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

                                    iv

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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
                                  vii

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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.

                                  1-1

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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.
                                  1-2

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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.
                             1-3

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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.
                             1-4

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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;
                                  2-1

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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
                                  2-2

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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;
                                  2-3

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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.

                                  2-4

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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
                                 2-5

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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 78.3F at one
atmosphere.  The liquid is lighter than water (sp.gr. 0.688 at 68F) and
the vapor is slightly lighter than air (sp.gr. 0.947 at 88F).  The
flashpoint (ASTM-D56) is 0F 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
165F.  The liquid is denser  than water (sp.gr. 1.574 at 70F) and  the
vapor is much denser than air  (sp. gr. 4.75 at 70F).  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 32F) 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 72F.  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 46F  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

                                  6-8

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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.
                                 8-3

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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.
                                  8-4

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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.
                                 8-5

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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.

                                  8-6

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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

                                 8-7

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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.


                                  8-8

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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

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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

-------
        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

-------
     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

-------
     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

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                                                                                                                                                       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

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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

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         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

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                               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

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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

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                               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

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                               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

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                               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

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                               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

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                               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

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                               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 
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          Appendix C

Accidental Release Information
        Questionnaire

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                 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.

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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

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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

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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)

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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

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Answers to EPA Attachment I
Page 6
     Avenue, adjacent to the Merrimack River, at 4243I2.5"
     latitude  and  7126'19.6" 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)

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Answers to EPA Attachment I
Page 8
     8-2a Sodium Cyanide (CAS #143-33-9)

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Answers to EPA Attachment I
Page 9
     8-3a Ethylenedlamine (CAS #107-15-3)
     8-4a Hydrocyanic Acid (CAS  #74-90-8)

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Answers to EPA Attachment I
Page 10
     8-5a Sulfuric Acid (CAS #7664-93-9)
     8-6a Nitric Acid (CAS #7697-37-2)

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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)

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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 Pties 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 yor  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.

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     Appendix E






HC1 Release Profile

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                                     -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 Ys      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.

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 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

-------
                                      -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  Vs   (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

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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)

-------
                                      -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 iht  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	

-------