford
Transportation Industries, Inc. railroad and a narrow strip of land.
Across the river lies a golf course, a multi-family residential area,
and a quarry. A 5,000-home residential housing development is proposed
to be constructed across the river and the development could be within
the impact area of a large scale accidental release.
On the western edge, the facility is bound by commercial
development (including a motel, a day-care center, and three
restaurants), and by additional commercial property to the north. To
the south lies another manufacturing plant. The 5-mile radius from the
plant includes all the population of Nashua and Hudson, New Hampshire,
and a substantial part of the populations of Tyngsboro and Dunstable,
Massachusetts. This represents a total population of approximately
108,000. The 5-mile total population figure reflects a rapid growth
rate in the area. When the plant was originally constructed, the area
was sparsely populated.
There is a steep downgrade slope from west to east (or from the
private residences towards the river.) Spit Brook crosses the western
boundary of the plant site and flows northeast for some 200 feet before
being conveyed beneath the plant through a 6-foot conduit to the
Merrimack River which flows from north to south.
Access to the plant is controlled through a guardhouse set at the
primary entrance. Three other plant entrances are kept locked and only
used in emergencies, or during heavy construction activities. The plant
site is surrounded by a fence, and employees have stickers on their cars
allowing them access to the on-plant parking area. Visitors must
register with the guard, who issues them a visitor's badge. This badge
must be displayed at all times while the visitor remains at the
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facility. Although security is adequate, the Audit team noted that
security requires improvement.
The three locked entrances may initially restrict exit of
evacuating employees during an emergency. Plant-wide evacuation
procedures need to be tested and evaluated by Grace through the
conducting of a full field chemical accident simulation.
3.2 SITE DESCRIPTION
The need for a better-than-average commitment to health and safety
is emphasized by the location of the plant. The facility is located
within an urban area, with an average buffer zone of only 387 feet to
densely populated areas. Some residences are directly adjacent to the
facility. The greatest buffer zone width is only approximately 4,800
feet to the east. The Merrimack River flows by the facility and four
townships, including Nashua, New Hampshire, are within a 5-mile radius
of the plant. The plant has recently acquired additional land and is
presently situated on some 40 acres. Actual process areas are confined
to approximately 5 acres on which the majority of the critical process
equipment is housed within several buildings. Raw material storage,
unloading, and shipping areas are outside these buildings and these
activities are conducted at various locations throughout the plant.
Ancillary operations, including boilers, cooling towers and
compressors are distributed throughout the facility. The plant sewer is
divided into separate north/south systems of surface drains and
underground sewers, both of which feed the wastewater treatment facility
located on the northern edge of the plant. A fluidized bed incinerator,
utilized for the thermal destruction of the liquid wastestream generated
by the facility is located towards the southern end of the site.
3.3 PRODUCTION OVERVIEW
The Hampshire Chemical Corporation began production in 1958, using
a newly patented high-technology manufacturing process developed by its
two original founders. In 1965, W.R. Grace and Co., a major U.S.
specialty chemical producer, bought the plant, making it one of the four
major chemical facilities operated and managed by its Organic Chemicals
Division. There are currently 325 full-time employees at the plant,
including some 200 factory personnel and 125 office and research staff.
Nearly 30 percent of the staff has been employed over 15 years with the
company, and 80 percent has been employed for over 5 years.
A number of commodity chemicals are processed at this location,
including common commercial industrial products such as caustic soda,
formaldehyde, amines, and sulfuric and hydrocyanic acids. The products
are used to create a wide line of items which include detergent and
sanitizer additives, agricultural nutrients, food additives,
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pharmaceutical ingredients, and beauty products. Major by-products are
recovered and sold. The principal chemical products manufactured are:
o Hampshire Chelating Agents, or amino acid compounds. These are
used for water softeners, in industrial boiler water treatment
formulations, detergents, bathroom cleaners, and chemical
intermediates.
o Metal-chelates. This group is used to provide essential trace
elements for plant fertilization in mineral deficient soils as
well as for adding essential nutrients to foods, and removing
toxic hydrogen sulfide gas in geothermal applications.
o Hamposyl Surfactants are developed to enhance the cleaning
capacity of detergents and soaps. They can be used in shampoos
and rug cleaning formulations.
o Organo amino nitriles are used as chemical intermediates.
o Sodium cyanide is sold to the metal finishing and electronic
industries.
o Anhydrous ammonia is recovered for agricultural and industrial
markets.
o Sodium sulfate is recovered at the facility and sold to the
paper industry.
o Phosphorous acid is recovered and sold for the production of
chemicals used in secondary oil recovery.
The Pilot Laboratory is used for research and development
purposes and for the production of small-volume chemical products.
The only wastestream generated and stored as a direct part of
process design is MIBKAN (organoarainonitrile) waste, which is designated
as Reactive - D003, and stored in a 5,000-gallon storage tank. This
tank is located within the 100-year floodplain, and is set in a concrete
diked area, whose walls top the floodplain by 2 feet. Other hazardous
wastes are produced by off-spec products and raw materials, process
wastestreams, and equipment cleaning or maintenance activities. These
wastes are drummed and kept in the drum storage area (400 55-gallon
drums maximum capacity), which is maintained outside the 100-year flood-
plain. The wastes include liquid chelating agents with high pH values,
classified as EPA Corrosive - D002, and solid sludge residues from
cleaning primary liquor storage tanks, including nitriles and free
cyanide (1-3%), classified as Reactive - D003.
3.4 FACILITY REPRESENTATION
In order to better assist the Audit team with its activities, the
facility made available the persons listed in Table 3-1 to answer
questions, identify and provide documentation, and generally assist the
team in its efforts.
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Table 3-1
Facility Representation
Employee Name
Jeremiah B. McCarthy
Lauchlin V. Hines
William J. Pasko
Roderic McLaren
Mark Stoler
James J. Todd
Eileen E. Conley
Facility
tf.R. Grace & Co.
Nashua, NH
W.R. Grace & Co.
Nashua, NH
W.R. Grace & Co.
Nashua, NH
W.R. Grace & Co.
Lexington, MA
W.R. Grace & Co.
Cambridge, MA
W.R. Grace & Co.
Nashua, NH
W.R. Grace & Co.
Nashua, NH
Title
Plant Manager
Assistant Plant Manager
Technical Manager
Manager of Regulatory
Services
Environmental Counsel
Safety Director
Environmental Engineer
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4 HAZARDOUS MATERIALS RELEASES*
4.1 NO. 5 REACTOR RELEASE - 8/5/88
The escape of hydrogen chloride from the No. 5 Reactor caused a •
release of about 108 pounds of Hydrochloric acid (HC1). Approximately
3,700 persons were evacuated from off-plant locations and 51 people were
evaluated at local hospitals. One person was kept overnight for
observation; the rest were immediately released. Although this quantity
of material apparently did not cause multiple injuries, there was
potential for greater harm. The release caused real concern and
awareness among the community.
HCl was released into the atmosphere primarily due to failure of
the 8-inch butterfly valve on the No. 5 Reactor in Plant #1, during the
addition of phosphorous trichloride (PCl-j) to the process. Additional
release occurred while abatement was underway for the initial problem.
To prevent re-occurrence of this failure, the plant has replaced
the 8-inch manual butterfly valve with an 8-inch Teflon lined, butterfly
valve and has installed a second in-line scrubber and a manometer to
check pressure, or vacuum in the reactor exhaust vent to the scrubber.
The long-term program includes installation of a vacuum sensor in
the exhaust vent to continuously monitor pressure, and an interlock with
the PCI- inlet valve, in order to prevent flow of PCI- to the reactor if
less than a 2-inch vacuum pressure is available.
Prevention observations by the Audit team for the No. 5 Reactor
include the following considerations for the Grace facility:
o Investigate the installation of a "Hammer" line blind in the
vent line to augment the 8-inch butterfly valve, or an
equivalent backup device to assure positive closure.
o Consider inclusion of a positive lockout valve for material
inlet when the 8-inch butterfly valve is open.
o Pressure test the unit before adding chemicals to assure
tightness and no leaks.
o Interlock the pressure/vacuum recorder to chemical addition and
to an alarm, and install a continuous monitoring vacuum gauge
with a readout in the control room. A manometer readout,
located where it can be continuously monitored during the
critical cycles of operation, should also be considered.
* Please refer to Appendix C, D and E for additional information about
the releases described in this Chapter.
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o Consider installation of a product weight indicator such as a
load cell or a level indicator for this reactor. This would
provide a more accurate measure of the reactants and further
reduce the possibility of an accident.
o Color code and label the incoming chemical lines to the reactor.
o Provide a positive means of assuring that the agitator is
functioning before chemicals are added.
o Remove paint from the sight glass or blank off the sight glass
if appropriate. Painted glass on a reactor is not an acceptable
safety practice and does not allow for visual observation of the
process.
o Perform an in-depth hazards review of the No. 5 Reactor and its
operations. The major focus of the review would be intrusion of
water and accidental mixing with PCI,,.
4.2 AMMONIA RELEASE - 4/6/88
The Operator did not get a signal to indicate that the ammonia
scrubber valve was incorrectly set and a valve to atmosphere remained
opened. Even after the error was discovered, the Operator became
distracted and left the critical valve open for approximately 10
minutes before reacting to the accidental release.
Prevention observations for the April 6, 1988, ammonia release are
listed below:
o Consider installing an alarm system to indicate when a bypass or
atmospheric vent is incorrectly left open.
o Study the feasibility of installing a system for automatically
knocking down exhaust fumes when these fumes are accidentally
vented to the atmosphere.
o Research the possibility of including a backup system for
monitoring critical valve settings.
o Review operating procedure for venting to the atmosphere in case
of failure of the primary control system. An alternative would
include manual bypass to a secondary scrubber.
4.3 HYDROCYANIC ACID (HCN) RELEASE - 3/15/88
During the process of transferring HCN to the #4 holding tank on
the roof of Plant #1, a leak occurred at the flange on the bottom of the
hydrocyanic holding tank. Because of an incorrect reading from the tank
differential pressure (DP) cell, the operator investigated and found
leakage around the DP cell flange at the bottom of the holding tank.
While the amount of leakage was relatively small (about 30 Ibs), the
potential existed for a far greater quantity to escape since 'the holding
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tank above the leaking flange gasket contained significant amounts of
HCN. The leak was detected through both indication of a weight change
in the process vessel and through a fixed point HCN detector alarm. The
response and mitigation of the accident by Grace were prompt. To
prevent future releases, the holding tank system has been removed and.
replaced with a three valve system of feed, wash, and nitrogen purge.
Audit team prevention observations are listed below:
o Study the possibility of reducing quantities of HCN used,
especially in areas where bottom outlets and flanges exist.
o Investigate the possibility of replacing other critical holding
tank systems with the three valve option of feed, wash, and
purge.
o Determine the possibility of eliminating all but the most vital
flanges. Replace non-critical flanges with welded connections.
4.4 SODIUM CYANIDE (NaCN) SOLUTION RELEASE - 1/16/88
A NaCN leak occurred from a flange at the pump near a NaCN storage
tank. The bolts on the flange were loose and apparently had not been
tightened by the maintenance crew.
Railroad personnel, who were delivering bulk chemicals to the
plant, asked about the spill and roped off the area. Upon hearing that
cyanide had leaked, they took it upon themselves to notify the local
fire department without properly coordinating the notification with
on-site response personnel. Very little NaCN did in fact leak and the
incident was not a serious one. The potential, however, existed for a
much greater spill.
Audit team observations regarding this release include:
o Pressure testing with water, air, or nitrogen of any newly
installed, recently replaced or repaired system, prior to
chemical introduction is important. Pressure testing minimizes
the potential for leaks, especially for systems using toxic,
corrosive, reactive or flammable chemicals. Grace personnel
should review their procedure for recommissioning equipment used
for hazardous material service.
o Ensure well-defined and maintained systems of communication
between Maintenance, Operations, and Response personnel. Poor
communications between these groups has traditionally been at
the root of many chemical industry incidents. In all cases,
initial responsibility remains with Operations personnel to
ensure that all equipment is tight and secure before chemicals
are introduced, valves opened or pumps started. Communications
and release notification procedures need to be reviewed.
o Evaluate lock-out/tag-out procedures of critical valve systems.
Currently, only tag-out is used for many critical systems.
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4.5 NITROGEN OXIDE (NOx) RELEASE - 6/6/87
Iron filing residue from raw material charges had settled out in
the piping above the discharge valve on a process vessel. When the
gasket on the valve failed, it allowed the escape of 400 gallons of
nitric acid solution which reacted with the iron filings. This resulted
in the release of approximately 11 pounds of NOx after containment. The
on-site emergency response teams responded promptly and knocked down the
vapors while diluting the process batch using the plant fire hose
system. No injuries, on- or off-site, occurred. However, some adverse
publicity was generated toward the plant in the local press and the
incident had the potential for greater harm.
The discharge piping and valving from the vessel have been modified
to minimize space for iron filings to accumulate in the area of a
gasketted flange. The flanged section and shutoff valve at the bottom
of the reactor have been removed. This will reduce the possibility of a
local reaction taking place.
Increased agitation during the reaction phase has also been
instituted to ensure proper mixing and a complete reaction.
The Audit team observed that Grace should:
o Locate flanges and valves as close to the vessel as possible and
wherever feasible to minimize dead ending of material. This is
also applicable to Tee take-offs from main-line piping.
o Minimize the number of flanges used wherever possible to lower
leak potential.
o Institute a formalized periodic gasket renewal and changeout
program.
o Consider the use of a "Super" gasket such as a flexitallic
gasket at all critical locations.
o Investigate the use of "state-of-the-art" variable spray nozzles
on fire hoses for improved "knocking" down of vapor clouds
during emergencies.
o Study the use of interlock valves to prevent material additions
for this process without agitator operation. This is
appropriate in all systems where separation or violent reaction
could occur.
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5 HAZARDOUS CHEMICALS AND TOXICOLOGY
Although the Grace facility uses and produces a large number of
chemicals, the Audit team concerned itself primarily with the hazards
associated with the four chemicals described in this section in terms .of
their toxicological impact. In the event of a release or other
incident, these are considered to be the chemicals in use with the most
potential for harm to health and the environment.
5.1 HYDROGEN CYANIDE (HCN)
HCN is a colorless liquid, miscible with water, and characterized
by a faint bitter almond odor. The boiling point is 78.3°F at one
atmosphere. The liquid is lighter than water (sp.gr. 0.688 at 68°F) and
the vapor is slightly lighter than air (sp.gr. 0.947 at 88°F). The
flashpoint (ASTM-D56) is 0°F and HCN vapor/air mixtures are flammable
from 6 to 41 percent HCN by volume.
HCN is highly toxic via the inhalation, ingestion, and skin
absorption exposure routes. It is a true protoplasmic poison that
combines in the tissues with oxygenation enzymes, interfering with the
transfer of oxygen to the cells, including the heart and brain. Acute
symptoms include headache, dizziness, a feeling of suffocation and
nausea. The OSHA Permissible Exposure Limit (PEL) is 4.7 ppm for a
fifteen minute exposure and the lowest published lethal concentration
(LCLQ) for humans over a 10 minute exposure is 178 ppm. This
concentration would be lethal without emergency medical attention and
the administering of a cyanide antidote.
HCN is a Class A poison. It is fast acting and can cause rapid
death at low exposures. Dangerous concentrations of HCN may be present
without causing warning or discomfort because the weak odor is neither
irritating or obnoxious.
5.2 PHOSPHOROUS TRICHLORIDE
PCL, is a clear, colorless, fuming liquid with a boiling point of
165°F. The liquid is denser than water (sp.gr. 1.574 at 70°F) and the
vapor is much denser than air (sp. gr. 4.75 at 70°F). PCI- is an
extremely reactive chemical reacting vigorously with water or acids
evolving highly toxic hydrogen chloride gas.
PC13 is highly toxic via the ingestion and inhalation exposure
pathways and highly irritating to the skin, eyes and mucous membranes.
The OSHA time weighted average (TWA) for PC13 is 0.5 ppm.
5.3 ANHYDROUS AMMONIA
Anhydrous ammonia is a very water soluble, colorless gas with an
extremely pungent odor. The gas may be liquefied by compression; it is
typically stored at ambient temperature at 150 to 175 psig. As a
liquid, ammonia is less dense than water, (sp.gr. 0.817 at 32°F) and the
vapor is less dense than air (sp.gr. 0.6). Mixtures of ammonia and air
are flammable at ammonia concentrations of 16 to 25%.
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Ammonia is a powerful irritant to the eyes and mucous membranes of
the respiratory tract. Acute symptoms include irritation of the eyes,
conjunctivitis, swelling of the eyelids, coughing, and vomiting. The
OSHA Time Weighted Average (TWA) is 50 ppm.
5.4 SODIUM CYANIDE/SODIUM CYANIDE SOLUTIONS (NaCN)
NaCN is a white, crystalline powder with a specific gravity of 1.60
at 72°F. The solid is readily water soluble.
NaCN, cyanide dust, and cyanide solution are toxic via the
inhalation, ingestion and dermal contact exposure routes. The OSHA time
weighted average (TWA) is 5 mg (CN)/m . Toxicity by ingestion as given
by LDc/% is below 50 ug/kg.
Employees, on- and off-site emergency responders, planners, and the
community should be thoroughly familiar with the quantities, locations,
and health effects of the chemicals listed in this section. The
chart in Table 5-1 lists the chemicals and storage capacities for the
largest volume hazardous chemicals at the facility.
Table 5-1
CHEMICAL STORAGE FOR THE THREE MOST HAZARDOUS CHEMICALS
HAZARDOUS CHEMICALS
Hydrogen Cyanide
Phosphorous Trichloride
Anhydrous Ammonia
STORAGE CAPACITIES
30,000 gallons
30,000 gallons
6,000 gallons
3 x 30,000 gallons
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6 HAZARDOUS CHEMICAL STORAGE AND HANDLING
6.1 STORAGE AND HANDLING OF HYDROGEN CYANIDE (HCN)
One of the key areas of concern for the Audit team was an
assessment of the storage and handling of HCN at the W.R. Grace
facility. The following sections provide an in-depth examination of
each of the critical storage vessels, and the handling and pumping
procedures followed for HCN as observed by the Audit team.
6.1.1 Storage
Overview of facility operations revealed that W.R. Grace has
reduced the total HCN storage capacity at the facility from over 100,000
gallons to a present capacity of (60,000 gallons) divided equally among
two storage tanks designated as A and B. When constructing a new more
conservative storage system, the facility took the opportunity to
install new piping, pumps, and tank monitoring instrumentation. Further
HCN capacity at the facility is provided by five railcars, each with a
20,000-gallon capacity. These cars are typically parked at the plant.
The plant operates a fleet of 31 cyanide railcars whose primary function
is delivery of HCN to the plant site from suppliers.
6.1.1.1 B HCN Storage Tank
The B Storage Tank (nominal capacity of 30,000 gallons) is a high
quality installation. It is well-designed and constructed and was
located on-site within the last 2 years. It is an ASME code vessel,
with no bottom outlet, fully insulated and placed within a partially
below-grade concrete dike enclosure. The safety features of this system
were reviewed both in the field and through the use of process flow
diagrams.
The tank is padded and purged with nitrogen from a dedicated
nitrogen tank. It is maintained under a nitrogen blanket with nitrogen
circulated to all tank ports. A scrubbing system continuously
circulates caustic through a venturi, removing HCN vapors from the
storage tank vent system. The venturi scrubber also helps maintain the
tank under a slight vacuum. The system operates from an electric driven
pump without emergency power backup. If power were lost for an extended
period, the HCN tank could overheat and create excessive vapor pressure.
There is space maintained equivalent to one storage tank in an on-site
HCN railcar, kept empty in case the tank develops a leak and needs to be
pumped out. The tank is maintained at a maximum of 46°F by circulating
the HCN through a circulating fluid coolant heat exchanger using a
submerged pump. The three submerged pumps are a redundant system and
offer back up for circulation, cooling and pump-out.
One "StaTox" fixed HCN monitor (set at 10 ppm) is mounted
immediately above the vessel. This continuous ambient monitor is 1 of
17 in place throughout the plant, all of which are tied to a central
control panel. The HCN storage tank is equipped with three independent
level sensors: a bubbler meter, a capacitance meter, and a high-level
alarm. The storage tank is sampled several times a week for color,
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stability, and contaminants. Low-pressure rupture discs are designed
to discharge into a diked area so that liquid entrainment would be
confined. A discrepancy of 10 percent was noted between the two
separate level indicators for the storage tank. This discrepancy was
discussed with plant personnel, who indicated a willingness to evaluate
and correct the problem. In addition to the two gauges, a backup
high-level alarm is in place for the tank.
The potential for a major HCN spill or vapor release would be as a
result of a large leak in the tank or a "run-away" polymerization of
HCN. Polymerization of a tank would result in high temperatures and the
possible vaporization of liquid HCN out of the emergency rupture disk.
However, emergency acid addition facilities are in place at the facility
in case the HCN begins to lose stabilizer. The potential for a
catastrophic event is minimized at the Grace facility through safety
devices, redundancy, and surveillance.
Observations:
Several modifications to the B HCN storage vessel would serve to
enhance the safety of the storage system and improve the mitigation
response, should a release occur. These observations,are itemized
below:
o The facility could install an additional water gun, capable of
400-600 gpm, with a fog nozzle, to be located in the area south
of the storage tank. The additional water gun, in combination
with an existing gun on the west side of the tank, would result
in enhanced coverage of the tank area during a release. In the
event of either a catastrophic tank failure or a high volume
release from the tank emergency vent stack (which discharges
into a diked well surrounding the HCN tank), the additional
water coverage would be used to remove HCN vapor from the air
and to dilute liquid phase HCN which may be released from the
tank. A deluge system should also be considered.
o Grace should consider providing for means to ignite HCN if the
water gun system fails to mitigate the vapor cloud. When HCN
burns, it produces water, nitrogen, and carbon dioxide. Flare
pistols are available at the site for this purpose, but a spark
ignition system should be investigated. A review of the
emergency procedures for igniting HCN is desirable.
o Grace should continue close analytical surveillance of the HCN
storage tank contents. Samples should be taken at least three
times a week to assure product quality and stability. This is
necessary to provide assurance that water from line washings is
not excessive. Excess water can cause HCN instability and a
potential release. Sample boxes should be used when drawing
samples to avoid employee exposure. These procedures should be
clearly documented in the standard operating procedure (SOP)
manual.
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o Grace should look into providing containers of stabilizer acid
at the emergency addition station to enable faster mitigation.
o Installation of closed circuit television monitors and an
additional P/A speaker for the HCN storage area should be
considered. Such a system would be monitored in a central
control room, allowing operators to accelerate their response to
problems and emergency situations.
o Installation of additional "StaTox" HCN monitors in the HCN
storage area. These could be located opposite existing
continuous ambient HCN monitors in order to provide redundancy
and better vapor detection in case of a wind shift.
o Installation of either a fixed or portable backup power supply
for the HCN tank scrubbing system pump. Backup power would
ensure the continuous scrubbing of the storage tank vent and
prevent the release of HCN in the event of power interruption or
failure.
o Purchase of a large portable electric generator that could
operate the HCN tank circulation pump and refrigeration unit
should be considered.
o Installation of warning lights and beacons to be activated
during HCN railcar unloading operations would serve to augment
the small stand-up warning sign presently in use.
o Continuation of the maintenance of at least one empty HCN
railcar available for filling from a potentially leaking HCN
storage tank.
o At a minimum, gauges should be routinely checked, recalibrated,
and replaced when necessary.
o A detailed process hazards review of the HCN storage tank area
should be considered.
6.1.1.2 A HCN Storage Tank
The A HCN Tank (nominal tank capacity of 30,000 gallons) was placed
into service within the past 3 years. The tank is very similar in
design to the B HCN storage tank, being ASME code with no bottom outlet
and equipped with a partially belov-grade diked containment area. It is
nitrogen-blanketed, fully-insulated, cooled, with a HCN scrubber on the
tank vent line. The vessel is also equipped with one "StaTox" HCN
monitor and three independent level sensors. The A HCN Tank is similar
to the B HCN Tank except that it is shorter and stubbier due to spacing
constraints.
The observations outlined in reference to system safety for the
B HCN Tank in Section 6.1.1.1 apply to the A Tank as well.
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6.1.1.3 HCN Tank Cars
Thick steel tank cars each having a nominal capacity of 20,000
gallons of stabilized liquid HCN with very low-water content are shipped
to the plant by rail. tf.R. Grace leases a fleet of 31 tank cars. Most
of the tank cars are less than 2 years old. For safety, it is extremely
important that there is no significant intrusion of water or other
contaminates. If contamination occurs, it could destabilize the HCN and
this could lead to a vapor cloud release. The highest potential for
water intrusion is at the source and during unloading operations.
Mechanical integrity of cars is also important for preventing a tank
rupture and chemical release.
Observations:
o Grace should perform a process hazards review of all aspects of
car loading in order to assure a stable HCN product in the car
at all times.
o The facility should continue to review procedures for mechanical
checking of cars and internal inspections and testing.
6.1.1.4 HCN Railcar Unloading Area
The HCN unloading system for 20,000-gallon railcars was reviewed
through a study of the SOP and by inspecting equipment and procedures at
both the A and B railcar unloading stations.
Railcars are positioned at the unloading stations, brakes are set,
and wheels are chocked to prevent accidental railcar movement during the
connection of piping and flexible metal hose. To reduce accidental
bumping or movement of the offloading car by another car, rail engine or
trackmobile, the incoming rail switch is locked in the off position.
The key for this rail switch lock is kept with the person conducting the
unloading operation.
Because neither of the unloading locations is located at a dead end
of the rail spur, there is opportunity for an accidental intrusion and
bumping of the car. The geometry of switches and track at the A
location (which also serves the NaCN loading dock) is such that it is
possible for the operator to lock-out the wrong switch.
W.R. Grace should consider the following:
o Revision of the unloading procedures and check list to include
specific switch lock-out. Formalize written standard operating
procedures to include specific switch-out routines.
o Installation of derails for lock-out at the north ends of both
the A and B unloading positions.
o Study of these areas to determine the need for diking. The
topography of the A unloading area slopes gently down towards
the Merrimack River, whereas the B area is somewhat protected by
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a berm betveen the tank cars and the river. Installation of a
diked pad with a collection sump at both stations would greatly
minimize the surface area available for HCN volatilization and
provide additional protection to the river in case of a
catastrophic railcar failure or a release during unloading
operations.
6.1.1.5 HCN Pipe Connections
The first step after opening the dome cover of the railcar
attachment area is to remove the pipe plugs in the car unloading angle
valves. This is a potentially hazardous step because if the angle valve
is not in the "closed" position when the plug is unscrewed, HCN could
escape to the atmosphere.
The facility should consider the following procedures:
o Check for valve closure by pulling with a valve wrench before
removing the pipe plug.
o Measure the distance from valve handle to valve body before
removing the pipe plug. This distance will be at a minimum when
the valve is in the closed position.
o Assure that the pipe plug is removed slowly and cautiously. If
there is any indications of leakage, the plug should be
immediately re-tightened. In any case, the person wearing
protective equipment should always be prepared to close the
valve.
The second step is to screw the pipe nipple into the angle valve
using a remote operated safety shut-off valve. Too long a pipe-thread
section on the nipple creates a potential for leaks since it allows the
end of the nipple to strike against the internal shoulder of the angle
valve before the threads themselves have made a tight seal.
o Grace should take steps to ensure that none of the pipe nipples
used have threaded sections which are too long.
o After connection of the entire unloading piping and flexible
metal hose system, the whole system must be pressure tested in
order to avoid HCN leakage. According to Grace, this procedure
is routinely followed.
6.1.1.6 HCN Product Unloading
Nitrogen pressure on the vapor space of the HCN car causes transfer
of liquid HCN to the storage tank. As the storage tank level rises, HCN
vapor moves to the caustic vent scrubber. When the last amount of
liquid HCN leaves the car, a surge of HCN and nitrogen flows to the
storage tank which could result in a temporary overload of the caustic
scrubber. Persons in the vicinity of the scrubber vent may be exposed to
HCN vapors.
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Field observations by the Audit team are listed below.
o Grace should continue the practice of checking to make certain
the vent scrubber is functioning properly and that the percent
caustic remains above 12 percent.
o Red flashing lights should be installed to inform people that
HCN loading is underway.
o Additional signs should be installed to warn people to stay away
during unloading operations.
o Increased policing should be considered to assure that
unauthorized visitors or personnel not directly concerned in the
unloading operation do register with the control room and are
prohibited from wandering through the area.
6.1.2 HCN Handling and Transfer
HCN is transferred in stainless steel piping from the storage tanks
to the individual processes by submerged pumps in the storage tanks.
The HCN delivery piping systems are designed either on a loop circuit
back to the tank or as a one-way system to the process areas with a
water wash and nitrogen blow back sequenced automatically. Both systems
avoid leaving HCN stagnant in the piping system for extended periods.
This prevents destabilization or freezing. It is important that all
flanges and valves remain tightly secured at all times, and that there
is no opportunity for process or reactor material to back up into the
storage tanks and initiate a runaway polymerization reaction.
6.1.2.1 HCN Feed System
W.R. Grace has recently installed a circulating loop HCN feed
system which conveys HCN to Plant #1 and to individual reactors within
the facility from the HCN storage tank. HCN is introduced to individual
reactors through flow meters. Rotometers are also used as a redundancy
backup device. The circulating loop system allows Grace to pump HCN at
low pressure to the various reactors. This is in contrast to a system
that charges a substantial amount of HCN to a reactor system from remote
storage thereby requiring substantial pressure.
The existing design of the HCN circulating loop does not allow for
stagnation or dead-ending of HCN lines, thereby reducing the potential
for polymerization and subsequent over-pressurizing of piping. The
lines branching off the loop system are sloped, allowing HCN to drain
and further preventing HCN stagnation.
The circulating loop HCN feed system services all of Plant #1. The
system replaces an older system of HCN weigh tanks and hold tanks
previously used for introducing HCN into reactor vessels.
The remainder of the facility operations depend on the older, one-
way design HCN feed systems. Grace is considering installing the
circulating loop system plant-wide.
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Observations;
o Grace should consider implementing a schedule for installing a
circulating loop HCN feed system in all processes throughout the
facility.
o A process hazard review on each existing system should be
conducted in order to assess the following:
- minimized flange connections;
- minimized valves;
- ideal locations for HCN detectors;
- measures to prevent backflow of reactor material to the
storage tank;
- maintenance;
- emergency shutdown in case of leak; and
- release mitigation.
o A reassessment of pipe routing and protection of all HCN piping
from external damage should be considered. This assessment
could include the following:
- Determination of whether all HCN pipes are at the highest
possible level over roadways and whether all pipe supports are
adequately protected from accidental impact.
o A periodic changeout of critical gaskets to guard against age
deterioration or leaks should be considered. The new Durco
Teflon gasket with metal inner ring currently in use at the
facility should serve to prevent massive gasket failure.
However, this type of gasket requires careful evaluation since
it is not very resilient. The flanges must have good alignment,
they must be parallel, and uniform torquing is required.
o All flanges should be covered in the vicinity of work areas.
Some flanges were observed uncovered.
6.1.3 General Safety Features
6.1.3.1 HCN Vapor Detectors
Vapor detectors are critical to early indication of a leak. The
"StaTox" HCN detector currently in use would sound an alarm for a
detected leak in the vicinity of the monitor. A large or major leak
would activate several "StaTox" HCN monitors simultaneously.
Observations;
o Additional "StaTox11 HCN detectors should be installed throughout
the plant, at carefully planned and appropriate locations.
o Standardization of routine maintenance and calibration is
necessary.
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o Grace should perform a process hazards review of the procedure,
plans, and actions to be taken upon sounding of an alarm. This
would include representation of what pumps are to be shutdown,
by whom, and should include an analysis of other vapor
mitigation actions to be undertaken such as flaring or water
dilution.
6.1.3.2 Integrity of Overall HCN Systems
It is important that all equipment containing or used for the
transfer of HCN be metallurgically sound. Of equal importance is the
proper functioning of redundant instrumentation and interlocks.
Observations;
Grace should consider the following:
o Undertake periodic inspections of tank interiors to check for
solids build-up, corrosion, pitting, and impingement erosion to
prevent tank leakage. This should be undertaken by a materials
specialist.
o Keep all critical instrumentation in proper operating condition.
This includes at a minimum: load cells, level gauges, level
alarms, temperature recorders, alarms, and flow meters.
6.1.4 First Aid and Medical Treatment for HCN Exposure
The toxic effect of HCN is the inhibition of the oxidation process
in body cells by restricting oxygen transfer from the blood to body
tissue. Poisoning can result from breathing HCN vapors, absorbing them
through the skin, or by ingesting liquid cyanide.
It is extremely important to prevent leaks or exposure to cyanide
vapors or liquid solutions. However, the potential for a leak always
exists. A leak creates the need to administer immediate treatment to
individuals or a group of persons for cyanide poisoning. The key to
successful treatment and full recovery is prompt treatment.
No more than 4 minutes elapsed time should occur between exposure
and initiation of treatment. A longer time period jeopardizes recovery
of the exposed individual. This is one reason why location, number, and
proper operation of HCN monitors are extremely important. It is also
important that all workers in the HCN areas "know" and recognize the
odor of HCN, be familiar with a standard, and understand the "sniff
test." A brief inhalation of 300 ppm HCN or more in air can result in
rapid loss of consciousness and death unless first aid is immediately
and effectively administered.
In response to leaks at the plant, Grace plant personnel who have
been trained and have practiced the procedure during simulation
exercises, generally administer first aid using Amyl Nitrite and oxygen.
This is an interim measure until medical help arrives. Medical
treatment can involve injections and more sophisticated measures which
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must be administered by qualified medical personnel. Even if a nurse or
doctor is immediately present, first aid is sometimes administered while
preparation is made by the medic to provide more sophisticated
treatment. Rapid initial first aid may be sufficient to save lives.
Observations:
Grace should consider the following:
o Emphasize the importance of immediate and proper first aid for
cyanide exposure through training sessions and safety meetings.
o Study the need for and use of the amyl nitrite antidote and
oxygen resuscitation by those responding to an exposure.
o Station additional antidote and resuscitation kits in accessible
places to help reduce the time from exposure to treatment.
o Develop a schedule for installation of additional "StaTox" HCN
detectors.
o Increase the number of available portable Monitox detectors, and
encourage routine use of this equipment.
o Maintain air monitoring even while wearing air masks because of
vapor ingestion through skin.
o Continue to periodically perform "man-down1' drills for HCN
exposure to check for response time, ability to respond, and
first aid skills. Use time and video tape drills for review and
discussion.
o Perform periodic larger scale field simulations to evaluate
emergency response and proper actions by personnel, including
involvement of neighboring residents.
o Review all "Buddy" positions and areas to ensure proper use and
coverage.
o Provide periodic review of the HCN "Sniff Test" and associated
procedures to be followed upon recognition of a release.
6.2 STORAGE AND HANDLING OF PHOSPHOROUS TRICHLORIDE (PCI.,)
PC13 storage capacity at the facility is limited to one 6,000-
gallon tank housed in a diked building with a chain link fence serving
as the building walls. Since PCl^ is water-reactive, extreme care must
be exercised in its handling and storage to assure that it never comes
into contact with water. Grace should consider fully enclosing the
storage area to further minimize the potential for precipitation and
water accumulation within the diked area.
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6.2.1 Storage
PCI- is stored in a 6,000-gallon thick-walled, carbon steel tank
situated over a concrete pit, under a roofed area with open sides. The
tank is not a pressure vessel and does not conform to ASME code. A
second empty tank is maintained under a nitrogen blanket beside the
primary tank for use as a transfer vessel in case of a leak, for
repairs, or for routine inspection and maintenance. Neither tank has a
bottom outlet.
The major environmental and safety concern is to prevent leaks or
contact with moisture in the air or with water. Contact with moisture
would produce hydrogen chloride gas.
Although the PCI- storage area and scrubber water drain are diked,
they are located inside the enclosed storage area. At a minimum this
drain should be covered and the containment area sloped in order to
insure that water will always flow away from the storage area. This
safety measure should be designed to accommodate pluggage of the drain
line.
Water accumulation was observed by the Team during the audit.
Observations;
o Grace should at a minimum, cover up the scrubber water drain,
and slope the containment area in order to insure that water
will always flow away from the storage area.
o The PCI- scrubber water overflow discharge should be directed
outside the PCI- storage area to preclude the possibility of
water contact with a PCI., release.
o Grace should develop an action plan for implementation in case
of a large PCI- spill in order to avoid or mitigate a serious
environmental incident. Current procedures do not address this
possibility in sufficient detail.
o A process hazards review of the total PCI- system, including
unloading, storage, and transfer to process, should be
conducted.
6.2.2 Handling Observations
o The facility should consider restricting traffic in the
immediate area during unloading of tank trucks to the storage
tank through use of safety ropes or barricades.
o Grace should establish procedures to minimize the opportunity
for truck movement, in addition to the wheel chocks already
being used, while PCI- transfer is underway.
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6.3 STORAGE AND HANDLING OF AMMONIA
The Grace facility has two 30,000-gallon anhydrous ammonia storage
tanks. These installations and the associated ammonia piping in the .
plant are relatively new. Aqueous ammonia is generated during the
majority of the saponification reactions conducted in the plant and in
the neutralization reaction of the nitrile process effluent, prior to
incineration. The dilute aqueous ammonia streams are distilled in the
ammonia distillation tower, producing 97 to 99 percent anhydrous
ammonia. This product is stored in three storage vessels and most of it
is sold.
6.3.1 Storage
High strength (in excess of 95 percent) ammonia is stored in two
30,000-gallon pressure tanks equipped with relief valves. Low strength
ammonia is stored in several atmospheric pressure tanks. The ammonia
tanks are not diked for spill containment.
Observations;
o The facility should consider installing a dike around the two
high-strength pressurized ammonia tanks in order to minimize the
affected area in the event of a large leak or spill. This would
also reduce potential for ammonia evaporation and contamination
of the river. This safety measure should be considered given
the unusual proximity of the plant to populated areas and to the
Merrimack River.
o Grace should consult with the Ammonia Institute and/or study
potential discharge from the relief valves mounted on top of the
tanks. This study should include evaluation of height of
discharge, and installation of a scrubber or other control
device. The facility should determine whether fire hoses with
spray nozzles should be used to reduce vapors in case of a
severe leak.
o Grace should conduct a study to determine if an emergency
flaring system should be installed on the storage tank vent
lines.
o A hazards analysis of the storage system should be considered.
6.3.2 Handling
A tall distillation column at 200 psig is used to enrich the low-
strength ammonia to a high concentration suitable for loading and
shipping in railroad tank cars.
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Observations:
Grace should consider the following:
o Perform a process hazard reviev on the ammonia distillation
column. The column operates at 200 psig. Even a relatively
small opening or leak, especially in the top section of the
tower, could carry vapors off-plant without their being detected
in the vicinity of the column.
o The tank car being loaded should be protected with a locked
derail.
o Grace should emphasize routine and preventive maintenance on all
aspects of the distillation column, storage tanks, pipelines and
car-loading systems.
6.4 STORAGE AND HANDLING OF SODIUM CYANIDE (NaCN)
NaCN is produced in several of the caustic soda scrubbers as a
by-product, and is also produced in the plant as a salable product. The
NaCN is loaded into thick, steel-walled railroad tank cars for transfer
from the facility.
6.4.1 Storage
A new tank and dike system is being constructed for NaCN storage.
The plans call for a substantial upgrade of the NaCN storage facility.
The existing system was observed to be substandard and in need of
repair.
Audit team observations include the following:
o Grace should complete the new tank and dike system as rapidly as
possible.
o The current NaCN storage tank has a low curb to direct leakage
or overflow to a drainage system. This drainage system was seen
to be covered over with soil and needed cleaning in order to
avoid possible run-off and contamination of adjacent areas.
When the new facilities are completed, the existing facility
should be removed and decontaminated.
o Grace should avoid situations which serve to deplete the slight
excess of free caustic soda in the solutions so as not to
produce hydrogen cyanide gas. A minimum pH of 12 percent should
always be maintained.
o A study should be conducted to assure that no opportunity exists
for spillage or run-off to mix with acidic material in the sewer
system and elsewhere on or off plant property.
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6.4.2 Handling
NaCN is a Class B poison and can be lethal in small quantities if
it enters the body. NaCN solution can be absorbed through the skin from
contaminated clothing or from direct contact between the solution and
the skin. The main concern in handling the material is the danger posed
through accidental mixing of NaCN solution with acids, enabling
generation of toxic hydrogen cyanide gas.
Observations;
o During loading of railcars with NaCN solution, the car should be
positively protected from accidental bumping or movement which
could cause disconnections in the loading hoses. This could
result in a leak or spill.
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7 GENERAL PROCESS AREAS
7.1 KETONE AMINO NITRILE (KAN) PROCESS
The KAN process area is one of the never installations at the plant
and appears to be well designed and located. Hydrogen cyanide (HCN) is
supplied through a take-off line from the HCN loop originating at the B
HCN storage tank. After the HCN has been charged to the reactor, the
HCN line is blown back with nitrogen. The line is sloped for proper
drainage which reduces the possibility of an accidental release of
residual product.
Observations:
o Periodic checking of all HCN line slopes for proper drainage and
avoidance of low spots should be part of routine standard
operating procedure (SOP).
o The proper operation and sequencing of the.agitator in the
reactor during chemical addition should be emphasized in the
SOPs. The agitator must always be running, with mixing taking
place before chemicals are added. It may be useful to consider
installation of interlocks along with power or amperage meters.
o An interlock or other equipment should be considered for
installation to ensure that the scrubber is fully functional
before any operation can begin.
o The KAN reactor is on load cells so that chemical additions can
be verified by weight. This requires flexible connections. The
alignment of some of these appear to be at the limit of the bolt
guides and this condition should be checked and corrected.
7.2 IMINODIACETIC ACID (IDA) AREA
The process area itself is located inside a building. This has the
advantage of minimizing the danger of freeze up of the solutions. There
is, however, a disadvantage of potential vapor accumulation. Product
storage tanks are outside and are not diked.
Observations;
o Building ventilation systems should be checked to establish if
they are adequate to control vapors in case of a leak.
o Plans for action should be available and fully understood for
responding to severe leaks of chemicals.
o An additional "StaTox" HCN detector should be located in the IDA
building.
o A process hazards review on the addition of HCN to the reactors
should be performed. This would include study of interlocks and
fail safe systems.
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7.3 NITRILOTRIACETIC ACID (NTA) AREA
The NTA area has a HCN feed system that minimizes the quantity of
HCN in the area and reduces the potential for a chemical accident. It
consists of a pipeline supplying HCN from the storage tank to the
reactor, with an automatic wash back of the HCN line to the tank with
water, as well as a purge back to the tank with nitrogen.
The reactors and other equipment are inside a building, in a set-up
similar to the IDA area. The operational control room is 1960's
vintage. The technology used is outdated and less safe than the
sophisticated solid-state controls presently available.
Observations:
Grace should consider interlocking the HCN feed to assure the
correct sequence and amount of chemical.
Additional "StaTox" HCN detectors in appropriate locations in
the building should be considered.
Grace should evaluate additional control room modifications
beyond the upgrades completed. Modernizing and upgrading the
control room equipment will minimize operator error, while
enhancing safety, mitigation, and accident prevention
activities.
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8 RELEASE PREVENTION AND ENVIRONMENTAL COMPLIANCE
8.1 SAFETY MANAGEMENT PROGRAMS AND EQUIPMENT
8.1.1 Process Hazards Review
A Process Hazards Review is a formalized method of "looking" for
unsafe conditions that could occur. Once identified, appropriate means
of prevention and mitigation can be implemented. Methods commonly used
are Checklist, Hazards and Operability Studies, What If, Failure Mode
and Effect, and Fault Tree analyses.
Observations:
Grace should consider performing Process Hazard Reviews on a
periodic basis (at least annually), and with greater frequency in the
more hazardous areas. These would be conducted in addition to the
reviews undertaken as a result of serious incidents, accidents, or
near-misses. An Inspection and Audit team from within the company, as
well as an independent group, should be retained to review operating and
safety procedures in order to identify potential hazards and suitable
remedial action.
Person(s) from outside the facility often see things from a
different viewpoint, and may uncover hazards not readily detected by
people close to the site or from within the facility. Therefore, Grace
should organize an occasional review of the facility and site by one or
more outside people in order to benefit from an in-depth study of
potential safety and environmental problems.
New, altered, or recycled equipment as well as any equipment which
has been out of use for a period of time should be inspected by a
committee prior to acceptance for use and startup. The committee would
generate written recommendations and appropriate user operating
procedures for startup and standard use.
Process modifications and changes can have far-reaching
implications beyond the obviously expected. Written approval should be
obtained from the Safety Section and upper management prior to any
physical change in equipment or changes in operating procedures
affecting hazardous materials.
8.1.2 Serious Incident or Near-Miss Reporting and Accident Review
The facility has in place a method of reviewing plant conditions
and incidents through daily morning meetings between area supervisors
and th<2 plant manager. Any safety or environmental concerns are
discussed at this time, and follow-up action is discussed.
Observations;
Grace should investigate and write up all incidents, near-misses,
accidents and spills. These reports can be useful for safety meetings,
training sessions, and can form the basis for changes in processes,
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equipment, or procedures. The reports should also be periodically
reviewed for any indication of trends, potential equipment
deterioration, personnel training needs, or de facto changes in
operating procedures.
8.1.3 Unobserved Operations
There are many areas in the different process plants where the
operators cannot observe the operations due to congestion (as in Plant
#1), or remoteness (as in reactor |5 Control Room, tank farms, etc.).
While television monitors are in use for some of these areas, Grace
should consider installing additional monitors to allow for continuous
monitoring of reactors and other potentially hazardous areas. Use of
such monitors allow control rooms to be located away from hazardous or
explosive areas.
8.1.4 Equipment Storage
Equipment used in work areas around the plant was seen to be
improperly stored during periods of non-use. For example, hoses were
lying on the ground (some with rocks and dirty debris in the hose ends)
in the hydrocyanic acid rail unloading area and in the phosphorous
trichloride and KAN reactor areas. Because of the serious consequences
from accidental contamination by some of the chemicals used, it is
suggested that hoses, pipes, and other similar items never be left on
the ground. This equipment must be properly maintained, temporarily
decommissioned, and suitably stored.
Observations!
o The facility should consider making storage racks available and
accessible for hoses and pipes in all user areas. Storage
containers and racks should also be made available for other
equipment frequently used at specific work areas (e.g., railroad
chucks.)
8.2 SAFETY MANAGEMENT PROGRAM AND PERSONNEL
8.2.1 Communications
When hazardous chemicals are inhaled or released, clear, timely,
and accurate communication is imperative both on and off the plant.
Proper procedures thoroughly instilled into plant employees can often
help prevent or mitigate the escalation of small, relatively
insignificant chemical incidents into major accidents with potential for
on- or off-site injuries and environmental harm.
Observations:
o Grace should ensure that the Public Address system is clearly
audible in all areas of the plant, including the more remote and
noisy areas.
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o While the head count system of using time cards to account for
plant personnel during evacuations is good, the system used to
account for visitors, contractors, and non-time card personnel
should be upgraded.
o Grace should improve the system for alerting neighborhood
residents in case of a vapor release and work to further improve
community relations. Such measures will reduce the likelihood
of panic in the event of a serious incident.
8.2.2 Contingency Plan and Emergency Response Teams
A contingency plan has been developed to cover response by the two
designated Emergency Response Teams to any type of emergency which might
occur on the plant. Management has the responsibility for keeping the
material in the plan up-to-date. Emergency Response Team members are
responsible for keeping current on necessary actions to be taken in case
of emergency. The plan includes general instructions on activating an
alarm during an emergency, alarm locations, and evacuation procedures.
Response team responsibilities are provided, with specific instructions
which include the following:
o First aid in HCN poisoning,
o Fire service team procedures,
o Communications and emergency phone numbers,
o Alarm system operations,
o Emergency response equipment,
o Plant preparation for severe storm or flood conditions,
o Press relations,
o Post emergency actions,
o Proper handling of chemical spills, and
o Release and reporting requirements.
Observations;
o A clear record should be maintained of personnel trained and
specific training levels achieved. Refresher training should be
provided routinely and documented accordingly.
o Site emergencies should be evaluated using a "post mortem"
discussion of actions taken, mistakes made, and proposed future
action and simulations under similar conditions. Mock
emergencies and simulations should be conducted.
o Grace should keep detailed records of all incidents, whether
practice or actual, in order to facilitate identification of
failures.
o Contractor training in safety and hazardous materials should be
expanded in order to reduce accident potential and the danger
for Emergency Response Teams who rely on trained personnel for
technical assistance operating during a chemical release.
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8.2.3 Training and Safety Operations
The plant has formalized a set of Safety Rules and Regulations
directed at every employee on the facility. These procedures have been
established to enhance personnel safety and improve plant response
during an emergency situation. The rules and regulations enable the
Emergency Teams to focus on areas of greatest need. The rules contain
information on the following:
o Emergency Alarms and Procedures
o Communications Equipment
o Personnel Protection Equipment
o No Smoking Zones
o Buddy Areas
o Pilot Plant Safety Procedures
o Tank and Vessel Entry
o Monitox HCN Detector
o Hot Work Permits
o Tags and Lock-out Systems
o Equalization and Holding Basin Area
o Contractor Area Permit Procedure
o Medical and First Aid
o Chemicals
o General Plant Safety Rules
Training in operations is important at any facility, especially for
a plant using extremely hazardous chemicals. The Training Manual for
NTA Operators was reviewed by members of the Audit team. It contained
time schedules, test levels, outlines of safety and emergency
procedures, chemical identification, and equipment operation procedures.
This manual was identified as the first in a series of manuals. The
other manuals in the series remain unwritten at this time. No specific
information was available in several areas, especially regarding:
actual use of the manual, numbers of sessions given, attendance, and
test results. In general, it was reported that most of the operators
relied upon their job experience, which averaged 15 years of experience
at the facility.
Re-training is an important part of a safety program. It serves to
ensure that all employees understand any changes in procedures and
operations, especially resulting from changes in equipment,
modifications of their operational ability, or new output requirements.
It is important that each employee understands the rationale behind the
changes, the reason for each procedure and safety rule, and has an
opportunity to provide feedback and engage in discussion about further
modifications or procedures.
Observations:
o SOPs should be maintained up-to-date with immediate
incorporation of changes in procedures, and periodic reviews
should be conducted to ensure that compatibility is maintained
between the SOPs and actual practices.
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o Standard Operating Conditions (SOCs) Sheets should always be
maintained up-to-date.
o Grace should incorporate SOP changes into existing training
programs.
8.3 SAFETY MANAGEMENT PROGRAMS
8.3.1 Maintenance
Adequate maintenance of all equipment in the chemical plant is
crucial to avoiding environmental releases or injury. Preventative and
predictive maintenance programs are essential to minimize equipment
failures. Timely and planned servicing is desirable as opposed to
relying on emergency repair.
Observations;
Grace should consider the following:
o Promote periodic change of gaskets to reduce and avoid sudden
gasket failure.
o Develop or find improved gaskets for use in critical areas.
o Minimize the number of flanges used in all systems by welding
sections together.
o Minimize the number of valves and remove unnecessary ones.
o Apply high-quality preventative maintenance to:
- pumps;
- interlocks;
- detectors;
- alarms;
- level and flow meters for temperature and pressure;
- electric circuit breakers;
- pressure release valves (sizing should be checked through
DIERS - Design Institute for Emergency Relief Systems); and
- tank, vessel, and pipeline integrity.
8.3.2 Facility Control Rooms
The control centers are normally occupied by two or more persons.
Equipment is controlled through instruments with displays of process
condition or status on panel boards or computer screens. While none of
the control rooms could be categorized as a "Safe Haven" in the sense of
a hermetically sealed, air-fed environment, they are located in areas
that would permit personnel to conduct emergency shutdown operations
under most conditions. Their location facilitates accounting for
personnel and enables dissemination of emergency instructions from the
control room.
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Observations;
o No personnel beyond those assigned to a given area should enter
the area without checking into the control room, to sign in or
receive a pass for the duration of their stay. This procedure
would serve to increase the accuracy of accounting for
personnel.
During a tour of the NTA control room, the low-pressure air alarm
activated several times. The "acknowledge" button was pressed, and no
further action was undertaken. The justification was that another area
was using too much air.
o Operators should not accept or be allowed to continue the
practice of acknowledging an alarm situation on an on-going
basis without initiating a correction.
o A written report should be submitted each time an alarm
acknowledgment is made without correction, and reviewed at the
daily staff meeting.
o The alarm pressure setting should be adjusted if the present
setting is too high for normal operation. As an alternative,
the correct pressure could be supplied with supplemental air via
a temporary compressor or from another source until the problem
can be corrected.
8.3.3 Prevention of Leaks and Vapors
Certain points and sources at the facility are more prone to leaks
and chemical releases than others. It is necessary that adequate
procedures and equipment be in place and maintained to deal effectively
with chemical releases and their resultant vapors, fires, and plumes.
SOPs, adequate training, and equipment are necessary to deal with
possible incidents, and must be maintained or readily available in all
critical plant areas. Typical situations and areas of the plant that
would require effective chemical emergency response include the
following:
o Scrubber failure,
o Relief valve discharge,
o Rupture disc discharge,
o Excess discharge from vents,
o Gasket failures,
o Hose failures,
o Corrosion or cracking of equipment,
o Faults,
o Pumps and pump seals,
o Packing gland releases,
o Failure of refrigeration and cooling systems,
o Over-filled tanks and reactors,
o Sampling system leaks,
o Explosions or fires, and
o Human error.
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Prevention systems in use at W.R. Grace are discussed below.
8.3.4 Fire Fighting and Vapor Suppression
Grace has recently installed a comprehensive red fire pull station
and smoke detector system throughout the facility. Activation of these
alarms and detectors provides automatic response from the Nashua Fire
Department. Green pull stations are located throughout the facility for
other emergencies that do not require immediate outside assistance. The
alarm systems activate two plant teams who are trained to respond
promptly. The site has a 350,000-gallon water storage tank equipped
with a backup 1,100 gpm diesel pump in case of electric power failure.
This tank and pump system ensures water supply to the hoses for fire
protection or vapor suppression.
Observations:
o Grace should consider installing a pumping system to enable
equipment to pump water from the river to fight a major fire.
o The facility should consider installing deluge systems in
certain high-risk areas. These areas could be determined
through process hazards surveys.
o Grace should provide fire hose nozzles with variable positions
to enable use in a straight water stream, as a spray, or in a
fog pattern. Position settings would depend upon the type of
emergency.
o Grace should consider installing a fixed-water monitor gun with
a variable nozzle at the A and B HCN unloading areas.
o The facility should assist the Nashua Fire Department in
establishing a Hazmat team knowledgeable in mitigation
techniques specific to Grace. This team would serve to
supplement in-house response units.
8.4 EMERGENCY PREPAREDNESS AND PLANNING ACTIVITIES
The Audit team reviewed W.R. Grace's facility emergency response
system, public alert and notification procedures, Title III activities,
and community involvement philosophy. Team observations are listed
below.
8.4.1 Emergency Response Systems
The written emergency plan developed by the plant safety officer
contains explicit directions and instructions in the event of a variety
of emergency scenarios. The plan is comprehensive and well organized.
A recent addition to these emergency procedures is a quick reference
manual outlining the protocols to be followed in the event of an actual
hazardous materials release at the plant. This manual is in the
possession of two supervisory personnel at all times of plant operation
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(24 hours per day/7 days per week) to ensure that rapid and correct
notification procedures are followed. This action reference manual
includes the names and telephone numbers of contact persons at the Local
Emergency Planning Committee (LEPC), State Emergency Response Commission
(SERC), NRC, and Federal and State Agencies.
8.4.2 Public Alert and Notification Procedures
The plant has two distinctly separate alarm systems. One is
dedicated to fire incidents, while the other is to be used for all
non-fire emergencies. There are color-coded alarm pull-stations
(red/fire, green/non-fire) strategically located throughout the
facility. The fire alarm system is tied into the Nashua Fire
Department, with an anticipated arrival time of about 3 minutes. The
second alarm system, used for plant incidents and emergencies notifies
the plant Emergency Service Teams (ESTs), composed of four to seven
trained plant personnel. While the EST is responding to the incident,
plant personnel must listen for a second alarm which signifies a need to
immediately report to designated rallying areas and for on-going
announcements over the public address system. These announcements
provide further information and instructions.
In the event of an incident with potential for off-site
consequences, the following procedures are followed:
o Plant emergency alarm is sounded;
o Plant Emergency Service Team(s) respond;
o Shift supervisors assess situation, notify plant management;
o Fire Department is notified;
o LEPC is notified (within 5 minutes of the incident);
o NRC is notified; and
o Superfund Amendment and Reauthorization Act (SARA) notifications
are initiated.
8.4.3 Title III Activities and Environmental Compliance
The facility has been very active in Title III activities. W.R.
Grace management encourages its supervisors to join the Local Emergency
Planning Committee (LEPC) in their respective communities. Facility
representatives have consistently taken a leadership role in the Nashua
LEPC and in the State Emergency Response Commission (SERC). At the
local level, Grace personnel participate in plant development and
awareness seminars. They cooperate with local fire departments in
joint- and plant-sponsored training efforts for spills, fire, and
hazardous releases within the plant or in the local community. They are
active participants in a Nashua LEPC Subcommittee and have acted as the
Chairperson of the SERC Subcommittee.
The facility has responded to SARA Title III requirements,
including submission of Tier II lists and a Section 313 report of toxic
air emissions, with Confidential Location sheets used for most of the
chemicals. The Section 313 compilation was a rigorous effort, costing
the company some 1,000 man hours.
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While the Audit team investigated the accidental chemical releases
discussed in Section 4, the team did not make a determination of Grace'js
compliance with the emergency notification requirements of Title III and
the Superfund statute.
The following sections discuss the Audit team's findings regarding
significant environmental compliance issues identified during the audit.
It is organized according to the major environmental areas reviewed.
The Audit team's assessment represents a review of certain
information relating to the W.R. Grace facility, obtained during the
audit, which did not include sampling or monitoring at the facility.
While the Audit team used reasonable care to avoid reliance on data or
information that is inaccurate, the team is not able to verify the
accuracy or completeness of all data and information made available to
the team. Some of the conclusions drawn could be different if the
information upon which they are based were determined to be false,
inaccurate, or incomplete. The Audit team makes no legal
representations whatsoever concerning any matter, including but not
limited to ownership of any property or the interpretation of any law.
8.5 POLLUTION CONTROL AND WASTE MANAGEMENT
8.5.1 Air Pollution Control
Air emission sources at the Grace facility in Nashua that are
subject to regulation include two 500-horsepower (hp) gas-fired
boilers; one 600-hp gas-fired boiler; one 800-hp gas-fired boiler; an
ammonia tower hot oil heater; a lime waste treatment, fluidized bed
incinerator; nitrilotriacetic (NTA) production equipment; and
iminodiacetic (IDA) production equipment. Grace has a current operating
permit issued by the State for each of these emission sources. Most of
these permits are current through September 1991. The permit for the
800-hp boiler was temporary and expired in September 1989.
These permits impose, as applicable, maximum operating feed rate
limits (incinerator and boilers), opacity limits (incinerator and
boilers), particulate emission limits (incinerator), sulfur dioxide
emission limits (boilers), and requirements for carbon monoxide
monitoring (incinerator only). The permits for the NTA and IDA
production equipment impose limits on HCN and ammonia boil-off
emissions, and limits on dust emissions. The equipment appears to be
operating in accordance wi.th the terms and conditions of their permit
requirements. This determination did not include stack testing. Most
of the emitted air streams are scrubbed to meet emission limits. Grace
has experienced problems with the operation of the incinerator's carbon
monoxide and opacity meter and is investigating replacements. Grace is
1. All boilers at the Grace facility are on interruptable natural gas
service. When gas is interrupted, boilers are equipped to operate
on No. 6 fuel as a backup energy source.
8-9
-------
currently negotiating with the state for the ability to increase the
solids feed rate to the incinerator from the current limit of 35 percent
to as much as 50 percent.
There are asbestos-containing materials (ACM) at this facility.
According to Grace memoranda on the subject, there appear to be about
1,000 feet of pipe insulation known to contain asbestos that should be
removed because of the potential for exposure. About 550 feet of ACM
insulation has already been removed and disposed of properly. Asbestos
is also known to be present in the wall siding and roofing at Plant #1
and in the louvres on the cooling tower. Grace personnel are uncertain
as to whether asbestos is present in the insulation surrounding many of
the production reactors. To remedy this uncertainty, Grace should
undertake a comprehensive asbestos survey to identify ACM throughout the
facility.
8.5.2 Water Pollution Control
Plants like the Nashua facility, which discharge directly to a
river or to other surface water, must meet limitations described in
permits issued as part of the National Pollutant Discharge Elimination
System (NPDES) or the State program counterpart. The Federal and
respective State NPDES programs operate under authority of the Clean
Water Act. The Nashua plant currently holds a permit for direct
discharge under NPDES to the Merrimack River after treatment of the
wastewater stream in an on-site wastewater treatment plant.
Concentrated wastewaters from all cyanide reaction vessels,
referred to as primary liquors, are currently piped to aboveground
storage tanks for further treatment. These liquors contain nitriles,
sulfuric acid, and some unreacted cyanide. Primary liquors undergo
treatment to destroy cyanides and ultimately thermal incineration to
burn off organic constituents in a fluidized bed incinerator. The
lime/incineration process is referred to as Phase II wastewater
treatment. The compliance status was not reviewed by the Audit team.
All other wastewaters enter the on-site wastewater treatment plant.
Entering wastewaters receive continuous cyanide monitoring. Assuming
cyanide concentrations are below levels of concern, the wastewaters
enter a double lined equalization basin for pH adjustment. Wastewaters
with elevated cyanide levels are diverted to a lined holding basin where
they then receive cyanide treatment before being released to the
equalization basin. These parts of the treatment system are referred to
as Phase I wastewater treatment.
From the equalization basin, wastewaters undergo biological
treatment which combines extended aeration with activated sludge. After
passing through a clarifier, treated wastewater is discharged to the
river unless elevated ammonia levels require that the wastewater pass
through the ammonia stripping tower. Wastewater treatment plant sludge
passes through a filter press and is shipped off-site as a non-hazardous
waste. This portion of the system is referred to as Phase III
wastewater treatment.
8-10
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Operating and monitoring records for the on-site wastewater
treatment plant indicate minor exceedances of the permit conditions in
1987 and 1988 for which no notice of violation or citation was issued or
penalties/fines assessed. No permit exceedances were noted to date in
1989, and past exceedances do not appear to indicate an inability to
meet the permit limits. Monitoring and record keeping requirements are
being met. No effluent samples were taken or analyzed by the Audit
team.
All stormwater from the process areas at this plant flows to the
on-site wastewater treatment plant and is treated before discharge.
Stormwater flow from the parking lots discharges into Spit Brook. The
integrity of the plant-wide sewer system should be reviewed and
.evaluated.
8.5.3 Hazardous Waste Management
The Resource Conservation and Recovery Act (RCRA) and associated
Federal and State regulations specify the procedures to be followed at
facilities which generate, treat, store, dispose, and transport
hazardous wastes. The Grace plant in Nashua is regulated both as a
hazardous waste generator and as a storage facility. It has a generator
identification number as well as a Part B Permit for its storage
facility.
Some RCRA compliance problems were noted by the Audit team. The
hazardous waste drum storage area sign "Danger-Unauthorized Personnel
Keep Out" cannot be readily seen when the gate door remains open. Not
all the drums were found to be labeled as per the terms of Grace's
storage permit (i.e., not labeled as to plant of origin, incomplete
hazard warning labels, and no notation as to whether a given drum was
full or not.) One drum was found to be leaking in this area, but
Grace's records indicate that this drum contained a non-hazardous waste.
Several drums were noted to be not in "good condition" (i.e., rusted.)
The RCRA hazardous waste storage tank in the KAN Plant was not labeled
as containing hazardous wastes nor were the requisite
"Danger-Unauthorized Personnel Keep Out" or "Danger-Restricted Area - No
Open Flames" signs posted. A safety concern was noted in that
electrical cords were located in close proximity to pools of water in
the hazardous waste storage area. The forklift truck used in the waste
drum storage area was not an intrinsically safe design.
A file review indicates that the Nashua plant is subject to RCRA
corrective action, and a RCRA Facility Assessment (RFA) has been
performed. Twenty-six Solid Waste Management Units (SWMUs) and three
Areas of Concern (AOCs) were identified by EPA. Several of the
potential SWMUs were determined to be process units, part of the
facility's waste minimization programs, or units that managed
intermediates from one process which are used as feedstock for another
process.
From a volume perspective, the most significant solid waste
management units are the former unlined wastewater treatment lagoons.
From 1958-1976, these lagoons served as the facility's only wastewater
8-11
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treatment system with the exception of separate cyanide treatment for
primary liquors. Several groundwater monitoring wells surround the area
of the former north lagoon referred to in the RCRA Facility Assessment
(RFA) report. The former lagoon sites have been turned into the
equalization basin, a holding basin, and a biological treatment plant.
A brief review of recent groundwater monitoring data presented to
the Audit team by Grace indicated elevated levels of cyanide (about 5
ppm in the worst well) and formaldehyde (18 ppm in the worst well) in
April 1988. According to the October 1988 sampling, these values had
fallen to less than 1 ppm for cyanide and no detectable formaldehyde.
Grace environmental staff offered no explanation for the rise in
groundwater contaminants in April 1988. It is unclear what future
groundwater contaminant patterns will look like.
Two additional areas that were identified in the final RFA report
that may also be of concern are another lagoon and a buried drum area.
These areas were reported to EPA (RCRA) on February 2, 1989. A
wastewater treatment lagoon previously located at the southern end of
the facility was apparently part of the original lagoon system
constructed in 1958. This lagoon was presumably unlined and similar to
the other three lagoons at the northern end of the facility.
At one of the SWMUs, an unknown number of waste drums was
reportedly buried at the northern end of the facility north and west of
the current hazardous waste drum storage area in 1964. EPA (RCRA) was
notified of this condition on February 2, 1989. Grace staff believe
these drums to contain non-hazardous shampoo-type wastes or
off-specification product. According to Grace staff, all known drums
had presumably been excavated and removed previously; however, during
some maintenance or improvement activity last year, additional drums
were uncovered. At the time of the Audit team's visit, an area of the
parking lot west of the current hazardous waste drum storage area was
partially dug up and several half buried drums were visible.
Additional soil and groundwater sampling of the SVMUs identified as
having releases will be performed during the corrective action process
to characterize the nature and extent of any potential soil and
groundwater contamination associated with past waste management
activities at the facility.. A RCRA Corrective Action Permit, issued
September 29, 1989, established requirements for this sampling activity.
8.5.4 Solid Waste Management
Regulation of solid waste disposal has traditionally been a State
responsibility. Although EPA has recently proposed Federal regulations
for solid waste management facilities under Subtitle D of RCRA, states
will continue to define regulatory requirements until the Federal
regulations are promulgated. The Grace plant in Nashua does not operate
its own on-site solid waste management facility. Generally there are no
substantive state requirements on generators of non-hazardous solid
waste who send such waste off-site for disposal. No solid waste
management problems were observed by the Audit team.
8-12
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8.5.5 Underground Storage Tanks
Records show that 16 underground storage tanks have been operated
at Grace's Nashua plant, as listed in Table 8-1. The capacities of
these tanks range from 500 to 20,000 gallons and all but two contain or
once contained petroleum product. Two of these tanks are double-lined
steel tanks; the remainder are or were constructed of bare steel. Three
of the tanks were closed in place and five tanks have been removed. One
additional tank was taken out of service in November 1988, but has not
yet been subject to closure. All in-service USTs are being integrity
tested at the required frequency. Grace indicates that all their
remaining USTs will be taken out of service on a timetable consistent
with UST regulatory requirements. No underground storage tank problems
were discovered by the Audit team.
8.5.6 Pesticide Use and Storage
Pesticide storage and use is regulated under the Federal
Insecticide, Fungicide, and Rodenticide Act (FIFRA). The Grace plant in
Nashua contracts out its pest management and weed control functions;
consequently this plant does not store or use pesticides. As a result,
no FIFRA problems were observed by the Audit team.
8.5.7 PCB Inventory Management
There are no PCB-contaminated or PCB-containing transformers in
service or in storage at the Nashua plant. All in-service transformers
have been tested and contain PCB concentrations well below 50 parts per
million. Grace reports that there are several PCB capacitors still in
service, although the Audit team was unable to view the area in which
these units operate and did not determine the size of these units.
Federal regulations under the Toxic Substances Control Act (TSCA)
require that after October 1, 1988, PCB large-high and large-low voltage
capacitors cannot be used where there is a risk of exposure to food or
feed.
In addition, the use of such units is prohibited after that date
unless the capacitor is used within a restricted-access electrical
substation or in a contained and restricted-access indoor installation.
These capacitors should be marked and labeled as containing PCBs in
accordance with the TSCA regulations. The Audit team did not note any
violations of applicable PCB regulations.
Grace has disposed of additional PCB-containing capacitors in the
past. Records indicate compliance with pertinent Federal and State
requirements governing the disposal of PCBs.
2. A restricted-access electronic substation is an outdoor, fenced or
walled-in facility that restricts public access and is used in the
transmission or distribution of electric power. A contained and
restricted-access indoor installation does not have public access
and has an adequate roof, walls, and floor to contain any release
of PCBs within the indoor location.
8-13
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Table 8-1
W.E. GRACE UBDERGBOUHD STORAGE TASKS
Tank No.
V-211
V-408
V-409A
V-409B
V-410
V-426
V-436
V-437
00
>L V-438
-P-
V-439
V-441
V-442
V-401
TF-120
TF-15-101
Tank
Capacity
Substance Stored (Gallons)
NH Tower Hot
12 Fuel Oil
16 Fuel Oil
116 Fuel Oil
12 Fuel Oil
16 Fuel Oil
Gasoline
Gasoline
Diesel
Diesel
16 Fuel Oil
16 Fuel Oil
Waste Oil
HCN
HCN
HCN Scrubber
Oil 5,000
10,000
12,500
15,000
15,000
15,000
5,000
5,000
10,000
7,000
20,000
15,000
500
Confidential
Confidential
—
Construction Date of
Material Installation
Bare Steel
Bare Steel
Bare Steel
Bare Steel
Bare Steel
Bare Steel
Bare Steel
Bare Steel
Bare Steel
Bare Steel
Double Lined Steel
Double Lined Steel
Bare Steel
Bare Steel
Bare Steel
Bare steel
1966
1957
1965
1968
1968
1966
1968
1968
1972
1969
1986
1986
1973
1962
1975
—
Date of Last
Integrity
Testing
7/88
—
—
9/85
10/85
10/85
10/85
10/85
2/86
2/86
2/86
2/86
—
—
—
6/88
Date of Tank
Next Scheduled Removal
Integrity Test Date
11/87
?
11/89
11/85
11/85
10/90 11/91
10/90 11/93
10/90 11/93
2/91 11/97
2/91 11/94
2/91 11/2011
2/91 11/2011
11/86
7/87
7/88
Pre-1985
Remarks
Closed in place
Removed
Removed
Closed in place
Removed 11/88
Removed
Removed
Closed in place
-------
9 SUMMARY OF MAJOR AUDIT OBSERVATIONS AND RECOMMENDATIONS
9.1 REACTOR NO. 5 HYDROGEN CHLORIDE (HC1) RELEASE
On August 5, 1988, Grace accidentally released HC1 into the
atmosphere as a result of equipment failure, human error, and inadequate
response procedures. Although the magnitude, duration, and
concentration of the release did not seriously affect health and the
environment, it caused a community-wide emergency and evacuation. This
release demonstrated a breakdown in communications, training, accident
investigation procedures, and corrective action. Grace concentrated its
efforts on mechanical corrections to Reactor No. 5 rather than on
initiating a comprehensive hazards analysis. In spite of the mechanical
corrections, the EPA Audit team identified further deficiencies. Field
evaluation results are listed below:
o A permanently mounted pressure monitoring device with continuous
recording should be installed on the reactor.
o Incoming chemical lines were not properly labeled or color coded.
The sight glass was non-functional.
o A 2-inch material inlet pipe, ball valve was not capped.
o The Control Room was inadequate in several respects: space
requirements, controls, check lists for critical operation
parameters, and gauges for agitator operation.
o A load cell or a.level indicator should be installed.
o The reactor was not equipped with interlocks (e.g., material
inlet and scrubber operation.)
o Grace should consider installing a blank or backup valve to
assure closure of the 8-inch inlet dilution pipe which was
involved in the release.
o The agitator current should be monitored to assure proper
agitator operation and speed.
9.2 HYDROGEN CYANIDE (HCN) STORAGE AND TRANSFER
The Audit team observed a highly sophisticated system for the
storage and transfer of HCN at tf.R. Grace. However, some areas of the
HCN storage and transfer system need improvement to minimize the chances
for a release of this extremely hazardous substance.
o An additional water gun equipped with a fog nozzle should be
installed at the A and B HCN storage tanks; a deluge system
should be considered.
o A spark ignition system should be installed as a means to ignite
the HCN in'the event that the water guns do not mitigate the
9-1
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vapor cloud. A flare gun and water spray would remain as
supplemental and backup systems.
o Containers of stabilizer acid should be readily available at the
emergency addition facility to enable rapid response and
mitigation.
o Additional HCN ambient monitoring devices should be installed in
the storage area to provide backup and additional coverage
during periods of variable wind direction.
o Coverage by the public address system must be improved in the
HCN storage areas. In addition, the area needs expanded
coverage from the closed circuit TV monitoring system.
o Flashing lights, additional signs and beacons are needed during
railcar unloading operations at both the A and B stations.
o Additional safeguards are needed to assure backup power for the
HCN scrubbing system. It is also important to ensure that the
proper level and percent of caustic solution is available at all
times.
o The circulating loop HCN transfer system should be expanded to
include service to the entire facility.
9.3 RAILCAR UNLOADING OPERATIONS
The hazardous material railcar unloading area is in close proximity
to the Herrimack River. The topography of the B unloading area slopes
gently down toward the river. The A station is partially protected by
an earthen berm. Grace should install a diked pad with a collection
sump at both unloading locations to minimize the environmental and
safety impact from a catastrophic railcar failure or release during bulk
unloading operations.
9.4 MONITORING
A study should be conducted to assess the adequacy of the number
and locations of the continuous monitors to detect accidental gas
releases. For example, additional HCN monitors are needed in the IDA
and NTA buildings. Expanded use of television monitors is recommended.
9.5 PHOSPHOROUS TRICHLORIDE (PC13)
In addition to preventing PCI- leaks from the storage tanks, the
chemical must not come in contact with moisture or water. The Audit
team observed deficiencies in the PC1~ storage area and recommends the
following:
o Grace should direct all scrubber overflow and standing water to
flow outside the PCl, storage area. The scrubber water drain
should be covered.
9-2
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o The facility should institute an internal tank test program.
o Grace must enhance the contingency plan to include mitigation
and response procedures for a large spill or release from PCI-
storage and transfer operations.
o Unloading trucks must be firmly secured to insure no movement
when unloading hoses are connected and product is being
transferred.
9.6 SODIUM CYANIDE (NaCN) STORAGE
The existing NaCN storage tank farm is not diked, and the facility
is equipped with a low curb so that any leakage or overflow would be
directed to a drainage system. The drain was observed covered with
soil. It was plugged and the drain had deteriorated. These tanks
should be diked to avoid run-off and environmental contamination from an
accidental spill or release, or improper operating practice.
9.7 EMERGENCY BACKUP POWER
The process part of the facility is supplied by only one main 34.5
KV power service line. Adequate provisions have not been made for
emergency backup power for critical process equipment. Grace should
initiate a study to determine what backup utilities are needed to
prevent a chemical emergency in the event of a power failure or the
loss of a critical utility for hazardous and extremely hazardous
material process lines. For example, the pumps to the HCN scrubbers
should be protected by a backup generator. Long-term utility failure
would require backup refrigeration capability to prevent a chemical
emergency.
9.8 CHEMICAL ACCIDENT PREVENTION
Accident prevention must be accomplished through proper safety
equipment, procedures, training, and management techniques. Prevention
deficiencies identified by the Audit team include the following:
o The emergency warning and public address system is not audible
in all areas of the plant.
o Grace needs to develop an efficient means of alerting the
neighborhood in the event of a chemical emergency.
o The facility needs to work more closely with community emergency
responders to increase knowledge, capabilities, equipment and
coordination.
o Lock-out and tag-out programs for out-of-service equipment need
to be improved to prevent human error or equipment failure that
could lead to an accidental release. The facility should
increase the use of lock-out procedures rather than rely solely
on tag-out.
9-3
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o Grace needs to routinely conduct chemical emergency simulations
which involve neighborhood services and mutual aid.
o The facility should conduct an interlock study to promote proper
sequencing of process operations for reactions and other
hazardous materials equipment to assure fail-safe operations.
For example, the rail spur used for HCN unloading should have
locked derails. Interlocks in the KAN and NTA areas could
include use for HCN feed, the reactor, and for agitator speed to
promote fail-safe operation.
o The control room in the NTA building is 1965 vintage. Grace
should develop and follow a schedule for control room upgrades
to promote accurate process monitoring and safer operations.
o Labeling of tanks and color coding of hazardous materials
process lines should be improved for proper emergency
identification during an incident.
o Agitator current should be monitored on the KAN reactor to
assure proper speed and operation and to reduce the possibility
of a chemical accident.
o Wheel chocks must be used to prevent movement of hazardous
materials railcars during unloading operations. Mechanical and
electrical safeguards to prevent truck movement during unloading
operations should be employed to enhance accident prevention
procedures.
9.9 OPERATION AND MAINTENANCE
The Preventative Maintenance program for equipment used with
hazardous materials should be upgraded to include routine replacement of
critical parts based on a history of failure, rather than on observation
of actual signs of failure. For example, critical gaskets should be
changed at regular and predetermined frequencies. Grace should conduct
a study allowing the facility to, over time, reduce the number of values
and flanges on hazardous materials lines in order to minimize leak
potential.
9.10 EMERGENCY VENTING
Grace needs to reevaluate the size and locations of emergency and
pressure relief vents and assess whether or not relief devices should be
vented to a flare, other air pollution control equipment or secondary
containment. This method of control is especially necessary for highly-
toxic or explosive gases. Pressure relief sizing should include
consideration of multiphase flow using DIERS technology. A relief valve
study should start with the KAN reactor pressure relief system since
this device appears to be undersized based on field observations by the
Audit team.
9-4
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9.11 ENVIRONMENTAL COMPLIANCE
The Audit team reviewed facility operations to assess environmental
compliance status. Results of this review show problems with the
continuous air pollution monitoring equipment (carbon monoxide and
opacity) for the lime, waste treatment, and fluidized bed incinerator.
This equipment should be repaired or replaced. Asbestos is found in
materials throughout the plant and should be removed and disposed of
properly to prevent the material from becoming airborne. Grace should
undertake a comprehensive asbestos survey and initiate immediate removal
of all friable material in remaining affected areas.
Drum labeling was deficient in the hazardous waste drum storage
area. Several hazardous waste storage drums were found with surface
rust and some were in poor structural condition. There is a need for
improved drum inspection and leak detection procedures. An electrical
cord was being used improperly in the waste storage area, in close
proximity to water. The forklift was not an intrinsically safe design.
The forklift truck and the cord both present a potential fire hazard and
are considered a safety hazard.
An unknown number of waste drums were buried at the northern end of
the facility. Some have been excavated and removed. At the time of the
audit, an area of the parking lot west of the current hazardous waste
drum storage area was partially dug up and several half-buried drums
were visible. This situation warrants prompt action to characterize any
potential contamination associated with past waste management activities
at the facility.
The integrity of the plant-wide sewer system should be reviewed and
evaluated. A review of groundwater monitoring data in the area of the
former wastewater treatment lagoons showed elevated levels of cyanide
and formaldehyde in April 1988. This should be investigated further by
Grace and the regulatory agencies.
9.12 HAZARDS ANALYSIS
Grace does not routinely use sophisticated hazards analysis
techniques for process equipment in hazards material service. Formal
hazards analysis techniques, such as hazards and operability studies,
failure modes, effects, and criticality analysis must be routinely used
to identify existing plant hazards before an accident occurs. Analysis
must be performed for certain hazards material lines at the research and
development stage, during conceptual and detailed design, and at the
operational phase. Such analysis should be conducted for any planned or
actual changes in process equipment. For example, a comprehensive
hazards and risk analysis should be conducted for: Reactor No. 5, HCN
Storage and Transfer Operations, IDA & KAN Reactors, the ammonia
distillation column, railcar unloading operations, PCI- storage, and
other critical hazardous materials operations. Comprehensive plant-wide
safety audits should be routinely conducted by Grace personnel and
experts not employed at the Nashua location in order to benefit from a
different perspective.
9-5
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9.13 ACCIDENT INVESTIGATION AND FOLLOW-UP
Chemical investigation procedures are inadequate. Grace does not
have a suitable program to investigate potential, actual, or near-miss
incidents using checklists, codes, standards, and formal hazards
analysis techniques. Existing accident investigation techniques fail to
adequately access system reliability, state-of-the-art corrective
technology, or the magnitude and probability of any incident
reoccurring.
Accident investigation techniques at Grace must be improved and
formalized using a systems approach to minimize the potential of an
accident reoccurring or a failure in other parts of the hazards material
line. Accident and near-miss reports must be completed, filed, and
evaluated for trends and followup. These reports must be readily
available to outside investigators and Audit teams for review and
evaluation.
9-6
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Appendix A
Site Plans and USGS Survey Map
-------
KEY
BLOG 1:
BLOG 2:
BLOG 3:
BLOG 4:
BLDG 5:
BLDG 6:
BLDQ 7:
BLDG 8:
BLDQ 9:
BLDQ 10;
BLDG II:
BLDG 14:
BLDQ 15:
BLOQ 16:
BLOG 17:
BLDG 18:
BLDG 19:
PRODUCT WAREHOUSE
PRODUCT WAREHOUSE
PROCESS-PLANT i
TANK FARM BUILDING
PROCESS-AGHCULTURAL PRODUCTS
ADMINISTRATION
REFRIGERATION
PROCESS-NTA PUNT
BOILERHOUSE
PILOT PLANT
RESEARCH LAB
PRODUCT WAREHOUSE
PROCESS-IDA PLANT
POLLUTION CONTROL
CALCIUM SULFATE PLANT
PROCESS-MIBKAN PROCESS
MAINTENANCE WAREHOUSE
Source: W. R. Grace & Co. Poisson Ave. Nashua, NH
Figure A-l Site Map
-------
I
to
New Hampton
State Liquor Store
33 Tourist 21
Info.
Center
Green Meadows
Golf Club
utum
Greenwood Leaf Dr.
Apts.
O Larsburg
5 Square
~ Apts.
Royal
D Ridge
Mall
Green Ridge
Restaurants
Source: W.R. Grace & Co. Poisson Ave. Nashua, NH
SCALE: 1/32" = 15.3 yds
-------
TO
X)l > HUDSON I • *" TO 25
Source: U.S.G.S. Nashua South Quadrangle New Hampshire - Massachusetts
7.5 Minute Series (Topographic)
Figure A-3 Topographic Site Map
A-3
-------
Appendix B
Photographs of the Facility
taken during the
April 10-14, 1989
Audit
-------
Photographic Log
Date: April 10. 1989
Time:_ afternoon
Location: W.R. Grace Facility
Nashua, New Hampshire
Photo By: Nermin Ahmad - TAT
Site Audit Team Member
Brief Description:
#5 Reactor -- side/top
view
Camera Model: Minolta SRT IQOb
Lens Used:
Number 3 of45
28 mm 1:2.8 MC 4> 49
Project: Accidental Release Audit -- W.R. Grace, Hampshire Chemicals Co., April 10-14, 1989
Date: _ April 10. 1989
Time:_ 'ternoon
Location: W.R. Grace Facility
Nashua, New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description:
#5 Reactor -- closer view
from the side of the top
Camera Model: Minolta SRT IQOb
Lens Used: 28 mm 1;2.8 MC
-------
Photographic Log
Date: April 10. 1989
Time: afternoon
Location: W.R. Grace Facility
Nashua, New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description:
#5 Reactor - 8" Butterfly
valve
Camera Model: Minolta SRT IQOb
Lens Used:
28 mm 1:2.8 MC {449
Number
o
Project: Accidental Release Audit - W.R. Grace, Hampshire Chemicals Co., April 10-14, 1989
Date: _ April 10. 1989
Time: afternoon
Location: W.R. Grace Facility
Nashua. New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description:
#5 Reactor - Dust Exhaust
System
Camera Model: _Man_Qlta_SRT lOOb
Lens Used: 28 mm 1:2.8 MC
-------
Photographic Log
Date: April 10. 1989
Time: afternoon
Location: W.R. Grace Facility
Nashua, New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description:
fi Reactor Roof vent —
view to east
Camera Model: Minolta SRT IQOb
Lens Used:
28 mm 1:2.8 MC ^49
Number 5 of
Project: Accidental Release Audit -- W.R. Grace, Hampshire Chemicals Co., April 10-14. 1989
Date: April 10, 1989
Time: afternoon
Location: JLJ^Jhrace Facility
Nashua. New Hampshire
Photo By: JJexmia JJimmL^TAT
EPA Site Audi t Team Member
Brief Description:
$5 Reactor Roof vent -
dilution blower
Camera Model: Jiinolta SRTL lOOb
Lens Used: 28 mm 1;2.8 MC >449
Project: Audit. April 10-14. 1989
Number 4 _of. 45
B-3
-------
Photographic Log
Date: April 13. 1989
Time: early afternoon
Location: W.R. Grace Facility
Nashua, New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description: Plant II;
hydrocyanic acid rail car
unloading - a general view
Number 38 of 45
Camera Model: Minolta SRT IQOb
Lens Used:
28 mm 1:2.8 MC I 49
Project: Accidental Release Audit - W.R. Grace. Hampshire Chemicals Co.. April 10-14. 1989
Date: April 13, 1989
Time: early afternoon
Location: W.R. Grace Facility
Nashua. New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description: Overview
of Grace rail siding,
facing north
Number 43 of 45
Camera Model: Minolta SRT IQOb
Lens Used:
28 mm 1:2.8 MC 4 49
Project: Accidental Release Audit - W.R Grace. Hampshire Chemicals Co., April 10-14, 1989
B-A
-------
Date: April 12, 1989
Photographic Log
Date: April 12, 1989
Time: early afternoon
Time: early afternoon
Location: W.R. fi
Farilit-y
Nashua, New Hampshire
Location:W.R. Grace FacilitY
Nashua, New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description:
Rear wheels of hydrocyanic
acid rail car at Plant f1
"A" unloading area
Brief Description:
Front wheels with chocks
and hydrocyanic acid rail
car unloading platform
Plant #1 - "A"
Camera Model: Minolta SRT IQOb
Lens Used: 28 mm 1:2.8
Project: Grace Audit. 4/10-14/89
Number 17 of 45
Camera Model: Minolta SRT IQOb
Lens Used: 28 mm 1:2.8
Project: Audit, April 10-14.*89
Number 20 of 45
B-5
-------
Photographic Log
Date: April 12, 1989
Time: early afternoon
Location: W.R. Grace Facility
Nashua, New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description: Plant #1:
Hydrocyanic Acid Rail Car
unloading operation:
termination of transfer by
Dick Farrel, Grace Employee
Camera Model: Minolta SRT IQOb
Lens Used:
Number 21 of 45
28 mm 1:2.8 MC j> 49
Project: Accidental Release Audit - W.R. Grace. Hampshire Chemicals Co.. April 10-14. 1989
Date: April 12, 1989
Time: early afternoon
Location: W.R. Grace Facility
Nashua. New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description: Plant #1:
Hydrocyanic Acid Rail Car
Unloading operations:
platform
Camera Model: Minolta SRT IQOb
Lens Used:
Number 26 of 45
28 mm 1:2.8 MC 4> 49
Project: Accidental Release Audit - W.R Grace, Hampshire Chemicals Co., April 10-14, 1989
B-6
-------
Photographic Log
Date: April 12, 1989
Time: early afternoon
Location: W.R. Grace Facility
Nashua, New Hampshire
Photo By: Nermin Ahmad • TAT
EPA Site Audit Team Member
Brief Description: Plant #1:
Hydrocyanic Acid Rail car
unloading operations:
termination of transfer by
Dick Parrel, Grace
employee
Camera Model: Minolta SRT IQOb
Lens Used:
Number 22 of 45
28 mm 1:2.8 MC 6 49
Project: Accidental Release Audit - W.R. Grace, Hampshire Chemicals Co., April 10-14, 1Q89
Date: April 12. 1989
Time: early afternoon
Location: W.R. Grace Facility
Nashua, New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description: Plant #1;
Hydrocyanic Acid Rail car
unloading operations:
termination of transfer by
Dick Parrel. Grace
employee
WATER CAPV
Camera Model: Minolta SRT IQOb
Lens Used:
Number 23 of 45
28 mm 1:2.8 MC A 49
Project: Accidental Release Audit - W.R. Grace, Hmapshire Chemicals Co., April 10-14, 1989
B-7
-------
Photographic Log
Date: April 12, 1989
Time: early afternoon
Location: W.R. Grace Facility
Nashua, New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description: Plant II;
Hydrocyanic Acid Rail car
unloading operations;
termination of transfer by
Dick Farrel, Grace employee
Camera Model: Minolta SRT IQOb
Lens Used: 28 mm 1:2.8 MC j 49
WATER CAPlf
I7CJ74S LB
-~aas KG
Number 24 of 45
Project: Accidental Release Audit -- W.R. Grace, Hampshire Chemicals Co., April 10 -• 14, 1989
Date: April 12. 1989
Time: early afternoon
Location: W.R. Grace Facility
Nashua, New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description: Plant #1:
Hydrocyanic Acid Rail car
unloading operations:
termination of transfer by
Dick Farrel. Grace employee
Camera Model: Minolta SRT IQOb
Lens Used:
Number 25 of 45
28 mm 1:2.8 MC 0 49
Project: Accidental Release Audit -- W.R. Grace, Hampshire Chemicals Co.. April 10-14, 1989
B-8
-------
Photographic Log
Date: April 12. 1989
Time: early afternoon
Location: W.R. Grace Facility
Nashua, New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description: Plant #1:
Hydrocyanic Acid Rail car
unloading operations;
termination of transfer by
Dick Farrel, Grace employee
Number 27 of 45
Camera Model:
Lens Used:
Minolta SET lOOb
28 mm 1:2.8 MC
-------
Photographic Log
Date: April 12. 1989
Time: early afternoon
Location: W.R. Grace Facility
Nashua, New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description: Plant #1:
Bottled breathing air supply
for hydrocyanic acid rail car
unloading operations
Camera Model: Minolta SRT IQOb
Lens Used:
28 mm 1:2.8 MC I 49
Number 29of 45
Project: Accidental Release Audit -- W.R. Grace. Hampshire Chemicals Co.. April 10-14. 1989
Date: April 13. 1989
Time: early afternoon
Location: W.R. Grace Facility
Nashua. New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description: Warning
sign for Plant #1 HCN
unloading activities
during operations
Number 40 of _45_
Camera Model: Minolta SRT IQOb
Lens Used: 28 mm 1:2.8 MC d 49
Project: Accidental Release Audit -- W.R Grace. Hampshire Chemicals
Ap
B-10
-------
Date: April 12. 1989
Time: afternoon
Location: W.R. Grace Facility
Nashua, New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description:
IDA - "B" Hydrocyanic acid
storage tank - sodium
hydroxide scrubber
Photographic Log
Camera Model: Minolta SRT lOOb
Lens Used: 28 mm 1:2.8 MC
Number 15 of 45
Project: Accidental Release Audit - W.R. Grace, Hampshire Chemicals Co., April 10-14, 1989
Date: April 12. 1989
Time: afternoon
Location: W.R. Grace Facility
Nashua, New Hampshire
Photo By: Nsrmln Ahmad - TAT
EPA Site Audit Team Member
Brief Description:
IDA - "B" Hydrocyanic acid
storage tank - sodium
hydroxide scrubber
.Camera Model: Minolta SRT lOOb
Lens Used: 28 mm 1:2.8 MC «S49
Project: Audit. April 10-14. 1989
Number 16 of 45
B-ll
-------
Date: Anril 12. 1989
Time: afternoon
Location: W.R. Grace Facility
Nashua, New Hampshire
PhotO By: Nprmin Ahmad - TAT
EPA Site Audit Team Member
Brief Description:
Photographic Log
IDA B-Refirtnr (V-1506")
Camera Model: Minolta SRT IQQb
Lens Used: 28 mm 1:2.8 MC 6 49
Project: Audit, Anril 1D-U, 1989
Number i« of AS
B-12
-------
Photographic Log
Dale: April 11, 1989
Time: early afternoon
Location: W.R. Grace Facility
Nashua. New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description:
Aminonitriles tank truck
loading
Number 11 of 45
Camera Model: Minolta SRT IQOb
Lens Used:
28 mm 1:2.8 MC <4 49
Project: Accidental Release Audit -- W.R. Grace, Hampshire Chemicals Co., April 10-14, 1989
Date: April 11, 1989
Time: early afternoon
Location: W.R. Grace Facility
Nashua, New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description:
Methyl-ethyl-Ketone (MEK)
storage tank
Camera Model: Miaolta_SRT IDOb
Lens Used: 28_mm 1 :2.8^MC M9
Project: Ajulit, April 10-14,1989
Number _1Q_ of._ 45
B-13
-------
Photographic Log
Date: April 13, 1989
Time: early afternoon
Location: W.R. Grace Facility
Nashua. New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description:
Ammonia distillation column
(left) and direct fired
heater
Camera Model: Minolta SRT IQOb
Lens Used:
28 mm 1:2.8 MC 6 49
Number 44 of 45
Project: Accidental Release Audit - W.R. Grace, Hampshire Chemicals Co., April 10-14, 1989
Date: April 13. 1989
Time: early afternoon
Location: W.R. Grace Facility
Nashua, New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description:
Ammonia distillation column
Camera Model: Minolta SRT IQOb
Lens Used: 28 mm 1:2.8 MC t*49
Project: Audit. April 10-14.1989
Number 45 of 45
B-14
-------
Photographic Log
Date: April 11. 1989
Time: early afternoon
Location: W.R. Grace Facility
Nashua, New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description: Ammonia
Scrubber and aminonitriles
(KAN) plant
Number 8 of 45
Camera Model: Minolta SRT IQOb
Lens Used:
28 mm 1:2.8 MC 4> 49
Project: Accidental Release Audit - W.R. Grace. Hampshire Chemicals Co.. April 10-14. 1989
Date: April 11. 1989
Time: early afternoon
Location: W.R. Grace Facility
Nashua. New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description:
Anrinnnitriles (KAN)
tank farm
Camera Model: Minolta SRT IQOb
Lens Used: 28 mm 1:2.8 MC rf 49
Number 9 of
Project: Accidental Release Audit - W.R Grace. Hampshire Chemica 1 s Co,._L_A_p_ril 10-14, 1989
B-15
-------
Photographic Log
Date: April 12. 1989
Time: afternoon
Location: W.R. Grace Facility
Nashua, New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description:
Waste water treatment
clarifier
Number 33 of 45
Camera Model: Minolta SRT IQOb
Lens Used:
28 mm 1:2.8 MC «4 49
Project: Accidental Release Audit - W.R. Grace, Hampshire Chemicals Co.. April 10-14. 1989
Date: April 12, 1989
Time: afternoon
Location: W.R Grace Facility
Nashua. New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description:
Waste water treatment
end-of-pipe ammonia
scrubber/absorber
Camera ModelMinolta SRT IQOb
Lens Used: 28 mm 1:2.8 MC ^49
Project:Audit. April 10-14. 1989
Number 32 of 45
B-16
-------
Photographic Log
Date: April 12, 1989
Time: afternoon
Location: W.R. Grace Facility
Nashua, New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description:
Waste water treatment
equalization basin
1, OOPfOOP gals/3 days
Number 30 of 45
Camera Model: Minolta SRT IQOb
Lens Used:
28 mm 1:2.8 MC 6 49
Project: Accidental Release Audit - W.R. Grace. Hampshire Chemicals Co.. April 10-14. 1989
Date: April 12, 1989
Time: afternoon
Location: W.R. Grace Facility
Nashua, New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description:
Waste water treatment
aeration basins
Camera Model: Minolta SRT IQOb
Lens Used:
Number
of _45
28 mm 1:2.8 MC I 49
Project: Accidental Release Audit - W.R. Grace. Hampshire Chemicals Co., April 10-14, 1989
B-17
-------
Photographic Log
Date: April 13t 1989
Time: afternoon
Location: W.R. Grace Facility
Nashua. New Hampshire
Photo By: Nermin Ahmad - TAT
EPA Site Audit Team Member
Brief Description:
Hazardous waste drum
storage area
Camera Model: Minolta SRT IQOb
Lens Used:
Number 35 of 45
28 mm 1:2.8 MC
-------
Appendix C
Accidental Release Information
Questionnaire
-------
Answers to EPA Attachment I
Identify the person(s) answering these Questions on
behalf of the addressee of this reporting requirement.
Further, identify a person that EPA may contact in case
it wants to discuss the answers to these Questions and a
lead contact to accompany an audit team throughout your
facility.
Persons answering these Questions:
Lauchlin V. Hines
Assistant Plant Manager
William J. Pasko
Technical Manager
David J. Laferriere
Process Engineering Manager
Eileen E. conley
Environmental Engineer
Lead Contact:
Jeremiah B. McCarthy
Plant Manager
2. Identify all environmental permits issued by federal or
state authorities that apply to the Facility. Describe
all activities at the Facility that are covered by such
permits.
Permit to Manage Hazardous Waste
Permit No. 048724173
Issued by N.H. Waste Management Division
Permitted activities: storage only of hazardous waste.
National Pollutant Discharge Elimination System
Permit No. NH0000591
Issued by Water Management Division
U-.S. Environmental Protection Agency
and
N.H. Water Supply and Pollution Control
Division
Permitted activities: Discharge of wastewater from the
facility to the Merrimack River.
Permit to Operate Cleaver Brooks 500 Hp Boiler A
Permit No. PO-B-193
Issued by N*.H. Air Resources Division
Permitted activities: Operation of 500 Hp Boiler A.
-------
Answers to EPA Attachment I
Page 2
Permit to Operate Cleaver Brooks 500 Hp Boiler B
Permit No. PO-B-1541
Issued by N.H. Air Resources Division
Permitted activities: Operation of 500 Hp Boiler B.
Permit to Operate Cleaver Brooks 600 Hp Boiler
Permit No. PO-B-1542
Issued by N.H. Air Resources Division
Permitted activities: Operation of 600 Hp Boiler.
Temporary Permit Cleaver Brooks 800 Hp Boiler
Permit No. TP-B-172
Issued by N.H. Air Resources Division
Permitted activities: Operation of 800 Hp Boiler.
Permit to Operate New Hot Oil Heater
Permit No. PO-B-1045
Issued by N.H. Air Resources Division
Permitted activities: operation of Ammonia Tower Hot
Oil Heater.
Permit to Operate Lime waste Treatment Incinerator
Permit No. PO-BP-2412
Issued by N.H. Air Resources Division
permitted activities: Operation of Lime Waste Treatment
Incinerator for the incineration of process waste
streams.
Permit to Operate NTA Production Equipment
Permit No. PO-BP-193
Issued by N.H. Air Resources Division
Permitted activities: Operation of production equipment
for the production of nitrilotriacetic acid.
Permit to Operate IDA Production Equipment
Permit No. PO-BP-2411
Issued by N.H. Air Resources Division
Permitted activities: Operation of production equipment
for the production of iminodiacetlc acid.
3. Briefly describe the Facility and its operations.
Include in this description a simple process flow chart
labeling process steps, vents, blowers, stacks, control
equipment, waste treatment systems, and safety
instrumentation. (Submit flow diagrams on eight an'i
one-half by eleven-inch paper if they are readily
available in this format.) List the major raw
materials used and end products produced at the
Facility.
Founded in 1958 and acquired by W. R. Grace & Co. in
1965, the Nashua Facility is one of four major chemical
facilities operated and managed by the Organic Chemicals
-------
Answers to EPA Attachment I
Page 3
Division. Most of the products manufactured at this
location are based on Hydrocyanic Acid chemistry and
cannot be produced elsewhere by Grace in the United
States or Canada. The facility consists of four
manufacturing plants, a research lab, office and
effluent treatment facilities.
There are currently 325 full-time employees, including
approximately 200 factory and about 125 office and
research personnel employed at the Nashua location.
Except for a scheduled two week shut-down each summer
for maintenance, replacement and reconditioning of
equipment, the plant normally operates 24 hours/day,
7 days/week.
The Nashua Facility is a batch specialty chemical plant.
We produce 133 products; some products are produced
continually and some are produced seasonally.
Since the Facility does produce so many products, an
interpretation of the desired process information was
requested from Raymond OiNardo, Manager, Region 1
Chemical Emergency Preparedness Program. As per an
August 25, 1988 conversation with him, we are providing
process flowsheets by the major product line groups
rather than providing a flowsheet for each product. The
major product line groups covered by these flow sheets
represent «70% of plant production. The remaining
products are, for the most part, simple variations of
one of these major product lines. (For example, EDTA is
made as a sodium salt solution by either of two
processes, both shown on the flowsheets. These sodium
salts are sold at various pH ranges and converted to
other crystalline or solution forms totalling more than
30 variations.)
Attachments 1 through 9 depict the flowsheets for the
major product line groups for the Nashua Facility. If
any additional information is required, it will be
provided upon request.
Major raw materials used at the facility:
1,3-diaminopropane
acetone
aminoethylethanolamine
ammonia, anhydrous
ammonia, aqueous solution
calcium magnesium oxide
calcium oxide
coconut acid
copper oxide
eyelohexanone
diethanolamine
-------
Answers to EPA Attachment I
Page 4
diethylenetriamine
ethylenediamine
ferric chloride
ferrous sulfate
formaldehyde
hydrocyanic acid
hydrogen peroxide
isopropanol
lauric acid
manganese oxide
magnesium oxide
methyl ethyl ketone
monomethanolamine
monomethylamine
nitric acid
oleic acid
phosphorous trichloride
potassium hydroxide, solution
sodium cyanide, solution
sodium hydroxide, solution
sponge iron
sulfuric acid
zinc oxide
Major products produced at the facility:
acetone aminonitrile (AAN)
anunon i a, anhydrou s
cyclohexanone aminonitrile (CHAN)
diethylene triaminepe,ntaacetic acid (HAMP-EX Acid)
disodium iminodiacetate (DSIDA)
ethylenediamine tetraacetic acid, 2.5% magnesium
(HAMP-ENE 2.5% Magnesium)
ethylenediamine tetraacetic acid, 6% manganese
(HAMP-ENE 6% Manganese)
ethylenediamine tetraacetic acid, 6.5% zinc
(HAMP-ENE 6.5% Zinc)
ethylenediamine tetraacetic acid, 7.5% copper
(HAMP-ENE 7.5% Copper)
ethylenediamine tetraacetic acid, 3% calcium
(HAMP-ENE 3% Calcium)
ethylenediamine tetraacetic acid (HAMP-ENE Acid)
hexamethlyenetriamine
iminodiacetic acid (IDA)
methyl ethyl ketone aminonitrile (MEKAN)
methyl isobutyl ketone aminonitrile (MIBKAN)
nitrilotriacetic acid, zinc (HAMPSHIRE NTA Zinc)
N-cocoyl sarcosine (HAMPOSYL C)
N-hydroxyethylethylenediaminetriacetic acid, 5% iron
(HAMP-OL 5% Iron)
N-hydroxyethylethylenediaminetriacetic acid
(HAMP-OL Acid)
N-lauroyl sarcosine (HAMPOSYL L)
N-oleoyl sarcosine (HAMPOSYL 0)
-------
Answers to EPA Attachment I
Page 5
pentasodimn diethylenetriaminepentaacetate,
solution (HAMP-EX 80)
sodium cocoyl sarcosinate (HAMPOSYL c-30)
sodium cyanide, solution
sodium lauroyl sarcosinate (HAMPOSYL L-30)
sodium sulfate
tetrasodium ethylenediamine tetraacetate, solution
(HAMP-ENE 100)
tetrasodium ethylenediamine tetraacetate
(HAMP-ENE NcU)
tetrasodium ethylenediamine tetrahydrate
(HAMP-ENE 220)
trisodium ethylenediamine tetraacetate, solution
(HAMP-ENE Na3)
trisodium nitrilotriacetate monohydrate (NTA)
trisodium nitrilotriacetate, solution (NTA-150)
trisodium N-hydroxyethylethylenediaminetriacetate,
solution (HAMP-OL 120)
trisodium N-hydroxyethylethylenediaminetriacetate
hydrate (HAMP-OL Crystals)
4. How large is the average buffer zone around your
facility? Provide a map showing your building location
and surrounding area.
Average buffer zone: 387 ft.
Site plan enclosed: Grace Dwg. 04-25 (Attachment 10)
The average buffer zone of 387 feet refers to the
literal Agency definition of a buffer zone as "any
unpopulated spaced owned by your company between your
process and storage areas and populated areas". Since
this definition refers specifically to areas owned by
the company, it does not include the effective
unpopulated area, both company owned and otherwise
owned, between the plant process and storage areas and
adjacent populated areas.
Although the populated area to the west of the facility
is adjacent to the facility boundary, to the south
there is a 1125 foot zone, to the north a 2300 foot zone
and to the east a 4800 foot zone between the facility
process and storage areas and populated areas.
5. Generally describe the area surrounding the Facility,
including but not limited to, business, residences,
schools, or other population centers. Identify the
approximate number of people within a five-mile radius
of the Facility.
The w. R. Grace & Co.-Conn.'s Organic Chemicals Division
facility in Nashua, New Hampshire, is located on Poisson
-------
Answers to EPA Attachment I
Page 6
Avenue, adjacent to the Merrimack River, at 42°43I2.5"
latitude and 71°26'19.6" longitude. Land in the area is
used primarily for commercial strips, with some
residential areas and multifamily residential
developments. The facility is separated from the river
to its east by the tracks of the Guilford Transportation
Industries, Inc. railroad. It is bound on the west by
commercial development (including a motel, a day care
center and several restaurants) and three private
residences; on the north by commercial property; and on
the south by a manufacturing plant. A golf course and
residential area lie across the river from the plant. A
five mile radius from the plant includes substantially
all of the towns of Nashua and Hudson, New Hampshire and
Tyngsboro and Dunstable, Massachusetts. The total
population of these four towns is 108,000.
6. How many people are employed at the Facility?
There are currently 325 people employed at the Facility.
7. Generally describe the terrain surrounding the Facility.
(e.g., geology, large bodies of water, man-made
features, etc.)
The terrain surrounding the facility is best described
by the attached United States, Department of the
Interior, Geological Survey Map. (See Attachment 11)
The land slopes steeply downgrade west to east. Spit
Brook crosses the western boundary of the plant site,
flows northeasterly for approximately 200 feet in an
open channel, and then is conveyed under the plant via a
6-foot conduit to the Merrimack River. The Merrimack
River lies to the east of the plant and flows from north
to south.
8. List all extremely hazardous substances present at your
facility in excess of the threshold planning quantity
listed in Appendices A and B of the Wednesday, April 22,
1987, Federal Register, pages 13397 through 13410, and
all CBRCLA hazardous materials generated, treated,
produced, used, stored, disposed of, or otherwise
handled at or by the Facility in excess of 10,000 pounds
in any calendar year. (See Table 302.4 of 40 CFR Part
302 for listed CERCLA hazardous materials.) For each
hazardous material and extremely hazardous substance,
identified, further identify:
a. The Chemical Abstracts Service (CAS) registry
numbers.
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Answers to EPA Attachment I
Page 7
b. The quantity generated, treated, produced, used,
stored, disposed of, or otherwise handled each
year over the past two years.
c. A brief description of how and the location
where it was used, treated, stored, disposed of,
or otherwise handled.
8-la Ammonia (CAS #7664-41-7)
-------
Answers to EPA Attachment I
Page 8
8-2a Sodium Cyanide (CAS #143-33-9)
-------
Answers to EPA Attachment I
Page 9
8-3a Ethylenedlamine (CAS #107-15-3)
8-4a Hydrocyanic Acid (CAS #74-90-8)
-------
Answers to EPA Attachment I
Page 10
8-5a Sulfuric Acid (CAS #7664-93-9)
8-6a Nitric Acid (CAS #7697-37-2)
-------
Answers to EPA Attachment I
Page 11
8-7a Formaldehyde (CAS #50-00-0)
8-8a Phosphorus Trichloride (CAS #7719-12-2)
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Answers to EPA Attachment I
Page 12
8-9a Hydrogen Peroxide (CAS #7722-84-1}
8-10a Ethylenediaminetetraacetic Acid (CAS #60-00-4)
-------
Answers to EPA Attachment I
Page 13
8-lla Sodium Hydroxide (CAS #1310-73-2)
8-12a Potassium Hydroxide (CAS #1310-58-3)
8-13a Ferrous Sulfate (CAS #7720-78-7)
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Answers to EPA Attachment I
Page 14
8-14a Ferric Chloride (CAS #7705-08-0)
8-15a cyclohexanone (CAS 108-94-1)
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Answers to EPA Attachment I
Page 15
8-16a Methyl Ethyl Ketone (CAS #78-93-3)
8-l7a Methyl isobutyl Ketone (CAS #108-10-1)
8-18a Acetone (CAS #67-64-1)
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Answers to EPA Attachment I
Page 16
8-19a Phosphoric Acid (CAS #7664-38-2)
9. Identify the hazardous material release prevention plans
and procedures you use or have used at the Facility.
Provide copies of such plans or procedures to EPA.
Hazardous material release prevention plans and
procedures consist of two components: prevention and
response.
Prevention
All operating procedures using hazardous materials are
designed to minimize the risk of a hazardous material
release. These procedures include Standard Operation
Procedures (SO?s) and Standard Raw Material Handling
Procedures (SRHPs). Attached are copies of SOP 0730
(Attachment 13) for the fatty acid chloride reaction,
and SRHPs 1200 (Attachment 14) and 1725 (Attachment 15)
for hydrocyanic acid and phosphorus trichloride as
examples of these procedures. Exact quantities have
been blanked out of SOP 0730 due to the proprietary
nature of this information.
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Answers to EPA Attachment I
Page 17
Other procedures include maintenance and inspection
procedures. Some of these procedures are part of
SRHPs while others are done on a routine basis, ranging
from daily to annually. Daily inspections include:
1. Morning tank farm readings by the Yard crew
which includes inspections for leaks.
2. Inspection of plant areas by the Production
Supervisor at the start of each shift.
3. Inspection of the hazardous waste storage areas
by the Pollution Control Operators.
4. Handling of hazardous materials by dedicated
work crews. For example, hydrocyanic acid is
unloaded by a dedicated crew that does not
unload or load any other material. Likewise,
the crew that unloads the other raw materials
never unloads hydrocyanic acid.
A copy of our Hazardous Waste Handling Permit
(Attachment 16) is attached as it outlines in detail our
procedures for handling hazardous wastes and some of
these inspection procedures.
Some examples of annual maintenance procedures include
cleaning, internal inspection and replacement of all
valves in the two hydrocyanic acid storage tanks and all
the hydrocyanic acid railcars. The maintenance
department recently purchased a new computer system to
improve documentation of all maintenance inspections.
Other procedures used to minimize risk of an accidental
release include (copies attached):
1. Contractor area permit (Attachment 17)
2. Contractor safety rules and procedures
(Attachment 18)
3. Equipment procedures
a. Equipment lock-out (Attachment 19)
b. Line or pump repair (Attachment 20)
c. Hot work permit (Attachment 21)
d. Vessel Entry permit (Attachment 22)
e. Defective equipment tag (Attachment 23)
Emergency Response
In the event of an upset or a release of a hazardous
material, we have an extensive emergency response
procedure to minimize the extent of the release. A copy
of this "Contingency Plan" is attached (Attachment 24).
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Answers to EPA Attachment I
Page 18
In summary, the contingency Plan works as follows:
There are over 100 emergency alarm pull stations
throughout the plant site. When a pull station is
activated, a plant wide emergency alarm sounds and the
pull station location is indicated on one of two central
alarm panels. The emergency alarm can be used for any
emergency requiring immediate assistance including an
accident, chemical release, injured employee, fire, etc.
Several things happen when an emergency alarm sounds.
1. One of two trained Emergency Service Teams (EST)
responds to the pull station location while the
other waits as backup.
2. All plant radios are turned to channel 2.
3. All material transfers in the plant are stopped.
4. The pollution control operator switches plant
effluent to a spill holding basin.
5. Office area paging systems are turned on.
The plant maintains two ESTs on site 24 hours a day,
seven days a week. In addition, the alarm system and
emergency equipment is tested and/or inspected on a
weekly basis. This includes emergency alarms, fire
prevention equipment, escape respirator checklist and
emergency locker checklist.
Each Emergency Service Team consists of a Production
Supervisor, three men from either the Production
Department or the Maintenance Department, and one
communications person from the Quality Control
Laboratory. The Production Supervisor and the three
team members suit up in personal protection equipment
for the response effort. The communications person mans
the central radio and telephone communication station.
Additional procedures are outlined in the plant "Safety
Rules and Regulations" (Attachment 25).
10. Identify the training activities at the facility related
to safety and loss prevention.
Training activities regarding safety and loss prevention
begin the day a new employee is hired and is given a New
Employee safety Indoctrination.
This indoctrination includes familiarization with the
plant's safety Rules and Regulations, Right-to-Know and
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Answers to EPA Attachment I
Page 19
Hazard Communication information.
Production employees are given further training in safe
handling procedures for hazardous chemicals when they
are assigned to a particular work area. This on-the-job
training normally consist of a 60 to 90 day period
during which the employee is trained by a qualified
operator and by the production supervisor. Employees
become familiar with emergency alarm locations by
participating in the weekly testing procedures.
In addition to on the job training, other safety and
loss prevention training is outlined below.
A. Safety Meetings
A-l Safety Coordinator-Plant Wide Safety Meetings
Once a month, the Safety Coordinator has plant
wide safety meetings which are mandatory for all
plant operation and maintenance personnel. These
meetings cover a variety of subjects such as:
Personal protective equipment
Right-to-Know, hazard communication
Hazards of specific chemicals
Respiratory protection program
Material handling procedures
Pollution control and spill procedures
A-2 Shift Supervisor Monthly Shift safety Talks
These are similar to the plant wide safety
meetings, but on a smaller scale. Once each
month, every production and maintenance supervisor
holds a safety talk for his employees. Subjects
are similar to the plant wide meetings but are
more detailed and more specific to the hazards
associated with that group's work and work areas.
A-3 Contractor Safety Talks
All contractors entering the plant site are given
an orientation and instructed on Contractor Safety
Rules and Procedures (See Attachment 18). This
orientation also includes information on the types
of chemicals and the hazards that the contractor
may be working near.
*-.
In addition, daily Contractor Area Permits and
daily Hot Work Permits are required so that
production supervisors are aware of what work is
being performed in what areas by contractors.
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Answers to EPA Attachment I
Page 20
B. Emergency Service Team Training (EST)
B-l Monthly Practice Alerts
Each of the eight ESTs has a practice alert once
every month. These practice sessions are
unannounced and simulate a real emergency ranging
from employee injury to chemical release. An
evaluation session follows each practice session.
B-2 Fire Department Training
ESTs have received special training at the Nashua
Fire Department training grounds including proper
hose handling, the use of different nozzles,
practice using fire fighting foam on oil fires,
etc.
B-3 EST Leader Training
All EST Leaders (as well as other management
personnel) have attended a week long hazardous
materials response training course at the
Association of American Railways training facility
in Pueblo, Colorado. The plant Safety Coordinator
and other personnel have also attended additional
training programs such as Tank Truck Emergency
courses at Texas A&M University.
c. Fire Extinguisher Training
Office and laboratory personnel have attended fire
safety training sessions at the Nashua Fire
Department training grounds that included practice
using fire extinguishers to put out actual fires.
D. Fire Department Seminar and Tour
All Nashua Fire Department personnel have received
two hours of classroom instruction on the chemicals
we handle as well as a complete tour of the plant
site.
We have also sponsored Nashua Fire Department
personnel to attend above mentioned hazardous
materials courses.
E. Hazardous waste
All personnel handling hazardous waste receive
training that includes the program outlined in the
Hazardous Waste Permit (See Attachment 16).
11. Briefly describe the methodologies by which the Facility
identifies safety hazards and the systems, procedures or
equipment used to prevent hazardous substance releases
from occurring.
In the early 1980's, a committee of key operating,
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Answers to EPA Attachment I
Page 21
technical and engineering personnel was formed to
evaluate our storage and handling of hazardous raw
materials. The Materials Use and Storage Team (MUST)
evaluated the use and handling of hazardous materials as
compared to applicable industry standards and practices.
The result was a major capital projects program to
improve the handling and storage of several materials
including: phosphorus trichloride, hydrocyanic acid,
monomethylamine, and anhydrous ammonia.
In designing changes to these systems, applicable
industry standards both voluntary and regulatory, were
used as the basis for design.
The most significant applicable voluntary standards
which were developed with substantial input from the
hydrocarbon industry are:
1. National Fire Protection Association NFPA-30,
Flammable and combustible Liquids Code.
2. NFPA-497, Classification of Class 1 Hazardous
Location for Electrical Installation in Chemical
Plants.
3. NFPA-497M, Classification of Gases, Vapors and
Dusts for Electrical Equipment in Hazardous
Locations.
4. American National Standards Institute ANSI B
31.3, Petroleum Refinery Piping
5. API Recommended Practice (RP) 520, Parts I and
II, Design and Installation of Pressure-
Relieving Systems in Refineries.
6. API STD 650, Welded Steel Tanks for Oil Storage
Tanks.
7. API STD 2000, Venting Atmospheric and Low-
pressure storage Tanks.
8. API 510, Pressure Vessel Inspection Code
9. API RP 2001, Fire Protection in Refineries
Another group which has played a major role in chemical
plant safety was the Manufacturing Chemists'
Association, Inc. (MCA), now the Chemical Manufacturer's
Association (CMA). The chemical Safety Data sheets
produced by that group contained "Properties and
Essential Information for Safe Handling and Use of ..."
various chemicals. MCA also produced manuals for
standard and recommended practices. This information
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Answers to EPA Attachment I
Page 22
was superseded by manufacturers Material Safety Data
Sheets (MSDS) and storage and handling booklets. All
products which are considered to be hazardous materials,
whether or not stored in permanent outside storage,
require MSDSs.
In addition to these voluntary standards, certain
applicable codes and standards are part of the laws of
the state of New Hampshire, or local fire laws. These
include:
1. Building Code Officials and Code Administrators
International BOCA Basic Fire Prevention code
and NFPA 101, Life safety Code; recommendations
based on these codes were made by the Nashua
Fire Department.
2. American Society of Mechanical Engineers (ASME)
Unfired Pressure Vessel Code, Section VIII,
Division 1 and Power Boiler Code, section I.
3. Referenced voluntary standards such as:
a. NFPA 70, National Electrical Code; especially
Article 500, Hazardous (Classified) Locations
b. NFPA 30, Described earlier
c. API STD 650, Described earlier
d. NFPA, Liquified Petroleum Gases.
Other mandatory laws at the federal level applicable to
plant operations include those under the jurisdiction of
OSHA, EPA and DOT. These laws have been incorporated
into state law in many instances.
Once a preliminary design is completed, process review
meetings are held to evaluate possible problems. In
most cases "what if type scenarios are explored similar
to a HAZOPS. These review meetings include input from
hourly maintenance and production employees,
supervisors, plant technical and process engineers,
project engineers and, in many cases, Grace Corporate
Risk Assessment Group and independent consultants.
Design reviews are continued until everyone is satisfied
with the design.
In addition to design meetings and applicable standards
and regulations, there are other basic principals used
as a design basis, including:
Minimizing the total volume and number of storage
containers.
Minimizing the quantity of hazardous materials inside
process areas.
Operation of systems at lowest possible pressures.
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Answers to EPA Attachment I
Page 23
Use of passive rather than active safety controls,
where possible.
Provision of redundancy on critical equipment
In addition to the major project efforts instituted by
the MUST program, a number of other methods are used to
identify potential safety hazards. These include:
Inspections by Grace Corporate Risk Assessment Group
Inspections by Grace Specialty Chemicals
Environmental, Health and Safety Department
Inspections by CNA Insurance Co.
Inspections by Marsh & McClennan Protection Consultants
Annual inspections by Hartford Steam Boiler (A
complete inspection of all ASME code vessels was
completed within the last year)
Monthly inspections by plant Safety Committee members
Plant maintenance Safety Work Order System
As a final step in evaluating potential releases, air
modeling studies are being prepared for several
"realistic worst case" scenarios involving the most
hazardous materials. The cases chosen were selected
with the help of Grace's Corporate Risk Assessment Group
and Marsh & McClennan Protection Consultants. The
results of this study will be made available for use by
the Local Emergency Planning Committee when the study is
completed.
12. For the August 5, 1988, Phosphorus Trichloride release,
provide answers to the following questions:
a. What was the cause of the accident?
b. How could the accident have been avoided?
c. What steps have you taken to avoid future
accidents of this nature?
d. Once the accident occurred, what steps were
taken to evacuate the immediate area and control
the situation? How can this process be
improved?
e. What are the potential health risks to workers
and persons in the immediate area of the
release? How many people were exposed at the
time of the accident and how were they treated?
f. What is the likelihood of a future accident at
the plant and what is being done to diminish
this risk?
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Answers to EPA Attachment I
Page 24
a. The cause of the August 5, 1988 Hydrochloric Acid
Release was the failure of a butterfly valve on the
atmospheric vent line on the reactor. This valve is
installed on the atmospheric vent line on the tank.
Normally this valve is closed during processing,
closing off the atmospheric vent, and all vapors are
vented through a water scrubber system. This valve
is opened when the reactor is being cleaned. The
failure of this valve to properly seat allowed the
vapors to escape through the atmospheric vent rather
than to the scrubber system.
b. The cause of the incident is described in 12a above.
The steps taken to avoid future incidents are
described in 12c below and have been implemented as a
result of our analysis of the event.
c. The failed valve has been replaced with a valve that
is specified for a more severe service. Additionally,
modifications have been made to the scrubber system
and to the process operation to carry out future
reactions under negative pressure which gives
indication ahead of time that all valves are properly
sealed. A secondary scrubber has also been added to
this system.
d. Once the venting of the vapors to atmosphere was
detected, the ongoing process was shut down and our
on-site emergency response team was activated. They
donned personal protective gear and breathing
apparatus, cleared the process area, and set up water
hoses to deluge the area with water to scrub the
escaping vapors out of the air. An improvement to
this response effort would be to provide fog nozzles
for the fire hoses. Deluging the area with a fog
spray would be more efficient for scrubbing the
vapors than deluging the area with a fire hose spray.
e. "High concentrations of hydrochloric acid vapors are
highly corrosive to eyes, skin, and mucous membranes.
The acid may produce burns, ulceration, scarring on
skin and mucous membranes, and it may produce
dermatitis on repeated exposure." (Ref.: Sittig,
Handbook of Toxic and Hazardous Chemicals, p. 375)
There were no on-site personnel exposed to the acid
vapors who were not protected by personal protective
gear and self contained breathing apparatus. There
were no on-site personnel treated for exposure.
EPA representatives were unable to detect any
concentrations of hydrochloric acid vapors in the
area surrounding the plant site. This fact, in
conjunction with air release modeling data, indicate
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Answers to EPA Attachment I
Page 25
that off-site exposure above the TLV concentration
was unlikely. Incident reports indicate that 51 off-
site people were examined for possible exposure. Of
these, one was kept overnight for observation and was
released the next day.
The remaining 50 were released immediately.
f. As was described in the answer to Question 12-c, the
failed valve has been replaced. Additionally,
modifications have been made to the scrubber system
and to the process operation to carry our future
reactions under negative pressure.
Process operations with the modifications are being
closely monitored by the Process Engineering Group to
assure that these process modifications are not only
operating properly but are resulting in the desired
process modifications.
A copy of the incident summary report that was
submitted to the responding Agencies is enclosed
(Attachment 26) .
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Appendix D
HCN Release Profile
-------
EPA ATTACHMENT II
03/15/88 HCN RELEASE
OMB tf: 2050-0065
U.S. ENVIRONMENTAL PROTECTION AGENCY
RELEASE PREVENTION QUESTIONNAIRE
INITIAL REPORT
1. FACILITY XAJ1E:
2. FACILITY ADDRESS:
3. KA3E OF OWNER:
SECTION 1. FACILITY PROFILE
W. R. GRACE & CO.-dbNN.
ORGANIC CHEMICALS DIVISION
POISSON AVENUE
Street
NASHUA
City
N. H.
Scare
Q3Q61
Zip Code
W. R. GRACE & CQ.-n
ADDRESS OF OWNER: GRACE PLAZA. IU'4 AVENUE OF THT? AMFKTf.AS
Street
NEW YORK
City
N.
State
10036
Zip Code
JEREMIAH B. MC CABTTrY
PLANT MANAGER
POISSON_AVEMIE_
Streec
NASHUA
City
N. H.
State
Zip Code
(6031 888-2320
Telephone
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EPA ATTACHMENT II
03/15/88 HCN RELEASE
6. Please indicate the year facility operations began.
Il] [9]
7. Identify the four-digit Standard Industrial Classification (SIC) that best
describes your facility operations and the primary product or service of
this facility.
[2]
a. SIC code
b. Primary product or service:
6a. Check the item below that best describes the status of facility operations
at the time of release.
s- txl 1° operation
b. [ ] Temporarily inactive
c. f j Permanently closed
8b. Check the item below that best describes the current status of facility
operations.
a. I ^ In operation
b. | J Temporarily inactive
c. 1 ] Permanently closed
If Item a is. marked, go to Section II Hazardous Substance Release Profile.
If Item b or c is marked, answer Question S.c. below.
8c. Is the shut down of operations at your ficility related to the accidental
release of hazardous substances?
I ] Y«
I 1 No
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•8-
EPA ATTACHMENT II
03/15/88 HCN RELEASE
SECTION' II. HAZARDOUS SUBSTANCE RELEASE PROFILE
The following section asks several questions
concerning the accidental release of hazardous
substances. If exact responses cannot be provided,
please provide estimates using your best
professional judgment.
9. Indicate the date release occurred.
[01 [3J - Cll l5l ' 181 [8j
(month) (day) (year).
10. Indicate the time of day release occurred.
10] 111 : bl
I J A.M.
[Xl P.M.
11. Indicate date release ceased.
10] [31 - HI fe] - [81 [8]
(month) fdayl (year)
12. Indicate time of day release ceased.
[0] III: [4] [5] estimated
I J A.M.
NOTE: In ^^fy^S P«ties notified of the release, we ha^e included
to so 1° Graf6 t0 ***• been notifie*. notification
to some of the listed parties may have been made by other officials
originally notified by Grace. otriciais
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•9-
EPA ATTACHMENT II
03/15/88 HCN RELEASE
13. Were federal authorities notified?
[Xl Yes [ 1 No
a. If yes', identify all federal authorities notified regarding the
release.
(If more than one, please attach list on separate paze)
RANDY RICE PLEASE SEE PAGE *
US EPA
(Name)
BOSTON. MA
(City)
MA D77m
(State)
C617)
(Telephone)
b. Indicate the date and time of day federal authorities were notified.
Idf^'llJtsI'tdld (Date)
(month) (day) (year)
1)1 fe] : bits) 'Time)
[ ] A.M.
kl P.M.
Were state authorities notified?
[X] Yes [ 1 No
a. If yes, identify all state authorities notified concerning the release
(If mcrs than one, please attach list on separate page)
JtLEASE SEE
MR. RICHARD STROME
N.iL. OFFTrF ny KMFB^FMPV
(Xaae)
CONCORD
(City)
N H 03301
(State)
(603) 271-2231
(Telephone)
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-9A-
EPA ATTACHMENT II
03/15/88 HCN RELEASE
13. (a) Mr. O'Brien
National Response Center
Washington, CD 02003
1-800-424-8802
(b) Notification on: 03/15/88
Notification at: 02:20 p.m.
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-10-
EPA ATTACHMENT II
03/15/88 HCN RELEASE
b. Indicate the date and time of day state -authorities were notified.
to! bl - hi 151 ' [3] Is*
(month) (day) (year)
lol [2l ' Col
I ] A.M.
[X] P.M.
*
IS.'Vere local authorities notified?
Yes [ J No
a. If yes, identify all local authorities notified concerning the release.
(If more than one, please attach list on separate page)
MR. RICHARD MC CANN
NASHUA OFFICE OF EMERGENCY PREPREDNESS _
(Name)
NASHUA _______
(City)
N. H. 03060
(State)
fern ) «81-4100
(Telephone)
b. Indicate the date and time of day local authorities were notified.
10 I [3 J * [1 1 [5 ] - 18 1 [8 1 (Date)
(month) (day) (year)
IOJ 111 : 15] I5l III! (Time)
[ ] A.M.
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-10A-
EPA ATTACHMENT II
03/15/88 HCN RELEASE
14. (a) Mr. Richard Andrews
N. H. Air Resources Division
Concord, NH 03302
(603) 271-1370
(b) Notification on: 03/15/88
Notification at: 02:15 p.m.
(a) Ms. Roberta Cirie
N. H. Waste Management Division
Concord, NH 03301
(603) 271-2943
(b) Notification on: 03/15/88
Notification at: 02:55 p.m.
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-11-
EPA ATTACHMENT II
03/15/88 HCN RELEASE
16. Was the general public notified?
[ ] Yes Ix] No
a. If yes, indicate the person that notified the general public of
release.
(If more than one, please attach list on separate page)
(Name)
(Title)
(Company or Government pffice)
(Telephone)
b. Indicate the date and time of day the general public was notified.
I 1 [ I - I 1 I I - I 1 I 1
(month) (day) (year)
(](]:(](] (Time)
[ J A.M.
f J P-3-
17. Were members of the general public evacuated?
[ ] Yes Ix] No
«. If yes, please indicate number evacuated.
[ ] M I ] M I J M
b. Please indicate dace and time of day evaluation began.
i ] r i - 1 i i J - 1 i M (Da«)
(month) (day) (year)
[ ] I J : U I J
[ ] A.M.
I J P.«-
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-12-
EPA ATTACHMENT II
03/15/88 HCN RELEASE
16. To the best of your ability, indicate the weather conditions at the time
of release for each item below. Approximations are acceptable.
a. Vina Speed (miles per hour)
b. Wind Direction
DEW POiNT
e. HuaiMita
d. Temperature (F-ihrcnheit)
«. Precipitation?
10) [0] [91
(N) [ rf fr J
[Ml UNKNOWN
D J r& 1 [5]
[ 1 Yes [x] No
19. Please check the one item below that best describes the location of the
release vithin your facility.
Process vessel
[ ] Storage vessel
I 1 Valves
I 1 Piping
( ] Unknown
[ ] Other (please describe)
(please check one item only)
20. Please check the one item below that best describes the operational
condition of releasing equipment at Che time of the release.
Process startup
Process shutdown
Loading
Unloading
Batch operation
Maintenance
Continuing operations
Unknown
Other (please describe)
(please check one item only)
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•13-
EPA ATTACHMENT II
03/15/88 HCN RELEASE
21. Please check the one item below that best describes the primary cause of
the release event.
Jx} Equipment failure
[ J Operator error
[ J Bypass condition
[ j Upset condition
[ ] Fire
{ ] Unknown
[ ] Other (Please describe)
(please check one item only)
22. Please check any itecs below that describe additional causes of the
release event.
Equipnent failure
Operator error
Bypass condition
[ Upset condition
[ Fire
[ Unknown
[XJ Other (Please describe)
NONE
(check as many items as apply)
23. Check the items below that describe the end effects of the release event.
(check as many items as apply)
IxJ
(X] Vapor release
( j Explosion
I I ?i«
[ ] Other (Please describe)
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-14-
EPA ATTACHMENT II
03/15/88 HCN RELEASE
24.a. Identify in the table belou the name of each hazardous substance
released, the quantity released, and the concentration and physical
state at the tine of release.
NAME SCANTITY UNIT PHYSICAL STATE CONCENTRATION
1. HYDROCYANIC ACID 30 LBS VAPOR inn?
2. jmmocYANTr Ann s CALS T.Tqrrrn 100%
3..
b. Please check the items bclov that describe your methods or source of
information for your"responses in Question 24.a.
I ] on-line instrument
[ j process records
[ ] engineering calculation
estimate
other (please describe)
(1) METEOROLOGICAL DATA
(1) COMPUTER AIR MODELING
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-15-
EPA ATTACHMENT II
03/15/88 HCN RELEASE
!5.a. In the table below, please estimate the quantity of substances listed in
Question 2^.a released to each media. Be sure to specify the
measurement unit.
NAME
.HYDROCYANIC ACID VAPOR
MEDIA
Air
Surface Vater
Land
Ground Vater
QUANTITY
30
-D-
-0-
-0-
USIT
2.HYDROCYANIC ACID LIQUID
3.
Air
Surface Vater
Land
Ground Vater
Air
Surface Water
Land
Ground Vater
-0-
-0-
-0-
-0-
Air
Surface Vater
Land
Ground Vater
b. Please, check the items below that describe your methods or source of
information for your responses in Question 25. a.
I ]
(1,2) DC ]
[ ]
[ ]
physical properties
observation
on-line instrument
engineering estimate
other (ple/se describe)
(1).
(1).
METEOROLOGICAL DATA
COMPUTER AIR MODELING
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-16-
EPA ATTACHMENT II
03/15/88 HCN RELEASE
26. a. Did any substances identified in Questions 24 and 25, migrate beyond
the legal boundaries of your facility (for example, a vapor release
was carried by prevailing wind beyond the fence line of your facility)?
(1) I xT Y*s Clf 7«*t please answer Question 26. b)
(2) Id Ko" (If no» skiP Question 26. b and answer Question 27)
b. In the table below specify the quantities of substances that migrated past
'your facility boundaries.
NAME MEDIA QCANTITY UNIT
Air MAXIMUM OF 30 LBS
1. HYDROCYANIC ACID VAPOR Surface Vater -0- LBS
Land -Q- LBS
Ground Water -0- LBS
Air -0- LBS
2. TTVDRnrvAMTr Arm T.Tnrrrn Surface Vater -Q- LBS
Land -0- LBS
Ground Vater -Q- J.RS
Air
3. Surface Vater .
Land '
Ground Vater
Air
Surface Vater
Land
Ground Vater
e. Please check the items below that describe your methods or source of
infcrsjiior. for your responses in Question 26.b.
{X1 physical prcperties and ambient conditions
[ ] observation
[ j on-line instrument
[ ] engineering estimate
other (please describe)
METEOROLOGICAL DATA
COMPUTER AIR MODELING
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-17-
EPA ATTACHMENT II
03/15/88 HCN RELEASE
27. Did injuries occur among facility employees as a result of the event?
[ 1 Yes
tx*j No
[ ] Don't know
*• If yes, please indicate number of injuries.
[ J [ 1 I ] I 1 I 1 M
[ ] Xuucbcr of injuries unknown
28. Did 'injuries occur among the general public as a result of the event?
[ ] Yes
PI No
I ] Don't know
a. If yes, please indicate number of injuries.
[][)[](] I 1 [ 1
[ ] Number of injuries unknown
29. Did deaths occur among facility employees as a result of the event?
I 1 Yes
'PI No
[ ] Don't know
a. If yes, please indicate number of deaths.
[ ] I ] [ ] M I 1 M
[ ] Nur.ber of deaths unknown
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-18-
EPA ATTACHMENT II
03/15/88 HCN RELEASE
30. Did deaths occur among the general public as a result of the event?
t } Yes
IxJ N'o
( ] Don't Know
a. If yes, please indicate number of deaths.
[][][][][](]
[ ] Number of deaths unknown
31. Did tnvirnniauntal effects occur as a result of the event?
[XJ No
| 1 Don't Know
a. If yrs. nlc.is- describe the impact.
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-19-
EPA ATTACHMENT II
'03/15/88 HCN RELEASE
SECTION III. CLEANUP AND PREVENTION PROFILE
32. Did yo«»r facility undertake cleanup of the release?
[ xj Yes (If yes, please answer Question 32)
I ] No ( If no, please answer Question 33)
33. Has cleanup of the release been completed?
txl Yes (If yes, please answer Questions 32.a and 32.b)
[ 1 No (If no, please answer Questions 32.a and 32.c)
a. Please supply the name and address of the party responsible for
cleanup.
William Pasko
(Name)
Technical Manager
(Title)
W. R. Grace & Co., Poisson Avenue
(Address)
Nashua, NH 03061
ICity. State)
(603 ) 888-2320
(Telephone)
b. Indicate the date cleanup activity ceased.
[0] [31 - [1] (5l ' [8] C8l
(month) (day) (year)
c. Please indicate the approximate date completion of cleanup activity is
expected.
I 1 [ 1 • I J I 1 ' I I I 1
(racr.ih) (day) (year)
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-20-
. EPA ATTACHMENT II
03/15/88 HCN RELEASE
Please describe the immediate response activities taken to contain or
minimize the release.
Please1 see Page 20A
35. As simply as possible, describe release prevention practices and policies
(backup systems, containment system, training programs) utilized at the
facility when the release occurred.
See response to Attachment 1, Questions 9, 10, 11.
36. Please indicate which of the prevention practices and policies listed in
Question 35, if any, were ineffective in preventing the release from
reaching th« environment.
NOME
37. Describe equipment repairs and/or replacements (management practices,
operational changes, etc.) made as a result of the release.
A new gasket was installed in the flange connection and «-h» ,,oeeQl
was then washed out with water. This was done so that all gaskets on
the vessel could be inspected and replaced as necessary.
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-20A-
EPA ATTACHMENT II
03/15/88 HCN RELEASE
34. The operator suspected there was a leak in the process vessel because the
instrument reading indicated a lesser quantity of hydrocyanic acid in the
vessel than there should have been. He informed the supervisor and the two
donned personal protective equipment to investigate.
When it was confirmed that there was a hydrocyanic acid leak, the on-site
emergency response teams were activated. A maintenance team was suited up
to assess and abate the leak.
The puddle of hydrocyanic acid crystallized upon exposure to the air and
evaporated.
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-21-
EPA ATTACHMENT II
03/15/88 HCN RELEASE
38. What additional preventative raeasura(s) will be taken to minimize- the
possibility of recurrence?
The process equipment design for this system has been
modified to eliminate-'the need for this process vessel.
-------
Appendix E
HC1 Release Profile
-------
-6-
EPA ATTACHMENT II
08/05/88 HC1 RELEASE
OMB H: 2050-0065
U.S. ENVIRONMENTAL PROTECTION AGENCY
RELEASE PREVENTION QUESTIONNAIRE
INITIAL REPORT
1. FACILITY XA.ME:
FACILITY ADDRESS:
3. KA.ME OF OWNER:
SECTION* 1. FACILITY PROFILE
W. R. GRACE & CO-CONN
. UKUANIC CHEMICAL DIVISION
POISSON AVE
NASHUA
N. H.
03061
Street
City
State
Zip Code
W. R. GRACE & CO-CONN
ADDRESS OF OVNER: GRACE PLAZA, 1114 AVENUE OF THE AMERICAS
RESPONDENT:
NEW YORK
Street
N. Y.
City
10036
State
Zip Cade
JEREMIAH B. MCCARTHY
PLANT MANAGER
POISSON AVE
NASHUA
N. H.
City
03061
State
Zip Code
(603) 888-2320
Telephone
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-7-
EPA ATTACHMENT II
08/05/88 HC1 RELEASE
Please indicate the year facility operations began.
II] [9] [5] 18]
7. Identify the four-digit Standard Industrial Classification (SIC) that best
describes your facility operations and the primary product or service of
this facility.
12] C8] 161 [9l
a. SIC code
b. Primary product or service: SPECIALTY CHEMICALS
8a. Check the item below that best describes the status of facility operations
at the time of release.
a. [X] In operation
b. I ] Temporarily inactive
c. f j Permanently closed
8b. Check the item below that best describes the current status of facility
operations.
«. I Xl In operation
b, [ ] Temporarily inactive
c. [ j Permanently closed
If Item a is. marked, go to Section II Hazardous Substance Release Profile.
If Item b or c is marked, answer Question 8.c. below.
8c. Is the shut down of operations at your facility related to the accidental
release of hazardous substances?
I 1 Yes
I J No
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•8-
EPA ATTACHMENT II
08/05/88 HC1 RELEASE
SECTION' II. HAZARDOUS SUBSTANCE RELEASE PROFILE
The fallowing section asks several questions
concerning the accidental release of hazardous
substances. If exact responses cannot be provided,
please provide estimates using your best
professional judgment.
9. Indicate the date release occurred.
lol tsl - (ol Is! - Isl
(month) (day) (year).
10. Indicate the time of d.iy release occurred.
tol Ul : (Ol
IXl A.M.
I 1 P.M-
11. Indicate date release ceased.
tOl 181 - tol l5l ' I8l fel
(month) fdayO (year)
12. Indicate time of day release ceased.
lOl til: I3l lol
[ j A.M.
tXl P.M.
NOTE: In identifying parties notified of the release, we have included
all officials known to Grace to have been notified. Notification
to some of the listed parties may have been made by other officials
originally notified by Grace.
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-9-
EPA ATTACHMENT II
08/05/88 HC1 RELEASE
23. Were federal authorities notified?
IX] Yes I 1 No
•. If yes. identify all federal authorities notified regarding the
release.
(If more than one, please attach list on separate page)
PAUL GROULX
(Name) US EPA
SERVICES DIVISION
(City)
MA. 02173
(State)
(617) 860-4300
(Telephone)
ADDITIONAL AGENCY NOTIFICATIONS: SEE ATTACHED
b. Indicate the date and time of day federal authorities were notified.
10] [8] - [01 [Si - 181 [8l
(month) (day) (year)
[Ol I7l • Ul Is! CTime)
[XJ A.M.
I 1 P.M.
14. Were state authorities notified?
the release.
a. If yes. identify *11 state authorities notified concerning
(If mere than one, pleise attach list on separate page)
JOHN GIFFORD _
(Naae) - N. H. UtFICK OF EMERGENCY MANAGEMENT
CONCORD
(City)
N. H. 03301
(State)
271-2231
(Telephone)
ADDITIONAL AGENCY NOTIFICATIONS: SEE ATTACHED
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ADDITIONAL AGENCY NOTIFICATBDNS: PAGE 9A (SEE #13a) - HC1 RELEASE' 08/05/88
FEDERAL
MS. KATHERINE DALY
US EPA
EMERGENCY RESPONSE TEAM
LEXINGTON MA 02173
617-860-4300
NOTIFICATION ON: 08/05/88
NOTIFICATION AT: 7:45 AM
MR TROUSDELL
NATIONAL RESPONSE CENTER
WASHINGTON DC 02003
1-800-424-8802
NOTIFICATION ON: 08/05/88
NOTIFICATION AT: 4:35 PM
PAUL O'CONNELL
US DEPARTMENT OF LABOR
CONCORD NH 03301
603-225-1629
NOTIFICATION ON 08/05/88
NOTIFICATION AT: Approx. 10:00 AM
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ADDITIONAL AGENCY NOTIFICATIONS: PAGE 9B (SEE #14a) - HC1 RELEASE - 08/05/88
STATE
MS KIM TAYLOR
NH AIR RESOURCES DIVISION
CONCORD NH 03302
603-271-1370
NOTIFICATION ON: 08/05/88
NOTIFICATION AT: 8:30 AM
MICHAEL GALUSKA
NH WASTE MANAGEMENT DIVISION
CONCORD NH 03301
603-271-2942
NOTIFICATION ON: 08/05/88
NOTIFICATION AT: 7:40 AM
NANCY KURSEWITZ
NH WATER SUPPLY AND POLLUTION CONTROL
CONCORD NH 03301
603-271-2457
NOTIFICATION ON: 08/05/88
NOTIFICATION AT: 11:35 AM
JOHN GREGOIRE
NH FIRE MARSHAL
CONCORD NH 03301
603-271-3294
NOTIFICATION ON: 08/05/88
NOTIFICATION AT 6:45 AM
DISPATCH
NH DEPARTMENT OF SAFETY
CONCORD NH 03301
1-800-852-3792
NOTIFICATION ON: 08/05/88
NOTIFICATION AT: 5:25 AM
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-10-
; EPA ATTACHMENT II
08/05/88 HC1 RELEASE
b. Indicate the date and time of day state .authorities were 'notified.
[01 [81 - fcl [51 - [81 [8J (Date)
(month) (day) (year)
[Ol [81 : t3l [41 (Time)
kl A.M.
[ J P..M.
15. Were local authorities notified?
[Xl Y«s I 1 No
a. If yes, identify all local authorities notified concerning the release.
(If more than one, please attach list on separate page)
RICHARD McCANN
(Name) NASHUA OFFICE OF EMERGENCY PREPAREDNESS
NASHUA
(City)
N. H. 03060
(State)
C603) 881-4300
(Telephone)
ADDITIONAL AGENCY NOTIFICATIONS: SEE ATTACHED
b. Indicate the date and time of day local authorities were notified.
IOJ [81 - [01 [51 - [81 [81 (Bate)
(month) (day) (year)
[Ol [5l : 111 [21 [111 (Time)
Id A.M.
I 1 P.M.
-------
ADDITIONAL AGENCY NOTIFICATIONS: PAGE 10 (SEE 15a) - HC1 RELEASE - 08/05/88
LOCAL
DISPATCH
NASHUA FIRE DEPARTMENT
NASHUA NH 03060
911
NOTIFICATION ON: 08/05/88
NOTIFICATION AT: 4:59 AM
DISPATCH
NASHUA POLICE DEPARTMENT
NASHUA NH 03060
911
NOTIFICATION ON: 08/05/88
NOTIFICATION AT: 4:59 AM
DISPATCH
HUDSON FIRE DEPARTMENT
HUDSON NH 03051
603-883-7707
NOTIFICATION ON: 08/05/88
NOTIFICATION AT: 5:00 AM
DISPATCH
HUDSON POLICE DEPARTMENT
HUDSON NH 03051
603-889-9090
NOTIFICATION ON: 08/05/88
NOTIFICATION AT: 5:00 AM
ROY WILLEY
HUDSON LEPC
HUDSON NH 03051
603-886-6000
NOTIFICATION ON: 08/05/88
NOTIFICATION AT: 8:40 AM
PAUL LARKAM
TYNGSBORO LEPC
TYNGSBORO MA 01879
617-649-7504
NOTIFICATION ON: 08/05/88
NOTIFICATION AT: 8:41 AM
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-11-
' EPA ATTACHMENT II
08/05/88 HC1 RELEASE
16. Was the general public notified?
flxl Yes [ ] No
a. If yes. indicate the person that notified the general public of
release.
(If more than one, please attach list on separate page)
ASST. FIRE CHIEF WILLIAM LYNCH
(Kane)
(Title)
NASHUA FIRE DEPARTMENT
(Company or Government pffice)
(603) 883-3353
(Telephone)
b. Indicate the date and time of day the general public was notified.
101 18] - [01 [5J - [81 [8J (Date)
(month) (day) (year)
I 01 [71 : [31 [5J (Time)
[E] A.M.
[ J P.M.
17. Were members of the general public evacuated?
Yes [ 1 No
a. If yes, please indicate number evacuated.
[0] [Ol lOl [21 [0] [Ol
b. Please indicate date and time of day evacuation began.
[Ol [81 - [OJ [51 - [8J [8J (Date)
(month) (day) (year)
[Ol [7] : [31 [51 (Time)
[Xl A.M.
[ 1 P.M.
JTODSON m
0 8 - n s
0 7 4 s AM 8 £8fte)
3500 PERSONS (Time5 (Approximately)
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-12-
; EPA ATTACHMENT II
•D8/05/88 HC1 RELEASE
16. To the best of your ability, indicate the weather conditions at the time
of release for each item below. Approximations are acceptable.
a. Vind Speed (miles per hour)
b. Vind Direction
DEWPOINT
c. JHOS05ISKSC (percent)
d. Temperature (Fahrenheit)
•"e. Precipitation?
I 1 to! Is!
SOUTH Isl IwJ
l6l I9l °F
[7U9J M
I 1 Yes bj No
19. Please check the one item below that best describes the location of the
release within your facility.
I X] Process vessel
[ ] Storage vessel
I ] Valves
[ ] Piping
{ ] Unknown
[ J Other (please describe)
(please check one item only)
20. Please check the one item below that best describes the operational
condition of releasing equipment at the time of the release.
[ ] Process startup
[ j Process shutdown
I ] Loading
[ ] Unloading
[ X] Batch operation
[ j Maintenance:
| j Continuing operations
[ j Unknown
[ ] Other (please describe)
(please check one item only)
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-13-
EPA ATTACHMENT tl
08/05/88 HC1 RELEASE
21. Please check the one item below that best describes Che primary cause of
the release event.
Equipment failure (please check one item only)
] Operator error
] Bypass condition
] Upset condition
1 Fire
] Unknown
j Other (Please describe)
22. Please check any itees below that describe additional causes of the
release event.
] Equipment failure (check as many items as apply)
J Operator error
j Bypass condition
] Upset condition
1 Fire
] Unknown
] Other (Please describe)
NONE.
23. Check the items below that describe the end effects of Che release event.
I ] Spill (check as many items as apply)
[X] Vapor release
[ ] Explosion
I 1 Fire
j ] Other (Plaase describe)
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-14-
EPA ATTACHMENT II
08/05/88 HC1 RELEASE
2i.a.
Icentify in the table below the name of each hazardous substance
released, the quantity released, and the concentration and physical
state at the time of release.
SAME QUANTITY
1. HYDROCHLORIC ACID 108 Ibs.
2.
3.
UNIT PHYSICAL STATE
VAPOR
CONCENTRATION
100%
b. Please check the items below that describe your methods or source of
information for your 'responses in Question 24. a.
[ ] on-line instrument
[ X] process records
[ X] engineering calculation
[ ] estimate
I xj other (please describe)
METEOROLOGICAL DATA
COMPUTER AIR MODELING
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-15-
ATTACHMENT II
08/05/88 HC1 RELEASE
15. a. In the table below, please estimate the quantity of substances listed is
Question 2^.a released to each media. Be sure to specify the
measurement unit.
NAME
1. HYDROCHLORIC ACID
MEDIA
Air
Surface Water
Land
Cround Water
QUANTITY
108 Ibs.
n 11^-
n TVLC
0 Ibs.
UNIT
2.
3.
Air
Surface Water
Land
Ground Water
Air
Surface Water
Land
Ground Water
Air
Surface Water
Land
Ground Water
Please, check the items below that describe your methods or source of
information for your responses in Question 25. a.
[ }
lx]
{ ]
[X]
physical properties
observation
on-line instrument
engineering estimate
other (please describe)
METEOROLOGICAL DATA
COMPUTER AIR MODELING
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-16-
EPA ATTACHMENT II
• 08/05/88 HC1 RELEASE
26. a. Did any substances identified in Questions 24 and 25, migrate beyond
the legal boundaries of your facility (for example, a vapor release
was carried by prevailing wind beyond the fence line of your facility)?
IxJ V«s (If yes, please answer Question 26. b)
I ] No (If no, skip Question 26. b and answer Question 27)
b. In the table below specify the quantities of substances that migrated past
"your facility boundaries.
NA!P SEPIA QUANTITY UNIT
Air 108 Ibs. MAXIMUM _
1. HYDROCHLORIC ACID Surface Vater Q -
Land 0
Ground Water p
Air
Surface Vater
Land
Ground Vater
Air
Surface Vater
Land
Ground Vater
Air
Surface Vater
Land
Ground Vater
c. Please check the items below that describe your methods or source of
ir.fcrsitior. for your responses in Question 26.b.
ixl physical properties and ambient conditions
j j observation
[ ] or.-line instrument
(XJ engineering estimate
(X] other (please describe)
METEOROLOGICAL DATA
COMPUTER AIR MODELING
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-17-
EPA ATTACHMENT II
"08/05/88 HC1 RELEASE
27. Did injuries occur among facility employees as a result of the event?
Yes
No
Don't know
*. If yes. please indicate number of injuries.
[ J [ 1 I 1 I 1 I I I 1
( ] Number of injuries unknown
28. Did 'injuries occur among the general public as a result of the event?
[ J Yes
I 1 No
| ] Don't know
ADDITIONAL INFORMATION ATTACHED
a. If yes, please indicate number of injuries.
M ( ] M ( 1 M M
( ] Number of injuries unknown
29. Did deaths occur among facility employees as a result of the event?
I 1 Yes
1X1 N°
( ] Don t know
a. If yes, please indicate number of deaths.
[](][][]()[]
[ } Nur.beT of deaths unknown
-------
ADDITIONAL INFORMATION: PAGE 17 (SEE #28) - HC1 RELEASE - 08/05/88
ALTHOUGH WE HAVE READ THE NEWSPAPER ACCOUNTS THAT PERSONS WERE TREATED AT
AREA HOSPITALS FOR THE POSSIBLE EFFECTS OF EXPOSURE TO THE VAPORS, WE ARE
UNABLE TO OBTAIN SPECIFIC INFORMATION ABOUT THESE POSSIBLE EXPOSURES, TO
CONTACT THESE PERSONS. PATIENT CONFIDENTIALITY REQUIREMENTS PREVENT THE
AREA HOSPITALS FROM DISCLOSING PATIENT NAMES.
INCIDENT REPORTS INDICATE THAT 51 PEOPLE WERE SEEN AT AREA HOSPITALS. OF
THESE, 50 PEOPLE WERE RELEASED IMMEDIATELY; ONE PERSON WAS KEPT OVERNIGHT
FOR OBSERVATION.
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-18-
EPA ATTACHMENT II
08/05/88 HC1 RELEASE
30. Did deaths occur among the general public as a result of the event?
I f Yes
[X] No
[ ] Don't Know
•. If yes, please indicate number of deaths.
[ 1 M I 1 M M ( 1
[ ] Number of deaths unknown
31. Did «savirnniaental effects occur as'a result of the event?
,
( ] Don t Know
a. If y*s. nlc.is« describe the impact.
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-19-
EPA ATTACHMENT II
08/05/88 HC1 RELEASE
SECTION III. CLEANUP AND PREVENTION PROFILE
32. Did your facility undertake cleanup of the release?
Jx] Yes (If yes, please answer Question 32)
I ] N'o ( If no, please answer Question 33)
33. Has cleanup of the release been completed?
(x] Yes (If yes, please answer Questions 32.a and 32.b)
[ ] No (If no, please answer Questions 32.a and 32.e)
a. Plc.ase supply the name and address of the pa'rty responsible for
cleanup.
William Pasko
(Name)
Technical Manager
(Title)
W. R. Grace & Company
(Address)
Poisson Avenue. Nashua. NH Q3Q61
£City, State)
(603) 888-2320 ___
(Telephone)
b. Indicate the date cleanup activity ceased.
1 01 1 81 - lol UJ - [8l
(.month) (day) (year)
c. Please indicate the approximate date completion of cleanup activity is
expected.
M M - M M - I 1 I 1
(mor.th) (day) (year)
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-20-
EPA ATTACHMENT II
08/05/88 HC1 RELEASE
Please describe the immediate response activities taken to contain or
minimize the release.
See Page 2QA, Section 34
35. As simply as possible, describe release prevention practices and policies
(backup systems, containment system, training programs) utilized at the
facility when the release occurred.
See reponse to Attachment I, Questions 9, 10, 11.
36. Please indicate which of the prevention practices and policies listed in
Question 35, if any, were ineffective in preventing the release from
reaching ih«t environment.
See Page. 20A, Section 36.
37. Describe equipment repairs and/or replacements (management practices,
operational changes, etc.) made as a result of the release.
See Page 20A, Section 37.
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20A
EPA ATTACHMENT II
08/05/88 HC1 RELEASE
34. When the operator detected a problem with the batch, he immediately shut
down the addition of raw material to the reactor vessel. The operator
notified the Production Supervisor who ordered the operator to begin to
cool the reactor. The on-site emergency response teams were activated.
Using the plant fire hose system, the two teams set up water sprays to
knock down the vapors.
36. The cooling of the reactor was effective in slowing down the release of the
escaping vapors; because of the volume of the batch, it is impossible to
immediately cool the batch to totally prevent the release of the vapors.
The water deluge of the area with facility fire hoses would have been
more successful if the fog nozzles were used instead of fire hose nozzles.
The emergency team was unable to properly seat the butterfly valve in the
atmospheric vent line on the reactor.. The failure of this valve has been
identified as the cause of the incident.
37. The first step implemented was the replacement of the 8" butterfly valve
with a new valve using Teflon as the material of construction for the
valve seat.
38. As a further precaution, we will implement changes which will allow the
scrubber to pull a vacuum on this reactor. Any slight vapor leaks,
therefore, will be into the reactor, rather than out to the atmosphere.
Finally, as part of this system, a vacuum gauge will be installed which
will indicate proper operation of the scrubber system and proper closure
and sealing of all valves in the reactor vent system.
We have begun a review of this and all other valves that vent to the
atmosphere to insure that all such valves are of the most suitable
materials of construction.
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-21-
EPA ATTACHMENT II
08/05/88 HC1 RELEASE
38. What additional preventative measure(s) will be taken to minimize the
possibility of recurrence?
See Page 20A Number ?qr
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