WATER POLLUTION CONTROL
     OIL & HAZARDOUS MATERIALS PROGRAM SERIES
OHM 7102 001
     Spill Prevention Techniques
     for Hazardous Polluting Substances
ENVIRONMENTAL PROTECTION AGENCY • WATER QUALITY OFFICE

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             SPILL PREVENTION TECHNIQUES
         FOR HAZARDOUS POLLUTING SUBSTANCES
  An Inventory and Survey of Hazardous Chemical Facilities in
Charleston, West Virginia; Baltimore, Maryland; Texas City, Texas;
          and the Suisun Bay-Delta Area, California

                    February 1971

                      Prepared by

                     J. L. Goodier
               J.I. Stevens, S. V. Margolin,
             W. V. Keary and J. R. McMahan

                  Arthur D. Little, Inc.
                Cambridge, Massachusetts

                under Contract 14-12-927

                         for

        ENVIRONMENTAL PROTECTION AGENCY
               WATER QUALITY OFFICE
    DIVISION OF OIL AND HAZARDOUS MATERIALS
                   Arlington, Virginia

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                          FOREWORD

     The need  for  this study  of spill prevention techniques for
 hazardous polluting substances was  established  by the recently en-
 acted Water Quality Improvement Act of 1970. The Division of Oil
 and Hazardous  Materials. Water Quality Office, Environmental Pro-
 tection Agency  determined that  a data  base of materials and tech-
 niques which  are used  to prevent discharges of hazardous polluting
 substances was needed.  It was determined that an appropriate means
 of  gathering  these  data would  be  to survey selected sites. Four
 geographically different areas were selected as a random sample to
 survey various industrial facilities and procedures designed to prevent
 spills of hazardous polluting substances.

     This prevention-oriented study was designed to complement the
 state-of-the-art  study  entitled, Control of Spillage  of Hazardous
 Polluting Substances and published  by  the Water Quality Office.
 Also, this study  was designed  to explore in greater detail and comple-
 ment publications  by  the U.S. Coast Guard entitled, Control  of
 Hazardous Polluting Substances and the Abstract of Proceedings of
 the Hazardous Polluting Substance Symposium.  The relationship of
 this prevention-oriented study to these previously published efforts
 has resulted in the documentation of existing procedures in consider-
 able detail, and  in recommendations  for the  prevention of spillage of
 hazardous polluting substances.

     It is reasonable to  expect that subsequent studies will  be made
 with reports prepared to illustrate new prevention and control  con-
 cepts, modified  monitoring and detecting techniques, new  counter-
 measure  or removal techniques and procedures, and the development
 of  detailed chemical, physical, and biological  testing procedures.
 These studies  will be designed  to  bridge gaps in the  availability of
information and technology  dealing  with the handling of discharges
of  hazardous  polluting  substances. This  prevention concept survey
 will constitute a basis for identification of areas of need in which the
 Federal Government and/or other capable bodies may respond  in a
 coordinated manner to  develop only those techniques and informa-
tion required to  minimize the dangers presented to the environment
by such discharges.

                       Dr. Hugh Thompson
                       The  Division of Oil  and  Hazardous Materials
                       Water Quality Office
                       Environmental Protection Agency
                       Arlington, Virginia
                              in

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                   TABLE OF CONTENTS

                                                    Page

List of Figures                                          vii

List of Tables                                            IX

  I.  SUMMARY                                        1
     A.  PURPOSE AND SCOPE OF STUDY                    1
     B.  FINDINGS                                     1
     C.  SUMMARY RECOMMENDATIONS                    3

 II.  INTRODUCTION                                   5
     A.  BACKGROUND                                 5
     B.  MODE OF SURVEY                              6

 III.  RECOMMENDATIONS FOR THE PREVENTION AND
     CONTROL OF SPILLS OF HAZARDOUS POLLUTING
     SUBSTANCES                                     9
     A.  BASIS FOR RECOMMENDATIONS                    9
     B.  SPILL PREVENTION RECOMMENDATIONS FOR
         HAZARDOUS POLLUTING SUBSTANCES              9

 IV.  SURVEY SITE OBSERVATIONS                        19
     A.  TE XAS CITY, TE XAS                            19
     B.  BALTIMORE, MARYLAND                        72
     C.  SUISUN BAY-DELTA, CALIFORNIA                 107
     D.  CHARLESTON, WEST VIRGINIA                    145


APPENDICES
     A.  INVENTORIES OF MAJOR TRANSPORT, TRANSFER,
         AND STORAGE FACILITIES INVOLVED IN HANDLING
         HAZARDOUS POLLUTING SUBSTANCES             187

     B.  SUMMARY OF PROPOSED REGULATIONS DESIGNATING
         HAZARDOUS SUBSTANCES                      203

     C.  INDUSTRIAL MUTUAL AID SYSTEM OF
         TEXAS CITY, TEXAS                           221

     D.  HANDLING OF CHEMICALSPILLS IN PUBLIC WATERS  269
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                TABLE OF CONTENTS (Continued)

                                                     Page

APPENDICES (Continued)
     E.  RESOLUTION NO. 68-65 - PRESCRIBING REQUIRE-
         MENTS FOR TWENTY-ONE WASTE DISCHARGES BY
         CALIFORNIA AND HAWAIIAN SUGAR COMPANY
         INTO CARQUINEZ STRAIT NEAR CROCKETT,
         CONTRA COSTA COUNTY                        275

     F.  INDUSTRIAL SPILLS AND HAZARD ALERT
         PROCEDURES                                 285
                          VI

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                           LIST OF FIGURES

Figure No.                                                         Page

    1      Area of Survey — Drainage Plan for the Industrial Area
           of Texas City, Texas                                      21

    2      Aerial View of Texas City Showing Location of Texas
           City Docks, Terminal Railway Company, and Monsanto
           Company Plants                                          23

    3      General Layout of GAF Corporation Property,
           Texas City, Texas                                        27

    4      Aerial View of Gulf Chemical and Metallurgical Corporation,
           Texas City, Texas                                        34

    5      Aerial View of Union Carbide Corporation Waste-Water
           Treatment Ponds Showing New Anaerobic Treatment Ponds
           under Construction in Foreground, Texas City, Texas         39

    6      Aerial View of Complete Union Carbide Corporation Facility,
           Texas City, Texas, Showing Adjacent Roads and Properties    41

    7      General Layout of Borden Chemical Company, Smith-
           Douglass Division, Texas City, Texas                        51

    8      Aerial View of Refining Division, Marathon Oil Company,
           Texas City, Texas                                        59

    9      General Layout of Texas City Refining Corporation,
           Texas City, Texas                                        65

    10      Topographical Survey of Texas City Refining Corporation
           Plant, Texas City, Texas, Showing Oil and Water Separator
           for  Plant Effluent                                        66

    11      Aerial View of Baltimore, Maryland, Harbor Showing
           General Location of Continental Oil Company               75

    12      Aerial View of Baltimore, Maryland, Harbor Showing General
           Location of Mutual Chrome, Allied Chemical Company Plant  92

    13      Aerial View of Baltimore, Maryland, Harbor Showing
           General Location of Procter & Gamble, National  Molasses,
           and Uniroyal Plants                                      101

    14      Aerial View of Procter & Gamble Plant, Baltimore, Maryland  102

    15      Area of Survey Conducted in Suisun Bay-Delta, California    108
                                  Vll

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                      LIST OF FIGURES (Continued)

Figure No.                                                          Page

    16     General Layout of California and Hawaiian Sugar Refining
           Corporation Properties, Crockett, California                  113

    17     General Layout of Johns-Manville Products Corporation Plant,
           Pittsburg, California                                       116

    18     Aerial View of Suisun Bay-Delta Area Showing General
           Location of Monsanto Company Plant, Avon, California       118

    19     Aerial View of Suisun Bay-Delta Showing General Location
           of Shell Oil Company Plant, Martinez, California              121

    20     Aerial View of Suisun Bay-Delta Area Showing General
           Location of Dow Chemical Company Plant, Pittsburg,
           California                                                131

    21     Aerial View of American Smelting and Refining Company,
           Set by, California                                          134

    22     Land Vfew of Industrial Chemical Division of Allied Chemical
           Corporation, Nichols, Cafifornia                            136

    23     Water View of Industrial Chemical Division of Allied Chemical
           Corporation, Nichols, California                            137

    24     Aerial View of Union Carbide Corporation, South Charleston,
           West Virginia                                             152

    25     Aerial View of Union Carbide Corporation, Institute,
           West Virginia                                             158

    26     Aerial View of Monsanto Chemical Company (left) and
           FMC Corporation Organics Plant (center), Nitro,
           West Virginia                                             171

    27     Aerial View of DuPont Plant, Belle, West Virginia             183
                                 vm

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                            LIST OF TABLES

Table No.                                                          Page

     1      Chemical Flow Through Texas City Terminal Railway
           Company Marine and Railroad Terminal - 1969              24

     2      GAP Corporation Bulk Storage Facilities                     29

     3      GAF Corporation Bulk Storage Facilities                     30

     4      Hazardous Material Listing of Monsanto Company,
           Texas City                                                37

     5      Chemicals and Plastics in use at Union Carbide Corpo-
           ration Plant, Texas City                                    42

     6      Storage Capacities for Chemical Compounds Handled at
           American Oil Company                                    47

     7      Hazardous Chemicals, Storage Capacities, and Transfer
           Rates at the Amoco Chemicals Corporation, Texas City        56

     8      Hazardous Chemicals Handled at Texas City Refining, Inc.      67

     9      Reported Oil and Other Spill Incidents in San Francisco
           Bay Region in 1968                                       110

   10      Reported Oil and Other Spill Incidents in San Francisco
           Bay Region in 1969                                       111

   11      Partial  Listing of Spills into the Kanawha River in the
           Charleston Area - 1965-1970                              147

   12      Hazardous Material Storage at Union Carbide Corporation,
           Institute and South Charleston, West Virginia                161

   13      Hazardous Material Storage at FMC Corporation, Inorganic
           Chemicals Division, South Charleston, West Virginia          168

   14      FMC Hazardous Material Storage at FMC Corporation,
           Organic Chemicals Division, Nitro, West Virginia              172

   15      Hazardous Material Storage at Monsanto Chemical Company,
           Nitro, West Virginia                                       180

   16      Hazardous Material Storage at E.I. du Pont, Belle,
           West Virginia                                             182
                                  IX

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                               I.  SUMMARY

A. PURPOSE AND SCOPE OF STUDY

     The Office of Oil and Hazardous Materials. Federal Water Quality Adminis-
tration, retained Arthur D. Little. Inc.. to develop an inventory* of major trans-
port, transfer, and storage facilities for hazardous polluting substances** at four
geographical locations in the United States.

     1.    Texas City, Texas,
     2.    Baltimore, Maryland,
     3.    Charleston. West Virginia, and
     4.    Various locations on the shorelines of San Pablo Bay and
          Suisun Bay, California;

From  these  inventories  strategic  facilities at each  geographical location were
selected to be surveyed. The plants were chosen with the assistance of the various
regional  offices  of  the  Federal Water  Quality Administration, and with the
assistance of the various state  agencies  responsible for the water quality of
state-owned and/or- controlled waters. In choosing survey sites, care was given to
selecting  plants that exposed  as  full a range of chemicals as possible, and to
gaining access to a representative cross section of the chemical industry.

     The study was designed  to investigate the "prevention" of hazardous mate-
rial spills, and to determine methods that would prevent such spills from entering
a  public  water  course,  thus  rendering  such bodies  of water temporarily or
permanently useless, or degrading the natural environment of the area.

B. FINDINGS

     It  was found that the  standards of the  American Petroleum Institute were
closely  followed when oil,  liquefied natural  gas, liquefied petroleum gas. and
petroleum were stored or processed. On this basis,  standards for the storage of
petroleum products have been established and adopted at most plant locations.
Storage tanks, retention dikes, and spill-control procedures showed little variation
at any of the geographical locations. The same cannot  be said  for the transporta-
tion, transfer, storage, and processing of hazardous polluting substances. Although
some of  the  larger companies have  established  in-house standards, and a few
municipal and state regulations to  control fire hazards are in effect, there are no
  *The inventory  of major transport, transfer, and storage facilities for hazardous polluting
   substances is presented in Appendix A.
 **The FWQA definition of hazardous polluting substances is given in Appendix B.
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 uniform industry-wide standards in the United States for storage tank construc-
 tion, secondary means of spill containment, or pipeline and hose positioning and
 testing. Design and protective measures vary considerably at each plant location.

     With few exceptions, the plants visited appeared to be making a concerted
 effort to prevent  spills,  for reasons  of pollution control, to prevent  loss of
 product, and  to maintain good public/customer relations. Considerable sums of
 money have been spent for waste-water treatment for continuous-flow discharges
 in an effort to meet the water quality standards established by the various state
 agencies, and  there is a continuing effort to improve many of these waste-water
 treatment procedures. The present trend appears to be toward the development of
 recycling effluent systems in which no waste-water discharges leave plant property
 and enter a public waterway.

     Present production and process methods throughout the United States create
 a great demand for copious quantities of water. One of the plants visited had a
 13,000,000  gallon-per-day (gpd) waste-water  discharge rate.  The cost of pro-
 ducing, handling, and treating this water represents a heavy financial burden to
 this firm. Consequently, almost any process or production modification that would
 reduce the water demand and handling and treating costs would be well received.
 Obviously spills of major proportions  would result in  an increase in the waste
 treatment load and could not be contained for any length of time by many of the
 plant properties. Another problem in handling and treating waste water is created
 by the extensive land acreage needed to accommodate  the  various treatment
 impoundments. Many of the plant photographs included in this report show that
 the waste-water acreage  frequently exceeds the acreage needed for production
 purposes.  At  some locations  private  organizations are providing  a service for .
 handling waste oil and spent chemicals. These concerns collect the waste material,
remove the solids, and later discharge the treated water into any convenient water
 course or into deep injection wells. One concern sprays the waste material onto
 the earth in a remotely located dump site, and then tills  the material into the
ground using  mechanized construction equipment. The results of this disposal
method can be best assessed following a  series of rainy seasons normal  to the
 State of California.

     At other locations  "satellite" chemical companies have  established them-
selves adjacent to large chemical processing plants. Their spent chemical wastes
are pumped into the recovery plant where the chemicals are extracted and the
waste  water  discharged  into  an open water  course.   At least one plant  has
established a  system of deep ocean disposal  in which  the spent chemicals are
barged  out to a deep-water, offshore disposal site. Such methods of disposal
warrant careful monitoring, however,  because off the coast of New York, for
example, large schools of  bluefish are attracted to the fringe of a spent acid
dump.
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     Most of the plant management were cooperative with our investigators, and
we  agreed to hold certain data on consumption and storage as "company con-
fidential."

C. SUMMARY RECOMMENDATIONS

     As a  result  of the various plant surveys and the investigators' general
knowledge of chemical spill prevention, a series of recommendations have been
developed  which,  if adopted,  should aid in  the prevention  of spills and  in
effectively reducing chemical spill damage. These recommendations are covered in
detail in Chapter  III  and  span the various phases of chemical handling  from
receiving to final shipment.
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                            II. INTRODUCTION

A.  BACKGROUND

     The fire  and explosion hazards  connected with the handling of petroleum
products have resulted in rigid regulations for the effective containment of such
materials. Although an accidental  spill  of  an oil-based  material can  be  easily
detected on the surface of a waterbody, the same is not true for  most  chemical
products, which are either water-soluble, or being heavier than water, sink and
settle on the bottom of the water course. In many cases  a chemical spill can be
more devastating to the natural ecology than an oil spill, resulting in extensive fish
kills (see introduction to appendixes).

     Methods  for treating, containing,  or  diluting chemical  spills are not so
advanced as those currently in service, or under development, for the control of
oil  spills. As  a result  the prevention  of  spills  is of paramount  importance.
Normally, the predominant causes of spills  can be determined by an analysis of
conditions relating to previous spills; they can easily  be  classified by  predomi-
nance and frequency, and the action  needed to prevent repetition of spills can be
accurately determined. Unfortunately, records and data on past chemical spills are
not  readily  available  at any of the usual sources - U.S. Coast  Guard, Federal
Water  Quality Administration, U.S.  Army  Corps of Engineers, or the  Water
Quality Control agencies of the various states. Most of the available information
on past spills record oil spills and slicks predominantly  since, as previously stated,
they are more  readily detected than the chemical spills.

     It is known  that many spills of  hazardous polluting substances occur  at
marine loading/unloading facilities due to defective flange connections, flexible
hose draining, and complete hose failure. Spills also occur at tank  truck and tank
car loading/unloading facilities. Buried tanks and buried pipelines, being prone to
metal deterioration from corrosion and electrolytic actions, have further contrib-
uted  to  chemical  spills  following   metal  failure.  Production  processes  have
"frothed" or "boiled" over to permit  the uncontrolled  escape of chemicals during
manufacture. The leaching action of rainwater on open stockpiles of materials,
stored at water-edge  locations,  has greatly  added to water contamination. The
chemical discoloration of the waterbodies is very apparent around such storage
areas in wet weather during aerial and marine surveys. Bulk storage tanks have
been overfilled, water draw  valves have been inadvertently left open, seams have
leaked, shell pinholes have developed, and in some spill cases, the contents of an
entire tank  have been spilled upon tank rupture. At least one tank  is known to
have suffered complete collapse.
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     One of the primary objectives of the study of spill prevention techniques for
hazardous polluting substances was  to  observe  industrial action being taken to
prevent and contain spills resulting from both mechanical and human failures. We
hope that the remedial action and precautions undertaken by some of the larger
chemical handling companies and their efforts to establish suitable spill control
standards and handling procedures will serve to alert industry nationwide to the
problems caused by the spilling of hazardous polluting substances.

B. MODE OF SURVEY

     To initiate the various surveys, taken as part of this study, our study team
contacted plant managers  directly — either  by telephone or a preliminary visit —
to arrange a  suitable date  and time for the conduct of the survey.  For national
organizations having one or more  plants  operating under  a remotely located
headquarters it  was frequently necessary to gain permission from the headquarters
to conduct the  survey. Such permissions were generally gained through the local
plant management. During the meeting, the  plant  representatives were given  a
letter of introduction  from  the  Regional  Office of the Federal Water Quality
Administration, which provided  a concise description of the purpose and objec-
tives of  the  survey.  Questions  directed to the  various investigators by plant
management served to elaborate on the contents of the letter.

     During these meetings pertinent data were obtained on the following factors

     (1)  Chemicals used in products —

         (a)  mode of receiving and shipping,

         (b)  methods of transfer,

         (c)  bulk storage facilities — number of  tanks and their
              capacities,  number of dikes,  dike drainage,  piping,
              valving and pumps, and so forth,

         (d)  basic production  process; curbing and/or trenching
              for spill containment;

     (2)  Plant drainage,  normal runoff, plant effluent, waste-water treatment,
         final discharge and geography of discharge;

     (3)  Past spill experience and methods introduced to remedy spill cause;

     (4)  Details on spill containment and cleanup plans in the event of a spill.
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     Once  out  in  the  plant  the  following  locations were visited to determine
physical conditions in each area:

     (1)  Marine loading/unloading area,
     (2)  Pipelines from dock to storage area,
     (3)  Bulk storage facilities (tank farm),
     (4)  Tank car unloading rack,
     (5)  Tank truck unloading rack,
     (6)  Production area,
     (7)  Effluent treatment impoundments  and final discharge,
     (8)  Central control station (if any), and
     (9)  Site of any past spills (if any) of sizeable proportion.

     Security measures at each location were carefully noted.

     In Texas most surveys were  made jointly with a representative of the Texas
Water Quality Control Board Regional Office in LaPorte, Texas.

     For the convenience of the reader, a glossary of terms and abbreviations has
been prepared to define uncommon words and abbreviations.
                     Glossary of Terms and Abbreviations
Terms
Boiler Slowdown Water
Water drained from the lowermost section of a boiler
for the removal  of precipitated/accumulated solids
(such water is generally contaminated by  chemicals
used to control scale buildup within the water and
steam section of a boiler)
Boom
a floating structure that can be positioned to enclose
and contain a floating spill of oil or hazardous mate-
rial
Crossed-Spring Lines
Fail-Safe
a line leading from the forward part of a marine vessel
aft to the pier, and a line leading from the aft part of
a vessel forward to the  pier; such lines prevent surge
by restraining the  vessel from moving ahead or astern
while moored alongside  a pier

a  mechanical and/or electrical device designed  to
counteract automatically the effect of an anticipated
source of failure
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 Gager
 'Panic Pond"
 Parapet
 Pickling Liquid
 Standoffs
 Treated Water


 Abbreviations

 API

 BOD

 DOT

 gpd

 ICC

 MCA

 mgd

MWP
 an individual  assigned to the task of monitoring the
 liquid level in  a bulk storage tank

 a large  emergency  pit  or pond to which effluent
 discharges can be diverted in the event of a spill

 a raised  curbing around a production area installed to
 confine  spill resulting from product "froth" or "boil-
 over"

 sulfuric  acid, caustic, and in some cases, muriatic acid
 contained in large vats or tanks used to remove mill
 scale from steel plates, pipes, etc., prior to painting
 same

 mechanical  legs or arms attached to a floating boom
 that  will hold the boom off a ship, barge, or  dock
 against the action of the tide, wind, or current

 plant  process water that has been  treated for the
 removal  of the bulk of chemical containments.
American Petroleum Institute
biological oxygen demand

Department of Transportation
gallons per day
Interstate Commerce Commission
Manufacturing Chemists Association
millions of gallons per day
maximum working pressure
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  III. RECOMMENDATIONS FOR THE PREVENTION AND CONTROL OF
           SPILLS OF HAZARDOUS POLLUTING SUBSTANCES

A. BASIS FOR RECOMMENDATIONS

     In this  chapter we present  a  series of recommendations which we believe
could be adopted  to decrease the danger of spills of hazardous polluting sub-
stances with  the resultant contamination of adjacent waterways. The recommen-
dations are.  in large measure, prompted by our plant survey visits, our observa-
tions of the  facilities, and discussions with operating personnel. We have written
these recommendations in light  of our knowledge of operating problems in the
industries represented and have taken account of histories of past problems with
which we are familiar.  Our intent is to present a working document which
indicates that some types of control are possible to prevent and contain effec-
tively spills of damaging proportions.

     It is probable, however, that  there are many specific spill problems which
were not observed during our surveys and are therefore not covered by specific
recommendations.  It  is also probable  that there are alternative solutions to the
problems posed. We do not consider our recommendations as mandatory; they are
offered only  as a guide toward spill prevention.

     One topic not adequately investigated is the problem associated  with the
diversity  of  types of materials handled.  Physical properties and  the  type of
hazard have  to be considered on a basis which takes this diversity into account.
A good approach for one material may be inadequate for another.

     One major factor that can  measureably  aid in  reducing human failure as a
prime cause  of spills would be fuller use of fail-safe devices which we found to be
quite adequate in some plants and entirely lacking in others.

B. SPILL PREVENTION RECOMMENDATIONS FOR
   HAZARDOUS POLLUTING SUBSTANCES

1. Spill Control

     Recommendations for the spill control of hazardous polluting substances are
listed below:

     a.   Whenever acids are maintained in bulk storage, an  adequate supply of
         neutralizing material, such as caustic, lime, or shell, should be available
         on the plant  property. The  neutralizing agent should be stored as
         closely as practical to the acid storage area and in sufficient quantity to
         neutralize the contents of the largest capacity of acid contained in any
         one storage tank.
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     b.   A supply of personal protective safety equipment, such as rubberized
          coveralls, rubber boots, safety goggles, gas masks, and rubber gloves
          should be maintained for immediate use in a centralized spill control
          location.

     c.    When  lighter-than-water chemicals are  handled and stored  within the
          plant, an adequate length of flotation spill-containment boom should
          be  available on the property,  along with a suitable vessel, to position
          the boom strategically and thus confine the spilled material.

     d.    Each  handler, transporter, or storer of hazardous  materials  should
          ascertain the chemical dispersants that have been approved by the state
          authorities, and an adequate  supply  of approved chemicals should be
          stored at the plant for the treatment of chemical spills.

2. Plant Drainage

     The following recommendations relative to plant drainage are also made:

     a.    Drainage from diked, hazardous-material storage areas should be valve-
          restrained to prevent a spill or other excessive leakage of a product into
          the drainage discharge or in-plant effluent treatment system.

     b.    Valves used for the drainage of diked areas should, as far as practical, be
          of manual, open-and-close design. The condition of the retained storm
          water  should be determined before drainage, especially if such drainage
          of impounded waters goes into water courses and not into waste-water
          treating plants.

     c.    All plant drainage systems, if possible, should flow into ponds, lagoons,
          OT catchment basins designed to retain materials less dense than water.
          Consideration should also be  given to  a possible chemical reaction, if
          spilled chemicals are commingled.

     d.    If plant drainage is  not engineered as above, the final discharge of all
          in-plant drainage ditches  should  be equipped with a diversion system
          that could, in  the event of an uncontrolled spill, be returned  to  the
          plant for treatment, the objective being to work toward a closed-cycle
          system.

     e.    Where drainage waters are chemically treated in more than one treat-
          ment  unit, natural hydraulic flow should be used. If pump transfer is
          needed, two "lift" pumps should be  provided, and at least one of the
          pumps should be permanently installed.
                                     10

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 3.  Marine Unloading-Load ing

      Relative to marine unloading/loading facilities, the following recommenda-
      tions arc made:

      a.   On at least an annual basis, all flexible hoselines should be subjected to
          hydrostatic testing. Inferior or discarded hoses should be removed from
          the dock area. Consideration should also be given to using hose lines
          with an outer strain relief braid or using metal-constructed, articulated-
          joint transfer lines.

      b.   When conditions  permit, all ships and barges loading or  unloading
          materials lighter than water should be effectively boomed in the area of
          material  transfer. When tide and current conditions warrant such  pro-
          tection,  "stand-offs" should be used to gain the fullest  containment
          efficiency of the floating boom.

     c.   Transfer  pumps and  flange connections should not be positioned di-
          rectly above the  water. When  practical, such facilities should be posi-
          tioned on  shore and  be confined  within a  suitable containment curb
          that will effectively contain material drips and spills.

     d.   All dock-mounted pumps and  pipeline connections should  have catch
          trays positioned under the potential leak area, and such trays should be
          emptied and cleaned following each material transfer.

     e.   Pressure-drop alarm and shut-off systems on  the lines leading from  the
          ship or barge should be provided so that losses from a line break will be
          held to a  minimum.*

     f.    Adequate mooring lines forward and aft and crossed-spring lines should
          be secured  to  all ships to  ensure a minimum of  movement during
          loading-unloading operations.

     g.    As far as practical, wooden decked docks with gaps between decking
          should  be  avoided as chemical spills  can  drip between the decking.
          Preferably,  full concrete or seawall-type marine loading-unloading facili-
          ties should  be used. Such dock areas should be equipped with perimeter
          containment curbs complete with valve-type drains  that can be opened
          to discharge rainwater and  be kept closed to contain  spills.
*McDermott, G.N., "Industrial Spill Control and Pollution Incident Prevention" (Procter &
 Gamble Company),   41st Annual Conference of the Water Pollution Control Federation,
 September 1968.

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    h.   Access to and from ships or barges should be such that the crews of the
         ships and/or barges have no occasion to pass in or around the loading/
         unloading control  area; fenced areas should guide persons safely away
         from the loading-unloading facility.

    i.    All  terminal flange connections on marine dock facilities should be
         blanked or capped  when not in service.

    j.    All  pump controls on marine docks should be secured in  the closed
         position or electrically isolated when not in service.

    k.   The practice of loading or unloading a barge or ship when such a barge
         or ship is tied outboard of another  ship should be avoided. The fueling
         or bunkering of a ship with the fueling barge tied  outboard of the other
         should be avoided. When practical, the fueling ship and the fueling
         barge should be secured directly to  the dock facility, using the marine
         terminal onshore  line  connections  to  transfer fuel  or hazardous pol-
         luting substances.

    1.   A direct line of communication, separate from  other in-plant or outside
         telephone lines,  should be  provided between  the  marine  loading/
         unloading facility and the immediate tank farm area.

    m.  "Slop" tanks should be provided at all marine  loading/unloading facili-
         ties to safely contain the products of flexible hose line draining and,
         when practical, to  contain polluted  bilge water discharged from visiting
         ships and barges.  Such tanks  should  be  installed  in  a fire-  and ex-
         plosion-proof  manner with  adequate  systems to prevent mixing  of
         dangerously incompatible materials.

    n.   For the prevention  of spills during flexible hoseline connection and
         disconnection, butterfly valves should be installed immediately adjacent
         to  the  terminal flange connection.  The  valves will  permit manual
         opening and  closing of the hoseline to retain  products that cannot be
         drained from the line after product transfer.

4. Tank Car and Tank Truck Loading/Unloading

    The following recommendations are made relative to tank car and tank truck
    loading/unloading procedures:

    a.   A system of containment curbs should be used  for tank truck unloading
         areas,  using ramps to provide truck access into the  confines of the
                                     12
                                                                       Arthur D Little Inc

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         containment curb.* The curb enclosure should be designed to hold at
         least  the  maximum  capacity  of any single tank truck loaded or un-
         loaded in the plant.

    b.   A trenching system should encompass each railroad tank car unloading
         area.  The  trench should be  designed  to  carry  away any spill to a
         catchment basin or holding pond,  at  least  equal  in  capacity to the
         capacity of the largest tank car loaded or unloaded in the plant.

    c.   As a fail-safe  precaution,  an interlocked warning light  or  physical
         barrier  system,  or  warning  signs,  should  be provided  in  loading/
         unloading areas to prevent vehicular departure before complete discon-
         nect of flexible or fixed transfer lines.

    d.   Prior to  filling  and  departure of  any tank car or tank truck, the
         lowermost  drain and  all outlets  of such vehicles should be  closely
         examined for leakage,  and if necessary,  tightened, adjusted, or replaced
         to prevent liquid leakage while in transit.

5.  Bulk Storage Tanks

    Relative to bulk storage tanks, the following recommendations are made:

    a.   No tank  should be used for the storage  of hazardous polluting sub-
         stances, unless its material  and construction are compatible with the
         material stored.

    b.   All hazardous material bulk storage tank installations should be planned
         so that a secondary means of containment is provided  for the entire
         contents of the largest single tank. Dikes,  containment curbs, and pits
         are commonly employed for this purpose, but they may not always be
         appropriate. An alternative system would consist of a complete drainage
         trench  enclosure arranged  so  that  the flow  could terminate and be
         safely confined in an in-plant catchment basin or holding pond. Drain-
         age into a storm drain or an effluent  discharge that  empties  into an
         open water  course, lake, or pond is acceptable, only after thorough
         analysis of the material ensures compliance with applicable water qual-
         ity standards.

    c.   Buried  hazardous material storage tanks represent a potential for unde-
         tected  spills. A buried installation, when required, should  be wrapped
         and coated to  retard corrosive action. In addition, the earth should be
'McDermott, G. N., op. cit.


                                     13
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     subjected to  electrolytic testing  to  determine if the tank  should be
     further shielded by a cathodic protection system. Such buried tanks
     should at least be subjected to regular hydrostatic testing. In lieu of the
     above, arrangements should be made to expose the outer shell of the
     tank for  external  examination at least every five years.  A means of
     conducting regular internal examinations of the tank at  five-year inter-
     vals should be provided (down-hole television, etc.).

d.    Partially buried tanks for the storage of hazardous materials should be
     avoided,  unless the  buried section of the shell is adequately coated,
     since partial burial in damp earth can cause rapid corrosion of metallic
     surfaces, especially at the earth/air interface.

e.    Above-ground tanks, depending on design (floating roof,  etc.), should
     be subjected  to integrity testing, either by hydrostatic testing, visual
     inspection, or by  a system of nondestructive shell thickness testing.
     When the latter system of integrity testing is used, comparison records
     of shell thickness reduction should be maintained.

f.    The foundation and/or supports of all bulk storage tanks should be
     subjected to at least annual examination by a person with  the technical
     competence to assess the condition of the foundation and/or supports.

g.    To control  hazardous  material leakage  through defective integral
     heating coils, the following factors should be considered and applied:

     (1)  The past life span of internal steam coils should be
          determined, and a  regular system of maintenance and
          replacement that does not exceed the anticipated life
          span should be established.

     (2)  To reduce failure from corrosive action, prolong life,
          and reduce replacement costs, the temperature and
          environment  have to be  carefully considered when
          selecting heating coil materials.

     (3)  The steam  return or  exhaust lines from  integral
          heating  coils which  discharge  into an  open-water
          course should  be  monitored  for  contamination,  or
          passed through a settling tank, or skimmer, etc.

     (4) The feasibility of installing an external heating system
          should also be considered.
                                  14

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h.   Each  hazardous material  bulk storage  tank should be externally ex-
     amined  at least  once a  month. Each  inspection  should  include  an
     examination of seams, rivets, nozzle connections, valves, and pipelines
     directly connected to the tank.

i.    New and  old tank installations should, as far as practical, be fail-safe
     engineered or updated into a fail-safe engineered installation. Consider-
     ation should be given to providing the following devices:

     (1) High liquid-level  bell or horn  alarms  with an audio
         signal at a constantly manned  operating or listening
         station;  in smaller  plants an  audible  air vent may
         suffice;

     (2) Low  liquid-level  alarms  with  an  audio signal at a
         constantly  manned  operating  or listening station;
         such  alarms  should have a nonbypassing reset  device
         that  can be  readjusted  to  a  given operating level
         following tank fill or  liquid removal;

     (3) High liquid-level  pump cutoff devices set to stop flow
         at a predetermined tank-content level;

     (4) Direct audible or code signal communication between
         the tank gagerand the pumping station;

     (5) At least one fast response system for determining the
         liquid level of each bulk storage tank such as  digital
         computers, telepulse, or direct vision gages.

j.    "Normal" plant effluent should be constantly monitored by a proven
     monitoring system, and  any deviation from normal  should  be engi-
     neered to  activate a visible readout recorder with an audible alarm that
     can be  heard at a constantly manned operating or  listening station. If
     practical, the monitoring device should be designed  to operate  a bypass
     to release the effluent discharge into a "panic" or holding pond;

k.   Visible  product leaks from  tank  seams and rivets should be promptly
     corrected.

1.    Tanks should not be used  with the knowledge that the "head" or "top"
     is  in a  corroded-through  condition. Action should be taken  to  drain
     such tanks and repair the defective member as promptly as possible.
                                 15

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     m.  When  practical, each bulk  storage tank  should  be lettered (code or
         otherwise) or color-coded to indicate its chemical content, the MCA or
         DOT coding being preferred, and the coding should duplicate those used
         for chemical transportation identification.

     n.   The surveys revealed a  number of cases (3) in which chemicals were
         spilled due to failure of wooden stave-constructed tanks. Under the
         circumstances, the  use of wooden tanks should be confined to water
         storage and should be avoided for liquid chemical storage.

6.  Pump and In-Plant Process and Transfer Pipelines

     Recommendations for pump and  in-plant process and  transfer pipelines are
as follows:

     a.   Each product pipeline should be  clearly marked by lettering (coded or
         otherwise), color banding, or  complete color coding to indicate the
         product transferred therein. The coding should conform with company
         policy  or standard  plant practice which, in turn, should conform with
         state or federal requirements.

     b.   Each hazardous material product-fill line which enters a tank below the
         liquid  level should have a one-way flow check valve located as closely as
         possible to the bulk storage tank. In addition  to confining the product
         to the tank, in the  event of valve or pipeline failure, the check valve
         should permit  overhaul of the main  shut-off  valve and should  aid in
         preventing shock loading of the pipeline and valves from a "slug" of the
         tank content caused by backflow into an empty fill line. As far as
         practical,  the product flow in suction lines should be controlled by use
         of a positive displacement pump.

     c.   Buried pipelines  should  be avoided.  However,  buried  installations
         should have a  protective wrapping and coating and should be cathod-
         ically protected if soil conditions warrant. A section of the line should
         be exposed and inspected annually. This action should be recycled until
         the entire  line has  been  exposed and examined on a regularly estab-
         lished  frequency. An alternative would be  the more  frequent use of
         exposable pipe corridors or galleries.

     d.   When a pipeline is not in service, the terminal connection at the transfer
         point should be capped or blank-flanged.
                                     16

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     e.   Wood to metal should be avoided as a pipeline support since it is apt to
         retain moisture and cause pipeline corrosion which, when coupled with
         the abrasive  action caused by the  pulsating action of the line, could
         cause line  failure with resulting  leakage.  Supports should be  designed
         with  only a minimum  point of surface contact  that allow for  the
         pulsating  movement  (expansion and contraction)  of the line (i.e.,
         rollers).

     f.   All above-ground valves and  pipelines should be subjected to a regular
         monthly inspection at which time the general condition of items, such
         as flange joints, valve glands  and bodies, catch trays, pipeline supports,
         locking of valves, and metal surfaces, should be assessed.

     g.   Elevated pipelines should be subjected to constant review to ensure that
         the vehicular traffic granted plant entry does not exceed the lowermost
         height of the  elevated line;  gate check-in  and in-plant travel  routes
         warrant attention in this respect.

     h.   As far as practical, all hazardous material pumps should be located as
         close as possible to the storage tank.

     i.   Flapper-type drain valves should  not be used to drain diked areas. Such
         drain valves  should be  of manual  open and close design,  and  they
         should be  kept in the closed position  when not in service. The drain
         lines from  diked areas should drain directly or indirectly into treatment
         or holding tanks or ponds or catchment basins.

7. Security

     Relative to security, the following recommendations are made:

     a.   All plants handling, processing, and  storing hazardous  materials  should
         be  fully fenced, and  entrance gates should be  locked and/or guarded
         when the plant is not in production or is unattended.

     b.   The master flow and  drain valves and any other valves that will  permit
         direct outward flow of the tank's content should be securely locked in
         the closed position when not in use.

     c.   The starter control on all hazardous material pumps should be secured
         or electrically isolated in the "off" position when the pumps are in a
         nonoperating status.
                                     17

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d.   The terminal loading/unloading connections of all hazardous material
     product pipelines should be securely capped or blank-flanged when not
     in service.
     Note: This security practice should also  apply to  pipelines  that are
     emptied of liquid content either by draining or by inert gas pressure.
                                18

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                    IV.  SURVEY SITE OBSERVATIONS

A.  TEXAS CITY, TEXAS

     Texas City is located on Galveston Bay, 15 miles north of Galveston Island
and 35 miles southeast of Houston, Texas. It has experienced a constant growth
in population, having increased from 5,749 recorded in the official census of 1940
to an estimated  population  high of 42,400 in 1969. The city is heavily indus-
trialized in the production of petroleum and chemical products.

1. Transportation

     In addition  to having a  deep water port (36 feet) channel, the city is served
by  the Texas City Terminal  Railway Company, which has daily connections with
the Gulf, Colorado & Santa Fe Railway Company,  the Missouri-Kansas-Texas
Railway  Company of Pacific Railroad, and the Fort Worth & Denver Railroad.
Central  Freight lines,  a motor freight carrier, has trucks and warehousing which
also services Texas City.

2. Drainage

     Charles R. Haile Associates, Inc., Consulting Engineers, Texas City, reported
in 1968  that water drainage in a 2100-acre industrial area was generally poor.
These findings were later substantiated by Arthur D. Little,  Inc., observations
during the period  August 20, 1970 through September 3, 1970 and especially
during a moderate two-day rainfall of September 2-3, 1970.

     The low  coastal area has been prone to flooding during heavy  rains, high
tides, and especially during storms of offshore origin. On July 27, 1943, the city
was exposed to a hurricane  that resulted in gust wind forces of 104 mph and a
rainfall of 17.3 inches in 39 hours. The U.S. Army Corps of Engineers is in the
process  of completing a 5-mile long  levee/dike to protect the land area from
inundation. The  city's greatest disaster occurred on April 16-17, 1947, when a
merchant ship's cargo of ammonium nitrate fertilizer caught fire and eventually
exploded, causing a second  ship to explode, and  complete devastation of the
commercial waterfront. The  explosions killed 576 persons and effected property
damage  in  excess of  $67 million.  Some 4000 persons were  also injured. The
industrial area suffered extensive damage from in-plant fires and explosions. The
extent of damage diminished with  distance from the  waterfront, but witnesses
reported  "shrapnel" damage  to oil and chemical bulk storage tanks as far as two
miles from "ground zero."

    The water quality control problem in Texas City results from the fact that,
even though all plants in  the area  are making a serious effort to meet the state


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water quality standards, the continuous effluent discharges and most spills termi-
nate in the same water body. The situation is such that once in the public water
course the chemical discharges  are cumulative. Tidal  flushing is comparatively
minimal and could not carry the pollutants effectively out into the Gulf,

     A hurricane situation with resulting heavy  rains and  flooding could also
overflow the waste water treatment ponds to create a "massive" spill.

     Figure 1 depicts the area of the Texas City survey.
                                      20

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  ;
>
»

                                                                           j   V TERMINAL RY. CO. BARGE C^NAJ
                                  FIGURE 1   AREA OF SURVEY-DRAINAGE PLAN FOR THE INDUSTRIAL AREA

                                            OF TEXAS CITY, TEXAS

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Texas City Terminal Railway Company
East Galveston Highway
Texas City, Texas

Contacts:    Mr. K. L. DeMart, Auditor-Assistant Secretary
            and Assistant to General Manager
            Mr. D. M. Holbrook, Harbor Master

Date of Survey:  August 24, 1970

Property Description

     This company controls extensive waterfront acreage on the Texas City Ship
Channel. The channel connects the main dock area and  a  barge canal with
Galveston Bay and  the  Gulf  of Mexico. The property also accommodates a
railroad marshalling  yard.  Since  its establishment in  1893 the company has
provided railroad switching facilities and has managed the deep water port for the
various industries in and  adjacent to Texas City. The terminal's drainage system
utilizes three outfalls, all ultimately emptying into Galveston Bay and San Jacinto
Bay, while  one  of the three  first empties into the Terminal  Barge Canal. The
normal effluent  discharge  averages  3,150gpd, which  is classified as domestic
sewage and waste  from a  locomotive service pit. The latter passes through an
oil/water separator prior to discharge  into the drainage ditches that cross the
property. Figures 1 and 2 provide an overall view of the land and waterfront area
controlled by the Texas City Terminal Railway Company.

Hazardous Chemicals

     A total of 33,952,046 bbls. of chemicals were handled in and out  of the
terminal during  1969. A complete breakdown of chemicals by name was not
available, since the practice of categorizing chemicals by name and quantity was
abandoned  some  years ago due to the  numerous "trade  names"  that have
developed in recent years. During 1969 the transportation media were as follows:

              Barges                       6,664
              Steam and Motor Ships         536
                                           7,200 Marine Total

              Box and Tank Cars           25,5 5 6
               (in and out)

 A  generalized inventory  of chemicals handled through the terminal in 1969 is
 provided in Table 1.
                                     22

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                                    Photo Courtesy of U.S. Geological Survey
FIGURE 2  AERIAL VIEW OF TEXAS CITY SHOWING LOCATION OF TEXAS
          CITY DOCKS, TERMINAL RAILWAY COMPANY, AND MONSANTO
          COMPANY PLANTS
                              23
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                                     TABLE 1
     CHEMICAL FLOW THROUGH TEXAS CITY TERMINAL RAILWAY COMPANY
                   MARINE AND RAILROAD TERMINAL - 1969
Company


Union Carbide Corporation

Stauffer Chemical

Monsanto Company

Borden Chemical

Amoco Chemical

American Oil Company

Gulf Chemical

Fallen Chemical

American Mineral Spirits

Diamond Shamrock Corp.

Southern Towing

Chotin Trans. Company

Thomas Pet. Trans.

Jefferson Chemical

Houston Chemical

American Mineral

Texas Transport & Terminal

En jay Chemical Company

Shell Chemical

H.E. Schurig  & Company
Hydrochloric
   Acid
   (bbls)
15,722.82
  Chemicals
    (bbls)

 19,994,712.25
778,724,774



414,291.660

 73,163,879



  8,378,810

  4,805,846

  6,865,082

  2,904,000

  1,560,000

  3,671,872

  2,044,600

  1,378,000

  1,865,146

    704,142

  1,621,850

  4,527,984

    704,076
Sulfuric
Acid
(bbls)
                                78,229,000
Phosphatic
 Fertilizer
 Solution
  (bbls)
                                              8,720,400
                                      24
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Bulk Storage Facilities and Pipelines

     The "terminal" owns no bulk storage tanks, and the various pipelines that
cross the property are all owned and maintained by the various chemical plants in
the area.

Past Spill Experience

     There is no record  of a major chemical spill at this location. Some minor
spills have been experienced and fast cleanup has been exercised under  the
supervision of the Harbor Master, who maintains a considerable length of floating
boom and a quantity of dispersal chemicals.

Spill Control Plan

     The Harbor Master, a well trained and competent individual, has complete
control over spill  prevention, containment, and  cleanup on the terminal. In
addition, the Texas City Terminal Railway Company is actively involved in the
Texas  City Mutual  Aid  Plan.  Even though this plan is engineered toward the
control of fire-  and explosion-type disasters, it could be utilized to combat  a
major  spill of oil or hazardous chemicals. The Texas City Industrial Mutual Aid
Manual (dated April 1964, revised August 1965) is reproduced as Appendix C.
                                      25

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GAP Corporation
P.O. Box 2141, Hwy. 146W
Texas City

Contact:    Mr. F. E. Wetherill, Plant Manager

Date of Survey:  August 25, 1970

Property Description

     This is a comparatively new plant (1967) that produces various chemicals
and polymers from high-pressure acetylene chemistry. Ultimate products are given
as follows:

          1,4-butanediol
         Butanediol
         Butyrolacetone
         Polyvinyl pyrrolidone
         Polyvinyl pyrrolidone - vinyl acetate copolymers
         2-pyrrolidone
         Vinyl pyrrolidone

The plant is situated well north of Texas City in open land quite clear from urban
or other industrial development. Figure 3  provides a schematic view of the plant
property. The plant effluent drainage discharge is monitored as 380,000 gpd; the
material drains through an open trench  into  Moses Bayou, Moses  Lake, Dollar
Bay, and finally into Galveston Bay and San Jacinto Bay.

     In-plant effluent treatment consists of an oil  skimmer, and two neutralizing
ponds (a 3-day  capacity holding basin, plus a 7-day emergency, or impounding,
pond) that can  be used for in-plant confinement of a chemical spill. Additional
facilities include a deep-sea disposal system whereby barges are used to transport
50,000 tpy* of waste chemicals (1400  tons per barge  trip) into a deep-water
disposal area (400 fathoms)  125 miles offshore into the Gulf of Mexico. Offshore
waste disposal averages 1  to 3  barge  loads a week with each barge  transporting
400,000 gallons of spent material.  The waste  consists  of a by-product  of
 herbicide rated  as:  2,5-dichloro-6-nitrobenzoic acid, sodium  salt, 9% sodium sul-
 fate, 5%; and water 86%.

      The plant also utilizes a deep injection well for waste disposal. Plant officials
 believe that they can effectively confine any  major chemical spill to the in-plant
 waste treatment facilities.
 *Tons per year
                                      26

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to
--J
a@OO     Sub Station

Paraeymene

Well Water

     I  I Cooling  Tower
                              FIGURE 3  GENERAL LAYOUT OF GAP CORPORATION PROPERTY, TEXAS CITY, TEXAS

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Hazardous Materials

     The  plant's  annual consumption is  company confidential; however, bulk
storage  capacities for all  chemicals  are  given in Tables 2 and 3.

Bulk Storage Facilities and Pipelines

     All tanks and pipelines were new in 1967.  There is a regular maintenance
schedule of internal examination and nondestructive shell thickness testing, and
all tanks exceeding 15 psi MWP are subjected to  hydrostatic testing. Production
tanks and tanks  likely to overfill and overflow have  curb enclosures for spill
containment. All pipelines are above-ground and hazardous materials are color-
coded. Two small gasoline storage tanks and one 500-gal. diesel oil storage tank
are buried installations. The tanks have protective coatings  and cathodic protec-
tion. The  plant has no bulk storage of solid materials. Most chemical materials are
received and shipped by tank cars and tank wagons of common carriers.

Past Spill Experience

     During the spring of 1970 there was a spill of 1000 gallons of nitrating acid,
i.e.,  a mixture of nitric acid and sulfuric acid. The spill, caused by a flexible hose
line  breaking, was effectively confined within the in-plant  drainage ditches and
holding ponds.

Spill Control Plan

     The plant operates on a 7-day week, 24-hour day basis with a minimum of
two  supervisors on  duty.  Each supervisor has complete jurisdiction over spill
control, containment, and clean-up. There is a special plan in effect to control
chlorine spills, and chlorine gas masks are carried in the chlorine tank car storage
area at all times. The plant is an active member of  the Texas City Industrial
Mutual Aid  Plan (Appendix C).
                                     28

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                                    TABLE 2
                 GAP CORPORATION BULK STORAGE FACILITIES

                               Acetylene Chemicals
1.4-butynediol-35%
Propargyl alcohol - 100%
1,4-butanediol-35%
1,4-butanediol - 100%
7-butyrolactone - 100%
2-pyrrolidone - 100%
N-methyl-2-pyrrolidone - 100%
N-vinyl-pyrrolidone - 80/100%
Polymer and copolymer solutions
Formaldehyde - 30%
Anhydrous ammonia
Vinyl acetate
Ethanol
Propane
n-butanol
p-cymene
Assorted organic waste mixture
Storage Capacity
     (gals.)
    560,000
     30,000
    230,000
    200,000
     60,000
     90,000
     100,000
     34,500
     15,000
    400,000
     30,000
     15,000
     15,000
     15,000
     15,000
       5,000
     30,000
                                                    Total
   1,844,500
                                      29
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                                      TABLE 3
                    GAP CORPORATION BULK STORAGE FACILITIES


                                 Herbicide Chemicals
                                                              Storage Capacity
                                                                   (gals.)
Benzoyl chloride                                                    50,000
Dichlor benzoyI chloride                                            140,000
Sulfuric acid - 94%                                                  65,000
Sutfuric acid - 50%                                                 100,000
Hydrochloric acid - 32%                                            100,000
Mixed nitric/su If uric acid                                             50,000
Caustic soda - 50%                                                  65,000
Dichlorbenzoic acid                                                  10,000
Dinitrochlorbenzoic acid                                              35,000
Amiben (chloramben)                                               180,000
Note: In addition, varying quantities of liquid chlorine are stored in railroad tank cars on a
      remotely located sidetrack.
Propane                                                            15,000
                                        30
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Gulf Chemical & Metallurgical Corporation
Hwy. FM519
Texas City

Contacts:    Mr. E. B. King, President
            Mr. R. C. Barr, Executive Vice President

Date of Survey:  August 25,1970

Property Description:

     This is an electrolytic tin refining plant (Figure 4) originally built by the U.S.
Government in 1941  to meet the demand  for tin during  World War II. The
refinery had a number of operators and owners until acquired by  the present
owners in  1968. The original tin processing methods have changed over the years,
and  many  of the original production buildings  are  now  derelict  and  in  an
advanced state of decay. The operational buildings, however, appear well main-
tained. The  plant produces 400 long tons of tin in ingot form each  month. For
the past  five  years the smelter  has  been processing low  grade Bolivian  tin
concentrates and some domestic secondary tin residues.

     A recent plant report  indicates that for the monthly production of 400 long
tons of tin, the plant consumed in all departments,  excluding the electrolytic
section, the following amounts of reagents:
           Coal (79.4% fixed carbon)
           Limestone (53.5% CaO)
           Machine shop turnings
           Natural gas (1000 Btu/MCF)
           Water (from wells)
           Power
           Hydrochloric acid (20°Be)
           Sulfur
           Flake sodium hydroxide
           Aluminum ingots
           Sawdust chips
           Sodium carbonate
 328.1 short tons
 104.9 short tons
  26.3 short tons
  47.814MCF
  21.75 million gals.
 630,430 kwh
  1330 short tons
  200 Ibs
  600 Ibs
  550 Ibs
  150 Ibs
35,500 Ibs
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The  plant water drainage system entails three open-ditch outlets that flow into
Swan Lake and thence into Galveston Bay. Flow rates are rated as follows:

         Outfall            Average Rates          Maximum Rate
                               (gpm*)

            1                     75                     150
            2                     45                       90
            3                     60                     120

The  discharge  involves waste solution  from the tin leaching process. The waste-
water treatment section of the plant has an  area of 70 acres which  includes
settling and  flocculation  processes for solid removal, neutralization of acids, and
discharge to further settling and evaporation ponds following which the clear,
neutralized water can be drained through an open ditch system into Swan Lake
(Figure 1).

Hazardous Chemicals

     1.   Hydrochloric acid - 50,000 tpy, 500,000-gal. bulk stor-
         age capacity; received by marine barge and tank truck;

     2.   Liquid caustic sodium  hydroxide  —   10,000 gpm**,
         10,000-gal. bulk storage capacity; trucked into plant

     3.   Liquid ammonium chloride - 10,000 gpm**, 20,000-gal.
         bulk storage capacity; trucked into plant;

     4.   Liquid sodium hydrosulfide — 20,000 gpy, 6000-gal. bulk
         storage capacity; trucked into plant;

     5.    Ferric chloride -  manufactured within the plant to meet
         production needs; 20,000-gal. bulk storage capacity.

     6.   Dry  soda ash — 50-ton bulk storage capacity tank, trucked
         into plant, air unloaded;

     7,  Limestone (crushed oyster shell) —  received by rail and
         truck; 2 to 3 tons on hand at all times;
 "gallons per minute
 ''gallons per month
                                     32

                                                                       Arthur DLittklnc

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     8.   Rock sulfur - 10-ton open storage;

     9.   Calcium chloride  — two 15,000-gal. storage tanks; con-
         sumption varying to a maximum of 30,000 gpm.*

Bulk Storage Facilities and Pipelines

     The plant tanks are old, and following a recent  tank failure, a system of
annual hydrostatic testing  was introduced. Major  storage tanks  were hydro-
statically tested  during August 1970, and  four tanks have  been subjected to
extensive repair.  All tanks and pipelines (except those passing through retaining
walls) are above-ground, exposed installations.

Past Spill Experience

     The plant had a 55,000-gal. spill of hydrochloric acid in July 1970. The spill,
which resulted from  the  failure of a bulk storage  tank, was drained  into the
in-plant settling and treatment ponds. The plant management claims that none of
the acid escaped into the water course.

     The Texas Water Quality Board claims that effluent samples from this plant
contain  excessive quantities of iron. The samples were recovered from a commu-
nal drainage ditch, but the smelting plant emphatically denies being  the source of
the iron pollutant.

Spill Control Plan

     On the basis of the plant's claimed ability to confine all spills safely to the
in-plant treating area, spill control is left to departmental supervisors,  who can
gain top management assistance  when warranted. The  plant is an active member
of the Texas City Industrial Aid Program.
 gallons per month
                                     33

                                                                        Arthur D Little Inc

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                                                                         Photo Courtesy of U.S. Geological Survey
FIGURE  4   AERIAL VIEW OF GULF CHEMICAL AND METALLURGICAL CORPORATION, TEXAS CITY, TEXAS

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Monsanto Company
201 Bay Street S.
Texas City, Texas

Contacts:    Mr. R. V. Butz, Plant Manager
            Mr. E. Hendricks, Manager, Environmental Control

Date of Survey:  August 27,1970

Property Description:

     Monsanto began operations in Texas City in 1943. The concern produces
numerous chemicals, plastics, and  petrochemical products for  varied industries;
however, the final products are reported to be:

            •   Styrene monomer,
            •   Methanol,
            •   Acetic acid,
            •   Ethylbenzene, and
            •   Phthalate esters.

     The plant (Figure 2) is in the  process of constructing a new 45-foot channel
and ship/barge facility that is probably one of the most modern and automated in
the nation. The new marine facility has  15 line connections, a parapet to contain
spills, nitrogen-cleared  hoses and lines, a remotely controlled hose-handling sys-
tem, direct  telephone communication with all tank gagers, and an elaborate
"slop" tank system for line draining.

     Most of Monsanto's drainage  now  passes into a disposal  pit for non-toxic
sludges, principally  CaSO4 (gypsum), calcium  formate,  and untreated lime. All
material is recovered from the pit and returned  to the plant for further treatment.

     The pit is located on a 12-acre tract, 0.5 mile south of Swan Lake. The solid
effluent is rated at 150 tpd, and since this newly established treatment system has
been installed, there is no effluent discharge.

Hazardous Materials

     The plant receives and ships materials by train and tank truck; however, 75%
of the  materials  are moved in and out through the plant's ship  and barge docks.
Table 4 lists  the chemicals handled and provides information  on marine ship-
ments. Bulk storage capacities, chemical production and consumption, photos and
schematic plans of the plant are considered to  be company confidential informa-
tion and are not available for outside publication.
                                     35

                                                                       Arthur D Littk Inc

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Bulk Storage Facilities and Pipeline

     All storage  tanks are above-ground installations  with diking adequate to
contain the entire  capacity of each tank. Tank pits and diked areas have valve-
controlled drainage lines  to permit removal of uncontaminated rainfall collec-
tions.  The tanks are equipped with remote, liquid-level recorders that indicate
tank levels in a control room  24 hours a day.  Non-destructive thickness testing
(audiogage)*  of  tank  tap and shells is done  on a recycling six-month  basis.
Flammable  tanks are blanketed  with nitrogen, and  high-liquid level alarms are
mounted on "critical" tanks, chlorine, and so forth.

     Pipelines are 90% exposed above ground,  and a system of cathodic protec-
tion with isolated flanges for buried lines has been  introduced over the past
 10 years.

Past Spill Experience

     The  State and the U.S. Coast Guard have  no record of past spills involving
hazardous materials at Monsanto, and the plant has no record of any significant
spills from loading-unloading operations.

Spill Control Plan

     Numerous precautions are taken to  prevent and minimize spills at Monsanto.
Perhaps the most important is that all loading-unloading operations are  never left
unattended. Material handlers  can shut down  pumps remotely in emergencies.
Flexible hoses are hydrostatically tested  at higher pressures and more frequently
than Coast Guard requirements (Monsanto 3 X MWP and USCG 1H X MWP).

     The plant spill procedure specifies that a spill alarm be sounded, along with a
location code, whenever a spill (gas or liquid) occurs. A trained emergency crew
can be at the spill location within minutes.

     The  plant  is  an  active  participant in  the  Texas  City  Mutual  Aid Plan
(Appendix C) and has joined forces with other industries in the plan for handling
any large spills that may occur in the harbor. Two sections (2000 to 2500-foot
total) of a Slickbar boom are  available  to contain spills of floating (insoluble)
materials. Most of the  plant's chemicals are highly  water-soluble, which makes
containment  or recovery  impossible once such  material has spilled into a water
course.
 'A proven and much used method of determining the thickness of metal, such as, especially,
 the shells of bulk storage tanks. The tank need not be empty to conduct this type of thickness
 test.
                                     36

                                                                        Arthur D Little Inc

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                                 TABLE 4
                    HAZARDOUS MATERIAL LISTING OF
                     MONSANTO COMPANY, TEXAS CITY
Raw and Terminated Materials
   Shipment Mode
Tanker        Barge
Estimated Percent
 Moved by Water
Benzene
Condensate Oil
Orthoxylene
Olefins
Caustic Soda
Acrylonitrile
Vinyl Acetate
Naphthalene
Butanol
Alkylbenzene
Products
Styrene monomers
Methanol
Acetic acid
Ethylbenzene
Phthalate esters
X
X
X
X
X X
X X
X X
X X
X X
X X

X X
X X
X
X
X
100
100
100
100
95
100
80-90
100
100
100

80-90
—
60
100
50
                                   37
                                                                    Arthur D Little Inc

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 Union Carbide Corporation
 Chemicals and Plastics
 P.O. Box 471
 Texas City

 Contacts:  Mr. J. F. Erdmann, Environmental Control Coordinator
            for Texas Plants
            Mr. A. R. Pettyjohn, Environmental Control Specialist

 Date of Survey:  August 28, 1970

 Property  Description:

     This is an extensive  petrochemical  manufacturing plant that  commenced
 operations in Texas City in 1941. It immediately adjoins the American Oil Co.
 and the Borden Co. plants and parallels State Hwy. 146 for a distance of about
 7500 feet.  In-plant treatment of  effluent  and plant drainage facilities are  as
 follows:

     Outfall 1 — This  outlet discharges into a drainage ditch near the mid
     point of the east boundary of the plant; it then  discharges  into a
     communal drainage ditch on the Texas City Terminal R. R. Co. prop-
     erty. The final discharge is into Galveston Bay and the  San Jacinto
     River Basin.

     Outfalls 2, 4, and 5 - These outlets discharge from the NW corner  of
     the plant  into Moses  Lake,  Galveston  Bay, and the San Jacinto River
     Basin.

     Outfall 3 — This outlet discharges into Swan Lake, Galveston Bay, and
     the San Jacinto River Basin.

     Outfalls 6-13 inclusive -  These outfalls discharge into the Texas City
     Terminal R. R. Co.  Barge Canal, Galveston Bay, and the  San  Jacinto
     River Basin.

     Outfall 14 - This outfall discharges into Galveston  Bay and the San
     Jacinto River Basin.

     Each drainage ditch is equipped with an effective oil skimmer trap. The plant
does have extensive  in-plant effluent  treating  ponds,  and two new federally
sponsored 50 by 100 feet, 6 and 12 feet deep, experimental anaerobic treatment
tanks, of  concrete construction, are currently being built. Figure 5  provides an
overview  of the anaerobic  treatment  tanks  while in the course of construction,
                                      38

                                                                       Arthur D Little; Inc

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   ,
   c
I

D
[T
                                i/ ANAEROBIC WASTE-WATER

                                TREATMENT FACILITY
                                                           Photo Courtesy of U.S. Geological Survey





FIGURE 5  AERIAL VIEW OF UNION CARBIDE CORPORATION WASTE-WATER TREATMENT


          PONDS SHOWING NEW ANAEROBIC TREATMENT PONDS UNDER CONSTRUCTION


          IN FOREGROUND, TEXAS CITY, TEXAS

-------
along with some of the original ponds used to treat and neutralize plant effluent
prior to discharge into the plant outfalls. Figure 6 provides a complete overview
of the entire plant and adjacent roads and properties.

Hazardous Chemicals

     Bulk storage capacities and figures on chemical consumption are considered
company  confidential. The plant did, however, provide a listing of 98 chemicals
transported,  stored  and processed, along with transportation methods used to
receive and ship the various chemicals (Table 5).

Bulk Storage Facilities and Pipelines

     All bulk storage tanks are fully diked. The dikes are mostly clay-constructed
with a  compacted oyster shell surface. Concrete-constructed dikes have  been
installed  in  "restricted" areas. Diked enclosures  are  drained through a gated
valve-type drain  located outside of the diked area. The drainage from the diked
area passes into the plant's internal drainage ditches and thence into the in-plant
effluent treatment ponds.

      To prevent  spills,  precautions are taken to see that the transferred material
never exceeds the receiving tank capacity. A number of liquid-level controls have
been installed, but are no longer calibrated; the plant feels that too much reliance
can be placed on these fail-safe devices. However, this is an educational factor that
can be  corrected by strict supervision and good  preventive maintenance proce-
dures. Remote, centrally located,  fill-level indicators are installed on major tanks;
however,  physical gaging is also used during a fill procedure — some tanks do have
high liquid-level-actuated  audible alarms. Some high  liquid-level pump cut-off
controls are provided; however,  the  facility is not  overall or extensive due to
remote location  of many tanks and pumps which, in some cases, would require
extensive electrical installations between the tanks and the pumps.

      Check valves are  provided on fill  lines at the pumps within diked areas;
however, no check valves are evident  immediately before or after the master fill
valve. Excess flow and checks are used on all liquefied petroleum and liquefied
natural gas tanks. There are no buried storage tanks.

      Tank and pipeline integrity tests are conducted on an "experience schedule"
 basis. This includes hydrostatic and non-destructive thickness testing (reflecto-
 scope and dye tests). The testing has proven to be most adequate, according to
 plant personnel. All tanks  are  coded to indicate  health, fire, and reactivity
 hazards. This is done by a company coding system that features the use of symbols
 to indicate the chemical hazard of the  tank contents.
                                       40

                                                                         Arthur D Little Inc

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rt>
                                 FIGURE 6    AERIAL VtEW OF COMPLETE UNION CARBIDE CORPORATION FACILITY.
                                            TEXAS CITY, TEXAS, SHOWING ADJACENT ROADS AND PROPERTIES

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                                       TABLE 5
                CHEMICALS AND PLASTICS IN USE AT UNION CARBIDE
                         CORPORATION PLANT, TEXAS CITY

                   Chemicals Handled and Methods of Bulk Transportation
                Material
  1.   Acetaldehyde
  2.   Acetic acid
  3.   Acetic anhydride
  4.   Acetone
  5.   Acrylate esters
         (ethyl, butyl, ethyl hexyl)
  6.   Aminoethyl ethanolamine (crude)
  7.   Aminoethyl piperazine
  8.   Ammonia
  9.   Amyl acetate (primary)
 10.   Amyl alcohols (primary)
 11.   Benzene
 12.   Butanol
 13.   Isobutanol
 14.   Butyl acetate
 15.   Isobutyl acetate
 16.   Butylene oxide
 17.   Carbitol
 18.   Cellosolve
 19.   Methyl cellosolve
20.   Butyl cellosolve
21.   Cellosolve acetate
22.   Chlorine
23.   Crotonaldehyde (crude)
24.   Cumene
25.   Diacetone alcohol
26.   Diethyl ether (crude)
27.   Diethyl sulfate
28.   Di-isobutyl carbinol
29.   Di-isobutyl ketone
30.   Di-isopropanolamine
31.   Dimethyl ether
32.   Dripolene
33.   Ethanol
34.   Ethanolamine, mono-, di-, tri-
35.   Ethyl acetate
36.   Ethyl benzene
37.   2-Ethyl hexanol
38.   Ethylene
39.   Ethylene diamine, di-, tri-f and
       tetra-amines
40.   Ethylene dichloride
41.   Ethylene glycol.di-, tri-, and
       tetra-gtycols
42.   Ethylene oxide
43.   Flexol plasticizers
        (OOP, DIOP, EPO, JPO, A-26, 3GH)
44.   Formic acid
45.   Glutaraldehyde
46.   Hexylene glycol
47.   Isobutyraldehyde
48.   Isooctaldehyde
Transport Method*
TT
TT
TT
TT

TT
TT
TT
TT
TT

TT
TT
TT
TT
TT

TT
TT
TT
TT

TT

TT
TT
TT

TT
TT
TT

TT
TT
TT

TT
TT
TT
TT
TT

TT
TT

TT
TT
TT
TC
TC
TC
TC

TC
TC
TC
TC
TC

TC
TC
TC
TC
TC

TC
TC
TC
TC

TC

TC
TC
TC

TC
TC
TC

TC
TC
TC
TC
TC
TC
TC
TC
TC
TC
TC
TC

TC



B
B
B
B
B

B
B
B
B
B
B
B
B

B
B
B
B
B
B
B
B

B

B
B


B
B
B
B

B
pipeline
B
B
B

B
B
B
B
B
B

S
S
S
S



S
S

S
S
S
S

S
S
S
S
S


S



S
S



S
S
S
S
S

S
S
S

S
S
S
S


                                         42
                                                                                Arthur D Little, Inc

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                                  TABLE 5 (Continued)
             Material

49.  Isodecaldehyde
50.  n-butyraldehyde
51.  Isooctanol
52.  Isodecanol
53.  Isophorone
54.  Isopropanolamine
55.  Isopropyl acetate
56.  Linear alcohols
57.  Liquified petroleum gases
        (propylene, butadiene, propane,
        butane)
58.  Methanol
59.  Methyl acetone
60.  Methyl amyl alcohol
61.  Methyl amyl acetate
62.  Methyl butanol
63.  Methyl butyraldehyde
64.  Methyl ethyl ketone
65.  Methyl isobutyl ketone
66.  Methyl isoamyl ketone
67.  Naphtha
68.  Niaz polyols
        (14-46,16-46,31-45)
69.  Nitrogen
70.  Oxygen
71.  Nonane, nonene
72.  Normal paraffins
73.  Kerosene
74.  n-pentanol
75.  Phenol
76.  Phenolic resin solutions
77.  Vinyl resin solutions
78.  Piperazine
79.  Polymine "H"
80.  "Prestone" anti-freeze
81.  n-propanol
82.  Isopropanol
83.  Propionaldehyde
84.  n-propyl acetate
85.  Propylene diamine, dipropylene triamine
86.  Propylene dichloride
87.  Propyleneglycol
88.  Propylene oxide
89.  Styrene
90.  Sulfuric acid
91.  Toluene
92.  Tridecanol
93.  Ucar latexes (130, 131, 180, 360)
94.  Valeraldehyde
95.  Vinyl acetate
96.  Vinyl chloride
97.  Vinyl resins
98.  Polyethylene resins

*Key to abbreviations:  TT = tank truck
                      TC = tank car
    Transport Method*
TT
TT
TT
TT
TT

TT
TT
TT
TT
TT
TT
TT
TT
TT
TT
TT
TT
TT
TT
TT
TT
TT

TT
TT
TT

TT
TT
TT
TT
TT
TT
TT
TT
TT
TT
TT
TT
TT
TT

TT
TT
TT
TT
TT

Bulk van
rail, and


TC
TC
TC

TC
TC
TC
TC
TC
TC
TC
TC
TC

TC
TC
TC

TC
pipeline
pipeline

TC
TCQ
TC
TC
TC
TC
TC
TC
TC
TC
TC
TC
TC
TC

TC
TC
TC
TC
TC
TC
TC
TC
TC
TC
B
B
B
B
B
B
B
B
B
B
B
B
B
B

B
B
B


B


B
B
B




B


B
B
B
B
B
B
B
B
B
B

B

B
B



S
S
S
S
S
S


S

S
S


S
S


S



S
S







S
S

S


S
S
S





S

Boxes by truck,
ship


B = barge
S = ship or tankers
                                       43
                                  Arthur D Little, Inc

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     Buried pipelines are extensive; they are protectively coated and wrapped,
with most lines having cathodic protection. Pipeline sections are double-jacketed
at roadways, railroad crossings, ditches, and in heavily traveled areas, and all the
casings are vented at both ends.

Past Spill Experience

     The  plant  experienced a  barge collision  in  the  intercoastal  canal  in
June 1970. A barge carrying refined kerosene was hit on the starboard  quarter,
which was entirely cut off by the impact. A resulting spark caused a fire,  the heat
of which  welded  both barges together.  The kerosene barge was leaking when
brought into the plant property where the cargo was pumped into the plant's
waste disposal system. A spill involving 42,000 gallons of ethanol occurred over a
36-hour period following plant start-up on January 1, 1970.* Another chemical
spill was  reported  January 5, 1970, when 20 to 25 gallons of acetone were
drained from a flexible hose without using a drip pan.*

Spill Control Plan

     All production units (about 60) are  autonomous, having  individual spill
control plans which are specifically outlined in an operating manual.  It is  not
practical to boom or confine a chemical spill at marine unloading areas  since all
chemicals  handled within the plant are water-soluble. The plant concentrates on
spill prevention and prompt removal of lighter-than-water  chemical spills. A new
waste-treatment clarification  plant is on the drawing board to replace the existing
25-year old facility. Construction permits have been applied for and a new $6
million facility has been proposed.
*State Water Quality Control Board, Austin.
                                     44

                                                                        Arthur D Little Inc

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American Oil Company
2401-5th Avenue, South
Texas City, Texas

Contacts:   Mr. R. E. Dickey, Manager
            Oil Movements & Marine Division

Date of Survey:  September 1, 1970

Property Description

    The American Oil Company facility is considered to be one of the largest
refineries in the nation. Its output averages 245,000 bbls of crude oil per day. The
plant  is surrounded on three sides by  the properties of  Marathon Oil, Union
Carbide,  Borden Chemical, and Amoco Chemical. The marine loading/unloading
facility is located on the Texas City Barge Canal. The plant drainage terminates in
Galveston Bay  and the San Jacinto River Basin. One outlet crosses State High-
way 341, at the southern end of the plant property, and then joins  a communal
drainage  trench (Union Carbide, Amoco) that crosses the Texas City Railroad
property to terminate just south of the Barge Canal. The plant discharges between
13 and 14  million gallons of effluent daily. A new sludge pit — 50 by 100 by 10
feet — was recently installed in the plant, and in-plant drains pass through holding
boxes  and  separator ponds prior to discharge. Another outlet handles three
discharges of domestic sewage at an average of 100 to 300 gpd.

Hazardous  Materials

     A complete listing of chemicals handled at American Oil is given in Table 6;
however, major shipments are handled in the following manner.

     Sulfuric acid  (98%) is  received by  barges which  are unloaded  at the Texas
City Barge Canal. The material is then pipelined in overhead lines to storage tanks
where it is eventually used for the alkylation units. About 98% of the spent acid is
recycled  back into the system and the remainder, 90% diluted with hydrocarbons
and water,  is returned into the marine barges.

     Caustic (50%) is received in a  similar manner  for use at  the plant's No. 1
alkylation  unit and the No. 1 cracking unit. In some cases, it is diluted  to 10%
strength before using.

     Ammonia is stored  at  -28°F  and  the entire production is supplied to the
export or domestic market. The material is shipped by all modes of transportation
- ship, barge, rail, and truck. The maximum storage capacity is 45,000 tons and
the plant produces  2000 tons in  a daily 24-hour operation.  The plant stores


                                    45

                                                                      Arthur D Little Inc

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miscellaneous treating chemicals,  such as commercial scale removers, lime for
water softening and others.

     Chrome, zinc, and phosphate are used within the cooling towers and hydro-
chloric  acid  is  used for deionizing  water. Other chemicals include drummed
inhibitors,  liquid dyes, and furnace  oil additives. Methanol is received by rail,
25,000 gallons being stored as a gasoline additive.

     Cresylic acids, extracted  from gas and oil, are stored in up to  six railroad
tank cars for shipment to Merichem in Houston. Aluminum chloride  is stored in
bulk quantity in dry storage. Benzene is manufactured, stored, used, and shipped.
Toluene is produced for gasoline blending. Xylene is produced and transferred to
the nearby subsidiary, Amoco Chemical. Sodium chloride brine is produced from
Texas brine  for regenerating  zeolites; about two to three tank car loads are
consumed annually. Tetra-ethyl lead is also stored and used in the plant produc-
tion process.  Chlorine is used for algae control in the plant cooling towers.

Bulk Storage Facilities and Pipelines

     All tanks  receive  regular non-destructive shell thickness  tests, and  the
majority of plant  pipelines are  installed in an exposed  position. All tanks have
external liquid-level gages. No dikes or retention barriers are used in the sulfuric
or caustic storage areas.  Dikes are used for benzene, toluene, and xylene storage,
and full-capacity retention  pits are provided under the tetra-ethyl lead  storage
tanks.  All lines are cleared of  product, using nitrogen  gas pressure, after each
transfer of material.

Past Spill Experience

     The plant has had four or five "boilovers" within the past four or five years.
The boilovers were caused by decomposition reaction, and one spill cost between
$5000  and $6000 to neutralize. Another spill did escape out into the water
course.

     A  diversion pond  is under  construction to permit  full  confinement  and
neutralization preparatory to outside release.

     The following spills were officially recorded:

     2/25/70 - 3-bbl. oil spill  from  faulty flange connection on  unloading
     barge (Texas Water Quality Board, Austin);

     3/12/70 - Sulfuric acid  foamed over alkylation unit tank (Texas Water
     Quality Board, Austin);
                                      46

                                                                        Arthur D Little, Inc

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                                                           TABLE 6

                         STORAGE CAPACITIES FOR CHEMICAL COMPOUNDS HANDLED
                                               AT AMERICAN Ol L COMPANY
                                                      (September 4,1970)

                   Unit Location
                                           Normal Capacity
                                                                                              Unit Location
                                                                                                                         Normal Capacity
Acid, Fresh
Sulfuric
Sulfuric
Sulfuric
Sulfuric
Sulfuric
Sulfuric
Sulfuric
Sulfuric.
Sulfuric
Sulfuric
Acid Oils
Acid Oils
Acid, Spent
Sulfuric (75%)
Sulfuric (90%)
Sulfuric
Sulfuric
Sulfuric
Additives and
Inhibitors
Additive Concentrate
Additive Concentrate
Additive Concentrate
Additive Concentrate
Additive Concentrate
Additive Solution
Additive Solution
Additive Solution
Additive Solution
Additive Solution
Additive Solution
Additive Solution
Additive Solution

No. 2 ammonia

Main sett, basin
Tank farm sett, basin
Waste-water ditch
No. 2 alkylation
No. 2 atkylation
No. 1 alkylation
No. 1 alkylation
Barge canal
No. 1 CCU
No. 3 CCU

No. 3 pipe still
No. 3 pipe still
No. 2 alkylation
No. 2 aikylation
No. 2 alkylation

c>
OSBLnear EPH
OSBL near EPH
OSBL near EPH
OSBL near EPH
OSBL near EPH
OSBLnear EPH
OSBLnear EPH
OSBLnear EPH
OSBL near EPH
OSBLnear EPH
OSBL near EPH
OSBLnear EPH
OSBLnear EPH

10,700 gals
10,700 gals
4,500 gals
1,900 gals
8,200 gals
7,500 bbls
7,500 bbls
1,566 bbls
1,566 bbls
470 bbls
562 bbls
500 bbls

14,000 gals
47,000 gals
7,500 bbls
7,500 bbls
335 bbls


184 bbls
133 bbls
133 bbls
382 bbls
382 bbls
169 bbls
140 bbls
168 bbls
141 bbls
169 bbls
169 bbls
21 8 bbls
219 bbls
 Sulfur Inhibitor

Aluminum Chloride
 Solution

Anhydrous
 Ammonia
 Ammonia
 Ammonia

Aromatics
 Benzene
 Benzene
 Benzene
 Benzene
 Benzene
 Benzene
 Benzene
 Benzene
 Benzene
                    Styrene
Styrene

West of No. 1
Ammonia plant
Ammonia plant
Ammonia plant
OSBL near P.S. #1
OSBL near P.S. #1
OS8L near urtraformer #1
OSBL near ultraformer #1
OSBL mar toluene
OSBL near toluene
OSBL near EPH
OSBL near EPH
OSBL near toluene
  1.400 gals


100,000 gals


 15.000 tons
 15,000 tons
 15,000 tons
 20,000 bbls
 20.000 bbls
 40.000 bbls
 40,000 bbls
 18,000 bbls
 18,000 bbls
  9,000 bbh
  8,000 bbls
  5,000 bbls
Benzene
Ethylbenzene
Ethylbenzene
Off-test styrene
Polyethyl benzene
Polyethyl benzene
Polyethyl benzene
and styrene residue
Toluene or xylene
Toluene or xylene
Toluene or xylene
Toluene or xylene
Toluene or xylene
Toluene or xylene
Caustic. Fresh
Caustic. Fresh
Caustic, Fresh
Caustic. Fresh
Caustic, Fresh
Caustic, Fresh
Caustic, Fresh
Caustic (10%)
Caustic (10%)
Caustic (40%)
Caustic (50%)
Caustic (5-10%)
Caustic, Fresh
Caustic, Fresh (25%)
Caustic, Spent
Caustic, Fresh (25%l
Caustic, Fresh
EDTA, Boiler
Water Chemical
Monoethanol
Amine
Amine
Amine
Amine
Amine
Sulfolane
WetSulfolane
Sodium Phosphate
and Caustic
OSB L near toluene
Styrene
OSB L near styrene
Styrene
Styrene
Styrene

Styrene
OSBLnear ARU
OSBL near ultraformer #4
OSBL near toluene
OSBL near fire drill grounds
OSB L near fire drill grounds
OSBL north of sludge ponds
No. 2 alkylation
No. 1 alkylation
No. 1 alkylation
No. 1 alkylation
Main sen. basin
Tank farm sett, basin
No. 2 ammonia
No. 3 pipe still
No. 3 pipe still
No. 3 CCU
No. 3 CCU
No. 3 CCU
No. 1 CCU
No. 2 CCU
No. 2 CCU
No. 3 ultraformer
No. 2 ultraformer

No. 1 power station

No. 1 ammonia
No. 2 ammonia
Ultracr acker
No. 3 CCU
No. 3 CCU
Aromatics recovery
Aromatics recovery

No. 2 power station
5.000 bbls
158.000 gals
9,000 bbls
148,000 gals
1 2,000 gals
20,000 gals

100,000 gals
70,000 bbls
70,000 bbls
40,000 bbls
40,000 bbls
40,000 bbls
105.000 bbls
500 bbls
1,008 bbls
1,008 bbls
1,008 bbls
108 bbls
182 bbls
6, 800 gals
47,000 gals
6,500 gals
500 bbls
550 bbls
100 bbls
1,000 bbls
1.000 bbls
1.000 bbls
340 bbls
5.400 gals

4,000 gals

4,850 bbls
950 bbls
250 bbls
290 bbls
318 bbls
1,780 bbls
360 bbls

2.500 gals
Note: 42 gallons per barrel
OSBL - outside battery limits
Acid oils are mixed creiylic acids
EPH - ethyl pump house
ARU — aromatics recovery unit
CCU - catalytic cracking unit
                                                                  47
                                                                                                                   Arthur D Little, Inc

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     3/17/70 - Duplicate to foamover incident took 12 hours to neutralize
     (Texas Water Quality Board, Austin).

     3/23/70 - Sulfuric acid spill; no details  (Texas Water Quality Board
     Files, Austin).

Spill Control Plan

     The emergency spill plan forms a lengthy section of the company's operating
manual. The  company is also an  active member of the Texas  City Industrial
Mutual  Aid System. Outfall  monitoring for pH is continuous with a remote
readout at a  control  center, operated and  staffed  24 hours a day. The plant
further maintains six organic detectors for emergency use. A 1600-foot length of
spill containment boom is readily available for plant use.
                                    48

                                                                      Arthur D Little, Inc

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Borden Chemical Company, Smith-Douglas Division
Grant Avenue
Texas City, Texas

Contact:   Mr. William F. Frazier, Jr., Production Manager

Date of Survey:  September 1, 1970

Property Description

     The Borden Chemical Company plant (Figure 7) began operation in 1957 for
the manufacture of sulfuric acid and fertilizer. The sulfuric acid manufacturing
has been abandoned, and  production is now being concentrated on the manufac-
ture of a complete range of fertilizers. During this visit the plant had temporarily
stopped production to further modify its production flow. Since the production
changes will alter raw chemical product storage and quantity demands, this report
is  directed  to detailing new production which was  to have commenced late in
November 1970.

     The property  fronts  on FM Highway 519  and is bounded on three  sides by
the plants of Union Carbide, American Oil, and Amoco Chemical. The plant's
drainage system  averages  30,000 gpd  of industrial waste, graded as  1% domestic
sewage, 2% boiler  blowdown water, 90% process water,  and  7% cooling water.
The drainage passes through the plant into a communal ditch also utilized by the
Gulf Chemical and Metallurgical Corporation.  The terminal outfall  empties into
Swan Lake (Figure 1). A  marine unloading facility is leased from the Texas City
Terminal Railway Co.

Hazardous Materials

     The following raw materials are used and  stored on the property to process
the various mono-ammonium fertilizers into finished products:

     1.   Sulfuric  acid (99%)  - received by  barge and currently
         trucked  to  plant. This  transportation procedure may
         change, but current consumption averages 2200 tpy.

     2.   Phosphoric acid (73% H3PO4) - received by  barge and
         currently trucked to the plant. This  transportation proce-
         dure  may  change,  but  current  consumption averages
         30,000 tpy.

     3.   Anhydrous ammonia  — 12,000 to 13,000  tpy — pipelined
         in from an immediately adjacent plant (American Oil).


                                    49

                                                                     Arthur D Little Inc

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     4.   Ammonium sulphate  — received in railcar from Houston;
         the plant utilizes 20,000 tpy; average storage, 300 tons.

     5.   Muriate of  potash  (60%  KaO content) — received from
         Carlsbad,  New Mexico, by hopper cars (90%) and  pneu-
         matic trucks  (10%);  average  consumption,  15,000 tpy;
         average storage, 300 tons plus railroad cars on siding.

     6.   Gypsum — 15,000 tpy mined on plant property; 1 million
         tons of reserve on site.

Bulk Storage Facilities and Pipelines

     Sulfuric acid tanks:

     Four at 42,000 gal. capacity each
     Two at 260,000 gal. capacity each
     Three at 10,000 gal. capacity each.

        Note: It is anticipated that when production is reactivated that two
        42,000-gal. tanks will be used and that the remaining  tanks will be
        "dead storage." The two 42,000-gal. tanks will  not be  used to
        capacity and  an average storage of 6000 to 7000 tons of sulfuric
        acid is expected.
    Phosphoric acid tanks:
                       Three at 54,000 gal. capacity each
                       One at 61,300 gal. capacity
                       One at 160,000 gal. capacity
                       One at 260,000 gal. capacity
                       One at 81,100 gal. capacity
                       Four at 45,300 gal. capacity each
                       One at 601,800 gal. capacity
                       Four at 26,000 gal. capacity each.
    Anhydrous ammonia tanks:
                       One at 18,000 gal. capacity
                       One at 6,000 gal. capacity
                                     50

                                                                      Arthur D Little Inc

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 PAGE NOT
AVAILABLE
DIGITALLY

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Use of the 6,000-gal. tank will probably be terminated. Only the ammonia storage
tanks and lines are liydrostatically tested; welds are also X-rayed, and the pressure
relief valves are tested and reset every 2 to 3 years. The ammonia transport line is
maintained by the plant; it is a 4-inch diameter line that is doped, wrapped, and
cathodically protected.

Past Spill Experience

     The plant's largest spill occurred about  five years ago when 10,000 gallons of
phosphoric acid  escaped, following the rupture of a lead-lined wooden stave tank.
Some  5000 gallons of  acid went into  a ditch that empties  into Swan  Lake.
Payloaders were  used  to dam the  plant,  and the acid-filled ditches were pumped
out. The plant's  wooden tanks have since been removed from active service. Other
rubber-lined  phosphoric acid  tanks have  sprung  pinhole leaks, but they  are
promptly detected and repaired.

Spill Control Plan

     The plant  is  a member  of  the Texas City Industrial Mutual Aid System
(Appendix C). As of February 1970, the  plant was engineered into a totally
enclosed water system and any spill will eventually enter the in-plant ditching
system. The following pumps can operate individually or in tandem to recirculate
spilled liquid or slurry:

                    One 3 by 4 Gallagher 40-hp 400 gpm,*
                    One 4 by 6 Gallagher 50-hp 600 gpm.*

Plant management  feels that  it  now has a system that  could handle any spill
except  the  large 260,000-gal. phosphoric  acid tank which will eventually be
removed from service.  The use of mechanized equipment to build temporary
dikes and to  block drainage ditches would be employed as an interim contingency
plan to contain a large spill.
•gallons per minute


                                     53

                                                                       Arthur D Little; Inc

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Amoco Chemicals Corporation
2800 Farm Road (519E)
Texas City, Texas

Contacts:   Mr. G. D. Fesperman, Operations Supervisor
            Mr. D. Womacks, Pollution Control Engineer

Date of Survey:  September 2, 1970

Property Description

     The Amoco Chemicals facility has two operational locations:  Plant A (12
acres) and Plant B (55-60 acres). Plant A, the original plant, has been  in operation
since  1947. Both plants produce petrochemical products, none of which could be
considered  as finished  products.  Each item  is  used for  the manufacture of
terminal  products by concerns other than the Amoco Chemicals Corporation. The
Texas  City operations are closely integrated  with the adjoining American Oil
Company's refinery for "charge stocks." The produced chemicals are used mostly
by  domestic chemical concerns.  There is, however, some  limited export of
chemicals to the foreign market.

     The plant has a marine loading/unloading facility on the Texas City Terminal
Railway  Co.'s Barge Canal in addition to its main  marine  terminal facility. All
drainage  from the dock facilities goes  to sumps that are cleaned as required. The
diked areas have valves which remain closed under normal conditions and, when
open, drain to a proven effective oil-separator  unit. Rainfall on areas other than
the loading facilities or the diked area drains into the Barge Canal.

     In Plant -A all surface runoff and process waste water in the eastern section
of the property drain to an  oil separator and a holding basin located near the
entrance  to  the plant.  The  area  comprises the  older section of the plant, a
common sewer system of which necessitates that all water go through a treatment
facility. The western section of Plant A has a new process unit, and the sewer and
drainage  systems are designed to  segregate contaminated water from clean rain-
water. Rainwater falling outside the unit or tank farm area drains into a ditch that  •
runs along the west side of the plant. Contaminated  water from the unit or the
tank farm area is collected for treatment.  All of the diked areas of Plant A have
drains which remain closed under normal conditions.

     In Plant B the drainage system design provides for collection of all contami-
nated water within the processing and tank farm areas for treatment. The rainfall
from  the same areas drains  into  conventional drainage ditches. Similar to the
other locations, all diked  areas have outlet valves which remain closed  under
normal conditions. Heavy settled material from in-plant waste-water treatment is
disposed of in a sludge pit located on the company property.

                                     54

                                                                      Arthur D Little; Inc

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     The plant itself disposes of 400,000,000 gallons of liquid waste each year. Of
this total about 1% is hauled offsite for processing by an outside firm. About 2l/2%
of the total quantity is hauled offsite by a local  firm for disposal at a facility
which has the Texas Water Quality Board disposal permit. The remaining waste-
water discharge joins waste water from the Union Carbide Chemical property and
later joins American Oil waste water in a communal drainage ditch. The combined
waste water from all three plants then flows through a ditch from the Texas City
Barge  Canal  into Galveston  Bay. The  total treated waste-water volume (three
plants) averages 200,000 gpd  or 73 mgy.

Hazardous Materials

     Products processed for shipment include:

         •    Indopol polybutenes,
         •    Amoco resin 18
              (a linear alphamethylstyrene polymer),
         •    Amoco styrene monomer,
         •    Amoco surfactants and oil production chemicals
              (corrosion inhibitors),
         •    Amoco methyl mercaptan
         •    Panaflax BN-1-plasticizer
              (an alkylated aromatic), and
         •    Panasol  solvents
              (aromatic solvents)

              Panasol Type            AN-1     AN-2    RX-34

           Initial Boiling Point (°F)    384      398      365
           End Point (°F)             504      525      441
           Aromatics Vol.%            99.9    100      100
           Gravity API @60°F         15.5      13.3     23.2
           Mixed Aniline Point (°C)     13.6      13.4     15
           Flash, Closed Cup (°F)      195      200      146 (TCC)
           Color, Saybolt             +17       -5      -29
           Kauri-butanol value        108      102      105
Table 7 provides  a listing of chemical-type storage capacities, transfer methods
and transfer rates.
                                    55

                                                                      Arthur D Little Inc

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                                    TABLE 7

         HAZARDOUS CHEMICALS, STORAGE CAPACITIES, AND TRANSFER
         RATES AT THE AMOCO CHEMICALS CORPORATION, TEXAS CITY
Chemical

Plant A
  Caustic 50%
  Caustic 5-10%
  Sulfuric acid
  Methanol
  Toluene sulfonic acid

Plant B
  Aluminum chloride
   solution 25%
  Aluminum chloride
   solution 25%
  Benzene
  Benzene
  Ethyl benzene
  Residue
  Sulfuric acid
  Ethyl chloride
  Caustic solution 50%
  Caustic solution 5%
  Styrene
  Xylene
  Xylene
  Paraxylene
  Paraxylene
  Heavy aromatic
   hydrocarbon
  Light aromatic
   hydrocarbon
  Sulfur
  Aluminum chloride
   (100%)
Storage Capacity
 (gals, plus 103)
        5.8
        2.5
       20.0
       40.0
   100,000 Ibs
        15.0
       63.0

       170.0
    97,000 Ibs

   110,000 Ibs
                                             Transfer Method
Tank truck
Tank truck
Tank truck
Tank truck
Tank truck
Tank truck
                   Transfer Rate
                  (gals, plus 103/hr)
20.0
170.0
2,800.0
830.0
100.0
4.4
11.0
23.0
97.0
4,200.0
2,800.0
1,000.0
2,800.0
160.0
Tank truck
Pipeline
Pipeline
Tank truck
Tank truck
Tank truck
Tank truck
Tank truck
Tank truck
Pipeline
Pipeline
Pipeline
Pipeline
Pipeline
-
13.7
13.7
-
-
-
—
-

52.7
13.7
13.7
90.0
3.0
Pipeline

Pipeline
Tank truck

Tank truck
12.0
24.0
                                       56
                                                                            Arthur D Little, Inc.

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Bulk Storage Facilities and Pipelines

     The plant has extensive bulk storage facilities,  most of which are diked,
curbed, or  trenched.  Each tank is internally  inspected and non-destructively
tested  each time it is removed  from service for cleaning.  Tanks and piping in
service under corrosive conditions are inspected periodically, depending on the
severity of the corrosive conditions.

     All  underground  lines between Plants  A and  B and  the American Oil
Company's refinery are cathodically protected. An undergound barge-loading line
from Plant A is cathodically protected two-thirds of  the way from the Plant A
docks  to Plant A. All lines at Plant B between the American  Oil refinery and
Plant B dock  facilities are  protected by a polyethylene  coating.  When used,
flexible hoselines at the dock facilities are tested to a pressure of 250 pounds, and
all insulating flanges are checked for conductance. It should be noted, however,
that most docklines are rigid metal lines with  a packed swivel joint to permit
movement and  connections between the marine vessel and the dock connection.

Past Spill Experience

     The U.S.C.G. Port Captain's office in Galveston has a record of the following
spills which were reported by its pollution control staff:

     3-11-69 Amoco — light crude oil leak from barge
     5-29-70 Amoco - S/S Amoco  experienced naphtha spill
     3-24-70 Amoco — chemical leaked from valve on dock

     Each of the spills was investigated and corrective action was introduced to
prevent a repetitive spill.

Spill Control Plans

     The plant's spill plan was subjected to revision on June 1, 1970. A complete
copy of the plan is provided as Appendix D.
                                      57

                                                                        Arthur D Little Inc

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Marathon Oil Company - Texas Refining Division
Foot of Sixth Street
Texas City, Texas

Contacts:    Dr. A. L. Benham, Acting Manager
            Mr. Harold Smith, Technical Service Manager
            Mr. Noble Norton, Engineering Dept. Manager
            Mr. Malcolm Johnson, Tech. Advisor/Water Treatment
            Mr. L. D. Rice, Manager/Production Control

Date of Survey:     September 2, 1970

Description of Property

     The  Marathon Oil  Company commenced operations at its Texas City plant
(Figures) in  1962. The refinery  has a 45,000-bbl/day throughput capacity. In
addition to basic petroleum production, the plant produces the following petro-
chemical products:

                       Heavy aromatics,
                       Benzene,
                       Cumene,
                       Propylene,
                       Toluene,
                        Xylene.

 The plant utilizes seven marine dock locations that can handle vessels sized from
 barges to super tankers (36-foot  channel at MLW). The property is quite exten-
 sive, located on both sides of the FM Highway 519 (State Hwy. 341) between the
 Amoco Chemical, American Oil, and Texas City Refining plants.

      Plant drainage averages 1.156 mgd at one outfall, and 3.2 mgd at a second
 outfall. The effluent travels in a roadside ditch under Loop 197 through a culvert,
 mixes with other plant wastes, and then drains into  the  industrial barge canal,
 Texas City Harbor, Galveston Bay, and the San Jacinto-Brazos Coastal Basin. The
 effluent consists of:

                    Process water        71.4%
                    Cooling tower water  24.4%
                    Boiler blowdown      4.4%

 The plant utilizes a 45-acre oxidation  pond for in-ptant water treatment prior to
  final discharge from the plant property.
                                     58

                                                                       Arthur D Little; Inc

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C
                     FIGURE 8   AERIAL VIEW OF REFINING DIVISION, MARATHON OIL COMPANY, TEXAS CITY, TEXAS

-------
Hazardous Materials

     Hazardous materials handled by Marathon Oil include:

     •   Benzene - Maximum storage capacity, 50,000 bbl; average
         storage, 50% of total; production, 3 to 5 mgy,

     •   Toluene - Maximum storage capacity, 80,000 bbl; average
         storage, 20% of total; production, 8 to 10 mgy,

     •   Xylene - Maximum storage capacity, 80,000 bbl; average
         storage, 20% of total; production, 8 to 10 mgy,

     •   Cumene - Maximum storage capacity, 80,000 bbl; average
         storage, 50% of total; production, 120 million bbl/yr,

     •   Sulfuric acid  98% - Maximum storage capacity, 16,000
         gal.; normal  consumption  averages eight 8,000-gal. tank
         cars/yr; spent sulfuric acid is used for in-plant water treat-
         ment,

     •   Caustic - Maximum storage, 16,000 gal. average consump-
         tion; one 8,000-gal. tan car/month; two tank cars (16,000
         gal.)  are normally transferred into and maintained in an
         above-ground storage tank. Spent caustic in 4000-gal. loads
         is trucked  out of the plant monthly by Arlhem Company
         of Houston.

Bulk Storage Facilities and Pipelines

     The bulk storage tanks are located in four tank farms; viz., the North, West,
South,  and Atlantic tank farms.  The  farms immediately surround the main
processing units. Immediately prior to visiting this plant, two days of heavy rain
had overflowed the roadside drainage  ditches on FM Highway 519 and partial
flooding was  evident  in  the  West  tank farm. This is apparently  a common
condition that has been worsened by the retention and diversion  of drainage
waters to facilitate construction of the hurricane levee that is being built under
U.S. Army Corps of Engineers sponsorship. It would seem that the State Highway
FM 519 drainage ditches are inadequate to handle even moderate rainwaters since
the actual  highway was under water. The waters that entered the private plant
property of Marathon could mix with any  contaminating substances (spiHs,
splashes, etc.) and cause these substances to flow into the highway storm drainage
system. The main storage tanks and piping appeared well preserved, and the plant
piping was adequately coated and protected at underground locations.


                                     60

                                                                      Arthur D Little Inc

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Past Spill Experience

    The only spill at Marathon Oil was recorded in the U.S. Coast Guard files in
Galveston:  October 26, 1969, Marathon Oil spill from separator leaked through
into drainage ditch. The separator was adjusted to prevent further leakage.

Spill Control Plan

    Marathon Oil is an active member of the Industrial Mutual Aid System of
Texas City, and an in-plant spill control plan is part of the company's operating
procedures. The plant also owns and maintains 1,600  feet of oil containment
boom that  could be handled by the Texas City Harbor Pilots Association in the
event  of a floating chemical or oil  spill. There are two boats that  can, in an
emergency,  be made available on  a 24-hour  day  basis  to  position  the  oil-
containment boom.
                                     61

                                                                      Arthur D Little Inc

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Malone Service Company
Malone Trucking Company
Malone Chemical Products Company
300-20th Street, S.
Texas City, Texas

Contacts:    Mr. Paul Malone, President
            Mr. Arthur Malone, Vice President

Date of Survey:  August 24, 1970

Property Description

     The Malone Service Company collects and disposes of plant waste materials,
combats oil and hazardous material spills, and conducts ship and barge draining.
The downtown location houses  the main office and chemical trucking terminal.
The firm's main waste treatment and disposal area is located southwest of town in
a 56-acre tract. (Monsanto Chemical also operates a 12-acre lime disposal facility
on  the property.) The  land is flat and drains through ditches and settling pits into
Swan Lake, a tidal "lake" connecting into Galveston Bay. The disposal area can
store and  treat 10,500 gpd  of chemical waste.  Six  company-owned 130-bbl
(5,460 gal.) capacity tank trucks collect the spent  chemicals from various plant
and dock  locations and transport them to the disposal site. The disposal facilities
consist of a series of six spent-chemical storage and disposal ponds and reclaiming
tanks, a  still, an evaporator, and a deep injection disposal well. The well  was
drilled under the supervision  of the Geologist  of the State of Texas. It has a total
depth of 5,300 feet and is  cased to a depth of 5,100 feet.

     The initial treatment pond is  slightly acidic, having a  pH of 5.5. A small
amount of  Monsanto  waste  lime is added  to maintain a pH of around 7.  The
material has a natural overflow into a 50 by  100 by 10-foot unlined pond  that
maintains a  water  level of about 5  feet. A  large  quantity of suspended salts,
chromates, and other solids is settled out at this phase, with the material flowing
into a second 50 by 50-foot  pond. The material is then lifted by a pump to  pass
through either of two available filters, with the  filtered liquid backflushed into the
salt pit. The material then passes through a metering system into  the cased deep
injection well.

     There are also five oil storage tanks and three oil/water settling pits.  The
contaminated water passes through a catch basin where it is separated from the
oil. The reclaimed  oil is  stored  in a 15,000-bbl capacity  storage  tank. Plans are
being developed for the installation of a smokeless incinerator to dispose of waste
oil that  cannot  be reprocessed. Currently, all oil is  sold  to reprocessors for
reprocessing or for oiling road surfaces within the state.
                                      62

                                                                       Arthur D Little; Inc

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Hazardous Chemicals

     The  product handled by Malone can only be classified as industrial petro-
leum, chemical wastes, and crude oil contained in a 90% water mix, which is a
varying mixture of waste chemicals resulting from petroleum and chemical prod-
uct manufacturing.

Bulk Storage Facilities and Pipelines

     The  plant is  new, and  during the  survey only a few test runs had been
attempted. Well pumping was to commence on September 1, 1970, and full waste
processing was anticipated for October 1, 1970. The storage tanks and process
vessels gave a new or reconditioned appearance.  Plans were under way to increase
the dikes  around the tanks to a height of 5 feet. All pipelines are stilt-supported
to a height of 14 feet above sea level as a precaution against high-water flooding.
In the event of a flood higher than the diked enclosure, the spent chemicals in
storage would be intermixed with the flood water.

Past Spill Experience

     The State Water Quality Board records showed a 6,000-bbl reclaimed oil spill
at Malone Service; 200 bbl reached Swan Lake where it was burned. The spill was
attributed to the action of an  ex-employee who intentionally opened the valves of
two tanks to permit the oil to escape. The valves were not locked at  the time of
this survey.

Spill Control Plan

     All electric control switches (pump controls, etc.) are installed 7 feet above
grade level and 14  feet above sea level to protect them from flood situations.
Electric motors, and  even some buildings, can be moved  following warning of a
hurricane  or high tide. It is anticipated that open pits, with the exception of the
chemical settling pit,  will be removed from  service within a year, and that they
will be replaced with a system of closed tanks to control the previously described
flood situation. An additional flood precaution can be effected with the complete
flooding of all tanks to anchor them securely into position. The concern has the
advantage of being Texas City's main spill control agency, having the experience
and equipment to contain and clean up most types of lighter-than-water material
spills. Their equipment includes  floating booms, vacuum pumps, and various
chemical absorbents, dispensers, and burning and singeing agents.
                                     63

                                                                       Arthur DLittldnc

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Texas City Refining, Inc.
East Galveston Highway
Texas City, Texas

Contacts: Mr. L. W. Robbie, Vice President/Operations
         Mr. P. D. Parks, Supervisor/Environmental and
         Corrosion Control
         Mr. A.E. Bynum, General Refinery Superintendent

Date of Survey:    August 31,1970

Property Description

     Texas City Refining, Inc. has been a producer of petroleum (65,000 bbl/day)
and  related  products  in  Texas City  since  1951.  The plant is quite extensive
(Figure 9) and  in close proximity to the properties of Marathon Oil Company,
Amoco Chemical Corp., Plant A, and the Texas City Terminal Railway Company.

     Plant production drainage averages between 900 to 1200 gpd, most of the
waste material emanating from the plant's sulfide stripping process. The discharge
is classified as 10.6% boiler blowdown water, 39.2% cooling water, 13% process
water, 37.2% service water,  and others. In-plant water treatment is quite exten-
sive, flowing through a primary  treatment  pond into an  aerated lagoon, then
through four  additional  treating ponds prior to discharging  into a  common
drainage ditch which carries drainage from FM Highway 519 (State Highway 341)
and Amoco Plant A. The ditch terminates in the  Texas City Railway Company
Barge Canal, which has tidal flow into the Texas City Ship Channel and Galveston
Bay. Figure 10 shows the water-treatment flow sequences.

Hazardous Materials

     After petroleum, the main product at Texas City Refining is considered to
be propylene; however, plant  officials  provided a list of materials used  and/or
processed  within the plant (Table 8).  The actual bulk storage figures and  annual
chemical consumption rates were not made available during the survey. Hazardous
materials are delivered neither by barge nor ship. Such materials are received and
shipped either by truck or rail, using local common carriers and railroad facilities.
                                    64

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                 OUT OF SERVICE

                      7
~
J
                                                             8k ^•W'.   ,— B5-«l*T	
                         FIGURE 9  GENERAL LAYOUT OF TEXAS CITY REFINING CORPORATION, TEXAS CITY, TEXAS

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cr\
                  FIGURE 10  TOPOGRAPHICAL SURVEY OF TEXAS CITY REFINING CORPORATION PLANT, TEXAS CITY,
                             TEXAS, SHOWING OIL AND WATER SEPARATOR FOR PLANT EFFLUENT

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                             TABLE 8

HAZARDOUS CHEMICALS HANDLED AT TEXAS CITY REFINING, INC.

      Chemical                     Supplier                     Unit
 1.   Kcppers liquid oil bronze
 2.   Liqui treat
 3.   Dianodic116
 4.   Slimicide C-30
 5.   Duosperse 408
 6.   AgelC-17
 7.   OGA 290
 8.   Hydrated lime
 9.   Sodium sulfite
10.   Aluminum sulfate
11.   Soda ash
12.   Liquid chlorine
13.   Liquid chlorine
14.   Aqua ammonia
15.   Aqua ammonia
16.   Caustic soda solution
17.   Sulfuricacid
18.   HFacid
19.   Tetra-mix 50
20.   Oil orange liquid
21.   Oil red liquid
22.   Oil blue "B" Liquid
23.   AFA-1
24.   AO-23
25.   DMD-2
26.   DMA-4
27.   FOA-208
28.   Paradyne 20
29.   733-PDA-D-75

30.   Diesel ignition improver-2
31.   Red-B liquid dye

32.   Red-G liquid dye

33.   Orange liquid dye

34.   Orange-R liquid dye

35.   Blue liquid dye

36.   Bronze liquid dye

37.   Black liquid dye

38.   Yellow liquid dye

39.   Green liquid dye

40.   Purple liquid dye
                            American Aniline
                            Betz Laboratories
                            Betz Laboratories
                            Betz Laboratories
                            Betz Laboratories
                            Betz Laboratories
                            Chevron Chemical
                            Dixie Chemical
                            Dixie Chemical
                            Dixie Chemical
                            Dixie Chemical
                            Dixie Chemical
                            Dixie Chemical
                            Dow Chemical
                            McKesson Chemical
                            Dow Chemical
                            E. l.duPont
                            E. I. duPont
                            E. I. du Pont
                            E. l.duPont
                            E. l.duPont
                            E. l.du Pont
                            E. I. du Pont
                            E. I. du Pont
                            E. I. du Pont
                            E. l.du Pont
                            E. l.duPont
                            Enjay Chemical
                            Ethyl Corporation

                            Ethyl Corporation
                            Ethyl Corporation

                            Ethyl Corporation

                            Ethyl Corporation

                            Ethyl Corporation

                            Ethyl Corporation

                            Ethyl Corporation

                            Ethyl Corporation

                            Ethyl Corporation

                            Ethyl Corporation

                            Ethyl Corporation


                                67
250-lb drum
Appr. yearly usage, 7500 gal.
4000 Ibs.
600 Ibs.
1500 Ibs.
4000 Ibs.
LCL-LTL
50-lb bags
100-lb bags
100-lb bags
100-lb bags
150-lb cylinders
2000-lb cylinders
Currently pending
Currently pending
10,000 gal. T/C
T/C or T/T
T/C or T/T
T/C
240-lb drum
240-lb drum
240-lb drum
240-lb drum
240-lb drum
240-lb drum
400-lb drum
400-lb drum
Appr. 390-lb drum
5 drums or more LTL
  55-gal. drums
LTL, 5 drums or more
55-gal.  drums
  240-lb drums
55-gal.  drums
  240-lb drums
55-gal.  drums
  240-lb drums
55-gal.  drums
  240-lb drums
55-gal.  drums
  240-lb drum
55-gal.  drums
  240-lb drum
55-gal.  drums
  240-lb drum
55-gal.  drums
  240-lb drum
55-gal.  drums
  240-lb drum
55-gal. drums
  240-lb drum
                                                                        Arthur!)Little Inc.

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                               TABLE 8 (Continued)
             Chemical

41.  MLA500
42.  Grade 110 catalyst
43,  HZ-1 catalyst
44,  MAF-50R
45.  Liquid  caustic soda
46.  Oxygen
47.  Nitrogen
48.  Hydrogen
49.  AEP-151
50.  Cronox 605
51.  Cronox 624
52.  Cronox 650
53.  Throcon R-1Q
54.  Durabead 6-B Catalyst
55.  Nalco 39
56.  Nalco 161
57.  Nalco 262
58.  Nalco 372
59.  Nalco 373
60.  HF acid
61   United granulated water
        softening salt
62.  Reynolds activated RA-1
63.  Primene81-R
64,  Crushed limestone
     1/2" to 1/4" (S)
     1" to 3/8"
65.  Sulfuric acid
66.  Sulfuric acid
67.  HF acid
68  Hydra ted lime
69.  Sodium sulfite
70.  Aluminum sulfate
71.  Soda ash 58% light
72.  Cat lubricant
73.  Hydrogen
74.  Nitrogen
75.  Oxygen
76.  Polyflo 123
77.  Unicor LHS
78.  Unicor
79.  Cat lubricant

80.   Liquid caustic soda
     Supplier

Ethyl Corporation
Filtrol Corporation
Houdry
Houston Chemical
Jefferson Chemical
Koenig Welding
Koenig Welding
Koenig Welding
Milchem Corp.
Milchem Corp.
Milchem Corp.
Milchem Corp.
Milchem Corp.
Mobil Chemical
Nalco Chemical
Nalco Chemical
Nalco Chemical
Nalco Chemical
Nalco Chemical
Olin Chemical
Ranch & Home

Reynolds Metal
Rohm & Haas
Servtex
 Smith Douglas
 Stauffer Chemical
 Stauffer Chemical
 Thompson-Hayward
 Thompson-Hayward
 Thompson-Hayward
 Thompson-Hayward
 Thompson-Hayward
 UCC
 UCC
 UCC
 UOP
 UOP
 UOP
 Van Waters & Rogers

 Wyandotte Chemical
        Unit

Bulk
70T H/C
70T H/C
Bulk
Bulk
Bulk
Bulk
Bulk
Bulk
Drum
Drum
4T6-lb drum
600-lb drum
50T H/C
500-gal. drum
55-gal. drum
55-gal. drum
Bulk
Bulk
Bulk
100-lb bags (min. order 100)

100-lb burlap bags
Drums
Bulk
 Bulk
 Bulk
 Bulk
 50-lb bags
 100-lb bags
 100-lb bags
 100-lb bags
 50-lb bags (36,000 Ibs)
 Bulk
 Bulk
 Bulk
 LTL
 LTL
 LTL
 36,000 Ibs
 (50-lb. bags)
 Bulk
 LTL = less than tank load
 LCL = less than car load
 H/C = hopper car
                                        68
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Bulk Storage Facilities and Pipelines

     The Texas City Refining plant has extensive tank fields. There are no buried
tanks, and the only buried pipelines are used only to transport hydrocarbons. All
buried lines are  cathodically protected. The tetra-ethyl lead storage tanks offer
considerable potential for property damage and personal injury, and are confined
within a special building that has restricted entry; the storage tanks are mounted
over pit enclosures. The "lead" tanks are subjected  to DuPont/Ethyl inspection
service  which  is  quite  extensive.  The remaining tanks are subjected to regular
ultrasonic integrity testing. No flexible  hoselines are used for the transfer of
hazardous materials.  Diking, trench,  pit, and containment  curb protection  is
provided to  confine accidental spills of acids effectively. The remaining chemicals
(Table 8) are not all protected in this manner.

Past Spill Experience

     A sulfuric acid spill was experienced two years ago, when a fiberglass storage
tank split and  released its acid content. The U.S. Coast Guard records one minor
oil  spill on February 18, 1970 when crude oil overflowed  from a  drip  pan.
Instructions were given  for more frequent inspection and emptying of drip pans.

Spill Control Plan

     Shift foremen, who are on 24-hour duty, have  been trained in spill control
by  the  plant's Safety Department. Spill reports are  routed to top management.
Individual workers are knowledgeable on procedures that should be undertaken to
control an accidental  spill effectively. The plant is an active member of the Texas
City Industrial Mutual Aid Plan (Appendix C).
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Reagent Chemical & Research, Inc.
East Galveston Highway
Texas City, Texas

Contacts: Mr. George J. Melder, Plant Manager
         Mr. Louis A. Claveloux, Manager Engineering (N.J./Hq.)

Date of Survey:    September 1, 1970

Property Description

     The Reagent Chemical & Research, Inc., plant is a new facility that recently
acquired a  building and unfenced,  open-land space on the Texas City Terminal
Railway  property. Work  was under way  to complete  the installation of the
processing and storage vessels at the time of the survey. The operation will involve
the recovery of ammonium chloride from 20% to 25% ammonium chloride liquor
effluent originating from the nearby Monsanto Company plant. The anticipated
annual production  of ammonium chloride recovery is in the vicinity of 8 million
bbl/year. Plant drainage has been estimated at 40,000 to 48,000 gpd through an
open ditch across  the  Railway property into Galveston Bay. The predicted
effluent  analysis,  as  filed  with the  State Water Pollution  Control  Board in
Houston, is 72% water, 25% ammonium chloride, 2.896% methanol, 0.1% methyl
lactate, and 0.004% organic nitrates.

Hazardous Materials

     Hazardous materials handled by Reagent Chemical & Research, Inc., include:

     •   Ammonium chloride  liquor (20-25%);  maximum storage
         capacity, 99,000 gal.;

     •   Hydrochloric  acid  (32%);  maximum  storage  capacity,
         6000 gal.;

     •   Anhydrous  ammonia; maximum storage capacity, 2000
         gal.; and

     •   Methanol.

Since the plant was not in active production at  the time of the survey, the annual
consumption of listed  materials could not be assessed.
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Bulk Storage Facilities and Pipelines

     The  plant  has  three  33,000-gal. capacity, undiked, ammonium chloride
liquor  (20-25%) storage  tanks. The tanks have a 0.5-inch  wall  thickness,  are
rubber-lined, and were originally mounted on a marine barge owned by the Dow
Chemical Company. The tanks, which were recently hydrostatically tested, will be
open-vented when  in service. The firm also has a new 6000-gal. capacity fiberglass
constructed hydrochloric  acid (32%) storage tank that has  also been  pressure-
tested  and will be open-vented when in service. The remaining tank, a 2000-gal.
anhydrous ammonia storage unit,  has been  built and equipped to all ICC code
specifications.  All  exposed pipelines and valves are of 2-inch diameter PVD and
PVC construction. U.S. Navy tests of this type pipe  for retaining core samples
indicates very  little dehydration of the cores, although the design of the valves
makes  it almost impossible to lock them in the closed position. The ammonium
chloride liquor will be  transferred from the Monsanto plant during daylight hours
(8 a.m. to 4 p.m.) in below-ground  fiberglass pipe. The finished product -
reclaimed ammonium chloride - will be bagged for shipment.

Past Spill Experience

     None to date.

Spill Control Plan

     Plans are under way to install a security fence around the bulk storage area
and to cover the ground within the storage tank area with an oyster-shell surface.
Although  none of the  tanks is equipped with high liquid-level alarms, an alarm
device  has been installed as an integral part of the production system. The plant
would  have the  immediate assistance of Texas City Terminal Railway and Mon-
santo spill specialists in the event of an emergency.
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 B.  BALTIMORE, MARYLAND

     The City of Baltimore, located  on the Patapsco River near its entry into
 Chesapeake Bay, is one of the major harbor ports of the United States. The city
 and the harbor areas it surrounds —  and to which it is adjacent — handle large
 amounts of materials from ships, barges, railroads, and trucks.

 1.  Drainage

     The drainage  from the city and its industrialized areas into the Patapsco
 River and the Chesapeake Bay emanates from the following major points:

     1.    Jones Falls, draining into the Inner Harbor and the North-
          west Branch of the Patapsco River;

     2.    Gwynns  Falls, draining into the Middle Branch of the
          Patapsco River;

     3.    Curtis Creek, draining into  Curtis Bay and  then into the
          Patapsco River, and

     4.    Colgate Creek, draining into  the Patapsco River.

     Because of the large number of industrial plants located  on or near the
harbor area, drainage occurs  directly from property into the river and bays from a
large number of outlets.

2. Potential Source of Hazardous Spills

     Before beginning  field  surveys of the Baltimore area, information on the
nature of the industries involved, the size of their operations, and records of past
spills of hazardous materials was sought. An excellent index of the probable major
sources  of potentially  hazardous  spills  was obtained through  reviews of the
Directory of Maryland Manufacturers for 1969-1970  and the Waterborne Com-
merce of the United States  for  the Calendar Year 1968. For example, approxi-
mately 75% of the total port tonnage  is represented by ores, coal, and petroleum
products, with each totalling approximately 25% of the total. The major bulk-
liquid hazardous material handled in Baltimore is sulfuric acid which accounts for
slightly  over  1% of the  total port traffic.  Liquid sulfur, sodium hydroxide,
molasses, and a number of chemical products not otherwise classified contribute
slightly over 1% of total port traffic on a combined basis.
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     Based on our assessment of the port traffic, it was apparent that manufac-
turers or users of basic bulk chemicals would be expected to present the greatest
potential for spills of hazardous materials because of the volumes handled and the
frequency of handling. Consequently, we established a tentative list of sources for
discussion  with  members  of the Baltimore  Harbor  Project of the  Maryland
Department of Water Resources.

     The inner harbor in Baltimore appeared to  be the most polluted waterbody
observed during the  survey. Floating solid debris was much in  evidence on the
surface  of the  water. Chemical runoff from open   stockpiles of material  is
common, and many  hues were evident during an aerial survey we made. Although
a number of extensive  spills have taken place, constant effluent discharges create
the greatest problem  in the area.

     As a result of  the reviews cited above, we selected certain plants  for the
survey. The reports of this survey follow.

3. Past Spill History

     In  discussions with members  of the  Maryland  Department of Water Re-
sources, Baltimore City Sewers, U.S. Coast Guard, Maryland Port Authority, and
the Corp of Engineers regarding past spills of hazardous materials, we found that
the recent (July 1970) spill of concentrated sodium hydroxide into the harbor is
the only one that  was documented to any  degree. Other spills  or  entries  of
hazardous materials, such as creosote,  paints, dyestuffs, plating  solutions, pickle
liquors, and so on, were mentioned, but very little definitive information could  be
obtained. In some spill instances, such as dyes and pickle liquors, the sources have
been established, with orders issued the offending firms to adopt methods for
preventing such spills from entering water courses in the future.

     We  got the impression  that  these  spills  could  be  largely attributed  to
operational inattention or poorly designed facilities. The past history of spills was
traceable largely to visible or floating substances, such as creosote, paint, or dyes,
to larger scale spills, such  as the concentrated  sodium hydroxide spilled during
transfer to a barge by Keystone Shipping Company's vessel, the Chancellorsville,
or to toxic substances, such as heavy metals. The spills were detected by various
methods.  The  large number of small spills that  could have  occurred  during
transfer operations at plants, loading terminals, and so on, could  have contributed
significant  amounts of hazardous materials to the water courses, but in individual
quantities difficult to document.
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Continental Oil Company
3441 Fairfield Road
Baltimore, Maryland

Contacts: Mr. Frank Wilson, Safety Director
         Mr. Alan Goldfarb, Chemist

Date of Survey:       September 1, 1970

Property Description

    The Continental Oil Company plant (Figure 11), located on the Patapsco
River, has provisions for receiving  and shipping hazardous  materials by ocean
tanker and barge. Finished products are shipped by truck, tank car, and tanker.

Hazardous Materials

     The plant manufactures detergent alkylates from petroleum fractions. The
hazardous raw materials are chlorine, sulfuric acid,  and  concentrated  sodium
hydroxide solutions.  Spent mixed acids (hydrochloric and sulfuric) are produced,
along with  hydrochloric acid and an aluminum chloride solution which are sold as
by-products.

Bulk Storage Facilities and Pipelines

     Sodium hydroxide (50%) is stored in a 1000-barrel (42,000 gallon) tank in a
diked area. Sulfuric acid is stored in two 125-barrel tanks; these are not presently
located in  a  diked area, but they  will eventually be diked. Hydrochloric acid
generated in the process is stored in a 5000-barrel tank for shipment as it is sold.
Spent mixed acids are stored in two curbed tanks of 300 to  400 barrels, and an
aluminum chloride by-product solution is stored in six fiberglass-reinforced tanks
estimated to hold about 15,000 gallons each.

Past Spill Experience

     The Continental Oil dock  was the scene of a large spill of concentrated
sodium hydroxide during  transfer from  tanker to barge by companies  using
Continental's facilities, but the caustic  was not destined for its use. There have
been no other spills of hazardous materials in large quantities.
                                    74

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                                         Photo Courtesy of Air Photographies. Incorporated
FIGURE  11  AERIAL VIEW OF BALTIMORE, MARYLAND, HARBOR SHOWING
           GENERAL LOCATION OF CONTINENTAL OIL COMPANY
                               75
                                                              Arthur D Little Inc

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Spill Control Plans

     There is a large supply of oyster shells stored near the diked area which
contains the  hydrochloric acid. The oyster shells are used to neutralize occasional
spills made in transfer operations. The water from the diked areas can be drained
through valved sewer connections and will thus pass through an API separator and
beds of oyster shells before entering the Patapsco River. Operating personnel have
a manual outlining protective procedures, and safety meetings held periodically
stress these procedures.  Notifications  of spills go to the shift foreman who must
make rapid  spot-decisions on methods of handling  them. However,  since such
spills commonly  occur  in normal plant  operations, the quantity is not large.
Because of the chlorine handling,  all personnel entering the plant are equipped
with gas masks.  The potential for spillage  at this plant appears minimal,  and
fail-safe methods  exist for the containment of most hazardous materials. Comple-
tion of the diking around the sulfuric acid tanks and completion of the dike
maintenance program already under way should materially improve the capability
for controlling spills.
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Swift & Company
2000 Chesapeake Avenue
Baltimore, Maryland

Contact: Mr. Cue, Plant Manager

Date of Survey:       September 2, 1970


Property Description

     The Swift & Company property, located on the Patapsco River at the end of
Chesapeake  Avenue,  is the former Mobil Oil  fertilizer  plant which has been
converted exclusively to the production of dry mix fertilizers.

Hazardous Materials

     Nitrogen solutions, anhydrous ammonia, phosphoric acid, and sulfuric acid
constitute the hazardous materials in this plant.

Bulk Storage Facilities and Pipelines

     Liquid  raw materials  are brought in by tank car in  the case of nitrogen
solutions, phosphoric  acid, and anhydrous ammonia. Sulfuric acid is delivered by
tank  truck.  These materials are stored in diked tankage  areas, the maximum
storage capacity  of which is approximately 25 tons  for anhydrous ammonia, and
90  to 100  tons for  the other materials. The unloading rates are low and the
pipelines are small and of limited length.

Past Spill Experience

     There have been no spills of any consequence because every effort is made to
contain the valuable raw materials.

Spill Control Plans

     Unloading and transfer procedures are dictated by standard companywide
procedures and insurance safety regulations. No provisions for drainage of water
from  diked  tank areas through waste treatment  plants have been made. Drainage
sewers empty into a ditch, but they have never been  needed, since the porosity of
the ground is sufficient for natural percolation to take care of the rainfall within
the diked area.  The  major spill problem  at Swift exists  in the  potential for
percolation  into the  ground  water. Because of the small amount  of chemicals
handled and the reactive nature or biological utilization, a spill is judged to have
low potential for significant contamination.


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Alcolac Chemical Corporation
3440 Fairfield Road
Baltimore, Maryland

Contact: Dr. Peter P. Bouroff, Director of Research

Date of Survey:       September 2, 1970

Property Description

     The Alcolac Chemical plant is located on property with no river frontage.
Drainage from the plant goes to a storm drain that ultimately enters Curtis Bay
through Stonehouse Cove. The property is fenced. This plant produces detergents
as its major product line, along with a number of special chemicals.

Hazardous Materials

     The raw materials are mostly water-soluble  liquids.  These include  sulfuric
acid,  chlorosulfonic  acid, liquid  sodium hydroxide, anhydrous ammonia, and
organic compounds,  such  as  fatty  alcohols,  trie thy lenemelamine,  diethylene-
melamine, ethylene oxide, acetone, and isopropanol. Some process intermediates
are active monomers.

Bulk Storage Facilities and Pipelines

     Raw materials  and products are shipped by tank  cars and  tank trucks.
Sulfuric  acid  is  stored in tanks ranging in size from 1,000 to 14,000  gallons;
sodium hydroxide is stored in 15,000-gallon tanks. In-process tanks of various sizes
are used. Storage tanks are  generally located in diked areas or in process plants
equipped with curbing and  drainage. Hydrochloric acid as a 28-30% solution is
stored prior to shipment. The firm would not release a breakdown of individual
volumes  of chemicals handled. Alcolac usually  ships about 3 to 4 million pounds
of products per  month which  requires some 2 to  3 million  pounds of liquid raw
materials.

Past Spill Experience

     Spills  at Alcolac  have all been  minor, and have taken place in areas where
clean-up or recovery was possible.
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SpiU Control Plan

     Automatic dumping procedures, along with containing tankage, are incorpo-
rated into the process at  Alcolac  because  of personnel hazards and property
protection requirements. Plant drainage proceeds through beds of marble chips
for neutralization prior to running into  a  storm drain that enters Curtis  Bay
through  Stonehouse Cove.  In-plant control of spillage is based largely on  per-
sonnel safety requirements. Good housekeeping, pressure from regulatory groups,
and  the  fact that Alcolac  has a water pollution  control subsidiary combine to
make the company quite conscious of its image, resulting in a low potential for
hazardous  spills at this site. Also, the final products are biodegradable materials
which, for minor spills, might be readily treated by natural biological processes.
Some solid wastes and sludges are  sent to a landfill area operated by a licensed
contractor. Plant  drainage water is monitored for pH and the instruments are
alarmed.
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 Environmental Technology, Inc.
 6001 Chemical Road
 Baltimore, Maryland

 Contact:  Mr. Robert Taylor, Owner

 Date of Survey:       September 3, 1970

 Property Description

     Environmental  Technology, Inc., on  a rental basis, uses the  property on
 Chemical Road for pilot plant work  on a proprietary waste treatment process.
 The company also leases storage tank facilities at the site of the former duPont
 plant on Curtis Bay. The storage tank facilities were not visited.

 Hazardous Materials

     This company is operating a waste collection service in the Baltimore area.
 Its service consists of storing wastes for future processing. The wastes are segre-
 gated only on the basis of corrosivity since some of the tankage is constructed of
 plain carbon steel.

 Bulk Storage Facilities and Pipelines

     The  concern has  leased a  200,000-gal.   rubber-lined tank,  in  which it
 proposes   to  store  corrosive  wastes, and two carbon steel tanks,  one of
 150,000-gal. and the other of 2,000,000-gal. capacity. The firm  has made arrange-
 ments  with a local transport company, Skyline Transport, to collect the wastes.
 Only about 10,000 gallons of waste are in storage at the present time. We did not
 see the tankage. However, we were told that the tanks in which  organics are
 stored, presumably the 150,000- and 2,000,000-gal. carbon steel ones, are diked.

 Past Spill Experience

     None has occurred.

 Spill Control Plan

     Diked storage is apparently the  only  control plan since  disposal  methods
have not yet been developed.
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Minerac Corporation
3520 Fairfield Road
Baltimore, Maryland

Contact: Mr. L. E. Strow, Plant Manager

Date of Survey:       September 3, 1970

Property Description

     The Minerac plant, which is land-locked, is located about 500 yards from the
Patapsco River. Its drainage goes into a small stream which enters the river. The
entire area is fenced.

Hazardous Materials

     The  company manufactures and ships proprietary chemical formulations
used in the  mineral dressing industry, but it would not identify  them. However,
we did ascertain that the raw materials it uses include sodium hydroxide, sulfuric
acid, carbon disulfide, and various alcohols.

Bulk Storage Facilities and Pipelines

     All chemicals  are  received in tank cars  or tank trucks and products are
shipped out in tank cars and drums. Various small tanks up to  10,000 gallons in
capacity are used to store chemicals; most of these tanks are located in buildings.
Carbon disulfide is stored in an underground  10,000-gal. tank for fire insurance
reasons. Permission to survey the plant was not granted, and no listing of tankage
volumes or plant production was released by  the firm.

Past Spill Experience

     Minerac,  according to its management, has had waste disposal problems, viz.,
sodium sulfides and some nickel and sludge  washings from tanks. Those effluents
have apparently come from poor control of wash waters, and so on, and not from
uncontrolled spills.

Spill Control Plan

     No special plan  for  handling spills exists,  other than those  for routine
operations. Curbed areas in the process buildings arc drained through a limestone
pit to meet  pH regulations on effluents. At the present time, up to 10,000 gallons
of a sodium sulfide solution might be stored, awaiting pickup by Rollins-Purle
with whom  Minerac has a contract for waste disposal. These wastes are trucked to
the R-P P'ant  i° New Jersey DV Matlack. Transfer rates for loading and unloading
are in the low  hundreds of gallons per  minute range. The small  size of the
operation and the  value of the product indicates that the potential for significant
spillage entering a water course is quite limited.

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 SCM-Glidden-Durkee
 Hawkins Point Road
 Baltimore, Maryland

 Contact: Mr. Leonard D. Burgess, Pollution Control Engineer
          Process Engineering Department

 Date of Survey:       September 4, 1970

 Property Description

     The SCM-Glidden-Durkee plant  is located  on Hawkins Point Road in the
 lower Patapsco River. Its principal product is titanium dioxide. Drainage from the
 area ultimately reaches the river. Apparently the plant has good security protec-
 tion. Permission  to inspect the property could not be obtained  so the following
 information is based on answers to questions posed.

 Hazardous Materials

              Sulfuric acid
              Sodium hydroxide (50% solution)
              Hydrochloric acid
              Aqua ammonia
              Chlorine

 Bulk Storage Facilities and Pipelines

     Sulfuric acid is barged into the plant from local sulfuric acid manufacturers
 and off-loaded into a 2000-ton  undiked storage tank located approximately 600
 feet from the Patapsco River at Hawkins Point. Another (approximately 500-ton)
 storage tank is used along with numerous  in-process tanks of unspecified size.
 Sodium hydroxide as a 50% solution is brought into the plant by tank trucks and
 stored in two 5000-gallon tanks. Hydrochloric acid is delivered by tank truck and
 stored in a 16,000-gallon tank.  Aqua ammonia is delivered to the plant by tank
 car and is pumped into  a 16,000-gallon  tank. Chlorine  is received in tank cars
 from which it is used directly.

Past Spill Experience

    Past  spills have all been local in  nature,  involving broken lines, leaking
pumps, and so on, and have been handled efficiently.
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Spill Control Plan

     SCM's in-plant handling facilities can best be described as conventional for a
chemical plant.  Since  easily  traceable solids (colored)  can be emitted, Glidden-
Durkee uses  holding ponds for settling prior to emission into the river. A major
effort is made to control pH and, we were told, provisions are made to neutralize
before waste waters enter the settling basins in  the river. Operating personnel are
trained in spill cleanup around outside tanks, especially with respect to acids, and
supplies of limestone are available for pouring onto acid spills.
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 Leidy Chemicals
 900 South Eutaw
 Baltimore, Maryland

 Contact:  Mr. Tom Strohm, Vice President

 Date of Survey:       September 4, 1970

 Property Description

     The  Leidy Chemicals plant is located in Baltimore in rather old buildings
 which are conveniently located for rail and truck shipments. Its drainage runs into
 the Baltimore sanitary and storm sewer system. The premises are fenced, although
 tank car sidings are located on a commercial street and are not secured.

 Hazardous Materials

     The list of hazardous materials is essentially that of bulk commercial chemi-
 cals. Those which have the greatest  spill potential are listed in the following
 section.

Bulk Storage Facilities and Pipelines

     Volatile liquids are stored in an  underground tank according to Baltimore
Fire Department regulations.   The following storage volume  estimates  were
provided:
         Hydrochloric acid
         Hydrofluoric acid
         Sulfuric acid
         Acetic acid
         Inhibited hydrochloric acid
         Ferric chloride solution
         Nitric acid
         Phosphoric acid
         Sodium hydroxide
         Volatile solvents
         Anhydrous ammonia
         Aqua ammonia (30%)
         Chlorine
15,000 gallons
15,000 gallons
15,000 gallons
10,000 gallons
 6,000 gallons
 6,000 gallons
 8,000 gallons
Not provided
Tank cars on rail sidings
Two 7500-gal. tanks, three 5000-gal. tanks
18,000 gallons
35,000 gallons
Usually less than six 100-lb cylinders
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Most loadings and unloadings are made from the top of the tanks. Consequently,
air pressure transfer is effected. Many of the chemicals  must be packaged  and
shipped according to ICC regulations.

     The following general information on magnitude of major chemicals handled
was provided:

     Hydrochloric acid and sulfuric acid — one tank car/week each
     Hydrofluoric acid — one tank car/month
     Nitric acid - two tank cars/month
     Ferric chloride - 50,000-60,000 gallons/year
     Inhibited hydrochloric acid - 50,000-60,000 gallons/year
     Volatile liquids  - 1 million gallons/year

Past Spill Experience

     Leidy has a  low accident rate which, it purports, stems from the necessity of
achieving  the best  possible insurance  rates. The  Baltimore Fire Department
regularly inspects the premises. Because of the large number of transfers, there is a
large number  of  drips, and  so  forth.  Consequently, a large amount of flushing
water is kept flowing in the plant. No large spills have occurred at this facility,
although small drips are an inadvertent aspect of its operation.

Spill Control Plan

     In the acid handling areas, the water collected from drainage areas is passed
through beds of marble chips for neutralization before going into a storm sewer.
It is apparent that dilution and flushing will become the  method of coping with
spilled  chemicals. The installation  is well operated for receiving, repackaging,
warehousing, and shipping. The tankage and equipment seem to be well main-
tained  and of modern design, although the building is very old. Transfer hoses are
inspected and  serviced on a monthly basis by an outside contractor.

     At this  location, any  spill enters  the storm sewer system;  of  course, a
significant  portion of the acids is removed  by neutralization. The  unloading of
sodium hydroxide from tank cars on the siding occurs along the street  front and
any  spill runs down the gutters into the sewers. In this case the ICC regulations
regarding tank car designs may be adequate protection unless a tank ruptures.
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Davison Chemical
W. R. Grace Company
101 North Charles Street
Baltimore, Maryland

Contact: Mr. Bert Mobley, Pollution Control Engineer

Date of Survey:       September 16, 1970

Property Description

     The  Davison plant is located on Curtis Creek. Permission to inspect the
property could not be  obtained. However, the results of questions posed their
representative are presented below.

Hazardous Materials

          Liquid sulfur
          Sulfuric acid
          Oleum
          Sodium  silicate
          Phosphoric acid

Bulk Storage Facilities and Pipelines

     Molten sulfur is received  via  tank  ship, and it was surmised that about
10,000 tons are off-loaded into a tank estimated to  have a storage capacity of
about 10,000  tons. This tank, which is not diked, is located about 150 feet from
Curtis Creek. Unloading rates are unknown, but are estimated to be as great as a
1000 tons per hour.

     Sulfuric  acid is  shipped out  by barge, rail, and truck, with spent  acid
returned to the plant in the same manner. It was estimated that at least 12 tanks
were  used to store sulfuric acid,  with  the  capacity  ranging from  50,000 to
500,000 gallons, i.e., from perhaps 375 to nearly 4000 tons. We estimate that the
firm could  possibly store between 10,000  and  20,000 tons of  concentrated
sulfuric acid at any time. Tanks are not diked and high rate transfers are made
through a 6-inch line (indicating that transfer rates of possibly 800 to 1000 gpm
are used). We were told that the usual provisions of valving, pumping, and so on,
are made for notification of spills. No estimate of yearly tonnage was provided.
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     Phosphoric acid is brought into the plant in railroad tank cars, and is used
directly  from these cars.  Very few  cars  are used  per year. A  sodium silicate
solution  is made and stored. It was estimated that maximum storage might involve
three to  four tanks, each  containing from 50,000 to  100,000 gallons. Alkaline
filtrates  are stored in  small quantities (unspecified) and used  to neutralize acid
wastes or sold to other companies for neutralization.

Past Spill Experience

     All  spills have been of a  localized  nature and  handled by established pro-
cedures,  such as the neutralization of acids by lime or oyster shells.

Spill Control Plan

     At the Davison plant, waste water from process areas and cooling waters run
into a lagoon. Monitoring of pH (acid or caustic addition) is used  to ensure that
records are maintained for regulatory purposes. Continued pH values outside of a
nominal range call  for shutdown and repair of equipment.
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Manganese Chemicals
Diamond Shamrock
711 PittmanRoad
Baltimore, Maryland

Contact:  Mr. Kenneth W. Olson, Engineer

Date of Survey:       September 14, 1970

Property Description

     The Manganese Chemicals plant extracts manganese chemicals from ore. The
plant drainage system ultimately discharges into Curtis Creek before  reaching
Curtis Bay.  Normal plant security fences were in place, and security personnel
were  obvious  since the plant was on strike. The plant is about  10 years old and
seems to be well maintained; however, because of the nature of its processes, it is
not especially  clean looking.

Hazardous Materials

     Hazardous materials handled in its operation include:

          •  Sulfuric acid                 • Hydrochloric acid
          •  Aniline                     • Propane
          •  Nitric acid                  • Liquid nitrogen
          •  Liquid chlorine

Bulk Storage Facilities and Pipelines

     The major hazardous materials are brought in by  tank car and tank truck.
The estimated storage capacities for these materials were given as follows:

            Sulfuric acid (66° Be) (tank truck)          8,000-10,000  gallons
            Aniline (tank car)                          10,000 gallons
            Nitric acid (tank truck)                     4,000 gallons
            Liquid chlorine (tank car)                  Used  from tank car
            Hydrochloric acid (20°Be) (tank truck)      8,000 gallons

Both liquid  nitrogen and propane are stored, the latter in a well-diked area.
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Past Spill Experience

     Plant spills have been limited to small quantities such as sometimes occur in
process areas due to  line breakage,  pump gland failures, and so on. Such spills,
which involved only the acids and aniline, have been localized; no spill of liquid
chlorine has occurred.

Spill Control Plans

     The local fire department has equipment for handling chlorine leaks and the
company  relies  on this source. Aniline  is stored in a curbed area,  along  with
hydrochloric acid,  whereas the other tankage storage areas have no curbed or
diked zones. Top loading and unloading techniques are preferred for transfer and
are normally used. In-plant surge  tanks are provided, and a diked pond  with no
outlets is provided for retention of liquids which cannot enter the waste water
stream from the plant.

     Settling ponds are used to collect water primarily to  remove suspended solids
before discharge into  Curtis Creek. The suspended solids' content is usually less
than  100 ppm,  well below the  permissible  level.  In-plant  handling of spills,
notification, and the like, are based principally on personnel safety and economic
losses.
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Mutual Chrome
Allied Chemical Company
Block and Willis Streets
Baltimore, Maryland

Contacts:    Mr. Edward Walsh, Assistant Plant Manager
            Mr. Nick Borodulia, Industrial Hygienist

Date of Survey:         September 15, 1970

Property Description

     The Mutual Chrome  plant (Figure  12), which is located on the northwest
branch of the  Patapsco River at  the entrance to  the inner harbor,  has some
drainage still going into the river.  Guards and security fences prevent unautho-
rized  access to the plant from  the land side; however,  access could be easily
achieved from the  harbor by boat.  Housekeeping appeared quite good for an ore
processing plant.

Hazardous Materials

     The  major hazardous raw  materials handled at Mutual Chrome  include
sulfuric acid, oleum, and ammonia. In addition, various chromate and dichromate
chemical products fall into the  hazardous materials category.

Bulk Storage Facilities and Pipelines

     Sulfuric acid  (66° Be) and oleum (> 100% H2SO4) are received  by barge,
with each unloaded into an individual 75,000-gal. tank. The unloading rates are
typically in the range of 200 to 300 tons per hour. Barge shipments of -approxi-
mately 1000 tons are received weekly. Anhydrous ammonia is used intermittently
upon demand in which case it is used directly from the tank car. Liquid potassium
hydroxide is used  infrequently, also directly from the tank car. The plant also
serves  as  a  transshipping plant  for Allied  Chemicals 50% sodium hydroxide
solutions,  and from 7 to 10 tank cars per month are off-loaded into tank trucks.
The barge unloading area has flexible hoses, and the pipeline to the sulfuric acid
tanks is relatively short. A fuel oil  tank  is surrounded with a high concrete wall
over which all piping goes; many other tanks  are in curbed areas, but no other
tanks are diked as the oil tank.

     Other tankages which exist at this plant are listed below:
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         1 - 75,000-gal. tank, approximately 25% sodium bichromate
         2 - 80,000-gal. tanks - sodium chromate
         2 — 40,000-gal. tanks — mixed chromates
         6 — 10,000-gal. tanks — mixed chromates
         2 — 30,000-gal. tanks — weak dichromates
         1 - 10,000-gal. tank - treating solutions
         1 - 10,000-gal. catch-all tank
         1 - 6,500-gal mix tank
         1 — 8,000-gal. chemical run tank
         1 - 15,000-gal. in-process sulfuric acid tank.

Past Spill Experience

     This plant  has had difficulties in the past due to chromium  chemicals
entering the surrounding waters. The personnel admitted, quite frankly, that these
spills were caused by poor attention to operating details, problems during startup
operations of new processes, and inadequate retention of the small leaks and spills
that occur in the normal operation of liquid-handling processes. Large spills from
storage tanks have never occurred, according to the plant personnel contacted.

Spill Control Plans

     The plant plans to install more curbed areas and to eliminate all potentials
for process  spills escaping from off the premises.  The unloading facilities appear
adequate, but are not especially outstanding. Apparently the plant is operated in
a manner which brings it little trouble from  the Maryland Department of Water
Resources. Surface drainage from the  area enters the harbor. Any catastrophic
spill, such as a rupture of one or more larger tanks, would enter the harbor.

     The plant has a well-documented  action plan for dealing with hazardous and
catastrophic accidents. The plan, dated August 1969, included information such as
individual persons, lines of authority, local  authorities, and the like. Although
certain improvements could be made in housekeeping and appearance, the general
impression is that the operational procedures are reasonably  tight and that the
professed plans have been directed toward abating past pollutional excesses.
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                                                     Photo Courtesy of Air Photographies, Inc.
FIGURE 12  AERIAL VIEW OF BALTIMORE, MARYLAND, HARBOR SHOWING GENERAL
            LOCATION OF MUTUAL CHROME, ALLIED CHEMICAL COMPANY PLANT
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Hynson, Westcott and Dunning
1030 North Charles Street
Baltimore, Maryland

Contact:  Mr. C. Baxter McLaughlin, Product Manager

Date of Survey:       September 16, 1970

Property Description

     The Hynson, Westcott and Dunning property is located near the heart of the
city  in  a  section near hotels and professional buildings. Its external appearance
belies the fact that it is a manufacturing plant. All spills or drainage go into the
Baltimore  city  sewers.  We  were not permitted  to inspect the  manufacturing
facilities.

Hazardous Materials

     Hazardous materials handled at the plant include:

            • Glacial acetic acid              •  Acetone
            • Bromine                       •  Various Pharmaceuticals
            • Sulfuric acid                   •  Mercury compounds

Bulk Storage Facilities

     The raw materials are received in carboy and drum lots, so there  is no bulk
storage. The amounts used annually were estimated as follows:

            Glacial acetic acid                 600-700 Ib/yr
            Bromine                        1000-1200 Ib/yr
            Sulfuric acid                     4500 Ib/yr
            Sodium hydroxide (flake)         3500 Ib/yr

Past  Spill Experience

     The company has been  cited for spills by  the Department of Water Resources
Hue  to  the entrance of highly colored dyes, such as fluorescein,  into the harbor
through storm drains.

Spill Control Plan

     The  company is having a  collection and neutralization system installed in
response  to a citation  by  the  Department of Water  Resources, and  is making
orovisions for putting the treated waste water from this system into the sanitary
sewerage system of Baltimore.
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National Starch Company
700 South Caton
Baltimore, Maryland

Contact:    Mr. George Meily, Plant Superintendent

Date of Survey:      September 15,  1970

Property Description

     The National Starch Company plant is located on an elevated area quite a
distance from  the  street;  however,  there appears  to  be little plant security.
Cooling water  and  boiler blowdown drain from an area behind the plant and
ultimately to Maiden's  Choice Run which empties into the Middle Branch of the
Patapsco River.

Hazardous Materials

     Hazardous materials handled at National Starch include:

            • Formaldehyde
            • Hydrochloric acid
            • Mercury compounds

Bulk Storage Facilities and Pipelines

     There are  no bulk storage facilities at National Starch, since its demands for
hazardous  materials are  met  by  shipments involving 55-gal. drum lots. The
maximum usage rate is  two or three drums per week.

Past Spill Experience

     No spills have occurred.

Spill Control Plan

     A spill control plan exists only for protection of personnel. Volumes handled
indicate that spill potential is minimal.
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Olin Corporation
Curtis Bay Plant
5501 Pennington Avenue
Baltimore, Maryland

Contacts:   Mr. Moon, Plant Manager
            Mr. Charles Estep, Facilities Engineer

Date of Survey:       September 17, 1970

Property Description

     The  Olin Corporation plant is located on Curtis Bay and has its own dock
facilities.  Its major products are  sulfuric acid and oleum. The area is bounded by
Pennington  Avenue, a major industrial trucking  route. Its drainage  flows into
Curtis Bay and water from the bay is used for once-through (single pass) cooling
of process equipment.

     Cooling water is pumped in quantities to 13,000gpm. The general appear-
ance of the plant  indicates good maintenance, and obsolete  facilities are being
removed to maintain the appearance.

Hazardous Materials

     Hazardous materials handled at the Olin Corporation include:

            • Molten sulfur
            • Sulfuric acid
            • Sodium hydroxide.

Bulk Storage Facilities and Pipelines

     Molten sulfur is received from tank ships and transferred into two tanks,
each capable of storing  12,500 tons. Sulfur  is unloaded at  the rate of 1500
tons/hour through  steam-heated  lines. The sulfur storage tanks appear to be well
maintained in an undiked storage area near Pennington Avenue and the docks. In
the event  of tank failure  the earth gradient would  drain the acid directly into the
water course.  A very limited amount of molten  sulfur is transshipped  in tank
trucks. Sulfur is received  approximately monthly in quantities from 5000 to
20,000 tons.

     Concentrated  sulfuric acid and oleum are stored in quantities up to 18,000
tons. The maximum  capacity of an individual tank is 5000 tons. Sulfuric acid can
be loaded aboard barges  at rates up to 400 tons/hour. Three to five barges per
month are loaded  in the range of 1500 to 2500 tons. Some  30 to  40 barges,

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 carrying up to 150 tons, may be loaded per month. Tank car shipments average
 15 per month, while tank  truck loadings vary between 100 and 150 per month.
 Spent acid is collected at this plant for barge shipment to other Olin plants, and
 some 30  to 40 tank truck shipments per month are received. The barge-loading
 facilities for sulfuric acid  are separated from the sulfur unloading facilities. The
 acid is pumped through overhead lines aboard the barges through swing-joint
 pipes, with a manually  operated valve  located at the base  of the swing-joint
 assembly. The  operator responsible for loading has the stop-start station for the
 loading pump located near  the shut-off valve.

 Past Spill Experience

     No spill of any significance has ever occurred in the plant.

 Spill Control Plan

     During unloading, both Olin and ship crew members are responsible for
visual monitoring of the unloading lines. The dock is equipped with warning lights
as required  by the U.S. Coast Guard  Regulation  1-21-16,  dated  January 1968,
regarding  security  of vessel and waterfront facilities. These  lights are to warn of
the loading or unloading of  hazardous cargoes.

     The return stream is monitored for pH, and should an acid leak occur, the
plant is shut down for repair. Supervisory personnel are present  on an around-
the-clock basis  at  the plant. The  general appearance of the plant indicates good
housekeeping operations, and  we judge the potential for a hazardous spill to be
minimal.
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FMC Corporation — Baltimore Plant
Organic Chemicals Division
1701 East Patapsco Avenue
Baltimore, Maryland

Contact:  Mr. J. Ford Wilson, Manager
Date of Survey:
Property Description
September 17, 1970
     The FMC Corporation plant at Baltimore is located on Curtis Bay. Although
a slip exists alongside the plant, it appears unused, since shipments to and from
the plant are  made  by truck and rail. Various processing areas are  scattered
throughout the area which is well secured from the land side. Area drainage goes
into Curtis Bay from a number of points.

Hazardous Materials, Bulk Storage Facilities and Pipelines

     A large number of organic chemicals are handled and manufactured. A listing
of the storage capacities of the major chemicals follows:
     Ethanol
     Methanol
     Methylene di-bromide
     Toluene
     Anhydrous ammonia
     50% sodium hydroxide

     66° Be"H2SO4

     Hydrochloric acid
     Aniline
     Allyl alcohol
     Chlorosulfonic Acid
     Dimethyl succinate
     Diketene
     Orthonitrophenol
     Sodium ethylate
     Ethyl acetate
     Aqua ammonia
     Methyl di-bromide
     Sodium nitrite
     Diethylcarbonyl
                     10 -  10,000-gal.
                      6 -  10,000-gal.
                      1 -  7,800-gal.
                      2-  13,000-gal.
                      1 -  20,000-gal.
                      4 -  10,000-gal.
                      3 -21,000-gal.
                      1 -  10,000-gal.
                      1 -  15,000-gal.
                      3 -  10,000-gal.
                      1 -  8,000-gal.
                      8 -  10,000-gal.
                      1 -  5,000-gal.
                      1 -  10,000-gal.
                      1 -  8,000-gal.
                      1 -  14,000-gal
                      2 -  10,000-gal
                      1 -  16,000-gal
                      1 -  14,000-gal,
                      1 -  8,500-gal
                      1 -  15,000-gal
                      2 -  10,000-gal
 tanks
 tanks
 tank
 tanks
 refrigerated tank
 tanks
 tanks
 tank
 tank
 tanks
 tank
 tanks
 tank
 tank
tank
 tank
 tanks
 tank
 tank
 tank
, tank
, tanks
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    Di-allyl phthalate monomers             8 - 10,000-gal. tanks
    Unsymmetrical dimethyl hydrazine       2 - 50,000-gal. tanks
    Ethyl and methyl chloroformate         3 - 10,000-gal. tanks
    Methyl chloride                        2 - 10,000-gal. tanks

    Other chemicals handled in drum lots and occasional tank cars are:

    Butyl carbitol                         Orthotoluidine
    Diethyl amine                         Trichlorobenzene
    Monochlorobenzene                   Triethylamine
    Orthochloraniline
     Several tanks  are  located  in  diked areas, but  there  is  no effort  being
expended to ensure that the volume in the diked areas is greater than the sum of
the stored volumes.

Past Spill Experience

     Plant  spill  experience  has been  limited to relatively  small  quantities in
process areas and from hoses and lines at loading points. Because of the diversity
and economic  value of the chemicals,  in addition to the hazardous natures, these
are removed and recovered in many instances. According to management, no large
spills have occurred at the plant, at least in the last 15 years.

Spill Control Plans

     Many tanks are located in curbed areas. Diked areas with drains which must
be  manually actuated run off into  the bay. If a large spill occurred in a diked
area, it would be removed by  pumps and trucks for treatment or disposal. The
plant has a supervisor for all shifts around  the clock, and has its own fire  and
security departments which are continually making plant inspections.
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Procter and Gamble
1422 North Nicholson
Baltimore, Maryland

Contacts:    Mr. Richard C. Smith, Plant Manager
            Mr. J. M. Davidson, Plant Engineer

Date of Survey:       September 17, 1970

Property Description

     The Procter and Gamble (P&G) plant,  shown in Figures 13  and  14, is
located  on the Patapsco River and  receives shipments by truck, rail, barge, and
ocean vessel. Normal drainage goes into the Patapsco River; however, much of the
plant area drains  to collecting sumps within the plant for treatment or recovery
before entering the sanitary sewer system of Baltimore.

Hazardous Materials

     Hazardous materials handled at P&G include:

            •  Oil, such as coconut         • Liquid sulfur trioxide
            •  Sodium hydroxide           • Phosphoric acid, and
            •  Sulfuric acid                • Aqua ammonia.
            •  Glycerine

Bulk Storage Facilities and Pipelines

     The largest shipments by water are  coconut oil, and the only other material
received by water  is 50%  sodium hydroxide. There are many storage tanks
situated throughout the plant both indoors and outdoors. An undiked tank farm,
probably 600 feet from the nearest  slip, contains 18 tanks of various sizes for the
storage of coconut oil and various other oils and products. The two largest tanks
are estimated  to contain about  500,000 gallons,  the  next  two tanks  about
300,000 gallons, eight tanks of approximately  150,000 gallons, and six between 5
and  100,000 gallons. Oil is pumped through overhead lines through the plant to
the farm. Fifty percent caustic is stored  in four tanks near the pier; each tank is
estimated to have a capacity of about 500,000 gallons. Two other caustic tanks of
nearly the same capacity are located  within the plant complex.

     Sulfuric acid (oleum) is stored  in three tanks estimated to have a capacity of
50.000  to 60,000 gallons each. Phosphoric acid  is stored in a tank with  an
estimated capacity of 10,000 gallons, and the same size tank is used for storage of
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liquid sulfur trioxide. Aqua ammonia  storage is handled by a single 15,000-gal.
tank. The glycerine produced is stored in two tanks, each having an estimated
capacity of 400,000  gallons.  Sodium  nitrate and  caustic mixes are  made and
stored in three  tanks, each of which has an estimated maximum capacity  of
100,000 gallons.

     Barge shipments of caustic are estimated  to  be received about every six
weeks. Tank cars and tank truck loadings and  unload ings are too frequent  to
document; of course,  typical transfer rates are under 100 gpm. Caustic unloading
piping is approximately 4 inches in diameter, which means ultimate  unloading
rates of probably 200 tons/hour maximum.

Past Spill Experience

     Troublesome past spills consisted  of detergents which, when they entered
waterways, were easily seen, even in small quantities, e.g., excess foam. The spills
usually took place in process areas and occurred  when less attention was given to
operational details prior to institution of the  recently initiated spill control plans
outlined below.  Besides the adverse publicity  resulting from such a spill, the mere
expense of the products, of course, would have dictated that  considerable atten-
tion be given to controlling spills in the past.

Spill Control Plans

     P&G is making every  effort to adopt an operational philosophy  based on
containing any spilled materials on its property in such a manner that releases to
water courses will be  known and controlled.  We were shown  plans for installing
sumps within the plant to collect possible spills,  and told that the present storm
drain system is being revised.  Drains from the dock surface into the harbor are
being sealed  off and  any spillage  will  be forced to enter plant sumps. P&G is
spending considerable money to ensure against spills entering the water courses.
Because of the value  of the materials  involved,  building sumps are pumped  to
collection and  recovery  areas  before  waste-water  discharges are  put into the
sanitary sewage system under permit from the city. Once-through cooling water is
used in the plant and  a small amount of BOD is added to this water from process
components, such as barometric condensers. Space limitations prevent diking tank
storage areas in a manner which would contain the entire liquid volume; however.
plans are under way to install  dikes which would be capable  of containing the
liquid volume of the largest tank in a complex.

     Around-the-clock supervisory  personnel are on  duty at the  plant, and it
appears that operational procedures exist for minimizing and controlling spills.
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                                              Photo Courtesy of Air Photographies, Inc.
FIGURE  13
AERIAL VIEW OF BALTIMORE, MARYLAND. HARBOR SHOWING
GENERAL LOCATION OF PROCTER & GAMBLE, NATIONAL
MOLASSES, AND UNIROYAL PLANTS
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-
                                FIGURE 14  AERIAL VIEW OF PROCTER & GAMBLE PLANT, BALTIMORE, MARYLAND

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Lever Brothers
5300 Holabird Avenue
Baltimore, Maryland

Contacts:    Mr. Wm. Wilson, Asst. Plant Manager
            Mr. Harlan Hyde, Plant Engineer

Date of Survey:         September 18, 1970

Property Description

     The Lever Brothers plant is located in an industrial area, is well maintained,
has good security fencing, but is not located on any  water  course. Its natural
drainage goes into storm sewers which empty into the water course. All shipments
are made by rail or truck. It manufactures a large line of soaps and syndets.

Hazardous Materials

     Hazardous materials handled by Lever Brothers include:

            • Coconut oil                 •  Hydrochloric acid
            • Sodium hydroxide           •  Fatty alcohols, and
            • Sulfuric acid                 •  Aqua ammonia

Bulk Storage Facilities and Pipelines

     Because of  the large number of storage  tanks holding raw materials, in-
process materials, and  products, we were unable  to  secure a  list of tank storage
volumes. We were told that  coconut oil is stored in tanks with capacities of up to
2.5 million pounds, and that 50% sodium hydroxide is stored in quantities up to
500,000 pounds.

Past Spill Experience

     The most significant spill at Lever Brothers occurred when process materials
were spilled into  the sewer system,  plugging the sewers and causing floods in a lot
used to store new General Motors cars. Because of the liability damages incurred
at that time, the  plant  installed a collecting basin in which oils and solids could be
retained before waste waters entered the city sewage system.
                                     103

                                                                       Arthur D Little, Inc.

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Spill Control Plan

     The  Lever Brothers plant has elaborate  drainage systems with provisions
made to reprocess most spills. Lever Brothers' policy is to keep everything on its
premises,  other than the waste waters which can be monitored as they enter the
sanitary sewage system of the city. The provisions that have been made to retain
and  prevent uncontrolled spills from leaving the premises appear to  be  well
devised and operable. A large number of rail car unloading stations exist as well as
a large number of tank  truck stations. Some tanks are located in diked areas,
other than fuel oil; however, a large number is located either in undiked or curbed
areas.

     This  plant appears to have one of the best developed systems for handling
product and raw material spills of any plant visited in the Baltimore area. In many
of the process areas, curbed areas are provided with drainage to collection sumps
equipped  with level-control pumps  that direct spillage into interim holding tanks
from  which it is usually returned to the process. Provisions have been made in
certain areas for the  collection  of  rainwater and its introduction into processes
since  small amounts of spilled detergents could be washed from the area. Drain
pans  have been placed under all bottling lines  so  that spilled materials  can  be
collected  for reprocessing along with washdown  waters. In-building and  area
drainages are designed to go through a limited number of points where monitoring
and control are possible. As previously mentioned,  it is the objective of the plant
to either retain all materials on the property or to monitor discharges for record
purposes.
                                    104

                                                                      Arthur D Little, Inc

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M&T Chemicals
Subsidiary of American Can
1900 Chesapeake Avenue
Baltimore, Maryland

Contacts:    Mr. James Feorine, Plant Manager
            Mr. Richard Rush, Production Supervisor
            Mr. Arnold Wasser, Corporate Environmental Officer

Date of Survey:       September 19,  1970

Property Descriptions

     The M&T Chemicals plant handles tin-plated steel scrap for recovery of tin
and various ores.  The accumulated  scrap metal does  not  lend  itself to good
housekeeping. However, the operation appears well maintained. There  is no
frontage on Curtis Bay, although the plant's drainage terminates in the Bay. All
materials are received and shipped by truck.

Hazardous Materials

     Hazardous materials handled by M&T Chemicals include:

            • Sodium hydroxide
            • Sodium nitrite solution, and
            • Various process solutions of chromium, tin, and antimony.

 Bulk Storage Facilities and Pipelines

      All liquids are  received via tank trucks. The following tanks, volumes, and
 materials stored were presented:

            50% sodium hydroxide          1  - 19,500-gal. tank
            Sodium nitrite solution          1  -  9,500 - gal. tank
            Settling tanks - various
             process solutions              6  - 22,500-gal. tanks
            Sodium antimonate            2  -  4,700 - gal. wooden tanks
             (all of the sodium              1  -  6,750 - gal. wooden tank
             antimonate tanks              1  -  3,000-gal. wooden tank
             are in buildings)

      Caustic shipment and  sodium  nitrite  shipments  are  made  at  a rate  of
 approximately one  tank truck per  week. Chromium chemicals, antimony, and
 strontium ores are brought into the plant as solids.  Mixtures of chemical for
 plating baths are  shipped out in drums as solids.
                                    105

                                                                      Arthur D Little, Inc

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Past Spill Experience

     Small process spills from pumps and overflowing tanks in process areas have
caused high concentrations in waste waters.

Spill Control Plan

     All process areas are sumped and  overflows are returned to process. Ob-
viously, catastrophic spills, such as  tank rupture, for example, might escape from
the building. Process tanks have low-  and high-level liquid alarms. The plant has a
settling pond,  but it is used primarily  for holding the solids from the process. The
plant  has  supervisory  personnel  on duty  around-the-clock because  of its  con-
tinuous electrolytic tin-recovery operations.
                                    106

                                                                       Arthur D Little, Inc

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C. SUISUN BAY-DELTA, CALIFORNIA

     The final section of the Sacramento River, below its confluence with the
Sacramento Ship Canal and, further below, at its confluence with the San Joaquin
River, was the actual site of the California survey (Figure  15). At this point, the
river has traveled slightly less than 400 miles  from its source in the Klamouth
Mountains near Mt. Shasta. For most of its  length,  the river flows in a southerly
direction. At  the City of Sacramento, the river begins to move westward, with its
final course flowing due West past the towns of Antioch, Pittsburg, Port Chicago,
Martinez, Crockett,  and Benecia on the river's northern bank. After passing
through Suisun Bay, the flow passes through the Carquinez Strait into San Pablo
Bay, thence to San Pablo Strait into San Francisco Bay.

Transportation

     Marine access up the river to Antioch is gained through a series of channels
ov varying depths, i.e.:

                                                 Depth at Middle Half
           Channel                              of Channel (feet)

         Suisun Pt. Reach                                34.4
         Bulls Head                                     35.6
         East Head                                      31.7
         Pt.  Edith Crossing Range                         31.6
         Preston Point Reach                             29.9
         Roe Island                                     30.8
         Port Chicago Reach                             31.5
         Middle Ground Channel
           West Reach                                  30.5
           East Reach                                   30.4

     The Southern Pacific Company Railroad and its connecting  systems service
the  area, and  there  are  numerous  automotive trucking concerns in the San
Francisco Bay area.

Drainage

     Rolling  agricultural countryside  runs  along  the  banks of  the  river, with
industrial complexes immediately adjacent to the river (Figure 15). Natural water
drainage empties into the Suisun Bay  Delta and, on  occasion, extensive  floods
have been experienced, with muddied waters visible as  far as 30 miles off shore in
the area of the Farallon Islands in the Pacific Ocean. The average annual rainfall
for the area has been recorded at 18 inches.
                                    107

                                                                      Arthur D Little; Inc

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     ~
     X
I
D
^
fT
                                                                                                          •^ Travis Air force B
                                    Marin Coun
                                        Novato
                                              Golden Gate

                                             San Francis
                                                                        Oakland
                                                                        International
                                                                      San Francisco
                                                                           Bay
                                                                    oulh San Francisco
                                                                    San Francisco
                                                                    International
                                                                                                                             Major Industries from Mouth of San Joaquin River
                                                                                                                                       to Western San Pablo Bay
                                                                                                            1 du Pont
                                                                                                            2. Crown Zellerbach
                                                                                                            3. Kaiser Gypsum
                                                                                                            4. Fibreboard
                                                                                                            5. Dow Chemical
                                                                                                            6. United Stales Sleel
                                                                                                            7. Johns Manville
                                                                                                            8. P.G.&E.
                                                                                                            9. Interpace
                                                                                                           10. Douglas Continental
                                                                                                             Oil
                                                                                                           11. Shell Chemical
                                                                                                           12. Allied Chemica
13. Western States
  Chem Co.
14. Monsanto
15. Phillips Petroleum
16. Allied Chemical
17. Shell Oil Co.
18. Time Oil
19 Humble Oil
20. Benicia Industrial Park
21. Carbon Products
  (Union Oil)
22. American Smelting
23. Union Oil Co.
           Gulf
          of the
       Farallones
                                                Half Moon Bay
PACIFIC  OCEAN
                                                     FIGURE  15   AREA OF SURVEY CONDUCTED IN SUISUN BAY-DELTA, CALIFORNIA

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Spill Incidents

     The record of spill incidents for the entire San Francisco Bay area in 1968
and  1969 are presented in Tables 9 and 10, respectively. The Suisun Bay-Delta
area has had a  total of 32 reported spills in the past two years. However, many
chemical spills could have gone undetected  and unrecorded, except for the "fish
kills" which occurred.

     The waterbody does not give an objectionable appearance, largely due to the
constant flushing  action of the Sacramento  River. The  contaminants would,
however, be cumulative in San Pablo and San Francisco Bay due to the restricted
opening to the open sea afforded  by the Golden Gate.
                                    109

                                                                      Arthur D Little Inc

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                               TABLE 9




REPORTED OIL AND OTHER SPILL INCIDENTS IN SAN FRANCISCO BAY REGION IN 19683







—
0







Month
Jan.
Feb.
Mar.
Apr.
May
Jun.
Jul
Aug
Sept.
Oct.
Nov.
Dec.
Total
Notes:

Number
of
Incidents
17
14
10
7
12
12
12
10
4
7
7
7
119

Suiiun Bay- San Pablo
Delta Area Bay
1 1
1 2
1 0
1 1
1 1
0 0
0 1
2 2
1 0
2 0
2 3
0 2
12 13
Location0
North Central
Bay Bay
2 12
2 7
2 6
0 5
1 9
2 10
2 7
3 2
1 2
2 3
2 0
3 2
22 65

Lower South
Bay Bay
0 0
0 1
0 1
0 0
0 0
0 0
0 1
0 0
0 0
0 0
0 0
0 0
0 3

Stream
1
1
0
0
0
0
1
1
0
0
0
0
4
Number of
Source Material Citations
Issued by
Land Vessel Unknown Oil Other SDF&Gb
86 3 13 4 4
64 4 13 1 2
45 191 5
25 061 4
39 0 11 1 5
46 2 11 1 2
65 1 93 3
24 4 82 2
21 1 40 1
14 2 70 5
43 070 7
23 261 3
44 55 20 104 15 43
a. Spill incidents were reported to the Regional Board office by telephone and/orFish and Game WLP-519, entitled, "Initial Pollution Report."
b. SDF&G =
State Department of Fish and Game
c The shipping wharfs of various refineries are located
r-+
C
D
r-
*— *
O
Source:



in various bays as follows:



Suisun Bay - Humble Oil Company, Phillips Petroleum Company, and Shell Oil Company
San Pablo Bay - Sequoia Refining Corporation and Union Oil Company
North San Francisco Bay - Standard Oil Company
State of California, San Francisco Bay Region, Water Quality Control Board













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                                                                               TABLE 10

                                REPORTED OIL AND OTHER SPILL INCIDENTS IN SAN FRANCISCO BAY REGION IN 1969*
Month
Jan.
Feb.
Mar.
Apr.
May
Jun.
Jul.
Aug.
Sept.
Oct.
Nov.
Dec.
Total
Number
of
Incidents
10
17
IS
13
23
11
16
11
23
23
12
12
186
Location0
Sunun Bay-
Delta Area
0
2
2
1
0
2
2
2
5
2
0
2
20
San Pablo
Bay
1
2
5
1
2
3
4
1
0
3
0
3
25
North
Bay
4
5
3
6
5
1
0
0
3
2
6
1
36
Central
Bay
4
8
3
5
14
4
8
7
12
11
5
4
85
Lower
Bay
0
0
0
0
0
0
0
0
0
0
0
1
1
South
Bay
1
0
1
0
2
0
0
1
2
0
0
0
7
Stream
0
0
1
0
0
1
2
0
1
5
1
1
12
Land
6
6
9
4
4
4
8
3
6
12
6
4
72
Source
Venel
2
7
2
S
10
3
6
7
t3
4
5
4
68
Material
Unknown
2
4
4
4
9
4
2
1
4
7
1
4
46
Oil
8
17
12
13
17
11
12
7
19
15
11
12
154
Other
2
0
3
0
6
0
4
4
4
8
1
0
32
Mumberof
Citations
Issued by
SDF&Gb
2
2
2
5
6
3
4
1
3
5
3
3
38
>
-1
«—»
c
Notes:    a. Spill incidents were reported to the Regional Board office by telephone and/or Fish and Game WLP-519 entitled. "Initial Pollution Report."

         b. SDF&G = State Department of Fish and Game

         c The shipping wharfs of various refineries are located in various bays as follows:     Suisun Bay - Humble Oil Company. Phillips Petroleum Company, and Shell Oil Company
                                                                           San Pablo Bay - Sequoia Refining Corporation and Union Oil Company
                                                                           North San Francisco Bay - Standard  Oil Company

Source:    State of California.  San Francisco Bay Region. Water Quality Control Board

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California and Hawaiian Sugar Company
830 Lor ing Avenue
Crockett, California

Contacts: Dr. Philip F. Meads, Technical Director
         Mr. Henry C. Strecker, Chief Chemist - Quality Control

Date of Survey:       October 27, 1970

Property Description

     The "C and H Sugar" plant located on Carquinez Strait, where  the Sac-
ramento River empties into the San Pablo Bay and thence into San Francisco Bay,
is  the world's largest sugar refinery. In a  27-acre floor space the plant produces
consumer,  institutional,  and industrial granulated, brown,  powdered,  and spe-
cialty sugars, as well as tablets  and cubelets, and a full line of manufacturers'
grades of granulated and liquid sugars, both in bulk and packaged form. The bulk
raw  cane sugar is delivered by cargo ships from Hawaii. A granary elevator and
belted conveyor unloading system transports the raw material from the ship into
large  storage  hoppers from which  it  passes into production.  The maximum
production averages 4200 tons of refined  sugar and 40 tons of molasses per day,
the production period running 10 out of every 14 days. The plant's industrial
waste drainage involves a total of 21  outfalls that discharge into the Carquinez
Strait, as illustrated in Figure 16, and described  in Appendix E. All outfalls have
shutoff valves, some of which  are  locked and  opened only under controlled
conditions.

Hazardous Materials

     Materials used at the C and  H  sugar plant, which if spilled in quantity could
degrade the natural  water quality, include:

     •   Bagged lime — delivered by truck,
     •   Phosphoric acid - delivered by truck,
     •   Liquid sugar — processed material,
     •   Bagged diatomaceous earth - delivered by truck and train,
     •   Bagged bone charcoal  - delivered by truck and train, and
     •   A limited quantity  of descaling chemicals, such  as soda
         ash, which are used to clean production lines, but which
         are neutralized before discharge into the Strait.

     A dry refined-sugar marine loading facility  is used by vessels of the Bay and
River Navigation Co. The  in-harbor vessels deliver the products to  nearby Rich-
mond, San Francisco, and  Oakland,  on a  maximum twice-a-day  sailing schedule.
                                    112

                                                                      Arthur D Little, Inc

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                          CAROUINEZ
                                                                  S  T  RAIT
  *
                              UNITED STATES PIERHEM) AND BULKHEAD LINE     ]
                                         AND HAWAIIAN SUGAR
                                              //'/"////"/
                                              RCNOUSE N01
                                                                                                                     OUTF»LLS E

                                                                                                                        OUTF4U.5 «DOED 9r I? " '0 O
D
C
                                       FIGURE  16  GENERAL LAYOUT OF CALIFORNIA AND HAWAIIAN SUGAR REFINING

                                                    CORPORATION PROPERTIES, CROCKETT, CALIFORNIA

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 Bulk Storage Facilities and Pipelines

      The bulk storage tanks are above-ground, undiked installations. The tanks in
 evidence and utilized by the plant have the following capacities:

      Liquid Sugar Storage

       1,2 — 1 million gallons each.
       3, 4, 5, 6, 7, 8, and  11 - empty, not currently in service.
       9 -  260,000 gallons
      10-  240,000 gallons
      12 -  13,000 to 160,000 gallons
      14 -  holding tank.
      15 -250,000 gallons.

 There is also  a 10,000-gal.  capacity stainless-steel tank used for the storage of
 phosphoric acid, and a 25,000-bbl boiler fuel oil storage tank.

 Note:  Tanks 13 and 15  are located   on land leased  from the
        Railroad Corporation. All tanks are epoxy-lined, and are
        internally inspected on an annual  basis to determine the
        condition of the inner lining.

 Past Spill Experience

     There have been no sudden and accidental spills which, to the knowledge of
 plant management, have in any way damaged the marine environment or degraded
 the ecology of the area. The state records indicate a l-bbl bunker oil spill when
 the S.S. Hawaiian  Builder was  bunkering on June 23, 1969, and a milky  white
 discharge from the plant was also recorded on October 24, 1969.

 Spill Control Plan

     Under the control of the State of California Regional Water Quality Control
 Board, San Francisco Region, the plant operates on a self-monitoring system of
 effluent discharge. This involves in-house and outside laboratory analysis of the
 waste water, and  submittal of a quarterly analytical report to the Water Quality
Control Board. In the event of a spill,  the plant would immediately contact the
local Water Quality Control Board, and  would  be guided by their direction in
rectifying spill damage.
                                    114

                                                                     Arthur D Little, Jnc

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Johns-Manville Products Corporation
P.O. Box 591
Pittsburg, California  94565

Contacts: Mr. Al C. Pennewell, Plant Manager
          Mr. Saul H. Bernstein, Paper Mill Production Superintendent
          Mr. Charles Beaney, Plant Engineer

Date of Survey:       October 28, 1970

Property Description

     The Johns-Manville plant is located in the downtown area of Pittsburg, one
block  from the Sacramento River. Figure  17  is a plot  plan  of  the plant.  The
production area is essentially flat.  The plant  can be divided  into four working
areas:  a paper mill; a roofing manufacturing area; an asbestos shingle production
area; and a flexboard and corrugated transite manufacturing operation. There is a
48-inch storm  drainage line which runs  along the side of the plant  and then
empties into the river. Sanitary, process, and cooling water is pumped to the city
sewer system.

Hazardous Chemicals

     This plant produces asbestos paper, asphalt shingles and roofing, corrugated
asbestos-cement sheets, asbestos insulating cements, and roofing coatings.

Bulk Storage Facilities and Pipelines

     The plant has three (two 25,000-gal. and one 50,000-gal.)  steam-traced tanks
for storage  of asphalt. These  tanks have no safeguards, but  cutting down the
steam-tracing causes the asphalt to  set up, thus creating, in fact, a spill prevention
condition. The plant also has a  50,000-gal. capacity storage tank which holds only
10,000 gallons of fuel oil for emergency purposes. There is no diking, and the area
where  there is a storm drain  lies 200 yards away from the tank.

     In addition, the plant  has two 5,000-gal. storage tanks,  sitting six to eight
feet above  the ground, which contain "cutback," a free-flowing, asphalt-base
material. There are  no spill-containment  methods for these tanks; however, the
tanks  are located approximately 200 yards from  the nearest storm drain. There
are no underground  storage  tanks. All materials enter and leave the plant by truck
or rail. There is no waterborne movement of material. The asphalt enters the plant
by  truck  only. Ninety  percent of  the products are shipped by truck.

Past Spill Experience

     The plant was on strike when  this survey was undertaken. There have been
no spills of record.   Periodically, there may  be some small spillage; however, this
facility has very little spill potential.

                                    115

                                                                       Arthur D Little; !nc

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                                            muuuuuu
                                                                                           PUMP [~l| 75.

                                                                                           MOUSF LI'	
                                               _J LJ LJ LJ LJ LJCONCRETE                                   '.,.
                                               OUTOOOB R*G SIORA6E    '.BF1   FLEX BOARD £. CORRUGATED TRANSITS MANUFACTURE
                                               „„„„,„_.*!              520', too'

                                                                                        FLAT C«» BRIDGF
                                                                       ASBESTOS SHINGLE MANUFACTURE
                                                                              520'« 100'
KJOPOO-GAL ELEV

TANK ON 100' ST TOWEF

ir
                      FIGURE 17  GENERAL LAYOUT OF JOHNS-MANVILLE PRODUCTS CORPORATION PLANT, PITTSBURG, CALIFORNIA
R

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Monsanto Company
Martinez, California

Contacts: Mr. V.T. Matteuci, Plant Manager
         Mr. W. L. Germain, Technical Supervisor

Date of Survey:       October 28, 1970

Property Description

     The Monsanto Company plant (Figure 18) at Martinez is one of its smaller
plants. It is located adjacent to the Phillips Petroleum-Avon  refinery, approxi-
mately one mile from  Suisun Bay. It immediately borders a slough that flows into
Suisun Bay. It produces:

         •    Sulfuric acid
         •    Sulfur
         •    Catalysts.

The waste-water disposal  system,  as approved  by the Regional Water Quality
Control  Board,  consists of a network of sewers which collect  all effluent and
drainage from the plant site. This waste water is collected in a sump and pumped
by  a double-pump system to the Phillips-Avon refinery  for treatment in the
Phillips waste-water treatment  system. The plant  has no marine facilities and
considers its bulk storage and loading facilities to be  minimal.

Hazardous Materials

     The following is a listing of the bulk, liquid  chemicals stored,  transported
and processed  by the plant and the percentages shipped  by various modes of
transportation:

          Chemical               Rail          Truck          Marine

          Sulfur                 0%          100%             0%
          Sulfuric acid            2%          45%             0%
          Potassium hydroxide    0%          100%              0%
          Potassium silicate                  not shipped
          Diethanolamine         0%          100%              0%
                                    117
                                                                      Arthur D Little; Inc

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                                          Photo Courtesy of Air-Photo Company, Inc.

FIGURE  18    AERIAL VIEW OF SUISUN BAY-DELTA AREA SHOWING GENERAL
             LOCATION OF MONSANTO COMPANY PLANT, AVON,
             CALIFORNIA
                                 118
                                                                Arthur D Little Inc

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Bulk Storage Facilities and Pipelines

     All  storage tanks are above-ground installations.  Secondary means of con-
tainment are not provided, but the plant's trenching system could handle a major
spill and direct same to the  Phillips Petroleum waste-water treatment  facility.
Storage capacities are as follows:

     • Sulfur                 - 600,000-gal.
     • Sulfuric acid           - 640,000-gal.
     • Potassium hydroxide    -  12,000-gal.
     • Potassium silicate      -  12,000-gal.
     • Diethanolamine        -  80,000-gal.

The annual consumption of these chemicals is company confidential. There are no
buried tanks or pipelines.

Past Spill Experience

     The plant has never experienced a major chemical spill. Management con-
siders that the possibility of "a major spill is highly unlikely."

Spill Control Plan

     Thery is no formal spill control plan, but any minor spills that might occur
could be contained within the limits of the waste-disposal trenches and treating
system. Acid  spills  would  be  treated with  caustic and/or washed with  large
volumes  of  water for dilution (caustic was not included on the  plant's listing of
hazardous materials).
                                    119

                                                                        Arthur D Little: Inc

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Shell Oil Company
1801 Escobar Street (P. O. Box 711)
Martinez, California

Contact: Mr. A. P. Cupit, Administrative Superintendent
         Mr. R. M. Thompson, Mgr., Air and Water Conservation

Date of Survey:       October 28, 1970

Property Description

     The Shell  Oil  Company  (Figure  19) is  a 100,000-bbl per day  refinery
producing agricultural spray oils, gasoline, diesel fuel, fuel oils, asphalt, kerosene,
lubricating  oil,  naphthas,  road oils, cleaning  fluids,  solvents,  stove oils,  and
greases. The plant is located in an elevated position on the south side of Suisun
Bay. It has a closed drainage system of waste sewers, all of which pass through an
API oil/water separator. The separator has an open and closed bay which allows
the use of scrapers to  remove  surface  oil and bottom sediments.  The  pH  is
controlled  with acid and/or caustic and flocculants such as iron or aluminum
sulfate. The waste water then passes through air flotation clarification units. The
clarified effluent is then held in a treatment pond preparatory to being pumped
through a deep-water (35 feet) diffuser. The final discharge into the river is made
on a programmed cycle, set to match the tidal  flow in the river. The rate of final
discharge varies from 3000 to  10,000 gpm to match the rate of tidal flow and to
gain a  dilution factor in excess of 100 to 1  at the edge of the rising plume from
the subsurface discharge in the river. Samples of the effluent are taken weekly to
determine the biological oxygen demand (BOD), metal content, fish toxicity, and
dissolved grease. The analysis is conducted partially in-house and partially by an
independent  analytical  laboratory, the latter conducting the biological testing
phase.

     Monthly  reports are submitted to the State  Water  Quality  Control  Board
which  may also  ask for spot-sampling on an unscheduled  basis. In addition to the
main water treatment ponds,  the  plant has four diversion ponds, having dimen-
sions of 150 by 50 by 6-10 feet. The diversion ponds provide a 24-hour holding
capacity. The facility also provides a storm water pond 300 by 400 by 10 feet in
dimension.
                                  120

                                                                       Arthur D Little Inc

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                                • ff-
                       ES"
                                             Photo Courtesy of Air-Photo Company, Inc.
FIGURE 19   AERIAL VIEW OF SUISUN BAY-DELTA SHOWING GENERAL
             LOCATION OF SHELL OIL COMPANY PLANT. MARTINEZ,
             CALIFORNIA
                                                              Arthur D Little Inc

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  Hazardous Materials

      In  addition  to  the petroleum-based  products,  the  following  production
  chemicals are used at Shell Oil:

      •    Sulfuric acid - received by both tank truck and tank car,

      •    Filter clay - 100-lb bags received by truck,

      •    Miscellaneous  organic  chemicals (viscosity improvers) -
           tetra-ethyl,  lead, soaps, lithium stearates,  and caustic -
           received by tank car,

      •    Lime and milk of lime (slurry)  - received by tank truck,

      •   Bulk rock salt - received by truck,

      •   Commercial inhibitors  (NALCO) - received in paper car-
          tons by truck,

      •    Dow liquid chlorine (for cooling water systems) - received
          in 1-ton containers by truck,

      •    Ferric  sulfate and  aluminum sulfate (flocculants) -  re-
          ceived by truck,

     •    Liquid sulfur dioxide (for extraction process) -  shipped
          from Dow Chemical or local smelters by truck,

     •    Furfuraldehyde  (solvent) - received in drums by truck,

     •    Diethanolamine (for scrubbing gases) - received by truck,

     •    Miscellaneous  cracking  catalysts  (heavier  than  water,
          similar to diatomaceous earth) - received by truck.

Bulk storage capacities and annual  consumption of chemicals are considered to be
company confidential information, and were not made available.
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Bulk Storage Facilities and Pipelines

     The plant has no buried pipelines, tanks, or flexible hose lines. All petroleum
product storage  tanks have diked enclosures; a number of chemical storage tanks
do  not have this protection. When  provided, the dikes have concrete reinforce-
ment on the inside. The exterior surfaces are protected from erosion by a coating
of  "flux"  that is actually cut back asphalt which coagulates when the solvent
content evaporates.  Since all tanks are  at  elevated locations, the  hillsides have
been stabilized with the same material. The Engineering Services Department has
established a regular inspection program for all vessels, tanks, and vessels contain-
ing materials at pressures above static. Such vessels are also subjected to regular
inspection  by the representatives of the plant's insurance carrier.

     Process vessels  are  subjected to non-destructive tests on a frequency deter-
mined by  past experience.  Sulfuric acid tanks are subjected to testing annually.
From a  fail-safe standpoint, all dike enclosure draining is monitored; product
transfer lines are  equipped  with pressure-drop, shut-off controls;  and one-way
flow check valves are installed on all sulfuric acid fill lines.

Past Spill Experience

     The plant has not had any hazardous material spills since 1964, this being as
far back as the plant contacts could recall.  A number of petroleum product spills
were found in the state records, viz.:

            6/17/69 -  Fuel oil spill when bunkering S. S. Andrew Jackson

             7/7769 -  Failure  to  properly close valve after loading caused
                        oil spill into Carquinez Strait

            8/13/69 -  Opened wrong valve and spilled between 1-4 bbl of
                        oil, while loading S.S. Catawba Ford

             9/8/69 -  One-bbl fuel  oil spill from S. S. Barbara

            9/15/69 —  Three-bbl  oil  spill  occurred when  loading S. S.
                        Millspring

            6/30/70-  Jet  fuel   spill   (10-15-bbl)  when barge  buckled
                        during loading  operation.
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Spill Control Plan

     The plant has a regular procedure for alerting personnel and initiating action
in the event of a spill. In addition, aid can be gained from  any or all of six
refineries in the area. The Western Oil and Gas Bay Area Subcommittee, which is
made up of the managers  from the six  refineries,  is in the  process of forming
either a profit or non-profit cooperative  to provide mutual aid in the event of a
chemical or oil spill. The cooperative is under legal study for  such items as the
"Good Samaritan Law." Until legal aspects  are fully  considered, only a verbal
agreement of aid is effective.
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E. I. DuPont de Nemours & Company, Inc.
Antioch Works
Antioch, California 94509

Contact: Mr. F. J. Hodges, Plant Manager

Date of Survey:       October 29, 1970


Property Description

    The DuPont de Nemours & Company plant is a modern facility which pro-
duces the following products:

    •   Freon 11, 12,21,22, 113, and  114
    •   Tetra-ethyl lead
    •   Titanium dioxide pigment.

    All three products are produced at one plant location within which each
product has its independent production area. The production areas and floors are
graded so that spilled  liquids drain into a ditch system. The ditches terminate in
any of the  plant's retention basins which have an 8,000,000-gal. capacity in total.
There are  no  by-passes around the basins. The ditches have strategically  posi-
tioned traps, skimmers, and control gates. The plant operates around the clock,
seven days a week. Occasionally on holidays, one or two of the areas are shut
down, but  a supervised skeleton crew is  always in attendance. All of the produc-
tion areas  are highly automated, with centrally located alarms, recorders, and
controllers. The drainage ditches are equipped with pH analyzers which operate
an on-site  and central control room  alarm. The pH values of plant effluents range
to a maximum of 9  and a low of 6. Field  operators routinely inspect ditch and
basin  facilities and log their observations. The inspections include pH equipment
operability and sampling of the various streams for laboratory testing.

Hazardous Materials

     Hazardous materials handled at  the duPont de Nemours plant include:

     •   Sulfuric acid (various concentrations) - maximum storage.
         26,200  gallons;

    •   Hydrochloric acid (including  chemicals which  form HC1
         when mixed with water) - maximum  storage,  162,000
         gallons;
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    •    Hydrofluoric acid - maximum storage, 18,800 gallons;

    •    Caustic (including chemical blends which  have  a  caustic
         base) - maximum storage, 39,000 gallons;

    •    Carbon tetrachloride - maximum storage, 48,000 gallons;

    •    Ethylene dibromide  — maximum storage, 40,000 gallons;

    •    Ethylene dichloride  - maximum storage, 48,000 gallons;

    •    Kerosene — maximum storage, 8,700 gallons;

    •    Acetone — maximum storage, 7,000 gallons;

    •    Tetra-ethyl lead - maximum storage, 780,000 gallons.

Bulk Storage Facilities and Pipelines

    The plant's tank installations which are all above-ground include the  fol-
lowing:

         Sulfuric -  5 tanks
         Hydrofluoric acid -  1 tank
         Hydrochloric acid — 7 tanks
         Caustic - 5 tanks
         Carbon tetrachloride - 1 tank
         Ethylene dibromide — 1 tank
         Ethylene dichloride - 1 tank (diked)
         Kerosene - 1 tank (diked)
         Acetone - 1 tank
         Tetra-ethyl lead - 3 tanks (separately diked).

     None  of  the diked areas has drains, and the dikes themselves are of natural
earth construction covered  with a "Gunite" coating to retard  erosion. In addition,
the tank pumping  systems are  located  outside of  the main diked area in an
adjacent but  separately  diked section. All pipelines are above-ground with the
exception of a length of liquefied  natural gas line and one buried water line. One
small toluene  tank is also a buried installation. The capacity of this tank was not
readily  available during the survey. Scale (measuring) tanks  within the plant are
equipped with earthquake  protection and  are spring-supported against an earth
tremor.
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Past Spill Experience

     No spills of any consequence have been experienced within the plant.

Spill Control Plan

     Management of each of the three production areas has developed a plan of
action that could  go into effect  in  the  event of a spill.  There is  constant
supervision, and  in an emergency employees  would  be  departmentally  inter-
changeable. In  spite of a very elaborate system of controls and fail-safe devices,
such as high- and low-liquid level alarms and even a high/high-liquid level alarm,
plant personnel realize that a storage tank could  rupture — in the event of a severe
earthquake, for example. In such an event, the storage content of any diked tank
would be readily contained  within the dikes. If the tank were not in a diked area,
the contents would flow into a ditch. If the earthquake did not alert operations,
the level alarm in the tank would. All of the storage tanks have high- and low-level
alarms which sound and flash in a central control room. The spilled liquid would
run down the ditch system to the effluent treatment  basins  which are 0.2 mile
from the  closest production area. An alerted operator would arrive at the basins
and  close the  inlet  gate, which  would divert the  liquid in the ditches to a
4,000,000-gal.  emergency basin. Material entering  the emergency basin would
remain there until it was pumped out — there is no drainage except for the basin
to overflow the dikes. Should  there be a delay before an operator diverted the
ditch  stream  to  the emergency  basin,  the  liquid would  enter the normal
1,800,000-gal.  basin.  The  residence  time for  liquid  entering  this basin  is a
minimum of 24 hours.

     To  enhance the described  spill protection plan, further improvements that
will  probably be installed during 1971 are being planned. In addition, the  plant
retains the services of Dr. Ruth Patrick, Philadelphia Academy of Science, an
authority  on  environmental management,  who conducts regular  in-plant and
offshore surveys to appraise and improve waste-water and effluent treatment.
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 Fibreboard Paper Products Corporation
Wilbur Avenue
 Antioch, California  94509

 Contact:   Mr. Frank J. Lyman, Technical Superintendent

 Date of Survey:  October 29, 1970

 Property Description

     The Fibreboard Paper Products Corporation plant is located east of Antioch
on the Sacramento  River, adjacent to the large Crown Zellerbach facility. The
property slants gradually toward the river. Most of the manufacturing facilities are
far removed from the waterfront. Surface drainage of the plant goes into storm
sewers which  go into the river. The  effluent of the plant  — process water and
cooling water - is discharged directly into  the river (approximately 1000 feet
offshore) after being treated for pH adjustment.

Hazardous Chemicals

     The plant produces Kraft corrugated board, Kraft lines, and bleached food
board. In treating the waste water, both sulfuric acid and caustic  soda are used for
pH adjustment, with all data recorded.

Bulk Storage Facilities and Pipelines

     The plant  has  two well-diked  storage  tanks for fuel  oil;  one, 35,000-gal.
capacity, and  the other, 120,000-gal.  capacity.  Each is curbed, draining to the
main effluent  discharge line.  The plant also has a 1,000,000-gal. plus storage tank
for handling the weak black liquor; it is classified as emergency storage. This same
tank has  provisions to handle  all emergency spill situations  in the  plant.

     The only waterborne movement is fuel  oil. The fuel oil barge depot is well
designed, with check valves, flanged hose connections, appropriate spill tanks, and
so forth. Alum used in the  process is received by pipeline from the adjacent
Crown Zellerbach  plant. The 9% caustic  soda is received by pipeline from the
Dow plant  near Pittsburg. Chlorine is received by tank cars, and  the cars are used
as a storage facility.

Past Spill Experience

     There have been no spill  incidents since the plant was  started.
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Spill Control Plan

     The plant has very elaborate  water intake and discharge systems, and very
careful control of the operation is maintained. Any anomaly is reported immedi-
ately to the local water control authorities. Excellent records are kept of the pH
value of the plant effluent. No formal spill plan has been adopted. Flexibility in
the operation allows the facility to avoid major spills.
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The Dow Chemical Company
Pittsburg, California

Contacts:   Mr. Edward Elkins, Manager, Western Division Planning
            Mr. David L. Bauer, Manager, Utilities and Environmental Control
            Mr. Dennis Brisco, Materials Handling Field  Superintendent

Date of Survey:  October 29, 1970

Property Description

     Operations in what is  now the Dow Chemical Company plant (Figure 20)
began in 1919; Dow took it over in 1938. It should be classified as a post-World
War I facility. It is located  adjacent to the United  States Steel facility, approxi-
mately half way between the central business areas of Pittsburg and Antioch. The
plant is on the Sacramento  River.  From the entrance to the plant to the water's
edge there is a gradual sloping of about 3 feet over a distance of one-half mile.
This plant has no flooding potential. For the purposes of this analysis, the plant
has been divided as  follows: dock  storage and ponding; in-plant storage next to
ponding; and in-plant  storage in the remainder of the  plant  (see Figure 20 for
areas under consideration).

Hazardous Chemicals

     Dow's  Pittsburg plant  produces chlorine, caustic soda,  chlorinated hydro-
carbons, xanthates,   pesticides (antimicrobial),  hydrochloric acid, protective
coatings, styrene  and butadiene latex, and miscellaneous industrial organic chemi-
cals for the mineral industry.

Bulk Storage Facilities and Pipelines

     Dow's  dock  storage area has 16 tanks  ranging  in size from 20,000 to
1,000,000 gallons. The largest tank holds 50% caustic soda, while the next largest
one holds 22° Be hydrochloric acid. The smaller tanks hold chlorinated  solvents
and  styrene. The tanks are properly diked  and are properly cross-piped to allow
transfer where appropriate. Standard valving procedures  are used in all tanks. The
ponding area adjacent to the river is the collection point for the waste water and
is the emergency  area for caustic spills where they could  be neutralized with acid.
The  in-plant storage next to the ponding area has six tanks — 10,000 to 40,000
gallons in size, containing 10-50% NaOH. The tanks are curbed and have drainage
to the pond.

     The rest of the in-plant storage is  for chlorine, ammonia, latex, and alcohol.
(There are  30  of these  tanks, all  under  10,000-gal. capacity.)  If any spilling
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                                        Photo Courtesy of Air-Photo Company, Incorporated
FIGURE 20  AERIAL VIEW OF SUISUN BAY-DELTA AREA SHOWING GENERAL
           LOCATION OF DOW CHEMICAL COMPANY PLANT, PITTSBURG,
           CALIFORNIA
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occurred with the chlorine or ammonia, it would vaporize. Spilled latex would
result in a frozen ooze  because of the low melting point. The  alcohol tanks,
located  near the rear of the plant are curbed and drain to the pond. There is no
underground storage, except the chlorine tanks.

     The primary  raw material  movement consists of salt,  which comes in by
barge and rail. The other movement  consists of hydrocarbons which come in by
pipeline from nearby points. A third or less of the products is shipped by water;
most are snipped  by truck.  Dockside  filling stations,  as well as truck filling
operations, are  available. Both are operated  competently, using appropriate
methods.

Past Spill Experience

     There have been no spills recorded in the history of the Dow plant.

Spill Control Plan

     No formal spill control plans have been published. Spill division areas, such
as a holding pond for the latex operation, and a holding pond for caustic (the
pond near  the river),  which will allow pH adjustment before discharging, have
been provided.
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American Smelting and Refining Company
Selby, California

Contacts:   Mr. Armand Labbe, Plant Manager

Date of Survey:  October 30, 1970

Property Description

     The American Smelting and Refining Company plant is presently being shut
down. It can be broken down into three areas: the silver and gold refinery, the
zinc smelter, and the lead  smelter; associated with the lead smelters is a 35-ton
sulfuric acid plant. The greater area of the plant is taken up by the slag piles
which are — and have been - used  for both fill and sweetener for the operation.
The plant area is flat. An  excellent dock facility exists which makes the area a
desirable deep-water site.

Hazardous Chemicals

     The plant produces sulfuric acid, liquid  SO2 lead,  zinc, refined silver and
gold, and associated lead and zinc smelter products. It is located across from Mare
Island. Figure 21 shows the entire facility from the air.

Bulk Storage Facilities and Pipelines

     In the acid plant there are  five 125,000-gal. storage tanks for the 98%
sulfuric acid. They are not diked.  However, in case of spills, lime from another
area of the  plant is available for use to preclude any spill reaching the water area.
The plant also has one 320-ton capacity (160-ton useful capacity) liquid sulfur
dioxide tank, and two 5000-gal. caustic soda tanks which are curbed and sumped.
The general area around the tanks is  sumped. The raw  materials for the plant
(concentrates)  are  brought in  by boat and  discharged by a modern unloading
system. The sulfuric acid and other products are moved by rail.

Past Spill Experience

     This plant is 85 years old; it is and has been under constant pollution control
surveillance. There has never been a hazardous spill, except for a coke spillage
from a barge. The plant will definitely be shut down by the end of 1970 and is for
sale; approximately 15 concerns are bidding for the property.
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                               Photo Courtesy of United Aerial Survey
FIGURE 21    AERIAL VIEW OF AMERICAN SMELTING AND
             REFINING COMPANY, SELBY, CALIFORNIA
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Industrial Chemical Division
Allied Chemical Corporation
Bay Point Works
Pittsburg, California

Contacts:    Mr. V. A. Fink, Plant Manager
            Mr. B. C. Rager, Safety Supervisor

Date of Survey:  October 30, 1970

Property Description

     The Industrial Chemical Division of the Allied Chemical Corporation plant
has been operational in the Suisun Bay area since  1910. Figure 22 is a land view
of the firm's general layout, and Figure 23 is a water view. Its chemical products
include:

         •    Sulfuric acid        "j
         •    Aluminum sulfate   >       manufactured products
         •    Hydrofluoric  acid   /
         •    Sodium bichromate [not manufactured but warehouse-
              stored and distributed].

The plant drainage has been  engineered to flow to a single, submerged outfall that
discharges into Suisun Bay. All waste water is passed through a 2500-ton capacity
treatment pond prior to final discharge into  the  bay. The effluent discharge is
rated at 3000 gpm, and the pond has a total retention time of 12 hours.

Hazardous Materials

     The following materials are produced, handled, and stored within the plant:

     •   Sulfuric acid — maximum storage, 4,000 tons; the material
         is tank-trucked from the plant to the  consumer.

     •   Aluminum sulfate liquor -  maximum  storage  capacity,
         200 tons of actual liquor with makeup from  dry alum;
         material is tank-trucked to consumer.

     •   Hydrofluoric acid  - maximum storage, 300 tons; shipping
         procedure: 90 percent, tank  car; remaining 10 percent,
         tank truck.
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                                             Photo Courtesy of Allied Chemical Corporation
FIGURE 22 LAND VIEW OF INDUSTRIAL CHEMICAL DIVISION OF
           ALLIED CHEMICAL CORPORATION, NICHOLS, CALIFORNIA
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                                             ISTRIAL CHEMICAL OIV.
                                             JED CHEMICAL CORP
                                        Photo Courtesy of Air-Photo Company, Inc.



FIGURE 23   WATER VIEW OF INDUSTRIAL CHEMICAL DIVISION OF
             ALLIED CHEMICAL CORPORATION, NICHOLS, CALIFORNIA
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    •   Sodium  bichromate (69  percent solution) — maximum
         storage,  60 tons;  shipments into the  plant are made by
         tank car; shipments out  of the  plant are made by tank
         truck.

    •   Nitric acid - maximum storage, 3000 gallons;

    •   Acetic acid — maximum storage, 1500 gallons;

    •   Anhydrous and aqua ammonia — maximum storage, 530
         gallons;

    •   Drummed caustic — maximum storage, 1300 gallons;

    •   Lime - maximum storage, 14,750 gallons.

Bulk Storage Facilities and Pipelines

    Bulk storage  and service tanks are positioned at various locations  on the
plant  property; some are elevated, and some have a secondary means of contain-
ment. A 4-inch  diameter pipeline about 300  yards long  lies  buried within the
plant. The  line (recently renewed)  does not have cathodic protection. All tanks
are hydrostatically tested on a regular inspection frequency, and some of the
sulfuric acid tanks  are equipped with high liquid-level alarms.

Past Spill Experience

    Mr. V. A. Fink has managed this plant since  1934 and cannot recall any spills
of hazardous materials  during that period of time.

Spill Control Plan

     The plant  has both  a "spill plan"  and  a  "disaster plan."  In addition,
$250,000 is being spent for water pollution control monitoring. The plant's main
outfall has  been  completely reworked. All drainage lines have been equipped with
pH recorders and  a  drop of 1  to 1.5  would trigger an  audible alarm within the
plant's  main control center. It is anticipated that the improved monitoring/spill
control system will be fully installed and operational  by March 1971. The plant
further maintains a readily available supply of caustic to neutralize acid spills. All
sulfuric  acid tanks are equipped with internal plugs that can be lowered into
position to seal off all tank outlets in the event  of a valve or pipeline failure.
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Industrial Tank, Inc.
210 Berrellessa Street
Martinez, California

Contacts:   Mr. Henry W. Simonsen and
            Mr. Jack O. Fries, Owners

Date of Survey:  October 29, 1970

Property Description

     Industrial Tank, Inc., has operated in the Martinez area for the past 22 years.
The original services included tank cleaning (marine and industrial), vacuum tank
trucks,  oil  and  special  liquid  pumping, weed control, and general  industrial
services. Its waste  water and spent chemical disposal services are currently being
extended.

     In addition to a downtown office and trucking terminal, Industrial Tank has
a spent-chemical treatment and disposal site on acreage  that is surrounded by oil
refineries (Shell  and Phillips), the closest water bodies being Walnut Creek and
Vine Hill Slough, which flow into Suisun Bay and the Sacramento River. A total
of 20  trucks (11  with  100-bbl capacity) are used to  collect waste oil and spent
chemicals from  an  area that  includes  Sacramento, Antioch,  and Richmond,
California,  transporting same to the Martinez disposal  site. Currently 10 major
industries are serviced, including Shell, Phillips, Humble, duPont, Dow, Union,
and  Standard Oil. The  concern also  provides oil spill clean-up services using
absorbent straw and a California Fish and Game Department approved "Hydro-
purge" oil suction device. Marine craft with oil spill clean-up capability are under
investigation for possible acquisition, and the  services of an environmental con-
trol geologist have been  retained on a consultant basis.

Hazardous Materials

     Hazardous  materials can best be described as waste oil and a mixture of
spent  chemicals,  some  of which are  commingled. The majority of  the oil is
recovered and used for spreading on highways for road dust control.

Bulk Storage Facilities and Pipelines

     At the disposal site there  are a total of  10 receiving tanks with each tank
averaging 400-bbl capacity. The treatment  flow includes a 700-bbl  treatment
tank, a  10,000-bbl settling  tank, and a battery of evaporation ponds which will
eventually  extend over a 20-acre area.  When in  full operation, the solids that
remain after treatment and  evaporation will be buried within the disposal site. All
pipelines and tanks are exposed, above-ground installation with  the exception of
one tank, which is partially buried.

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Past Spill Experience

     The plant experienced one major  spill  when flood water  came over the
perimeter levees and washed  out the treatment ponds. To prevent repetition of
this occurrence, flood control  levees have been raised and stabilized.

Spill Control Plan

     As the leading spill  control and water clean-up  agency in the Sacramento
River Basin, Industrial  Tank  has a built-in spill control plan that would go into
effect in the event of an emergency. Suction trucks, dispersants, and mechanized
grading equipment, backed up by a number of years of spill containment and
clean-up experience, would go into immediate service.
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Hercules, Incorporated
Hercules, California

Contacts:    Mr. Gordon Hoffman, Assistant Plant Manager
            Mr. C. Sausaman, Assistant Technical Superintendent

Date of Survey:  October 29, 1970

Property Description

     The Hercules plant, which comprises the town of Hercules, is located on San
Pablo Bay. The property was not surveyed because corporate approval could not
be obtained. The plant seems to be well laid out. There is a definite sloping to ward
the bay, but provisions have been made for surface drainage to go to the  waste
water treatment plant which is used for the ammonia and nitric acid plant  and is
equipped with appropriate  pH control. A second waste-water treatment system
will be in operation in 1971 for the methanol and formaldehyde plant. Biological
techniques  will be used. Some surface water will probably be handled in that
facility.

Hazardous Chemicals

     This facility produces  urea, methanol, formaldehyde, ammonia, nitric acid,
ammonium nitrate, nitrogen tetroxide, and urea formaldehyde.

Bulk Storage Facilities and Pipelines

     The following storage  tanks are located in the plant. Most of the tanks are
diked; exceptions are noted.

     2  - 100,000-gal. tanks for ammonium nitrate and UN-32 (mix-
     ture of NH4NO3 and urea)
     These  two tanks are submerged. The first  one is an old tank
     which has been newly  lined  with stainless  steel, while the
     second is a submerged concrete tank.

     1  - 20,000-gal. methanol tank,

     4  - 30,000 to  50,000-gal. fertilizer solution tanks, which will
     be diked in 1971,

     2  - 10,000-gal. sulfuric acid tanks, which are undiked,
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     1 - 100,000-gal. tank plus an anhydrous ammonia tank,

     8 to 10 small tanks containing methanol and formaldehyde.

     Most shipments are  made by truck; some by rail. There are no waterborne
movements. The loading docks are located in individual plant areas.

Past Spill Experience

     Approximately  10 years ago, a spill of formaldehyde  from a tank was
recorded. This was a tank overfill-overflow occurrence.

Spill Control Plan

     Plant spill control practice is said to be excellent. Spill prevention procedures
are stated to be in existence, but were not discussed or shown, except for surface
water problems  and waste-water  treatment. We were assured that appropriate
procedures are being followed.
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J and J Disposal
Benicia Industrial Park
Benicia, California

Contacts:   Mr. Howard Jenkins, President
            Mr. C. J. Tranby (Winton Jones Contractor, Inc.)

Date of Survey:  October 30, 1970*

Property Description

     The J  and J  Disposal firm is  a comparatively new concern involved in the
disposal of waste chemicals. Its 243-acre disposal site is located in the rolling hill
country  north of Suisun Bay and  the  Sacramento River. The elevation is esti-
mated to be  600 to  700 feet above  sea level  and has a State  of California
"Class 1" dump rating which  is given only to sites that have no waste water
discharge. The operators contend that prior to commencing  operations they met
- and continue to meet — the demands of 13 regulatory bodies.

     The concern has six 110-bbl capacity vehicles and uses four to five common
carrier tank trucks (mostly 30-bbl capacity with 42 gal/bbl)  to haul spent chemi-
cals  from  as  far  as Richmond, California (10  miles) to the dump  site. The
chemicals are  pumped into evaporation and  settling ponds where sun and wind
evaporation separates  the  waste  water from the chemicals. The  University of
California in  Berkeley  has  measured a  76-inch annual evaporation  rate in the
locale  and an  18-inch average rainfall has been recorded for the area. There are no
perennial streams at the disposal site, and the intermittent flow of rain water in
the various  gulches has been diverted from the area. The operators have experi-
mented with spraying the waste liquids directly onto the soil to hasten evapora-
tion. The separated chemical solids are then finally bulldozed into the soil.

Hazardous Materials

     The firm's report (dated September 1970) to the California Department of
Health reported disposal of the following waste materials during the month:

         Sour water                7,750 bbl
         Spent caustic              8,035 bbl
         Oil slop                   4,180 bbl (from tank bottoms)
         Floe                     9,066 bbl
         Wash water               1,070 bbl
         Phenolic water            1,820 bbl
	Sulfuration tar            2,743 bbl (contaminated asphalt).
'Data further clarified during telephone conversation of November 4, 1970.


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Bulk Storage Facilities and Pipelines

     The disposal area has no storage tanks or pipelines.

Past Spill Experience

     Spills have been  confined to a 1-bbl spill resulting from careless operation
during  preparation  for  a spray  test. The  spill  was reported  to  the State of
California even though it was confined to the disposal site.

Spill Control Plan

     J  and J Disposal has a close business relationship with Winton Jones Con-
tractor, Inc. In the event of a spill, all of the Jones  mechanized contracting
equipment could  be quickly  diverted and  transported  to the disposal  site to
control and confine the spill by the fabrication of earthen retainment dikes.
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D. CHARLESTON, WEST VIRGINIA

     Charleston, the  capital city  of West Virginia, is located on the Kanawha
River at the junction of the Elk River, principal tributary of the Kanawha. This
site  has  been located  on  the  main  stream of East-West transportation since
development of highways  to  the West  began  in  the early 19th  century. Its
development as a major center for chemical manufacture began after World War I
and was based on the availability of fuel. Complex plants for the manufacture of a
variety of  materials were established by  a number of major national  chemical
companies. These plants have been expanded and modernized continuously, and
the trend continues today. The Kanawha  is navigable  for about 90 miles from its
source at the junction of the Gauley and New Rivers above the London dam to its
junction with the Ohio at Point Pleasant above Huntington. Charleston is located
at about 55 miles up the river.
     The industrial development of the river extends from the head of navigation
about 90 miles to about 40 miles up river at Nitro, West Virginia. This area is the
territory covered by the Charleston survey. It includes the Elk River on which are no
facilities of interest. Industrial development on the Ohio  River at the mouth of
the Kanawha has begun, notably  with a polyester plant operated by Goodyear.
These  facilities, however, are outside  the geographical area of interest  and the
Kanawha between that point and Nitro is relatively undeveloped. This definition
of the  area of interest was selected  by the Cincinnati Regional Office of the
FWQA  and was based upon maps  provided  by the American Electric Power
Company and on river charts provided by the Corps of  Engineers. These data
provide reliable information on  facilities  which are so  located that  spills of
hazardous materials could contaminate the Kanawha River.

1. Site Character

     The topography of this  area is that of low mountainous terrain with very
little flat land. The  Kanawha  flows between steep banks  with  tributary streams
joining the river through relatively narrow valleys. There are three navigation and
flood control dams on the river — the Marmet and London  dams above Charleston
and  the Winfield dam below Charleston.  Spills from the  facilities in  the area
would  quickly find  their way to the Kanawha where they would be confined to a
restricted water course rather than  dispersed  over widespread harbor and beach
systems. The existence of the dam and lock systems suggests that confinement of
the river water on a temporary emergency basis would be possible in the event of
a spill which might require such action.
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2.  Data Sources

     The Department of Water Resources (DWR) of the State of West Virginia,
with offices located in Charleston, was an important source of information. This
agency works quite closely with local industry and operates under water quality
criteria  established by law by the State of West Virginia in 1965. The state has
had a voluntary spill alert system in operation since  1958.  As part of their water
quality  criteria, reporting of spills is now mandatory. Operational malfunction
and  discharge  of wastes through  treatment-plant outfalls  is the most frequent
occurrence; direct chemical spills are infrequent. Attention to these spills is paid
by the state on a single-case basis. No attempt at coordination and analysis has yet
been made.

     An industry committee known as the Kanawha River Industrial Advisory
Committee  (KRIAC)  has operated for many years in close  cooperation with the
DWR. Almost  all of the large chemical plants have members on this committee.
The  committee has been coordinating the  use of the Kanawha River by the plants
in the interests of protection of the river as well as  maximum usefulness of this
resource to industry. Furthermore, the committee takes an active interest in all
environmental  problems relative to industry in the valley and was thus a valuable
resource for data to fulfill the objectives of this study.

     Visits were made to the Huntington offices of the Corps of Engineers and
the Coast Guard. Both agencies receive spill reports, and the Coast Guard takes
action on a case basis where it is required to control the  spill. Records of spill
problems are also available in the Department of Water Resources files at Charles-
ton.  The Corps of Engineers provided three items which gave valuable data for the
Charleston  survey,  the first being a  set of Kanawha River navigation charts
showing the location and character of all of the riverside  dockage and shipping
facilities, as well as the industrial intakes in the valley; the second document being
a listing of all of the riverside facilities for which permits have been issued; and
the third item being  a  set of aerial photographs  which provide good illustrative
detail of the nature of the physical  facilities in the survey area.

3. Past  Spill Experience

     In  1958  a cooperative program of spill reporting on  a voluntary basis was
initiated by KRIAC  and  the  West Virginia authorities.  On the basis  of this
experience a mandatory program  was adopted as part of  rules and regulations
adopted by the Water Resources Board  of West Virginia in 1965. Copies of
reporting forms are offered as Appendix F, This system incorporated two features
which appear especially desirable:
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     (1)   The quantity, name,  nature, and specific hazard of the
          material spilled; and

     (2)   the  current estimate  of the river flow and  consequent
          dilution.

     This information is considered vital toward the preparation of an effective
spill control plan and is lacking on most reporting systems viewed throughout the
nation.

     Other sources of past spill data are the Coast Guard, the Corps of Engineers,
and  FWQA itself. Data  from these sources is summarized in Table 11. It  is
apparent that  the spill data are fragmentary and incomplete; only 12 instances of
spills are reported for the years 1965 through 1970. Many water-soluble and
heavier-than-water chemical spills could have gone undetected.

     The work of the KRIAC Committee and the unified approach to control and
improvement  of the river quality represent a good program. This work, together
with the design and operating standards of the larger companies, indicates a serious
attempt  is being made to  improve water quality  in the valley.  Because spills
will be carried downstream with  the flow of the river, emphasis is on prevention,
and primary containment of spills is of paramount importance.

                                  TABLE 11
            PARTIAL LISTING OF SPILLS INTO THE KANAWHA  RIVER
                     IN THE CHARLESTON AREA - 1965-1970
Date

 7/27/65
Material

Acrylic "Acid
 7/28/65    Croton oil

10/26/65    Toluene
12/15/65    Tetralone and tetralol

 1/19/66    Crotonaldehyde

 8/18/66    Isopropanol

 5/4/68      Normal paraffins

10/26/69    MIBK

 4/22/70    2-ethyl-butyraldehyde

 9/  /70    Methanol

11/  /70    Acrylonitriles

11/24/70    PPCH
Amount                   Cause/Remarks

 10,000 gal.      Tank dumped to cooling water
                drain to prevent runaway
                polymerization

     45 gal.      Hose drainings

  1,000 gal.      Truck overturned
100,000 Ib       Operating error

 38,900 Ib       Faulty relief valve

 22,800 gal.      Barge leak

     75 gal.      Valve leak on barge

    100 gal.      Hose leak

     25 gal.      Barge leak

N/A             Hose break

 42,000 gal.      Pumping into tank  with valve open

N/A « 100 gal.)   Intentional disposal.
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Union Carbide Corporation
Environmental Control Group
South Charleston, West Virginia

Contacts:   Mr. George J. Hanks, Manager
            Mr. F. D. Bess, Assistant Manager
            Mr. E. M. Hall, Manager Institute Plant
            Mr. R. Payne, Engineering Manager

Date of Interview:    October 8,1970

     The Environmental Control Group has responsibility for all of the Union
Carbide facilities in the Chemicals and Plastics Division, including the two plants
in the Kanawha Valley and the plant  at Texas City. This plant was visited  in
recognition of the fact that the  larger chemical companies, such as Carbide, have
had  extensive  experience  in coping with  dangerous chemicals, including the
problem  of spills and hazards to the public  and contamination of the waterways.
The most significant development relative to these problems is the establishment
of the  Environmental  Control Group  itself.  The  corporation  recognizes this
function as an essential part of operating a  chemical industry and has established
the group with qualified personnel with  the authority to enforce adequate control
measures. Its personnel participate actively and continuously  in the planning  of
new  functions,  and  in  the  maintenance of existing plants. The group has veto
power over process design  features on new  facilities where it considers that
operation of the proposed process would endanger the environment.

     Union  Carbide  is an active participant and an initiator of the cooperative
program with the state  for voluntary reporting of chemical spills and analysis  of
the danger involved. In connection with this effort, Union Carbide entered into a
cooperative program with the Mellon Institute to classify the potential hazard  of
all materials handled by the Chemicals  and  Plastics Division. As a result, data on
the degree  of  hazard  and  methods  for containment and  clean-up are swiftly
available in the event  of any spill. An alerting procedure  ensures that qualified
people at Carbide and at the Mellon Institute are quickly available at any time  to
help with a spill problem. In the event  that a  spill reaches  the river, data on the
flow  in the  river at the time of the spill are available; this information, combined
with  an estimate of the quantity of the spilled material, can effect a prediction  of
the  concentrations expected downstream  in  the  river and thereby an overall
assessment of the problem.  The concentration in the river is then monitored  to
verify the prediction and, if necessary,  water users can be advised to discontinue
using the water until the danger is passed. Union Carbide's experience shows that
there are two or three spills a year which must be reported and monitored in this
way. There have been  no spills of toxic materials.  The problem has  been with
chemicals which impart taste, odor, or affect the clarity of the river.
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     Union  Carbide's  primary  defense  against  spills  is concentrated on the
process unit which is designed to prevent spills and to contain them should they
occur. This includes sumps in the process area,  drip pans, check valves, and
operating standards  which tend to emphasize the importance of containment of
chemical materials. An economic incentive is added by a charge imposed on each
process unit for the  amount of waste it sends to the waste-treatment plant. The
manager  of a process section cannot afford to be careless with chemical discharge
because it hurts his profit performance record. The second line of defense against
spills -  and a very effective one  - is the collection of all  liquid wastes and
processing  them in a waste-water treatment system. The only water used in the
plants that is  not processed through this system  is cooling water  which is not
exposed  to process materials. Drainage from process areas, sumps at  receiving and
loading stations, and the diked  areas around storage tanks is all  connected to a
process sewer system which discharges to a waste-treatment plant.

     An  important function of Union Carbide's Environmental Control Group is a
system of inspection and maintenance to ensure that control measures remain in
efficient  operation and that hazards for spills do not develop. Several features of
this program were outlined. First, the position  of  all dike valves is inspected on a
weekly basis. Open valves are called to the attention of the operating supervisors.
All tanks and  other  equipment have a regular schedule of inspection. The timing
varies with the nature of the tank and its contents, but it generally never exceeds
one  year. The method of inspection also varies. In some cases, inspection is by
visual survey of the empty tank. Many are hydrostatically tested, and on most the
shell thickness is measured. Safety valves are subject to regular examination. This
includes, in most cases, replacement of the valve with a shop-inspected and-tested
unit.

     Engineering standards  are developed in conjunction with the Engineering
Division  by active participation in  the  design  of  new facilities,  and  by specific
designs for modification of the  existing plants in the interests of  better spill
prevention, containment, and control. Safety is also a primary consideration in
design. An example  of the attention given to design matters of this nature is in a
study  of the problem of filling storage tanks with flammable  materials. If such
tanks are filled from the top, the chances for  vaporization and formation of an
explosive atmosphere in  the tank are high. If they  are filled from  the bottom, the
entire head of the tank  is imposed on the fill line with consequent dangers of a
break  and a major  spill. Another problem is whether or not  the  falling liquid
stream in a topfill operation would create a static charge with a resulting spark
and  ignition of the  tank contents. After considerable design  study, it was con-
cluded that a real hazard in this respect did exist and a small-scale model fill
operation  was set up by the research group. Under proper  conditions, it was
found that static charges and an explosion could be initiated. The resulting design
standard for storage tanks in this category is, therefore, to fill from the top, but
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through a pipeline which extends to the bottom of the tank and whose outlet is
below the liquid  level in the tank. To prevent siphoning back through this line,
the top of the loop is vented with a second line  which extends to a sufficient
height to serve as a siphon breaker and is connected  to the top of the tank.

     In addition to the plant facilities, Union Carbide operates an extensive barge
fleet with operations not  only  on the Kanawha  River, but  in the  Ohio and
Mississippi systems as well.  Operations of this fleet are controlled from a center in
the Kanawha Valley and extensive use of radio contact and control is made. Any
barge can make contact with this center in a matter  of minutes for assessment and
advice on any problem.
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Union Carbide Corporation
Chemicals Division
P. O. Box 8004
South Charleston, West Virginia

Contacts: Mr. R. G. Lilley, Department Head
            Environmental Control Coordinator
         Mr. William Young, Assistant to Mr. Lilley
         Mr. Robert Aspley, Supervisor
            North Charleston Bulk Storage Area

Date of Survey:       October 7, 1970
Property Description

     The principal production plants of Union Carbide's Chemicals Division in the
South Charleston area are located on a large island in the Kanawha River channel
and on the left bank in South Charleston (Figure 24).  These plants are about 55
miles above the mouth of the Kanawha River. A large bulk storage area is located
directly across the river in North Charleston.

     This is a very large organic chemicals plant employing over 2000 men. The
plants have two sewer systems — one for cooling water  and rain run-off, the other
for water contaminated with chemicals. The  contaminated  water sewer system
connects with the South Charleston municipal sewage  plant, which was designed
in cooperation with  Union Carbide and is presently operated by Union Carbide
personnel.

     The Union Carbide Company has made and is continuing to make improve-
ments in  its handling of  the extremely large number of potentially hazardous
chemicals to reduce the possibility of spillage into the waterways. The experience
and procedures of this company can serve  as an excellent guide to other organic
chemical producers who are altering old plants or building new ones. In a large
organic chemicals plant it is desirable to have separate sewer systems to ensure the
collection and treatment of spilled chemicals. Systematic diking, modification of
equipment to reduce spills, provision of catch basins and drip troughs, systematic
loading and unloading procedures, level indicators, leak alarms, and the like, have
served to reduce the spill hazards in this plant.
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                                                                     Photo Courtesy of U.S.A. Corps of Engineers
FIGURE 24  AERIAL VIEW OF UNION CARBIDE CORPORATION, SOUTH CHARLESTON, WEST VIRGINIA

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Union Carbide Chemicals Division - North Charleston Bulk Storage Area

     The North Charleston bulk  storage area consists of 35 acres of developed
land  and  10 acres of undeveloped  land, and  has a total storage capacity  of
17,200,000  gallons. Individual tank  (30 to 40) capacities range from 33,000 to
810,000 gallons. There  is also storage for approximately thirty 30,000-gal.  tank
cars on a temporary basis.

     All tanks are  diked  with a containment volume greater than the capacity of
the enclosed tank. Most of the dikes are earthen but a few are concrete. Earthen
dike areas are sprayed with a weed killer each year in late July or August to kill
vegetation. All dikes have a drain valve which is kept closed, except when opened
to drain off rainwater.   All dike valves are checked every Sunday to make sure
they are properly closed. If a valve is opened to drain a dike, it is closed on the
same shift. If it is necessary to leave a valve open into the following shift, that fact
is  entered in the log so  it may be properly closed  by the next shift. All pumps
with  packing  glands have been  replaced by pumps with mechanical  seals to
eliminate leakage into diked areas.

     Liquid chlorine, gasoline, and 26 organic chemical liquids are unloaded  from
barges and  6  organic liquids are loaded into  barges at  the  barge station. All
drainage from flexible hoses goes to a 40,000-gal. holding tank for pumping to the
treatment plant on demand. Flanges on hoses from the barge  are broken over a
trough and all drips are picked up in a sump and pumped to a holding tank by a
pump operated by a float switch for delivery to the contaminated sewer.  Most
barges are loaded or unloaded promptly, but chlorine barges are held from 4 days
to 2  weeks as  the  chlorine is used in the plant processes. The chlorine is piped
under the  river through a jacketed pipe buried 6 feet below the normal river
bottom. The inner pipe is 3 inches (schedule 80) and the outer pipe is 6 inches
(schedule 40). Possible leakage at both the inner and outer  pipes is checked  once
a year by  applying up to 50 pounds of air pressure to the jacket and checking for
pressure drop and  bubbles. All other pipe lines are not jacketed. In case of a leak
in the  chlorine line, the  control room can  shut off the flow by  remotely
controlled valves. Chlorine storage tanks are inspected  visually and by reflecto-
scope or audio gage every  4 years. Chlorine hoses are tested with dry air at 350
pounds  of pressure every 3 months.

     All solvent storage tanks are held under pressure equal to 2 inches water and
vented to  atmosphere through flame arresters. There are high-level, low-level and
leak detectors on all tanks, and these are monitored in the control house. When a
tank  is being  pumped  out, the  leak  alarm  will  go on after the  level drops
one-eighth inch to 1 inch. The leak alarm is reset automatically when the remote
valve is  closed again after pumping. Vented air from acrylate tanks and vented air
from filling  tank cars with acrylates goes through scrubbers using 20% triethylene
tetramine and 80% ethylene glycol for removal of acrylate fumes from exit air.

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      All  truck and  tank car loading and unloading areas have collection drains
 which go to the 40,000-gal. holding tank  for pumping to the water-treatment
 plant.

 Automated Warehouse

      This facility is  located on  the South Charleston side of the river.  The
 warehouse  has storage capacity for sixty-four thousand 55-gal. drums of liquid
 chemicals. Any spillage or drips from this entire area go to a sump and thence to
 the treatment plant which was designed to handle loads of this nature. If  the
 flood system  of spray heads is  activated, the  water flow would exceed  the
 capacity  of the  contaminated-water sewer  connection and excess  water would
 flow over the weir and into the river.

 Tank Car and Tank Truck Loading and Unloading Areas

     There are numerous tank car and tank truck stations on the mainland and
 the island portions of this plant. With the exception of one remote area where few
 cars are loaded, all  tank car and tank truck loading and unloading  is done over
 drains that go to the  contaminated-water sewer system.

     Tank cars are spotted  from 8 p.m. to  8  or 9 a.m. to avoid in-plant traffic
 during the day. All spotted tank cars were observed to have derail devices in place
 ahead  of cars to prevent other cars from hitting them by accident while they were
 being loaded or unloaded.

     Tank cars and  tank trucks are  cleaned with steam and, while still hot, are
 dried by inserting an air nozzle system of special design to sweep the walls of the
 tank. All  washings go to the contaminated-water sewer. If a car contains a large
 "heel" of solvent, it may be drained and sent  to be burned in the boilers.

 Sewer Systems

     Prior to 1954 all wastes went to the river, except for concentrated wastes,
which were burned. In 1954 two completely separate sewer systems were  instal-
led;  one  for clean  cooling water,  rainwater, etc., and the other for  water
contaminated with chemicals. The  cooling water and run-off water outfalls drain
to the "back channel" between the island and the South Charleston shore. The
contaminated-water sewers go to a flume system which carries the waste  to the
treatment plant.  All drains  and  pits are clearly  marked  to  make  sure  plant
personnel do  not dump waste or washings into the clean-water sewer system.
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     Outfalls of the clean-water sewer system go into the river from above water
level and the mixing zones are surrounded by floating booms to catch any floating
material that might accidentally go into the river. Some time ago an operator tried
to wash down some spilled detergent and the resulting foam collected in the boom
at the clean-water sewer outfall. The foam was recovered by a floating skimmer
pump which can be moved from place to place as needed.

     Flow of water to the treatment plant now runs 8 to 9 million gpd, but is
down from  the almost  14  million gpd of a few years ago, because  of tighter
controls by operators in the plant. Instruments for monitoring the organic carbon
content of the waste water are  located at two points in the waste-water flume
system. Plans call for increased installation of remote sensing units which can be
monitored form a central control station. A "panic pond" is under consideration.
It may be used to hold highly contaminated water which may be diverted to it on
the basis of the organic carbon monitors.

Spill Notification Procedure

     All  spills  —  regardless of size and whether they  went to ground, to  the
treatment plant, or to the river — are reported by calling the Utilities Foreman
who enters it in the log.  He is kept advised of the effect of all the plant materials
on the treatment plant,  effect on river, and  other considerations. If the spill is
large, it is reported to the state authorities,  and the FMC plant and the Nitro
water works downstream are notified. As is usual in  the area's approach to spill
control, Carbide has available a nomograph  system. It allows them to calculate  the
parts per million (ppm) of the spilled substance in the river from the spillage rate
in gallons per hour and the river flow in cubic feet per second. Depending on the
oral toxicity hazard rating (1 to  5), the  Nitro water plant  may be shut down for
spill concentrations ranging from 10,000 down to 1.0 ppm.

     The company belongs to the Kanawha River Industrial Advisory Committee
(KRIAC) which has taken an active interest in all environmental problems of the
area, and has set up the reporting system with the state for all spill incidents.

Hazardous Materials

     Materials transported by barge at the North Charleston bulk storage area are
listed below.
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                          A.  Incoming Chemicals

           1. Ethylene glycol               15. Methyl cellosolve
           2. Acetone                     16. Butyl aery late
           3. Methanol                    17. Isopropyl alcohol
           4. Methyl ethyl ketone          18. Acetic anhydride
           5. Propionic acid                19. Isobutyl acetate
           6. Cellosolve acetate, 99%        20. Cellosolve
           7. n-propanol                   21. Glyoxal, 40%
           8. Butanol                      22. L. G. Carbitol
           9. Ethylene glycol               23. Amyl alcohol
          10. Propionaldehyde              24. Isobutyl alcohol
          11. Ethyl acrylate                25. Isopropyl acetate
          12. 2-ethyl hexyl acrylate         26. Ethylenediamine
          13. Vinyl acetate                 27. Chlorine
          14. Cellosolve acetate, 95%

                          B.  Outgoing Chemicals

           1. Butyl acetate                  4. Ethylene Dichloride
           2. Propylene dichloride           5. Butyl cellosolve
           3. Methyl amyl alcohol           6. Ethyl acetate

Past Spill Experience

     See Table 11 for a listing of past spills.
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Union Carbide Corporation
Institute, West Virginia

Contacts:    Mr. M. E. Hall, Environmental Control Manager
            Mr. William Miller, Engineer

Date of Survey:       October 7, 1970

Property Description

     The Union Carbide Corporation Institute plant (Figure 25) is a large facility
that processes  about 20  major organic  chemicals. Ethylene is a principal raw
material, and derivatives include ethylene glycol, many plasticizers, resins, poly-
urethane, and also derivatives of chlorine and of HCN. It is a newer facility than
Union Carbide's plant at Blaine Island in Charleston and for this reason was easier
to update relative to the  most  modern safety and spill control measures. Three
separate docks are operated for  shipment and receipt of materials by  barge. One
of these docks is reserved exclusively for chlorine receiving; the others handle a
full line of liquid materials.  Floating docks are provided, with provisions for the
barge to moor securely to the dock by conventional shipping practice. Transfer
pumps are  installed on  the docks and  the barge  connection is  made by a
combination of flexible hose and portable pipeline. The flexible hose is required
to prevent undue strain on the pipeline system. Armored high-pressure hoses are
used. The pumps are fitted with drip pans and slop tanks. Upon completion of a
transfer the pipeline is blown clear to the storage tank and back  to the barge by
an appropriate gas, either  air, if a non-flammable material is involved, or nitrogen,
if an inert gas is required.

     Adjacent to the dock area  there is a storage tank farm with about 20 tanks
of 100,000-gal. capacity. These  tanks are vertical and cylindrical with fixed roofs
and contain such materials as ethyl acetate, ketone, acetone, and glycol. There are
also four spherical tanks for storage of ethylene oxide. Each tank is surrounded
by a separate earthen dike. There is a drainage connection from inside the diked
area to the chemical plant sewer. This drain is fitted with a valve which is closed,
except when there is need  to drain rainwater from the system. Fill lines to the
tanks are installed in the  standard vented-loop Union Carbide system. Discharge
pumps are located inside the diked area. This system is typical for tank farm areas
at the Institute plant.

     In  addition to the riverside tank farm, there are five other large systems of
storage tanks complete with appropriate diking. The diking is either earthen or
concrete. In crowded areas it has been necessary to use concrete dikes. In some of
the process areas, there is also a sizeable amount of storage. For example, at one
location there are  a number of 5000-gal. vertical storage tanks. These are located


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    -
    I
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                                                                                                  Photo Courtesy of U.S.A. Corps of Engineers
                                FIGURE 25  AERIAL VIEW OF UNION CARBIDE CORPORATION, INSTITUTE, WEST VIRGINIA

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behind a concrete dike and the drainage from the dike system is to the process
sewer. Proper operations of such a system in a process area is more controversial
than a diked storage tank farm area. There are problems with both housekeeping
and safety if the drain from the diked area is maintained closed  and operating
personnel are in favor of keeping these drains open. At the present time, however,
the standard is to keep the drain valve in the closed position. If it must be opened
for any  reason, the process supervisor must  obtain permission  to open the valve.
Such  permission is granted  after  sampling and analyzing the material  to be
drained.  If the drainage time overlaps a change of shift, the  outgoing operator
closes the valve, logs it closed, and the incoming operator then opens it and logs it
open. This procedure avoids any controversy over the responsibility for leaving a
valve  open. The position of all of these valves is checked on a weekly basis by the
Environmental Services Group. Any open valves are called to the attention of the
operating supervisor who must then come out and  close it.

     The plant receives and ships material both by truck and rail.  There are two
major terminals of transfer in the plant which handle many products. There are
also about  12  stations at the individual process  units which handle specific
products. At the multiple product stations,  transfer lines terminate in a manifold
and  are  then  connected  to  the tank  car or rail car by flexible  hose systems.
Transfer pumps are available  at this station  with a suction line connected  to the
car by flexible hose and a discharge connected to the appropriate transfer line by
another flexible hose. These manifolds and the transfer pump are located within a
curbed area with a special drain. In some cases this drains to a special sump for
pumping to a  reclaiming area. In other cases, the sump drains to a  process sewer.
The tank car  or tank  truck  spot is also sloped so that it drains  to the process
sewer.

Drainage

     At the Union Carbide Institute, the process sewer system  is entirely separate
from  the storm sewer system. Only clean water can get to the storm sewer. The
process  sewer line takes all of the waste from the processing areas of the plant and
is also connected to the diked areas around all of the storage tanks, as well as the
rail and truck shipping areas. This system effectively prevents the discharge of any
contaminated  waste directly to the river. All waste must be processed through the
treatment plant before discharge to the river.

     The waste-treatment plant includes primary settling basins, aeration cham-
bers,  and secondary clarifiers. Union Carbide has developed and employs  special
instrumentation to analyze the effluent from the treatment plant for total carbon.
These instruments are also  used to monitor the sample process  areas  which
discharge to the treatment plant. In this way, trouble can be located quickly and
the offending  unit  can correct  the difficulty.  The waste-treatment facility is
designed to minimize  the impact  of a large spill.  At  normal flow rates, the

                                   159

                                                                       Arthur D Little Inc

-------
aeration basins provide a total of three days of residence time. This large capacity
allows for dilution and equalization of contamination problems, and also allows
time for analysis of unusual situations requiring corrective measures. In addition,
a very large area adjacent to the treatment plant has been reserved as a "panic"
pond for a temporary holding of contaminated fluids for emergency treatment.

Hazardous Chemicals

     A  general description  of the  materials handled in this facility  and at the
Institute plant is presented in Table  12.

Past Spill Experience

     See Table 11 for a listing of past spills.

Spill Control Plan

     Union Carbide is a member and follows the practice of the several Kanawha
Valley emergency and disaster control plans.
                                    160

                                                                       Arthur D Little, Inc.

-------
                                                      TABLE 12

                 HAZARDOUS MATERIAL STORAGE AT UNION CARBIDE CORPORATION
                            INSTITUTE AND SOUTH CHARLESTON. WEST VIRGINIA*

Product Name
Aerowl MA pur
Ammonium lauryl polyether
Benzene thiophene free
Tertiary buunol
1-2butyleneoxide
Calcium carbide sludge
Calcium chloride fuel pro
Carbon tetrechlorkJe pur
Chloroform
Dtchloreth'eth
Diphenyl emina
Dipotanium hydrogen
Tort dodecyl marcaptan
Epichlorohydrin
Flexol platticizar TCP
Formalin, 37%
Formaldehyde 50%
Gaioline white
Gluconic acid 50% tech
Glycerine superol
Granular carbon 12 x 4 cal
Heptane pur
Hexene pur
Hydrogen peroxide albone
Isobutylene
Lauryl alcohol lulfate
Launy alcohol Sipanol L2X
Methaerylic acid - glacial
Meth methyl acetate mix
Nonane napht mineral tprt
Phosphoric acid, 75%
Phoiphoroui oxychloride
Platticizer extender 125
Potanium hydrox, 45% LC
Silicate of loda
Sodium aluminate tech
Solvent Bronoco rubber
Sulfur dioxide comm gr.
Sulfuric acid. 93% W.N.
Tall oil fatty acid pur
Tate itopropyl tiunate
Urea pur
Vinyl chloride
Xytel commercial gr.
Nitrogen drlox
AlfJOtiliconetet
Acetic acid glacial
Butoxy triglycol
Oichlorethyl ether
Isobutyl aaylate
Methanol
Tridecanol mixed itomen
UCON brake fluid PM 4869
UCON brake fluid PM 4823
Vinyl acetate HQ
Vinyl acetate L-HQ
R 21
AFgly
Acetic acid gla
Acetic acid
Container
Type
T/T
T/T
T/T
T/T
T/C
Berg.
T/C
T/T
T/T
T/T
T/T
T/T
T/T
T/C
T/T
T/T
T/T
T/T
T/C
T/T
Pkg
T/T
T/T
in
T/T
T/T
T/T
T/T
T/C
T/T
T/T
T/C
T/T
T/T
T/T
T/T
T/T
T/T
T/C
T/C
T/T
T/T
T/C
T/T
T/T
T/C
T/C
T/C
T/T
T/T
Barge
T/T
T/T
T/T
T/C
T/C
T/C & T/T
T/T
T/C & T/T
T/T & Barge
                                      Source
                                     Purchased
                                     Purchaiad
                                     Purchased
                                     Interplant
Storage Tank
   She*

    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
    A
     B
    A
    A
    A
     B
    A
     A
     A
     B
     A
     A
     A
     A
     B
     A
     C
     A
     B
' From a computer program prepared by the Union Carbide Corporation.
    Product Name

Acetic acid strong
Mixture PM 4325
Acte Acid PM 1417
Acetic Acid PM 1486
Acetic anhydride
Acetic anhydride
Acetic anhydride
Acetone

Acetone
Mixture PM 4200
Acetone PM 3964
Acrylonit MMHQ

Acrylonitrile

Airecon PM 4578
Amino et ea

Pri amyl ale

Amyl tallate

Anhydrol PM 1473
AnhydrolPM 1474
Mixture PM 4078
Mixture PM 4079
Mixture PM 4080
Mixture PM 4081
Mixture PM 4082
Mixture PM 4083
Mixture PM 4084
Mixture PM 4085
Mixture PM 4135
Mixture PM 41S7
Mixture PM 4176
Antidult  Agt JM
Mixture PM 4337
Butanol

Butanol esters gr.
Butanol residue
Mixture PM 1524
Sec butanol
Butox ethoxprop
Prop f ilmer bep
Butoxy triglyco
Bu acet AM vise
Butyl acetat 98
Butyl acet PU G
Bu acetat CA 149
N butyl acetate

Mixture PM 3934
 Butyl acrylate
 Butyl aery MMHQ
 Bulylimine
 Butylamine CR
 Butylamine 97PC
 Butyl Carbitol
Container
Type
Barge
T/C
T/C
T/T
Barge
T/C & T/T
T/C
T/C & T/T
Barge
T/T
T/T
T/T
T/C & T/T
Barge
T/C & T/T
Barge
T/T
T/C & T/T
Barge
T/C & T/T
Barge
Barge
T/C & T/T
T/T
T/C & T/T
T/T
T/T
T/T
T/T
T/T
T/C & T/T
T/T
T/C & T/T
T/T
T/T
T/T
T/C & T/T
T/C
T/C & T/T
Barge
Barge
T/C
T/C & T/T
T/T
T/C & T/T
T/C
T/T & T/C
T/C & T/T
T/T & T/C
T/C & T/T
T/C & T/T
T/C & T/T
Barge
T/T
Barge
T/T
T/C & T/T
T/C & T/T
T/T
T/C & T/T

Source
"
514
"
"
Interplant
"
"
Interplant

"
514
"
Interplant

"

514
Interplant

"

614

"
"
••
"
••
"
"
••
••
"
514

••

"
Interplant

"
514
"
Purchased
Interplant
"
514
"
"
"
"


"
Interplant
"
Interplant

"
514
Storage Tank
Sin'
A
A
A
A
B
B
B
C

A
A
A
B

B

A
A

B

A

A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
C

B
A
A
A
A
A
A
A
A
A
A
C

A
B
B
A
A
A
A
                                                          161
                                                                                                          Arthur D Little, Inc

-------
                                                            TABLE  12 (Continued)
       Product Nwm

  Butyl Carbitol
  Butyl CB acetat
  Butyl Ollotolve

  Butyl CSacm
  Butyl chloride
  Butyl chloride
  Butyl«neOX12
  Butyl Ether
  Butyralde enhyd
  Butyralda anhyde
  Butyruldenyde
  Butyric Acid
  Cartaitol low gr.

  Carbitol PM 0600
  Mixture PM 4467
 Certaitol Acetat
 Cellonlv*

 Cello Acet PU G

 Mixture PM 4446
 Cellosolve Acet

 Cyclohexanone
 Cyclohexylimine
 Diaceton Ale
 Diac Al T PM 0366
 Mixture PM 4143
 Oibutylamine
 Dibutylamine
 Dibutyl phthala
 Oiane221
 Di*n«234
 Diane 234
 Oiethano lamina
 Diathanolamine
 Oiathano lamina
 OiethPM 1713
 Dieth PM 3368
 Mixture PM 4047
 Diethox tarragl
 Diathylamina
 Dietene glycol

 Diatana glycol A/F grade
 Dieth Gl PM 3253
 Dieth triami HP
 Mixture PM 3931
 Diethyl ethanol amine
 Di 2 ehex phoi ac
 Diethyl maleata
 Diethyl succinat
 Diitobutyl carbinol

 Diisobj carbino

Diiiobu ketone
Diisopropano lamina
Mixture PM 4246
Mixture PM 4280
Mixture PM 4490
Diitopropylamine
Container
Type
T/C
T/C & T/T
T/C & T/T
Barge
T/C & T/T
T/C & T/T
T/T
T/C & T/T
T/T
T/T
T/C
Barge & T/C
T/T & T/C
T/C & T/T
Barge
T/C & T/T
T/T
T/C & T/T
T/C & T/T
Barge
T/C & T/T
Barge
T/T & T/C
T/C & T/T
Barge
T/C
T/T & T/C
T/C & T/T
T/T
T/T
T/C & T/T
T/T
T/C & T/T
T/T & T/C
T/C & T/T
T/T & T/C
T/T & T/C
T/T & T/C
T/C
T/C & T/T
T/T
T/T
T/C & T/T
T/T & T/C
T/C & T/T
Barge
Barge
T/T
T/T & Barge
T/T
T/T & T/C
T/T & T/C
T/T & T/C
T/T & T/C
T/C & T/T
Barge
T/T & T/C
Barge
T/T & T/C
T/T & T/C
T/C & T/T
T/T
T/T
T/T & T/C

Source
..
"
••

••
••

"

••

Interplant
514
Interplant

514
••
••
Interplant

Interplant




Purchased

514

"
Interplant
"
514
"

"
Interplant
••
••
••
514
"
"
Interplant
Interplant




514

"






Interplant
514



Interplant
Storage Tank
Size*
A
A
B

A
A
A
A
A
A
A
B
A
B

A
A
A
B

B

A
B

A
A
B
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A

A
A
A
A
A
A
A
A
A

A

A
A
A
A
A
A

Product Name
Dimet am propyl
Dimethyl ea anh
Dime aa R. Haas
Dioxane PM 4805
Dioxane
Dioxane
Di-n-propy famine
Dipropylene gly
Epichlorohydrin
Estanol

Ester Diol 204
Ethane liquifier
Ethane
Ethanol 190 pf gross
EthanoCS19 190
Et 190 PF und LO

Ethan 190 und LO
Ethanol SOI 190
Eth>noSD2B 190
Ethano SD3A 190
Mixture PM 31 63
Mixture PM 4811
Ethanol SD29E
Ethan SD29C 190
Ethano SD29 190
Ethan SD29B 190
Eth.no SD30 190
Eth 190 PF SD29H
Ethan SD39B 190
Ethano SD40 190
Eth 190P SD40 8
Ethan SD3A190P
Eth SD4 Spir Gr
Et 190SD23HLO
Et 190SD30A
Et 190SD35ALO
Ethan SD38B 190
Eth SD33F 190 LO
Eth 190PSD401
Eth 190P SD40 1
Ethanol 200PF spirits
Ethanol 200 SD2
Ethano CD 19200
Ethano CD 19 200
Ethan SD2B 200
Mixture PM 3856
Ethan SD3A 200

Eth SD3A 200 PF
Ethano SD29 200
Eth SD29 200 PFE
Ethan SD39C 200
Eth 200P SD70 7
Ethan 200 SD40
Ethoxydimethyldihydropyran
Etho«ytrigly TE
Ethoxy trigtyco
Et Acet 95 98PC

Etac8789PCIC
Eth acet 99PC

Container
Type
T/T & T/C
T/T & T/C
T/T & T/C
T/T & T/C
T/T & T/C
T/C & T/T
T/C & T/T
T/C & T/T
T/C & T/T
T/C & T/T
Barge
T/T & T/C
T/T
T/T
Barge
T/C & T/T
T/C & T/T
Barge
T/T
T/C & T/T
T/C
T/C & T/T
T/C & T/T
T/C
T/C & T/T
T/T
T/C & Barge
T/C & T/T
T/T
T/T
T/T
T/C & T/T
T/T
T/C & T/T
T/C & T/T
T/C & T/T
T/C
T/T
T/T
T/T
T/T
T/T
Barge
T/C & T/T
T/C & T/T
T/T
T/C & T/T
T/T
T/C & T/T
Barge
T/T
T/C
T/T
T/T
T/T
T/T
T/T
T/T
T/T & Barge
T/C & T/T
Barge
T/T & T/C
T/C & T/T
Barge

Source
514
"
••
514



"
Interplant
••

514
Interplant
514
Interplant

514

••
514

••

••
••
••
••
••
S14
"



"
"
"

••
••
••
••

Interplant

••
514
••
••
••

••
••
514
••
••



Interplant
514




Storage Tank
Size*
A
A
A
A
A
A
A
A
A
B

A
A
A
C
A
A

A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
B
B
B
A
A
A
A

A
A
A
A
A
A
A
A
B
A

A
B

                                                                       162
                                                                                                                                Arthur D Little, Inc

-------
                                                            TABLE 12 (Continued)
        Product NIITW

   Et K 99 6PC UG

   Etac USP NF FCC
   Eth KM ACS
   Mixture PM 5228
   Et acet 96 98PC

   Mixture PM 3640
   Mixture PM 5146
   Ethyl aerylata
   Ethylamina anhydrous
   Ethylamine
   2-ethylbutanol
   2-et-butanol CR
   2-ethyl butyraldehyde
   Etane clhy anhy
   Ethyl dia 98PC

  Eth diam water
  Mixture PM 3648
  Etene dichlorld

  Eth dich radiit
  Ethylene glycol

  Ethylana glycol A;F grade
  EthyleneglyCR
  Ethyl gly 879A

  EIGIINPM1717
  Mixture PM 1975
  Ethyl gly tails
  Ethylene oxide
  Et oxide red in
  2 ethyl hexaldehyde
  2 ethylhexanol
  2-e-hexanol rec
  2-«t hexoic acid
  2-et hexoic acid
  2-et hexyl acet
  Et-hexacry MMHQ
 2-ethyl hexylami
 2-et hex tallate
 n-ethylmorpholi
 Et prop acrolei
 Eth lil prehydr
 Et lilicate 40
 Et lilicate cond
 Flexol PM 5303
 Armttrg plan A
 Flex plait 3 GH

 Flex PI 3 GM

 Flex platt 4 GO
 Flex plan 1010
 Mixture PM 4316
 Flexol PM 4574
 Flex plan 10 A
Mixture PM 4373
Flex plait 380
Flexol PM 3321
Flex plait A 26
Mixture PM 4847
Flex plait 3 CF
Container
Type
T/C & T/T

Barge
T/T & T/C
T/C & T/T
T/C & T/T
T/T & T/C
Barge
T/C & T/T
T/T
Barge
T/C
T/T & T/C
T/C & Barge
T/C & Barge
Barge
T/C & T/V4
T/T & Barge
T/C
Barge & T/C
T/T
T/C & T/T
Barge
T/T & T/C
T/C & T/T
Barge
Barge
T/C & T/T
T/C & T/T
Barge
T/T
T/T
T/C & Barge
T/C
T/C
Barge
T/C & Barge
T/T & Barge
T/C & T/T
T/T
T/C & T/T
T/T & Barge
T/T & T/C
T/C & Barge
T/T & T/C
T/C
T/T & T/C
T/T & T/C
T/T & T/C
T/T
T/T & T/C
T/C & T/T
Barge
T/C & T/T
Barge
T/C & T/T
T/r & T/T
T/C & T/T
T/T
T/T & T/C
T/T
T,'C & T/T
T/T
T/C & T/T
T 'C & T/T
T/T & T/C

Source
,(

••

"
Interplant
Interplant
514
Interplant

514
Interplant
514
Interplant

„
Exchange

514

Interplant
514
Interplant

514
„
Interplant
514
Interplant
514

,,




,,

„

514

,.


Storage Tank
Size*

B
A
A
A
A

A
A
B
A
A
B
B
A
B
,

A
B
A
C


C


A
A
A
A
A
A
B
A
A
A
B
A
A
A
A
A
A
A

A
B
a


A
A
A

A

«

A
A
A

Product Name

Mixture PM 4803
Flex TOF SP FMC
Flex plast TOF
Flexol TOF FMC
Flexol TCP
Flex plast 2 88

Flex Pla PM 4398
Mixture MP 4592
For aci phar GR
Methane FMC 153
Glutaralo 25PC
Glycerine super
Gly triacetate
Mixture PM 3989
Mixture PM 4298
Glycol diacetat
Glyoxal 40 SPC

Glyoxal
Heptadecanol
HeptanolPM 1655
Hexane
1-hexanepur
1-hexanol
Hexyl cellosolve
Hex glydiacet
Hexylene glycol

Mixture PM 4607
Isobutanol
Isobutanol mons
Isobu AceCA 149
Isobutyl acetat
Mixture PM 4624
Isobutyl Cellosolve
Isobutyl acrylate
Isobutyl heptyl ketone
Iso octanoic ac
Isobutyraldehyde
Isodecanol mixed isomers
Isopentanoic ac
Isooctylaldehyde
Isopentanoic ac
Isop rec HG Gr

Isop ref PM 0437
Isoprop PM 0455
Isopropanol 99

Mixture PM 3921
Mixture PM 4333
Isop'noPM 3710
Mixture PM 3852
Mixed isops
Isop-opyl acet

Isop acet 99PC
Isopropylamine
Kromfax solvent
U Lot TCX878 HS
UCAR latex 862
Container
Type
T/C & T/T
T/T & T/C
T/C & T/T
T/T
T/T
T/T & T/C
T/T
T/T
T/T & T/C
Pipeline
T/T
T/T
T/C & T/T
T/T
T/T
T/C & T/T
T/T & T/C
Barge
Barge
T/C & T/T
T/C
T/T
T/T
T/T
T/T & T/C
T/T & T/C
T/C & T/T
Barge
T/T
T/C & T/T
Barge
T/C & T/T
Barge
T/T & T/C
Barge
T/C & T/T
Barge
T/T
T/C & T/T
T/T
T/T
T/T & T/C
Barge
T/T
T/T & T/C
T/C & Barge
T/C & T/T
T/T & T/C
Barge
T/T
T/T
T/C & T/T
Barge
T/T
T/T
T/T
T/T
T/T & T/C
T/C & T/T
Barge
T/C & T/T
T/C
T/C & T/T
T/T
T/T

Source




"
••
••
••
Interplant
514
Interplant
Purchased
514
"

"
Interplant


Interplant
514
Interplant
Purchased
Interplant
514
"
"


Interplant







514
"
Interplant
514
"
Interplant
"
514
Interplant
514
"



I nterplant

514
••



lnterpl;-nt




514

Storage Tank
Size*
A
B
B
B
A
A
A
A
A
_
A
A
A
A
A
B
B

B
A
A
A
A
A
A
A
B

A
B

B

B

B

A
A
A
A
A
B
A
A
A
A
B

A
A
B

A
A
r>.
A
A
B

A
A
A
A
A
                                                                     163
                                                                                                                            Arthur D Little, Inc

-------
TABLE 12 (Continued)

Product Nun*
UCAR latex 879
U Lit TCX87«0
Uttx TPX 3410
Mixture PM 4876
Mewtyl oxide w. Ml.
Methyl oxM in
Methane!

MMhanol
Methanol
Mixture PM 47S4
Mixturt PM 3822
Mixture PM 5102
Methoxytriglyco

Mtthoxytriglyco
Mfthyl acetate
Mi Acato K«at
Ma Action PM 1039
Mi Amyl acetate

Mixture PM 4433
Mithyl amylalc

Methyl emyl ilc. semi ref .
Mithyl Carbitol

Methyl Butyrildehyde
Methyl CellOKl

Methyl CS aceta
Methyl CS *e«t>
Me ethinolimine
Me et ketone

Mixture PM 5166
Mi itoimyl keto
Me i«obu ketone
Mixture PM 3987
Meth pemaMehy
Met tit hy ph a
Mixture PM 0021
Mixtun PM 0261
Mixture PM 1633
Mixture PM 3076
Mixture PM 3091
Mixture PM 3094
Mixtur. PM3101
Mixture PM 3104
Mixture PM 3171
Mixture PM 3231
Mixture PM 3260
Mixture PM 3349
Mixture PM 3390
Mixture PM 3477
Mixtura PM 3492
Mixture PM 3538
Mixture PM 3539
Mixture PM 3549
Mixture PM 3610
Mixture PM 3634
Mixture PM 36S9
Mixture PM 3665
Mixture PM 3675
Mixture PM 3677
Mixture PM 3737
Container
Type
T/T
T/T
T/T
T/T
Barge
T/C » T/T
T/C & T/T
Birge
T/T
T/C & T/T
T/T
T/C
T/T
T/C & T/T
Berge
Barge
T/T & T/C
T/C & T/T
T/C & T/T
T/C & T/T
Barge
T/T
T/C & T/T
Barge
Barge
T/C & T/T
Barge
Barga
T/C & T/T
Barge
T/T & T/C
T/T ' T/C
T/C & T/T
T/C & T/T
Barge
T/T
T/C & T/T
T/T
T/T
T/T & Barge
T/T & T/C
T/T
T/T
T/C & T/T
T/C & T/T
T/C & T/T
T/T
T/C
T/T
T/T
T/T
T/C
T/T
T/T
T/T
T/T
T/C & T/T
T/T
T/T
T/T
T/T
T/T
T/T
T/T
T/T
T/T

Source
••
"
"
"
Interplant
514
Interplant

"
"
514
"
••
Interplant

"
514
"
"
"

••
••

Interplant
••


"

514
••
514
Interplant

514
"
Interplant
514
Inter plant
514

"
••

"

••
"
••
"




••
514


••




"

Storage Tink
Size*
A
A
A
A
A
A
C

C
C
A
A
A
B

B
A
A
A
B

A
B

B
A

A
B

A
A
A
A

A
A
A
A
A
A
A
A
A
A
A
A
B
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A

Product Name
Mixtura PM 3754
Mixture PM 3B63
Mixture PM 3899
Mixture PM 3949
Mixtura PM 3979
MixturePM4067
Mixture PM 4077
Mixture PM 41 01
Mixture PM 41 37
Mixture PM 41 65
Mixture PM 4257
Mixture PM 4260
MixturePM 4266
Mixture PM 4293
MixturePM 431 2
MixturePM 431 3
Mixture PM 4321
MixturePM 4371
Mixture PM 4374
Gly mix PM 4384
Mixture PM 4389
Mixture PM 4448
Mixture PM 4460
Mixture PM 4468
MixturePM 45 17
ERLA 4565
MixturePM 4610
Mixture PM 4622
Mixture PM 4645
Mixture PM 4709
Mixture PM 4733
MixturePM 4761
MixturePM 4767
Mixture PM 4819
Mixture PM 4820
MixturePM 4825
MixturePM 4828
MixturePM 4851
Mixture PM 4863
Mixture PM 4876
Mixture PM 4896
Mixture PM 4903
Mixture PM 4904
Mixture PM 4927
Mixture PM 4934
Mixture PM 4936
Mixture PM 4973
Mixture PM 5005
Mixture PM 5021
Mixture PM 5028
Mixture PM 5052
Mixture PM 50S3
Mixture PM 5069
MixturePM 5101
MixturePM 51 37
MixturePM 51 61
MixturePM 5 169
MixturePM 5175
MixturePM 51 84
Mixture PM 5194
MixturePM 5196
Mixture PM 5197
MixturePM 5219
Mixture PM 5259
Mixture PM 5268
Mixture PM 5273
Container
Type
T/T
T/C & T/T
T/C & T/T
T/T
T/T
T/C & T/T
T/T
T/T
T/T
T/T
T/T
T/T
T/T
T/C
T/T
T/T
T/C
T/T
T/T
T/T
T/T
T/T
T/C & T/T
T/C & T/T
T/T
T/T
T/C & T/T
T/T
T/T
T/T
T/T
T/T
T/T
T/C
T/T
T/C & T/T
T/T
T/T
T/C
T/T
T/T
T/C & T/T
T/T
T/T
T/T
T/C & T/T
T/T
T/T
T/T
T/T
T/T
T/T
T/T
T/T
T/C & T/T
T/T
T/C & T/T
T/T
T/T
T/T
T/T
T/T
T/T
T/T
T/T
T/T
                                              Source
                                              514
                                              514
                                              514
StoretaTenk
  Sin*

   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
   A
       164
                                               Arthur D Little, In

-------
                                                          TABLE 12 (Continued)
Product MMM
Mixtura PM 5301
Monoethen ICF
Mo I'MMtnino I m In
Monotfthtnoliniin
Monoathaa148
MoiMMthaa 1J038
Monoteopropano
Mixtura PM 4670
Morpno line
Mixtura PM 3757
Mixtura PM 0371
Nl polyol D 41 3
AX pel PPG 426
NO PPG 1025 ONE
Nl pel PPG 1025
N dtol PPG 1226
Nl pal PPG 2025
Nl pol PPG 2026
N P PPG 2026 ONE
Nl Pol PPG 3025
NIAXtrlLG168
NIAX trlol LG 56
NITrlLG560NE
NIAX trl LHT 240
NIAX trILHT 112
NIAX tri LHT 67
NIAX pol E33B
NIAX poly E 341
NIAX trl LHT 42
NIAX pol E 321
NIAX poly D 410
NIAX poly E 322
NIAX poly E 325
NIAX poly D 414
NIAX triol LC 60
NIAX triol LF 70
NIAX reeln S 109
NIAX poly E 261
Nl polyol 50 48
NIAXtoocyTDR
NIAX polyol 3145

Nl polyol 14 46
Ni polyol E 241
NIAX pol 33 46
Nl polyol E 344
Nl polyol E 193
NIAX pol 60 58
NIAX polyol D
NIAX poly D 417
NIAX poly E 147
N polyol E 151
N polyol E 160
Nl polyol E 204
Nl polyol E 229
NIAX poly E 304
NIAX rat T1 10 R
NIAX poly 1646

NIAtr!LHT34RG
NIAX triol LM 62
NIAX pol E 316
Nl polyol D 403
NIAX poly E 274
N poly LG 660
T/T
T/T & T/C
T/C ft T/T
T/T ft T/C
T/T ft T/C
T/T & T/C
T/T ft T/C
T/C & T/T
T/C & T/T
T/T
T/T
T/C & T/T
T/T
T/T
T/T
T/T
T/T
T/C
T/C ft T/T
T/C ft T/T
T/T
T/C ft T/T
T/C & T/T
T/T
T/T
T/T
T/T
T/C
T/T
T/C
T/C
T/C & T/T
T/C & T/T
T/C
T/C & T/T
T/C
T/T
T/T
T/C 
-------
TABLE 12 {Continued)

Product Nam*
Tergitol NPX AN
Tergitol TMN
Tergitol X D
Tergitol X D
Mixture PM 4881
TEOS40
Tetraethyl gly
TetetenepenUmi
Tetraethylorsil
1.2. 3. 6-tebenz
1,2, 3, 6-tebenicr
Toluene, nitrogen gi
Trichlorethane
Triethanolamine, comm.
Triethanolamine
Triethanolamine
Trieth 99
Mixture PM 4024
Mixture PM 4771
Trietene Glycol

Trietene glycol

Trietene gly HP

Trieth gly HP

Mixture PM 31 29
Triethylene tetramine
Triiiopropamla
Tri propy jly
UCAR latex 46
UCAR latex 131
UCAR lat 180 Wet
UCAR lat 360 Wet
U Lat L19 Kelly
U Lat 360 modif
UCAR Lat PM 5100
UCAR Lat 131 mod
Mixture PM 5178
UCAR Lat 180 mod
UCAR lat add ft
UCAR latex 360
UCAR latex 891
Mixture PM 3923
UCAR latex 680
UCAR latex 370
UCAR imp F120S2
UCAR PM 4386
Mixture PM 4096
UCAR fuel AD 600
UC lat VCX 1370
UCAR Pap B1 40
UCAR Pap Bl 40
UCAR Solv LM
UCAR 2 LM
UCAR latex 865
UCAR lat WC 130
Mixture PM 5124
UCON dewier JL1
Mixture PM 4461
UCON B F PM 4961
UCON PM 4274
UCON PM 3265
Mixture PM 4250
Mixture PM 4210
Mixture PM 4016
Container
Type
T/T
T/C
T/T
T/T
T/T
T/T & T/C
T/T & Barge
T/T & T/C
T/T & T/C
T/C & T/T
T/C & T/T
T/T
T/T & T/C
T/C
T/C & T/T
T/T & T/C
T/C & T/T
T/T
T/T
T/T, T/C »
Barge
T/T. T/C &
Barge
T/C, T/T &
Barge
T/T, T/C &
Barge
T/T
T/T
T/T & T/C
T/T & T/C
T/C & T/T
T/C » T/T
T/T
T/C & T/T
T/T
T/C & T/T
T/T
T/C & T/T
T/C & T/T
T/C & T/T
T/C & T/T
T/T
T/T
T/T
T/T
T/T
T/T
T/T
T/T
T/T
T/T
T/C & T/T
T/C & T/T
T/C & T/T
T/T
T/T
T/C & T/T
T/T
T/C & T/T
T/T
T/C
T/T
T/T
T/T
T/C
T/C & T/T

Source
Interplant

514
"
"
"
Interplant
Interplant
514
"
Imerplant
••
514
Interplant
Interplant

••
514
"
Interplant



"

"

514
Interplant
514
514

"

"
••

"
"




••



"


••


514

"

"

••







Storage Tank
Size*
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
B

B

B

B

A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A

A
A
A
A
A
A
A
A

Product Name
UCON PM 4324
Mixture PM 4329
UCON PM 746
Mixture PM 4602
UCON PM 4823
UCON PM 4916
Mixture PM 3983
UCON PM 5157
UCON PM 5158
UCON PM 5255
UCON 75H 1400
Mixture PM 3031
UCON PM 3427
Mixture PM 4191
Mixture PM 4191
UCON PM 1884
UCON 50HB 170
UCON 50 HB 260

Mixture PM 4857
UCONIutaPM 1269
UCON lub PM 0903
Mixture PM 3736
UCON 50HB 400
UCON 50 HB 600
U50HB660COSG
UCON lub SA 33
Mixture PM 4952
Mixture PM 5008
UCON lub SA 20
UCON 50HB 3520
UCON BOH B 5 100
UCON lub LB 65
Mixture PM 4775
UCON lub Lb 285
UCON lub LB 385
UCON lubPM 1461
UCON PM 5066
UCON lub LB 625
UCON lub PM 0827
UCONPM 1175
UCON PM 1243
UCON rub lub 77
UCON lub LB 1145
UCON lub PM 0824
UCON lub LB 1715
UCON lub LB 1715
UCON lub PM 1018
UCON DA 1905
Mixture PM 3196
UCON sol WC 144
UCON sol WC 322
UCON PM 3068
UCON PM 3047
UCON PM 3417
UCON WC 65
Valeraldehyde
Valeric acid
Valeric acid
Mixture PM 4000
Vinyl acetate
Vin acet in LHQ
Mixture PM 3847
Mixture PM 3870
Viny chlo
Vin et ether cr
Vinyl et ether
Container
Type
T/C & T/T
T/C & T/T
T/C & T/T
T/C & T/T
T/C & T/T
T/T
T/T
T/C
T/T
T/C
T/T
T/T
T/T
T/C & T/T
T/C & T/T
T/T & T/C
T/T & T/C
T/C, T/T &
Barge
T/T
T/T
T/T
T/T
T/C & T/T
T/C & T/T
T/T
T/C & T/T
T/T
T/T
T/T
T/T & T/C
T/C & T/T
T/T
T/T
T/T
T/T
T/C
T/T
T/T
T/T
T/T
T/T
T/T
T/C & T/T
T/T
T/T
T/C & T/T
T/C
T/C
T/T
T/C & T/T
T/C & T/T
T/T
T/C & T/T
T/C
T/T
Barge
T/T
T/C & T/T
T/T
Barge
T/C & T/T
T/T
T/C & T/T
T/C
T/C
T/C

Source
..
"
••
••
••
••


••
"
514

••

"
••
"
••


"
••
"


"
"
"
••
"
••
"
"
••
514

••
"
"

"


"
"


"
"


••

••

••
Interplant

514

Interplant
"
514
••
Purchased
514
••
                                                        Storage Tank
                                                          Sin*

                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A

                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            A
                                                            B
                                                            B
                                                            A
                                                            A
                                                            B
                                                            A
                                                            A
      166
                                                Arthur D Little InC

-------
FMC Corporation
Inorganic Chemicals Division
South Charleston, West Virginia

Contacts:    Mr. M. E. Birmington, Resident Manager
            Mr. F. Harvey Herbert, General Engineering Superintendent
            Mr. E. P. Cook, Assistant Pollution Control Supervisor
            Mr. Jack Bowling, Department Superintendent
            Mr. E. F. Eckert, Department Superintendent
            Mr. Chuck Taylor, Department Superintendent
            Mr. George Walther, Department Superintendent

Date of Survey:       October 6, 1970

Property Description

    The Inorganic  Chemicals Division  plant of the FMC  Corporation is located
on the south bank  of the Kanawha River and covers an area about one-quarter
mile wide by one mile long. It is bounded on the east by UCC's plant and on the
south and west by  mixed commercial and residential districts of South Charles-
ton. The land is flat, but is on a bluff situated about 20 to 30 feet above the river.
A large number of chemicals are processed and manufactured; the most significant
of these are chlorine, caustic soda,  carbon bisulfide, carbon tetrachloride,  am-
monia, and hydrogen peroxide. A relatively new operation is the manufacture of a
dry bleach from chlorine, urea, and caustic soda.

Hazardous Materials

    Table 13 is  composed of a list of hazardous materials handled at the FMC
Corporation, Inorganic Chemical Division Plant.

Bulk Storage Facilities and Pipelines

    Caustic soda is a principal product of the plant and is loaded and shipped in
16,000-gal. railroad  tank cars. There is also some shipment  of 70% caustic by tank
truck  and barge. The loading station is comprised of eight spots for tank cars and
one for trucks. Operation is usually confined to the day shift and is controlled by
two operators. The  cars are top-loaded and the operator observes the fill visually,
stopping the pump by remote control.  The loading  area is surrounded by  a
drainage culvert  which runs  directly into the river. Caustic soda is stored in  a
number of vertical tanks, each about 20 feet in  diameter by 30 feet high with a
capacity of  500  tons of  50% NaOH. The tanks are emptied, cleaned, inspected,
and repaired on an annual basis. Level monitoring is effected by a float-type gage
with an indicator outside the tank. All transfers are recorded and cross-checked
by gaging both the sending and receiving tanks.


                                   167
                                                                     Arthur D Little Inc

-------
                                   TABLE 13

            HAZARDOUS MATERIAL STORAGE AT FMC CORPORATION,
                        INORGANIC CHEMICALS DIVISION
                      SOUTH CHARLESTON, WEST VIRGINIA
Material
Shipment Container Size   Source
  (thousands of gallons)
Storage Tank Size*  Comments
Sulfuricacid, 93%
Hydrochloric acid, 33%
Brine (25% NaCI)
Liquid chlorine

NaOH, 70%
NaOH, 50%
NaOH, 50%
NaOH, 50%
NaOH, 20%

KOH, 45%
Urea
H2O2,70%
H202,50%
H202,25%
Tri-octyl phosphate
Carbon tetrachloride
Liquid sulfur
Aromatic solvent
Carbon bisulfide

Anhydrous ammonia
Aqua ammonia, 29%
*{a) Under 100,000 gallons
 (b) 100,000 to 500,000 gallons
 
-------
     Carbon tetrachloride is stored in  an above-ground tank farm consisting of
one large (100,000-gal.) and seven small vertical tanks. Carbon bisulfide is stored
in horizontal tanks which are located  in a below grade  concrete sump and are
permanently covered with water. Any spill or leakage sinks to the bottom of the
sump and is collected and recovered from a low spot. Shipment is by rail car with
top connections only. The transfer is made from storage by nitrogen pressure and
is monitored from an elevated control booth.

     FMC maintains two transfer stations for barge shipments on the river bank.
One of these is exclusively  for receipt of liquid sulfur and is fitted with steam-
traced transfer lines. The transfer pump is on the sulfur barge and the storage tank
is located on the river bank. Inspection of these tanks is carried out twice a year.

     At the dry bleach plant chlorine is received by tank car and used, as needed,
by unloading with dry air; there is no storage for chlorine. Urea is stored in a tank
with a capacity for about two tank trucks; the trucks are unloaded by their own
self-contained pumps. There is a storage tank for  10,000 gallons of sulfuric acid,
unloaded from tank cars by air pressure. The product of this plant is a dry powder;
it is stored in aluminum tote bins prior to packing for shipment in fiber drums.

     The hydrogen peroxide plant is new and has been built with careful  atten-
tion to desirable safety features. The principal danger is one of detonation; there
is  little spill  potential. An "organic work solution" is used  and stored in four
5000-gal. horizontal tanks in a scuppered area. The solution is expensive and care
is necessary to prevent any loss by leakage or spill.

Past Spill Experience

     See Table  11 for a listing of past spills in the Charleston area.

Spill Control Plan

     FMC uses a rather formal procedure of notification and action in the event
of  a spill; in  general,  it  conforms  to  the KRIAC system. The first  step is
notification to the FMC Pollution Control Department. This group determines the
severity of the spill by  consideration of  the nature and quantity of the material
spilled and the river flow data at the time of spill. When appropriate, FMC then
notifies the state and the other industrial  and municipal water users which may be
affected.

     FMC follows  company standards, which recognize the spill hazard, in the
design  and maintenance of its facilities. Recommendations of the Pollution
Control Department are given full consideration  in development  and review of
these standards.
                                    169

                                                                       Arthur D Little Inc

-------
FMC Corporation
Organic Chemicals Division
Nitro, West Virginia

Contacts:   Mr. Robert Simokat, Engineering Superintendent
            Mr. Martin Smith, Process Engineer
Date of Survey:       October 6, 1970

Property Description:

     The FMC Corporation plant at Nitro, West Virginia, is a small producer of
organic chemicals. The facility is approximately 40 years old and was owned by
the Ohio Apex Chemical Company until  the 1950's. It is located on the right
bank  of the Kanawha River about  42.7 miles from its mouth (Figure 26). The
plant is on sloping ground fairly close to  the river.  All chemicals come into the
plant by rail or truck.

Chemical Storage Facilities

     Most chemicals are stored  in tanks which have  been removed from railroad
tank  cars and are now located  on permanent concrete footings. These tanks are
not diked. The principal tank farm is located along a railroad siding in the plant.
Most  of the tanks have sight glasses and  some have level indicators in the tank
yard control room as well as in the process control room.

     Old tank-car tanks are gradually being replaced by new tanks. Dikes are being
placed around new installations. Money has been budgeted for long-range diking
of all tanks in the plant. Methanol is stored in a diked area and POC13 is stored in
two sets of two tanks in  separate diked areas. The dikes will hold more than one
tank volume. The POC13 tanks are of solid nickel as are the lines. Carbon bisulfide
is  stored in two 330,000-gal. tanks under water and below ground level.  The
product is stored for resale.

Spill Notification  Plan

    FMC's spill plan consists of a shift foreman notifying the area supervisor who
determines what has been spilled and the quantity and then calls the engineering
superintendent, the laboratory  superintendent,  or the plant  manager; the West
Virginia Department of Water Resources is also notified.
                                    170

                                                                     Arthur DLitthlnc

-------
rr
C
                                                                                                     Photo Courtesy of U.S.A. Corps of Engineers
                                       FIGURE 26  AERIAL VIEW OF MONSANTO CHEMICAL COMPANY (left) AND FMC

                                                   CORPORATION ORGANICS PLANT (center), NITRO, WEST VIRGINIA

-------
  Sewage Treatment

      Some of the truck loading areas have drains that go to the "acid sewers" and
  thence to a  neutralizing tank before going to the aerated lagoon for biological
  treatment. Several process areas are also connected to this system so the spills are
  treated before being released to the river.

  Preventive Maintenance Program

      There is no routine preventive maintenance  program. As leaks are noted, the
 parts are repaired or replaced.

 Hazardous Materials

      Hazardous materials  handled at the FMC Corporation, Organic Chemicals
 Division, are  presented in Table 14.
                                   TABLE 14

          FMC HAZARDOUS MATERIAL STORAGE AT FMC CORPORATION,
                         ORGANIC CHEMICALS DIVISION
                             NITRO, WEST VIRGINIA
 Material
 POCI3
 PCI 3
 KP-140
 TBP
 MDP
 Kronitex

 Butyl alcohol
 Butyl cellosolve
 Caustic
 Cyclohexanol
 Heptane
 Methanol
 Phenol
 Cresylie acid
 Phosphorus
Shipping Container Size
 (thousands of gallons)

         6
         8
         10
         10
         10
         10

         10
         10
         10
         10
         6
         6
        20
        20
         17
                                               Source
T/T & T/C
T/T & T/C
T/T & T/C
T/T & T/C
T/T & T/C
T,T & T/C

T/T & T/C
T/T & T/C
T/C
T/T & T/C
T/T
T/T
T/T & T/C
T/T & T/C
T/C
                 Storage Tank Size*
 (a)
 (a)
 (a)
 (a)
 (a)
 (c)

 (a)
 (a)
 
-------
Past Spill Experience

     See Table 11  for a discussion of past spill experience.

Conclusions

     This plant has many old but fairly small tanks of 8,000-10,000 gal. capacity
that are  close enough to the river to present a potential spill hazard. The plant is
gradually replacing these old tanks and is incorporating dikes in its new installa-
tions. While the size of potential spills from this plant is relatively low, the present
policy of improving the installation should be pursued actively to further mini-
mize spill potential.
                                      173

                                                                         Arthur D Little Inc

-------
 FMC Corporation
 American Viscose Division
 Nitro, West Virginia

 Contacts:   J. C. Moody, Plant Manager
            H, C. Gainer, Technical Superintendent
            John Janicki, Chief Environmental Chemist

 Date of Survey:        October 9, 1970

 Property Description

     FMC's American  Viscose  Division  is a fairly  large operation producing
 essentially  a single  product — rayon staple. The property is located on the right
 bank of the Kanawha  River, 42,9 miles above its mouth. While the property goes
 to the river, most of the manufacturing facilities are about one-quarter mile back
 from the river bank.

 Barge Station

     Caustic  soda  is brought  in by barge and by-product  anhydrous  sodium
 sulfate is shipped out  by barge. In a  heavy rain,  some sodium sulfate could be
 washed into the river, but there is little  likelihood of a large spill.

 Carbon Bisulfide Storage

     Carbon bisulfide is stored in steel tanks in a concrete basin and submerged in
 water.  Carbon bisulfide is brought into the plant in 20,000-gal. tank cars and one
 car will fill  two of the submerged tanks. When carbon bisulfide is pumped into the
 storage tank in  the process area, the tank is monitored by a Magnetrol level
 control. The tank also  has an overflow and a sight glass. Any  overflow returns to
 the water pit. Periodically, any spilled carbon bisulfide is pumped to a tank car
and sent back to the producer for repurification.

 Sulfuric Acid Storage

     Sulfuric acid is pumped directly from the Allied Chemical plant. There are
 three storage tanks, but only one is used as a receiver and the acid is transferred
from it. There are  level indicators on  the tanks and  plant personnel call for a
specific number of gallons of sulfuric acid to be  pumped over. The warning horn
is checked  daily and the functioning of the level  and alarm system is checked
twice a week.
                                   174

                                                                      Arthur D Little, Inc

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     There are no dikes around tanks, but most leaks from sulfuric acid tanks are
of pinhole size and are usually taken care of by neutralizing the acid with soda ash
until the leaking part can be repaired. These tanks are also so far from the water
that little danger of water pollution exists.

Zinc Sulfate Solution

     Zinc sulfate is shipped into the plant in tank cars containing a 34% solution
of ZnSO4 'H2O. The car is air-pressurized at 7 pounds per square inch to force
the solution to prime the pump. The suction pipe goes in through the dome of the
car to the bottom, and when the contents are pumped out, the pump is shut off
and the suction line drains back into the car. The  storage tanks hold over one
tankcar load each, so there is little danger of running them over. There is no sewer
or sump in the area so if any  solution were spilled it would go on the ground.
Because of the method of operation, the possible spill volume would  be only a
few drops.

Caustic Storage

     Sodium hydroxide is pumped  from the barge into tanks that will hold more
than a bargeload. The tanks have a level control. The caustic line is steamed out
back to the barge with a 15-pound steam line, so all drainage is returned to the
barge. Tank areas are not diked, but are very far from the river.

Sodium Hydrogen Sulfide

     Sodium hydrogen sulfide is shipped into the plant as a 48% solution in  tank
cars and is pumped to the process areas.

Amine-Phenol Mixture

     An amine-substituted phenol mixture is brought into  the plant in tank cars
and is pumped  to a process area storage tank. A  Magnetrol level  control cuts off
the pump when the tank is full. Any overflow goes back to  the  tank car. If the
overflow line were plugged, there is a 2000-gal. catch tank to take any overflow,
but it has never been needed.

Oleic Acid

     Oleic  acid (red oil)  arrives at the plant in  tank cars  and is pumped to the
process areas.
                                    175

                                                                      Arthur D Little Inc

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Spill Reporting Procedure

     Spills are reported to the Technical Department and, if they are serious, are
also reported to the state as is done in the other companies in the KRIAC group.

Sewer System

     This plant  has one section that  is connected to an aerated lagoon disposal
system, while all other areas are on a  common sewer system connected to a river
outfall. They will  soon separate sewers to comply with  the new West Virginia
requirements, and  also  plan to install a "panic pond" to protect their disposal
system from heavy overloads.

Hazardous Materials

     Potentially hazardous materials handled at this plant are listed below.

Material                  Shipping Container Size         Source

93% H2 SO4                         -                  Pipeline
50%NaOH                1,200,000 pounds              Barge
Carbon bisulfide             195,000 pounds              Rail
Amine-phenol mix            66,000 pounds              Rail
Oleic acid (red oil)             30,000 pounds              Rail
NaHS45%                  106,000 pounds              Rail
Chlorine                      2,000 pounds             Truck (cylinders)

Past Spill Experience

     See Table 11 for a listing of past spills.

Conclusions

     This plant  has relatively few chemicals that  could  contaminate the river.
Tanks holding caustic and sulfuric acid are not diked, but are a long distance from
the river. Materials such as CS2 and  the amine-phenol mixture are handled in
well-designed equipment with good safeguards to minimize  spill dangers.
                                   176

                                                                     Arthur D Little Inc

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Monsanto Chemical Company
Nitro, West Virginia

Contacts:   Mr. H. M. Galloway, Environmental Control Manager
            Mr. John J. Matten
            Mr. Bernard H. Estep

Date of Survey:        October 6, 1970

Property Description

     Monsanto's storage areas include one fairly  large facility along the river in
which  acetone  and crude  oil are stored on receipt from barges, a separate tank
farm area where  organic  solvents are handled, and a number of storage tanks
adjacent to process areas where the material is used.

     At the river there are two separate receiving  stations (Figure 26). Barges are
tied to piles. The pumping station for unloading materials is located on shore and
connection is made to  the barge with flexible pressure hose. The hose is inspected
and  pressure-tested on a  regular schedule and the date of latest inspection is
stencilled on the hose.  One of the two receiving stations handles acetone which is
pumped  to a 500,000-gal.  tank on the river bank enclosed in a large earthen dike.
The  second receiving station  handles  tall  oil  which  is  pumped  to  three
500,000-gal. tanks and a  variety of product and  intermediate organic materials
which are stored in four 300,000-gal. aluminum tanks. This tank farm follows the
standard Monsanto practice for diking.

     Monsanto  handles and  stores carbon disulfide. This material is received by
pipeline  from the  adjacent FMC plant.  In many  plants the standard for carbon
disulfide is  to  keep  the storage tanks completely immersed  in  a diked area in
water.  Any  spill or leakage of carbon disulfide in such a  system must drain to a
low point in the  water pool from  which it can be recovered by a sump pump.
Monsanto's installation is new and follows a different design philosophy. The tank
is enclosed in a dike and provision is made for water flooding if necessary. Since
the diked area is normally empty, any spill can be quickly detected and handled.
In the storage tank proper, Monsanto  follows the usual  practice of maintaining
the tank full of water above the carbon disulfide level. When the tank is filled,
water is displaced through a separator and flows to the process sewer. When the
tank is emptied, water is automatically admitted to maintain the tank full and at
atmospheric pressure.  It is necessary to  use thermostatic temperature  control to
prevent freezing of this sealed water in the tank and in the transfer lines. The dike
around the carbon disulfide tank  is of reinforced concrete design.
                                    177

                                                                      Arthur D Little; Inc

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     HCN is obtained from the Belle plant of DuPont by railroad tank car. When
the  car is shipped, DuPont notifies Monsanto and  any delay  in the  60-mile
transfer down the river can be investigated immediately. A carefully worked out
plan of  notification  and  emergency  action  is in force  in  the event  of any
emergency during shipment of the car between the two plants. At the Monsanto
plant the tank car is spotted in an exact location at the unloading position. The
car is of special  design,  including roller bearing trucks so that easy  movement
without shock can be effected.  Connection from the tank car to Monsanto's
unloading pump  is  made by a solid stainless-steel pipeline; no flexible joints are
used. The  pipe  is pickled with  acid and washed  before  installation and then
pressure-tested to 40 psi with nitrogen. Nitrogen at 10 psi is then used to force
unload the car to Monsanto's storage tank. Monsanto's storage  tank is a refriger-
ated tank with special provision for monitoring for leaks of HCN gas. A pressure
control  system maintains 2 psi of nitrogen on  the storage  tank and the  vent  is
through a flare. A pilot light burns constantly at the top of the flare so that any
HCN in the vent gas is  automatically  destroyed. All connections to the  storage
tank, as well as to the box car, are at the top of the tank.  There are no bottom
connections of any kind. HCN is soluble in water and there is a deluge  system
fitted to the storage tank as well as to the tank car area for immediate flooding of
any leak with water.

Drainage

     Although the plant  is located directly on the Kanawha River, there is no
drainage  directly to  the river.  All effluent flows through a  treatment plant,
including  rainfall. The storm runoff does not greatly  increase the load  on the
treatment plant.

Design and Operating Practices

     Monsanto's practice is to build a dike  around any tank containing a toxic,
flammable, or water-insoluble material.  Chemicals such as HCN, aniline, butyl
acetate, formalin, xylene, and acrolein are diked. Inorganic  reagents such as
sulfuric acid  are  not diked. Monsanto  feels that the cost of a dike for these
materials is not justified, since the most likely method of disposal of a spill would
be by dilution and control discharge to the  river in any event. A  spill would not
flow directly to the river, but would be handled via the treatment plant. Carbon
disulfide  and  HCN  were  cited  as two  dangerous materials for which  special
handling  is required. Facilities for these chemicals were  inspected during the
plant tour.
                                    178

                                                                      Arthur D Little, Inc.

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     In addition to diking, it is Monsanto's practice to use catch basins and sumps
wherever the likelihood of leakage and spill is high. The standard for fill lines to
large storage tanks is evolving. Current practice is to run this line to the tank via a
high loop. The line enters the top of the tank and extends to near the bottom so
that during the fill there is no fall of liquid in the tank. This practice guards
against vaporization of volatile materials and ignition via static charge. To prevent
siphoning, Monsanto drills a small vent hole in the fill line inside the tank near the
top. This design is under review because of the fear that during the  fill spray of
liquid through this vent hole may cause some static electricity problems. All tanks
are subject  to regularly scheduled inspection to determine their condition. The
shell thickness is  inspected by ultrasonic gaging. On tanks where  corrosion is
likely to be a problem, the tank is emptied, cleaned, and visually inspected.

Hazardous Chemicals

     A list of materials handled at the Nitro plant is included as Table 15.

Past Spill Experience

     See Table 11 for a discussion of postspill experience.

Spill Control Plan

     Monsanto is a member of the KRIAC Committee and follows the practice of
the several Kanawha Valley emergency and disaster control plans.
                                     179

                                                                        Arthur DLittklnc

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                                                                        TABLE IS
       Mitral
                                          HAZARDOUS MATERIAL STORAGE AT MONSANTO CHEMICAL COMPANY,
                                                                 NITRO, WEST VIRGINIA
                                    Ship. Container Sin
                                                                    Source
                                                                                          Storage Tank Sin*
Dimer Mid
93%H,SO»
100XH,SO«
TSA
Acrolein
Hydrobetyl alcohol
TAA
Aqua ammonia
ATC
Aniline
ButyraMehyde
Carbon-bisulfide
Oenzoline
Chlorine
TBM crnol
Cyctohcxylamim
Dodecyl benzene
DIPA
DTAP
DO A
Heavy
   aromatic naphtha
Heptane
Hydrogen cyanide
liopropanol
Kerosene
Methanof
Methyl mercaptan
Morpholtne
«6 process oil
Ptrapnenetidine
Semolube 393
Santolube 394-C

TBA
Trichloropropene
Toluene
Xylem
SOKauttic
Isoamylene
Formaldehyde
Potassium hydroxide
CTO

« Variol
Butanol
CHM
Pnthslfc  anhydride
Ethyl acrylato
2-Elhyl-nexyl ecrylate
Anhydrous ammonia
Nitrogen
Acetttdehyde
2,6-dimethyl morpholme
Sultur dichloride
Sulfur
Sulfur monochloride
300.000
  8,000
150.000
 10,000
 10.000
  6,000
  8,000
  5,000
  5.000
 10,000
 20.000
 10.000
Pumped from
neighboring plant

  6,000
 10.000
 20,000
 10,000
 10.000
 10,000
  8.000
 10,000

 10.000
  6.000
  6,000
  6,000
 10,000
  6.000
 20,000
  6,000
  8,000
 10,000
 10,000
 10,000

 20,000
 10,000
 10.000
  6,000
 12,000
  6,000
  6,000
 10,000
300.000

  6.000
  6.000
 10.000
  6,000
  S.OOO
  8,000
  6,000
  6,000
 10,000
 10,000
  8,000
  4.000
  10,000
Barge
Rail
Barje
Rail
Rail/truck
Rail
Rail
Truck
Truck
Rail
Rail
Rail
Truck
Rail
Rail
Rail
Rail
Rail
Rail
Rail

Rail
Truck
Rail
Truck
Rail
Truck
Rail
Truck
Rail
Rail
Rail
Rail

Rail
Rail
Rail
Truck
Rail
Truck
Truck
Rail
Rail, truck,
barge
Truck
Truck
Rail
Truck
Rail
Rail
Truck
Truck
Rail
Rail
Rail
Truck
Rail
(bl
la)
Ib)
(i)
(a)
(a)
la)
(a)
(•I
la)
(a)
la)
(a)
(al
la)
la)
(a)
(a)
(a)
la)
la)
la)
(a)
(a)
(a)
(a)
(al
la)
(al
la)
la)

(a)
(9)
(a)
la)
la)
(al
(a)
(a)

(c)
(a)
la)
(a)
la)
la)

-------
        00
                                    Material
#2 Varsol
Butanol
CHM
Phthalic  anhydride
Ethyl aery late
2-Ethyl-hexyl acrylate
Anhydrous ammonia
Nitrogen
Acetaldehyde
2, 6-dimethyl morpholine
Sulfur dichloride
Sulfur
Sulfur monochloride
TCE
Muriatic acid

Creosote oil
Dowtherm A
Diphenyl-amine
2,3 Dichloropropene
Oiisobutylene
Mersize

Santoflex DO

Santoquin
Oil  additives

Santocizer 429
Avadex
                            Vegadex
                            Santoflex 13

                            Santoflex 503A
                            Avadex BW
Ship Container Size
       (gal.)

  6,000
  6.000
 10.000
  6.000
  8,000
  8,000
  6.000
  6,000
 10,000
 10,000
  8.000
  4,000
 10.000
  6,000
 20,000

  6,000
  6,000
  6.000
 10,000
 10,000
 10,000

 10.000

 10.000
 10.000

  6,000
 10,000
                                       10,000
                                        6,000

                                       10,000
                                       10.000
                                                                                                   Source
Truck
Truck
Rail
Truck
Rail
Rail
Truck
Truck
Rail
Rail
Rail
Truck
Rail
Truck
Rail

Truck
Truck
Truck
Rail
Rail
Rail/truck

Rail/truck

Rail/truck
Rail/truck

Rail/truck
Rail/truck
                                                                                                   Rail
                                Truck

                                Rail
                                Rail/truck
                                                                                                                            Storage Tank Size*
(a)
(a)
(a)
(a)
(a)
(a)
(a)
(a)
(a)
(a)
(a)
(a)
(a)
(a)
(a)

(a)
(a)
(a)
(a)
(a)
(a)

(a)

(a)
(a)

(a)
(a)
                                                                 (a)
                                 (a)

                                 (a)
                                 (a)
                                                                                                                                           Comments
                                                                                                                                                         Kerosene

                                                                                                                                                         Cyclohexyl mercaptan
                                                                                                                                                         Not diked
                                                                                                                                                         Stored in tank Ca

                                                                                                                                                         Not diked
                                                                                                                                                         Liquid/not diked
                                                                                                                                                         Stored in tank car
                                                                                                                                                         Stored in tank car
                                                                                                                                                         Not diked
                                                                                                                                                         Not diked
                                                                                                                                                         Not diked
                                                                                                                                                         Trichloroethylene/not diked
                                                                                                                                                         HCI/not diked

                                                                                                                                                         Stored in tank car
                                                                                                                                                         Not diked
                                                                                                                                                         Not diked
Paper sizing agent/not diked
6-dodecyl-1,2-dihydro-2,2,
4-trimethylquinoline/not diked
Not diked - Ethoxyquin-1,2-dihydro-
6-ethoxy-2,2,4-trimethylqu incline
Not diked
proprietary, complex mixtures
Plasticizer/not diked
Not diked - Solution of
S-2,3-dichloro-allyl
diisopropylthio carbamate
Not diked - Solution of
2-chloroallyl diethyldithio
carbamate
Not diked - N-(1,3dimethylbutyl)
N '-pheny I -p-pheny lened iam ine
Not diked, rubber antioxidant
Not diked - Solution of 2.2.
3-trichloroallyl diisopropylthio
carbamate
c
-t
                            '(a) Under 100,000gal.
                              (b) 100.000 to 500,000 gal.
                              (c) Over 500.000 gal.

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 E. I. DuPont
 Belle, West Virginia


      The E.  I. DuPont facility was not  visited.  A  list of hazardous materials
 handled was furnished  by DuPont and is  included as Table 16. Figure 27 shows
 the DuPont facility at Belle, West Virginia.

                                     TABLE 16

                 HAZARDOUS MATERIAL STORAGE AT E. I. DuPONT
                              BELLE, WEST VIRGINIA

 Material                   Ship Container Size       Source       Storage Tank Size*

 Acetic acid                                       T/C              (a)
 Anhydrous ammonia                               T/CB             (c)
 Methyl, di and
 tri-methyl amines                                  T/C T/T           (a)
 Acetone                                          B                (c)
 Aniline                                           T/C              (a)
 Cyclohexane                                      B                (c)
 Di-isopropylamine       * -j-j jd                   T/T              (a)
 Ethanol                S g §>                   T/C T/T           (a)
 2-ethyl hexanol         § 8 §                   T/T              (a)
 Ethylene glycol         °. ix o                   T/C B             (c)
 Hexamethylimine        « 2 oo                   T/C              (a)
 Hydrogen cyanide       ° § P                   T/C              (a)
 Isobutanol              § CN 8                   T/c T/T           (a)
 Isopropyl ether          ^ ^ °                   T/C              (c)
 Methyl ethyl ketone      E 2 §                   T/C              (a)
 N-butanol              •§ g, E                   T/c              (a)
 Methacrylate monomers   g, 1* 2                   T/C T/T           (c)
 Methyl formate         i £ u                   T/C              (a)
 Molten sulfur           « S c                  T/T              (a)
 Tergitol®               | JJ 2                  T/T              {a)
 Methanol               b § S                   B                 (c)
 Dimethyl sulfate         _^^ £                  T/CT/T           (a)
 Dimethyl ether          = = ?                  T/C               (a)'
 Formamide             H i- CD                  T/C               (a)
 Phosphoric acid          • • •                   T/T              (a)

T/C  = Railroad Tank Car  T/T =  Tank truck   B  = River barge

 *(a)  Under 100,000 gal.  (b) 100,000 to 500,000  gal.   (c)  Over 500,000 gal.
                                       182

                                                                           Arthur D Little Inc

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    -
    -„:
c
-t
D
                                                                                                        Photo Courtesy of U.S.A. Corps of Engineers
                                           FIGURE 27   AERIAL VIEW OF DUPONT PLANT, BELLE, WEST VIRGINIA

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Allied Chemical Corporation
Industrial Chemicals Division
Nitro, West Virginia

Contacts:   Mr. Kelley Fagg, Plant Superintendent
            Mr. William Stocker (from Morristown Office)

Date of Survey:      October 8, 1970

Property Description

     This company produces  sulfuric acid and hydrofluoric acid in a plant located
close to the  Kanawha River  on the right bank of the river 43.2  miles above its
mouth. It is a comparatively  small plant producing only two products. There is a
barge  unloading area at  the  river, a sulfuric acid manufacturing unit, a hydro-
fluoric acid manufacturing unit, storage tanks for both products and a  series of
lagoons for settling out the gypsum by-product.

Barge Station

     Barges of fluorospar and molten sulfur are unloaded to supply the chemical
processing plants.  In addition to the sulfuric acid  manufactured by the  plant,
additional sulfuric acid may be barged in and unloaded for resale. Also soda ash is
unloaded and shipped out by  rail in covered hopper cars.

Sulfur Storage

     Two tanks for storage of liquid sulfur are maintained at 275°F by means of
internal  steam coils.  The tanks are provided with  quench water and  steam to
blanket out any possible fire.  The total capacity of these tanks is 18,000 tons, but
there is little danger of a spill  that would contaminate the river because the spilled
sulfur would cool quickly and it will not flow below 243°F.

Hydrogen Fluoride Storage

     The anhydrous hydrogen fluoride is stored  under 40 pounds of pressure in
three tanks of 100,000  to 110,000 pounds capacity each. These tanks are on
scales and  any leakage can be detected by weight  loss as well as by odor. This
product is more likely to  be an air pollutant than a water pollutant. Any spills in
this area or any vapors knocked  down by  fog nozzles would go to the treatment
ponds where the acid would be neutralized  before final release to the river.
                                    184

                                                                      Arthur D Little Inc

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Sulfuric Acid Storage

     Sulfuric acid is stored in four tanks of 1000 tons capacity each. They are
used at the 800-ton level so total capacity is 3200  tons. The tanks are on pads 3
feet off the ground and there are no dikes. Loading  is done only in daylight hours
with an operator present. If a leak should occur,  the  operator can cut off the
pump. Any back drainage or pump drips resulting from filling a tank car or tank
truck are drained into the sump under the filling area and to the soda ash pit for
neutralization.

Preventive Maintenance and Inspection Program

     Two men are assigned to the preventive maintenance program and also  spot
any  leaks that  might occur.  From experience,  the plant  personnel know the
expected lives of various components. Tanks are  inspected every 2 to 3 years by
test drilling and rewelding.

Spill Monitoring and Reporting

     A pH  probe is constantly monitoring the cooling  water in both the hydro-
fluoric acid unit and the sulfuric acid unit. As a further check for leaks, a manual
determination of pH is  done at 7 a.m. each day. In addition the operators have
methyl orange, and  a  colorimetric test  is run twice  per  shift.  In case of an
emergency the operators call the supervisor or plant  superintendent.

Materials Shipped from the Plant

     All  anhydrous hydrogen  fluoride is shipped  in tank  cars. Sulfuric acid is
shipped  both by rail and in tank trucks. Allied Chemical also ships  three truck-
loads of molten sulfur per week to the nearby Monsanto plant and 2000 tons per
month to the  FMC plant in South Charleston. Soda  ash  is loaded in  covered
hopper cars.

     All  hazardous  materials  are shipped with an  accompanying "MCA Chem-
Card — Transportation Guide" (obtained from the Manufacturing Chemists' Asso-
ciation) which contains instructions to cover spills of the particular  chemical being
shipped.

Past Spill Experience

     See Table  11 for discussion of past spills.
                                    185

                                                                       Arthur D Little Inc

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Conclusions

     This plant has only a limited potential for spills that would affect the river.
Sulfuric acid is non-toxic in dilute solution and only small amounts of acid would
normally get to the river. It is questionable whether diking of the sulfuric tanks
would  be desirable in this plant due to the distance of the tanks from the river.
The  hydrogen fluoride  tanks present a  much greater potential for air pollution
than water pollution.
                                    186

                                                                      Arthur D Littk Inc

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APPENDIXES

-------
The illustration (top) on the opposite side depicts the
31st major chemical fish-kill during 1970 in Escambia
Bay, Florida.

                              - Wide-World Photo

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                          APPENDIX A
    INVENTORIES OF MAJOR TRANSPORT, TRANSFER, AND STORAGE
FACILITIES INVOLVED IN HANDLING HAZARDOUS POLLUTING SUBSTANCES
                         Texas City, Texas


                         Baltimore, Maryland


                         Suisun Bay—Delta Area, California


                         Charleston, West Virginia
                               187

                                                           Arthur D Little Inc

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    The plant inventories, upon which the survey covered in this report was
based, were developed from the following sources:

     1.   Fortune Plant and Product Directory, Volumes 1 and 2,
         1966;

    2.   Local telephone directories for each community;

    3.   Directory  of  Texas Manufacturers,  Volumes 1 and  2,
         Bureau of Business  Research, The  University  of Texas at
         Austin, 1970;

    4.   West  Virginia  Manufacturers  Directory,  West  Virginia
         Department of  Commerce/Industrial Development Divi-
         sion, 1970;

    5.   Maryland Manufacturers Directory, Maryland Department
         of Economic Development, 1969/1970;

    6.   Chamber of Commerce listings:

         •    Charleston, West Virginia,
         •    Texas City, LaMarque, Texas, and
         •    Metropolitan Baltimore;

    7.   Baltimore  Charles Center Inner Harbor Management, Inc.

    8.   City of Charleston, West Virginia, City Engineers Office;

    9.   Contra Costa County Directory of Industries, published by
         Contra Costa County Development Association, Martinez,
         California.
                                   189

                                                                     Arthur D Little Inc

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TEXAS CITY, TEXAS
 1. American Oil Company
   (Subsidiary of Standard Oil Company of
   Indiana)
   Box 401, 2401-5th Avenue, S.
   Refining Manager: Guy L. Honeycutt
   Employees:  1500

 2. Amoco Chemicals Corporation
   (Subsidiary of Standard Oil Company of
   Indiana)
   P.O. Box 568,
   2800 Farm Road, 519 E.
   Plant Manager: L.T. Larson
   Employees: 400

 3. Borden Chemical Company, Smith-
   Douglas Division
   (Subsidiary of the Borden Company)
   P.O. Box 1571, Grant Avenue
   Production Manager:  W.M. Fraser, Jr.
   Employees: 100

4. GAF Corporation
   P.O. Box 2141, Highway 146, W
   Plant Manager: F.E. Wetherill
   Employees: 185

5. Gulf Chemical & Metallurgical Corp.
   P.O. Box 2130, Highway FM 519
   President:  E.B. King
   Employees: 150

6. Malone Chemical Products Company
   Malone Service Company
   Malone Trucking Company
   P.O. Box 709
   300-20th Streets, S.
   President:  Paul Malone
 7.  Marathon Oil Company-Texas Refining
     Division
     P.O. Box 1191, Ft. of 6th Street
     Acting Manager: A.L. Benham
     Employees: 345

 8.  Monsanto Company
     P.O. Box 1311, 201 Bay Street, S.
     Plant Manager:  R.V. Butz
     Employees: 1700

 9.  Reagent Chemical and Research, Inc.
     East Galveston Highway
     Plant Manager:  G. Melder

10.  Texas City Refining, Inc.
     P.O. Box 1271, East Galveston Highway
     President and General Manager:  W.H. Fetter
     Employees: 300

11.  Texas City Terminal Railway Company
     P.O. Box 591, E. Galveston Highway
     General Manager:  W. Wimberly
     Employees: 92

12.  Un ion Carbide Corporation
     Chemicals & Plastics Division
     P.O. Box 471, Texas City Heights
     Plant Manager:  R.P. Barry
     Employees: 2600
                                        190
                                                                              Arthur D Little; Inc

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BALTIMORE, MARYLAND
 1.   Acme Plating Company
     6001 Chemical Road
     Baltimore 21226
     Plant Executive: P.M. Kaiser
     Employees: 5

 2.   Adcrafters, Inc.
     1701 Washington Boulevard
     Baltimore 21230
     President:  William L. Graf
     Employees: 51

 3.   Aerosol International, Inc.
     3511 8th Avenue
     Baltimore 21226
     Plant Manager: A.A. Prestwidge
     Employees: 13

 4.   Agrico Chemical Company
     (Division of Continental Oil Company)
     2272 S. Clinton Street
     Baltimore 21224
     President:  D.H. Bradford, Jr.
     Employees: 109

 5.   Allied Chemical Corporation
     Agricultural Division
     2000 Race Street
     Baltimore 21230
     Supervisor:  W.P. Chamberlain
     Employees: 50-130 seasonal

 6.   Alcolac Chemical Corporation
     3440 Fairfield Road
     Baltimore 21226
     President:  Dr. V.J. Blinoff
     Employees: 160

 7.   Allegheny Pepsi-Cola Bottling Co.
     400 Key Highway
     Baltimore 21230
     General Manager:  Stanley Goldberg
     Employees: 300

 8.   Allied Research Products, Inc.
     4004 E. Monument Street
     Baltimore 21205
     President:  Jules Horelick
     Employees: 125
 9.   Almag Chemical Corporation
     1800 Cherry Hill Road
     Baltimore 21230
     President:  Joseph Eisenberg
     Employees: 22

10.   Alpha Chemical Company
     1503-13 Argyle Avenue
     Baltimore 21217
     Owner:  Maurice H. Simson
     Employees: 11

11.   Aluminum Finishers, Inc.
     5000 E. Monument Street
     Baltimore 21205
     President & Sales: L.Coburn Kingsbury
     Employees: 22

12.   American Brewery
     (A Division of Allegheny Beverage Corp.)
     1700 N. Gay Street
     Baltimore  21213
     General Manager & Purch: Louis A. Urbanski
     Employees: 141

13.   American Can Company
     Boston & Hudson Streets
     Baltimore  21224
     Plant Manager: Wendell Strickland
     Employees: 900

14.   American Oil Company
     3901 Asiatic Avenue
     Baltimore  21226
     Manager: M.C. Hopkins
     Employees: 70

15.   American Smelting & Refining Company
     Highway & Eastbourne Avenue
     Baltimore  21224
     Manager: AJ. Kleff, Jr.
     Employees: 968

 16.  American Sugar Company
     1100 Key Highway E
     Baltimore 21230
     Refinery Manager: James A. Moore
     Employees:  700
                                       191
                                                                              Arthur D Little Inc

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Baltimore, Maryland (Continued)
17.  Ansam Metals Corporation             24.
     1026 Patapsco Avenue
     P.O. Box 2847
     Baltimore 21225
     President Purch. & Sales:  E. Hettleman
     Employees:  11
                                         25.
18.  Armco Steel Corporation
     Advanced Materials Division
     3501 E. Biddle Street
     Baltimore 21213
     P.O. Box 1697
     Baltimore 21203
     General Manager: George J. Arnold     26.
     Employees:  2367

19.  Armco Steel Corporation
     Advanced Materials Division
     Research Section
     3501 E. Biddle Street
     Baltimore 21213                     27.
     P.O. Box 1697
     Baltimore 21203
     Manager: G.N. Goller

20.  Athey, C M Paint Company, The
     1809 Bayard Street                   28.
     Baltimore 21230
     Chairman of the Board: C.B. Athey
     Employees:  35

21.  Baltimore Copperas Company
     3900 Hawkins Point Road             29.
     Baltimore 21226
     President: Jacob Caplan
     Employees:  3

22.  Baltimore Paint & Chemical Corp.
     2325 Hollins Ferry Road               30.
     Baltimore 21230
     President: E.L. O'Brien
     Employees:  375

23.  Baltimore Rustproof Company
     409 N.Exeter Street                  31.
     Baltimore 21202
     Partner & Manager: Solomon Berman
     Employees:  11
 Baltimore Tar Corporation
 1900 Race Street
 Baltimore 21230
 President & Purch.: Fred N. Lyons
 Employees:  13

 Bauer Chemical Company
 1120 N.Appleton Street
 Baltimore 21217
 President, Plant Mgr., Purch. & Sales:
 John G. Bauer
 Employees: 4

 Bethlehem Steel Corporation
 Baltimore Yard
 1101 Key Highway
 Baltimore 21230
 Chairman: E.F. Martin
 Employees: 2685

 Braun Rendering Company, Inc.
 2008 Ontario Avenue
 Baltimore 21230
 Exec. VP & Purch.: Clarence E. Braun
 Employees: 31

 Bruning Paint Company, Inc.
 Fleet & Haven Street
 Baltimore 21224
 Director of Sales:  Raymond S. Kerin
 Employees: 100

 Burrough Bros. Pharmaceuticals, Inc.
 2301 Hollins Street
 Baltimore 21223
 VP & General Manager:  Reuben H. Israelson
 Employees: 76

 By-Products Processing Company, Inc.
 829 W. Pratt Street
 Baltimore 21201
iPresident: Kenneth H.L. Turner
 Employees: 7

 Chesapeake Asphalt Products Company
 110S. Regester Street
 Baltimore 21218
 General Manager & Purch.:  W.D. Gerber, Jr.
 Employees: 8
                                       192
                                                                               Arthur D Little, Inc.

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Baltimore, Maryland (Continued)
32.
33.
34.
35.
36.
37.
38.
Chesapeake Paperboard Company, The
Fort Avenue & Woodall Street
Baltimore  21230
President; Plant Manager & Purch.:
  James E. Smith
Employees: 200
Coca-Cola Bottling Company of Baltimore
1200 W.Hamburg Street
Baltimore 21230
President & General Manager:
  William R. Ellis                    41.
Employees: 212
Contact Paint & Chemical Corp.
4903 Snader Avenue
Baltimore  21215
President & Sales:  Marvin Sklar
Employees:  12
39.  Delta Chemical Manufacturing Company, Inc.
     2101 Washington Boulevard
     Baltimore  21230
     President & Purch.: D.H. Koumjian
     Employees: 17

40.  Dentocide Chemical Company
     3437 S. Hanover Street
     Baltimore  21225
     President & Sales:  Dr. Saul Moses

     Donahue, J. Paints, Inc.
     2220 Langley Street
     Baltimore  21230
     President, Plant  Exec. & Sales: F. Donahue
     Employees: 40
                                         42.
Continental Can Company, Inc.
Plant 16
3500 E. Biddle Street
Baltimore  21213
Plant Manager: G.R. Decorato
Employees: 1500

Continental Oil Company
3441 Fairfield Road
Baltimore  21226
Plant Manager: W.B. Carter
Employees: 205

Crusader Chemical Company,  Inc.
2330 Seven Street
Baltimore  21230
President, Director Research, Plant
Manager, Purch. & Sales:
 Paul Stamberger
Employees: 6

Dek, Inc.
701-09 Luzerne Avenue
Baltimore  21224
President, Plant Manager & Purch.:
  Cyprien L. Brien
Employees: 3
     Dryden Oil Company, Inc.
     Braddish Avenue & Western Md. RR
     Baltimore  21216
     President:  Lindsey D. Dryden
     Employees: 58
43.  Dulany-Vernay, Inc.
     2250 Reisterstown Road
     Baltimore 21217
     President: John F. Miller
     Employees: 63

44.  Duro-Lite Paint Company
     1525 Benhill Avenue
     Baltimore 21226
     President Purch. & Sales: Dr. David
       Sonnenschein
     Employees: 5

45.  Dynasurf Chemical Corpation
     1411 Fleet Street
     Baltimore 21231
     President: Dr. Irvin Baker
     Employees: 35

46.  FMC Corporation
     1701 Patapsco Avenue
     Baltimore 21226
     P.O. Box 1616
     Baltimore 21203
     Res. Manager: J. Ford Wilson
     Employees: 378
                                        193
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 Baltimore, Maryland (Continued)
47.   Feralloy Eastern Corporation           54.
      2001 Kloman Street
      Baltimore 21230
      VP General Manager: T.B. Treadwell
      Employees:  20

48.   Fuld Bros., Inc.
      702-710 S.Wolfe Street                55.
      P.O. Box 6073
      Baltimore 21231
      President: E.K. Lipsy
      Employees:  60

49.   GAP Corporation
      1500S. Ponca Street
      P.O. Box 5166                        56.
      Baltimore 21224
      Chairman & President:
        Dr. Jesse Werner
      Employees:  130

50.   Glidden-Durkee Division                57.
      Pigments & Color Group
      3901 Hawkins Point Road
      Baltimore 21226
      Sales Manager: L.C. Byrne
      Employees:  571                      58.

51.   Glidden-Durkee Division of
      of SCM Corporation
      3901 Hawkins Point Road
      Baltimore 21226
      VP & Plant Exec.: W.L. Rodich          59.
      Employees:  527

52.   Glidden-Durkee Division
      SCM Corporation
      Ceramics Group
      5601 Eastern Avenue                  60.
      Baltimore 21224
      VP & General Manager: W.L. Rodich
      Employees: 300

53.   Grace, W.R. & Company
      Agricultural Products Division           61.
      Curtis Bay Works & Mill Plant
      Baltimore 21226
      VP - Agricultural Chem. Grp.:
        F.J. Sergeys
      Employees: 264
                                      194
 Grace, W.R. & Company
 Davison Chemical Division
 101 N.Charles Street
 Baltimore 21201
 President: Charles E. Brookes
 Employees:  139

 Grace, W.R. & Company
 Davison Chemical Division
 Curtis Bay Plant
 Baltimore 21226
 P.O. Box 2117
 Baltimore 21203
 President: Charles E. Brookes

 Green Spring Dairy, Inc.
 1020W.41 Street
 Baltimore 21211
 President: James J. Ward, Sr.
 Employees: 490

 Griffith & Boyd Company
 1800  S. Clinton Street
 Baltimore 21224
 Employees: 12

 Hanline Bros., Inc.
 1400  Warner Street
 Baltimore 21230
 President: Leonard H. Cohan
 Employees: 50

 Haven Chemical Corporation
 1501  S. Haven Street
 Baltimore 21224
 President:  K.N.Yellott
 Employees: 15

 Hynson, Westcott & Dunning, Inc.
 Charles & Chase Streets
 Baltimore 21201
 President: J.H. Fitzgerald Dunning
 Employees: 145

 Industrial Chemical Division
 Allied Chemical Corporation
 Block & Wills Streets
 Baltimore 21231
President: J.S. Brown
 Employees: 321
                                                                              Arthur D Little, Inc

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Baltimore, Maryland (Continued)
62.   Koontz,H.E. Creamery, Inc., The       70.
      5600 Reisterstown Road
      Baltimore 21215
      President: George C. Oursler
      Employees:  320
                                         71.
63.   LACO Products, Inc.
      4201 Pulaski Highway
      Baltimore 21224
      President: S.A. Hoffberger
      Employees:  50

64.   Langrall, J & Bros., Inc.
      2105 Aliceanna Street                 72.
      Baltimore 21231
      VP& Sales:  H.Edwin Jones
      Employees:  35-250

65.   Lenmar Lacquers, Inc.
      150 S. Calverton Road                 73.
      Baltimore 21223
      President: Leonard E. Eisenberg
      Employees: 50

66.   Lever Bros. Company
      5300 Holabird Avenue                 74.
      Baltimore 21224
      P.O. Box 1737
      Baltimore 21203
      Plant Manager:  F.A. Vaughan
      Employees:  1111
                                         75.
67.   M&T Chemicals, Inc.
      1900 Chesapeake Avenue
      Baltimore 21226
      Plant Manager:  D.B. Read

68.   Mangels, Herald Company, Inc.
      1414 Key Highway                    76.
      Baltimore  21230
      Chairman: Walter B. Mangels, Jr.
      Employees: 96

69.   Man/elite, Inc.
      3020 Nieman Avenue
      Baltimore  21230
      Employees: 29
Maryland Plating Company, Inc.
316 N. Holliday Street
Baltimore 21202
President: Joseph Eisenberg

Masury Paint Company
1403 Severn Street
Baltimore 21230
P.O. Box 778
Baltimore 21203
President: W. Graham Schwartz
Employees: 120

Mrs. Bee's Packing Company, Inc.
137 S. Warwick Avenue
Baltimore 21223
President: Myles  Katz
Employees: 66

National Brewing  Company
3720 Dillon Street
Baltimore 21224
President: Jerold C. Hoffberger
Employees: 844

National Chemical & Plastics Company, The
1424 Phi I pot Street
Baltimore 21231
VP & Plant Exec.  Arthur A. Eisenberg
Employees: 22

National Cylinder Gas Division
Chemetron Corporation
1700 Newkirk Street
Baltimore 21224
Branch Manager:  John C. Ross
Employees: 17

National Lead Company
Baltimore Branch
214 W. Henrietta Street
Baltimore 21230
P.O. Box 1815
Baltimore 21203
Plant Sup.:  Ralph W. Hisey
Employees: 51
                                      195
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 Baltimore, Maryland (Continued)
 77.   National Pharmaceutical Manufacturing
       Company, The
      4128 Hayward Avenue
      Baltimore 22115
      President: I.M.Mendelsohn
      Employees:  44

 78.   Occidental Petroleum
      Occidental Agricultural Chemical Corp.
      Summers Fertilizer Division
      Easter Division, Totman Building
      (210 E. Redwood)
      Baltimore 21202

 79.   Olin Mathieson Chemical Corporation
      5501 Pennington Avenue
      Baltimore 21226
      Works Manager:  A.B. Moon
      Employees:  105

 80.   Philadelphia Quartz Company
      1301 E. Fort Avenue
      Baltimore 21230
      Plant Manager: J. Van Winkle
      Employees:  12

 81.   Plan Corporation
      1415 Key Highway
      Baltimore 21230
      President: James Beach Platt, Jr.
      Employees: 50

 82.   Pompeian Olive Oil Corporation
      4201 Pulaski Highway
      Baltimore 21224
      President: S.A. Hoffberger
      Employees: 47

 83.   Prima Paint Corporation
      819 S.Caroline Street
      Baltimore 21231
      President: Albert A. Shuger
      Employees: 42

84.   Procter & Gamble Manufacturing Co.
      1422 Nicholson Street
      Baltimore 21230
      Plant Manager: Richard C. Smith
      Employees: 450
 85.
86.
87.
88.
90.
91.
92.
 Royal Crown Bottling Company of
   Baltimore, Inc.
 401 E. 30th Street
 Baltimore 21218
 President & Purch.: Kenneth H. Burcham
 Employees:  158

 Royster Company
 2001 Chesapeake Avenue
 Baltimore 21226
 Supervisor:  M.G. Rogers
 Employees:  101

 Schaefer, F&M Brewing Company, The
 1101 S. Conkling Street
 Baltimore 21224
 General Manager: Joseph J. Waters
 Employees:  350

 Schapiro & Whitehouse, Inc.
 Parking & McHenry Streets
 Baltimore 21230
 President: Daniel Schapiro
 Employees:  300

 Seaboard Asphalt Products Company
 Asiatic Avenue N. of Northbridge Road
 Baltimore 21226
 Owner:  H.R.Gundlach
 Employees:  26

Seaboard Lacquer, Inc.
 3105 W. Coldspring Lane
 Baltimore  21215
 President:  Merle W. Rubens
 Employees:  10

Sherwood Feed Mills, Inc.
2341 Boston Street
 Baltimore 21202
President:  E.F.Sherwood  Dickinson
 Employees:  66

Sinclair and Valentine
 (Division of Martin Marietta Corp.)
2950 Loch Raven Road
 Baltimore  21218
 Br. & Plant Manager & Sales:
  Charles J. Sweeney
 Employees:  23
                                       196
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Baltimore, Maryland (Continued)
 93. Solarine Company
     4201 Pulaski Highway
     Baltimore  21224
     President:  S.A.  Hoffberger
     Employees: 50

 94. Southern Galvanizing Company
     1620 Bush Street
     Baltimore  21230
     President:  Irvin B. Golboro
     Employees:  106

 95. Southern Lacquer Company
     1426 Philpot Street
     Baltimore  21231
     Work Manager:  Aaron A. Eisenberg
     Employees: 23

 96. Stalfort, Inc.
     Chemical Specialties Division
     319 W. Pratt Street
     Baltimore  21201
     President:  John Irving Stalfort
     Employees: 82

 97. Standard Distillers Products, Inc.
     306-310 E. Lombard Street
     Baltimore  21202
     President & Purch.: Andrew W. Merle,
     Employees:  64

 98. Standard Oil Company (Indiana)
     American Oil Company
     Baltimore  Refinery
     3901 Asiatic Avenue
     Baltimore  21226

 99. Swift & Company
     Agricultural Chemicals Division
     5600 Chemical Road
     P.O. Box 3410
     Baltimore  21226
     Manager:  C.P. LaVo
     Employees:  47
  100. Webb, A.L. & Sons, Inc.
       921 E. Fort Avenue
       Baltimore  21230
       President:  Charles A. Webb
       Employees: 12

  101. Young Aniline Works, Inc.
       2731 Boston Street
       Baltimore  21224
       VP& Sales: Robert J. Grant
       Employees: 50

  102. Young, J.S. Company, The
       2701-2851 Boston Street
       Baltimore  21224
       President:  W.B. Belitz
       Employees:  123

  Curtis Bay

  103. Kennecott Refining Corporation
       Kenbo Road
       Curtis Bay
       P.O. Box 3407
       Baltimore  21226
       Refinery Manager: C.A. Zeldin
       Employees: 780

Jr.104. Manganese Chemicals Company
       (A Division of Pickands Mather & Co.)
       711 Pittman Road
       Curtis Bay
       Baltimore  21226
       President:  F.R.Dykstra
       Employees:  144

  105. USS Agri-Chemicals, Inc.
       Ordnance  Road
       P.O. Box 3478
       Curtis Bay
       Baltimore  21226
       District Manager:  S.R.Post
       Employees:  70
                                       197
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Baltimore, Maryland (Continued)
Dundalk

106. Cello Chemical Company, The
     8200 Fischer Road
     Dundalk
     Baltimore 21222
     President: Michael J. Catena
     Employees: 40

107. Eastern Stainless Steel Corporation
     Rolling Mill Road
     Dundalk
     Baltimore 21224
     President: John M.Curley
     Employees: 1396

108. Parboil Company, The
     Division of Beatrice Foods
     8200 Fischer Road
     Dundalk
     Baltimore 21222
     President: H.D.Hammond
     Employees: 125

109. Four Roses Distilling Company
     1919 Willow Spring Road
     Dundalk
     Baltimore 21222
     P.O. Box 357
     Baltimore 21203
     Plant Manager: C.N. Belik
     Employees: 525

110. I ntercoastal Corporation
     2320 Edgewater Avenue
     Dundalk
     Baltimore 21222
     General Manager: Roy L. Hartman
     Employees: 90

Sparrows Point

111. Bethlehem Steel Corporation
     Sparrows Point Plant
     Baltimore 21219
     Chairman: E.F.Martin
     Employees: 27,750

112. Bethlehem Steel Corporation
     Sparrows Point Yard
     Baltimore 21219
     Chairman: E.F.Martin
     Employees: 2902
 113.  National Can Corporation
      Reservoir Road
      P.O. Box 6606
      Sparrows Point
      Baltimore 21219
      President: R.Stuart
      Employees:  376

 114.  Palm Oil Recovery, Inc.
      c/o Bethlehem Steel Company
      Sparrows Point Plant
      P.O. Box 6657
      Baltimore 21219
      President: J.C. Van Esterik
      Employees:  25

 115.  U.S. Protective Coatings, Inc.
      5 Church Lane
      Sparrows Point
      Baltimore 21219
      President & Purch.: Robert L. Henry III
      Employees:  5

 116.  Vulcan Materials Company
      Metallics Division
      Gray's Road
      P.O. Box 6501
      Sparrows Point
      Baltimore 21219
      Plant Manager & Purch.: J.J. Jeffries
      Employees:  35

Halethorpe

117. Carl ing Brewing Company
     4501 Hollins Ferry Road
     Halethorpe
     Baltimore  21227
     VP Eastern Division: Bruce P. Wilson
     Employees: 290

 118.  Union Carbide Corporation
      Linde Division
      Yale and Benson Avenues
      Box 7475
      Halethorpe
      Baltimore 21227
      Plant Sup.: JohnH.Hecox
      Employees:  25
                                      198
                                                                             Arthur D Little. InC

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SUISUN BAY-DELTA, CALIFORNIA
Antioch

 1.   Antioch Building Materials Company
     Sumersville Road & Pillsbury -
      Antioch Highway
     President: Joe Cesa
     Employees: 36

 2.   Antioch Newspapers, Inc.
     1700 Cavallo Road
     Manager: Keith Emenegger
     Employees: 42

 3.   Crown Zellerbach Corp.
     Box 10
     Resident Manager: Charles E. Young
     Employees: 900

 4.  E.I. du Pont de Nemours & Co.
     P.O. Box 310
     Manager: Frank J. Hodges
     Employees: 435

 5.  Fibrebrand Corporation
     San Joaquin Pulp & Board Mill
     Wilbur Avenue
     Plant Manager:  R.G. Beauregard
     Employees: 575

 6.  Fulton Shipyard
     Waterfront
     Owner: F.L.Fulton
     Employees: 40

 7.  Imperial West Chemical Company
     P.O. Box 313
     President: D.A. Huckabay
     Employees: 9

 8.  Kaiser Gypsum
     P.O. Box 460
     VP & General Manager: R.A. Costa
     Employees:  100

 9.  Kerley Chemical Corp.
     Willow Road & S.P. Railroad Tracks
     Manager:  Ralph E. Kerley
     Employees: 4
10.  S & H Boatyard
     Route 1, Box 514
     President:  Dan Sanderson
     Employees: 7

Avon

11.  Monsanto Company
     Post Office: Martinez
     Manager: V.T. Mattericci
     Employees: 28

12.  Phillips Petroleum — Avon Refinery
     Post Office: Martinez
     Manager: C.R. McCullough
     Employees: 900

Benicia

13.  Humble Oil Refinery
     Benicia

14.  J and J Disposal
     Benicia Industrial Park
     President:  Howard Jenkins

Crockett

15.  California and Hawaiian Sugar Company
     830 Loring Avenue
     General Manager:  Neil  L. Pennington
     Employees:  1450

Hercules

16.  Hercules Incorporated
     Hercules
     Manager:  L.B.Johnson
     Employees:  225

17.  Sequoia Refining Corporation
     Old Highway 40 - P.O. Box 68
     Plant Manager:  Walter  0. Nelson
     Employees:  85
                                       199
                                                                              Arthur D Little Inc

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Suisun Bay - Delta, California (California)
 Martinez

 18.   Berwind Railway Service Company
      111 Mococo Road
      Plant Manager:  William L. Heritage
      Employees: 15

 19.   Industrial Tank  Inc.
      21 OBevellessa Street
      Owners: Henry W. Simonsen and
                Jack 0. Fries
      Employees: 25

 20.   Shell Chemical Company
      P.O. Box 75T
      Plant Manager:  Marvin L. Baker
      Employees: 190

 21.   Shell Oil Company
      P.O. Box 711
      Refinery Manager:  A.J. Wood
      Employees: 1015

 22.   Telfer Tank Lines, Inc.
      Foot of Talbart
      President: John W. Telfer
      Employees: 50

 23.   Trumbull Asphalt Company
      120 Waterfront Road
      Superintendent: Louis E. Southers
      Employees:  13

 Nichols

 24.   Chemical and Pigment Company
      Post Off ice: Pittsburg
      Manager: Everett Harris
      Employees:  25

25.   Collier Carbon and Chemical Corp.
      Port Chicago Highway
      Superintendent: Robert A. Royce
      Employees:  30

26.   Industrial Chemical Division
      Allied Chemical Corp.
      Post Office: Pittsburg
      Superintendent: V.A. Fink
      Employees:  115
Pittsburg

27.   The Dow Chemical Company — Western
        Division
      Loveridge Road
      General Manager:  E.G. Stalhling
      Employees:  660

28.   Linde Company (Division of Union Carbide)
      California Avenue at Loveridge Road
      Plant Manager: L.P. Mitchell
      Employees:  53

29.   Shell Chemical Company
      Willow Pass Road
      Manager:  Marvin Baker
      Employees:  250

30.   Standard Pipe Protection Division
      General Steel Industries, Inc.
      P.O. Box 310
      Manager:  Gale O.  Carroll
      Employees:  25

31.   Stauffer Chemical  Company
      (Cowles Chemical  Division)
      Loveridge Road
      Plant Manager: Alfred J. Lukks, Jr.
      Employees:  20
Shelby
32.
American Smelting and Refining Co.
Post Office: Crockett
Plant Manager: A.F. Labbe
Employees: 425
                                       200
                                                                               Arthur D Little, ln<

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CHARLESTON - KANAWHA RIVER, WEST VIRGINIA
 1.  E.I. Du Pont (Belle)
     P.O. Box 65
     Belle
     Plant Manager: G.A.Cato

 2.  FMC Corporation
     Inorganic Chemicals Division
     P.O. Box 8127
     So. Charleston
     Plant Manager: M.E. Birmingham

 3.  FMC Corporation
     Organic Chemicals Division
     P.O. Box 547
     Nitro
     Plant Manager: L.L. Cavender

 4.  FMC Corporation
     American Viscose Division
     Nitro
     Plant Manager: J.C. Moody

 5.  Monsanto Company
     Organic Chemicals Division
     Nitro
     Plant Manager:  Bill G. McGuire

 6.  Union Carbide Corporation
     Chemicals Division
     P.O. Box 2831
     Institute
     Plant Manager:  W.B. Corydon

 7.  Union Carbide Corporation
     Chemicals Division
     P.O. Box 8004
     South Charleston
     Plant Manager:  R.L.Yelton

 8.  Union Carbide Corporation
     Mining  & Metals Division
     Alloy
     Plant Manager:  F.M.Charles

 9.   Union Carbide Corporation
      Technical Center
      Plant Manager: F.D. Bess (Asst.)
10.  Union Carbide Corporation
     Linde Division (Belle)
     Plant Manager: M.H. Kunneman

11.  Diamond Shamrock
     P.O. Box 615
     Belle
     Plant Manager: RJ.Sutch

12.  Libbey-Owens-Ford Glass Company
     57th Street E.
     Charleston
     Plant Manager: J.T. Zellers, Jr.

13.  Owens-Libbey-Owens Gas Department
     Charleston

14.  Allied Chemical Corporation
     Industrial Chemicals Division
     P.O. Box 478
     Nitro
     Plant Manager: Ray Maize

15.  Allied Chemical Corporation
     Semet-Solvay Division
     Harewood

16.  National Lead Company
     Evans Division
     P.O. Box 1467
     Charleston
     Plant Manager: F. Leake, Jr.

 17.  Republic Steel Corporation
     P.O. Box 37
     Nitro
     Plant Manager: W.L. Grimm

 18.  M idwest Steel Corporation
     Sattes
      Riverside
     Plant Manager:  J.W. Harper (Charleston)

 19.  West Virginia Steel
      900 Brooks Street
      Charleston
      Plant Manager: J.R.Harris
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Charleston - Kanawha River, West Virginia (Continued)
20.  Trojan Steel
     1414 MacCorkle Avenue
     Charleston
     Plant Manager: J.R. Harris
21.  True Temper Steel
     P.O. Box 1233
     Charleston
     Plant Manager: C.E. Peckham
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           APPENDIX B

SUMMARY OF PROPOSED REGULATIONS
DESIGNATING HAZARDOUS SUBSTANCES
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                                               December 30, 1970
                      DRAFT
    The proposed regulations provide a flexible designation scheme which not
only provides a maximum of protection to the public health or welfare, but also
provides  for the development of information to define more accurately what
dangers are involved. The purpose of the proposed regulations is to make it clear
that the spill  of any substance is potentially hazardous depending  upon the
properties and effects of the substance discharged. These regulations will provide
a basis for related regulations to be issued under section 12, particularly notice
regulations  to be issued  by the Coast Guard. The proposed regulations will
provide a basis for decisions by qualified persons in  charge of response activities.

    Three  separate  groups of designated hazardous substances are  proposed,
which when taken together, include the full range of elements and compounds:

    1.   A table of specifically identified substances which when
        discharged  as a result of a spill or abnormal discharge
        produce a receiving water quality which exceeds permis-
        sible standards specified in the table.

    2.   Substances which possess a high potential for danger be-
        cause of certain detrimental or lethal properties and effects
        when discharged in any quantity as a  result  of a spill or
        abnormal  discharge,  unless the  Administrator  can  be
        assured that a tolerable  negligible risk of danger is pre-
        sented.

    3.   Substances which when discharged as a result of a spill or
        abnormal discharge produce receiving water criteria which
        exceed applicable State or Federal water quality criteria,
        or exceed other specified criteria and limits.

The theory  underlying the proposed regulations is that as data and information
are developed, the  hazardous substances designated in groups 2 and 3 will be
redesignated as hazardous in group 1 with specific permissible standards.



            PRELIMINARY



   Subject  to  Revision
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                      Environmental Protection Agency
                                Washington

                             (18 CFR Part 611)

              DESIGNATION OF HAZARDOUS SUBSTANCES

                      Notice of Proposed Rule Making

     Notice is hereby  given that the Administrator, Environmental  Protection
Agency, pursuant to the authority contained in section 12(a)(l) of the Federal
Water Pollution Control Act (33 U.S.C.  1162(a)(l)) which was delegated to the
Secretary  of the Interior by the President in Executive Order No. 11548 dated
July 20, 1970 (35 F.R. 11677) and transferred to the Administrator by Reorgani-
zation Plan No. 3, 1970, proposes to adopt a new Part 611.

     The Water Quality Improvement Act of  1970 (P.L. 91-224, 84 Stat. 91)
amended the Federal Water Pollution Control Act (33 U.S.C. 1151 eq seq.} to add
a new section 12 to that act which provides in subsection (a)(l) of that section as
follows: "The President shall,  in accordance with subsection (b)  of this section,
develop, promulgate, and revise as may be appropriate, regulations (1) designating
as hazardous substances, other than oil as defined in section 11 of this Act, such
elements and compounds  which,  when discharged in any quantity  into or upon
the navigable waters of the United States or adjoining shorelines or the waters of
the contiguous zone, present an imminent and substantial danger to the public
health or welfare, including, but not limited to, fish, shellfish, wildlife, shorelines,
and beaches;. . . ." The President by Executive Order 11548 dated July 20, 1970,
has delegated his authority under  section 12(a)(l) quoted above to the Secretary
of the Interior which authority was transferred by Reorganization Plan No. 3,
1970, to the Administrator, Environmental Protection Agency, who proposes to
designate hazardous substances that present an imminent and substantial danger
to the public health or welfare when discharged in any quantity into or upon the
navigable waters of the United States or adjoining shorelines or the waters of the
contiguous zone as indicated in the following proposed regulations.

     In  determining those elements and compounds which are  proposed to be
designated  as hazardous for purposes of section 12(a)(l) of  the Federal Water
Pollution Control Act, it was recognized that any substance has the potential for
presenting  an imminent and substantial danger to the public health or welfare
depending upon the properties  and effects of the substance discharged. It was also
recognized that for the majority of materials which may be designated as hazard-
ous substances, sufficient verification of  existing and  developed data  must be
obtained to permit the establishment of definitive safe minimum standards which
should not be exceeded in receiving waters. Accordingly, a flexible designation is


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proposed which it is believed not only provides a maximum of protection to the
public  health  or welfare from  the dangers associated with the discharge of
hazardous substances, but also provides for the development of information and
data to define more accurately what those dangers are. This proposed designation
would  particularly reference and direct attention to substances which have been
determined to be  hazardous during transportation,  storage,  or other handling
modes.

     Three separate groups of designated substances are proposed in section 4
which  when  taken together,  would  include  the  full range of  elements and
compounds. Notification of any pollution event involving the discharge of any
hazardous substances designated in the  following proposed  regulations will be
made in  accordance with regulations  issued  by the United States Coast Guard
under the authority of section 12(c) of the Federal Water Pollution Control Act
and  Executive Order No. 11548 dated July  20, 1970. The proposed regulations
will serve as a basic reference for other related regulations to be issued under the
authority of section 12 of the Federal Water Pollution Control Act.

     Interested persons may submit, in triplicate,  written  data or arguments in
regard  to the  proposed regulations to the Administrator, Environmental Protec-
tion Agency,  Washington, D.C. 20460. All  relevant  material received not later
than 30  days after publication  of this  notice in the Federal Register will be
considered.

     Part 611 would be adopted as follows:

        PART 611 - DESIGNATION OF HAZARDOUS SUBSTANCES

Section
                     1. Applicability
                     2. Definition
                     3. Purpose and Intent
                     4. Designation of Hazardous Substances
                     5. Receiving Water Standards for Hazardous Substances
                     6. Notice

     Authority:  The provisions of this Part 611 issued under section 12(a)(l) of
the Federal Water Pollution Control Act (33 U.S.C.  1162(a)(l)).
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Section 1  APPLICABILITY

     The regulations of this part apply to hazardous substances other than oil,
which  when discharged into or  upon the navigable waters of the United States,
adjoining shorelines or the waters of the contiguous zone present an imminent
and  substantial  danger  to  the public health or welfare  within  the meaning of
section 12(a) of the Federal Water Pollution Control Act.

Section 2  DEFINITIONS

     As used in  this part, the following terms shall have the meaning indicated
below:

     (a)  "Discharge" means, but is not limited to, any spilling, leaking, pumping,
pouring, emitting, emptying, or dumping.

     (b)  "Vessel" means every  description of watercraft or other artificial con-
trivance used,  or capable of being used, as a  means of transportation on water
other than a public vessel.

     (c)  "Public vessel" means a vessel owned or bare-boat chartered and oper-
ated by the United States, or by a State or political subdivision thereof, or by a
foreign nation, except when such vessel is engaged in commerce.

     (d)  "United  States" means the States, the District of Columbia, the Com-
monwealth of Puerto  Rico, the Canal Zone, Guam, American Samoa, the Virgin
Islands, and the Trust Territory of the Pacific Islands.

     (e)  "Person" means an  individual,  firm, corporation, association, and  a
partnership.

     (0  "Contiguous zone" means the entire zone  established  or to be estab-
lished by the United States under article 24 of the Convention on the Territorial
Sea and the Contiguous Zone.

     (g)  "Offshore or onshore facility" means any  facility (including,  but not
limited to, motor  vehicles, rolling stock, and pipelines) of any kind and related
appurtenances thereto which is located in, on, or under the surface of any land, or
permanently or  temporarily affixed to any  land, including lands beneath the
navigable waters  of the United States and which is used or capable of use for the
purpose of processing, transporting, producing, storing, or transferring  for com-
mercial or other purposes any hazardous substance designated under this part.
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     (h)  "Applicable water quality  standards" means water quality standards
adopted pursuant to section 10(c) of the Federal Water Pollution Control Act (33
U.S.C. 1060(c)) which are identified and  described in 18 CFR 620 and State-
adopted water  quality standards for  waters which are not interstate within the
meaning of that Act.

     (i) "Public health or welfare" means, but is not limited to, the physical,
economic  and social well being of persons and includes the preservation  of fish,
shellfish, wildlife and public and private property, shorelines and beaches.

     (j) "Persistent"  means  that quality  ascribed to elements and compounds
whereby they remain appreciably unchanged regardless of physical, chemical or
biological  action occurring in the aquatic environment over an extended period of
time.

     (k)  "Administrator"  means the Administrator, Environmental Protection
Agency.

     (1) "Pollution event" means a discharge, other than  a normal  chronic
discharge, during transportation or storage, or a discharge, other  than a normal
chronic discharge, from commercial, mining, manufacturing, refining, processing,
or related activities which, over a short period of time, significantly exceeds the
average maximum hourly  flow  or significantly  exceeds  the  average maximum
hourly concentration of the element or compound discharged.

     (m)  "Qualified" means a demonstrated  ability of a  person through profes-
sional registration or other recognized water quality management or water pollu-
tion control experience to make decisions for the protection of the public health
or welfare during pollution events.

     (n)   "Degradable" means that quality ascribed to elements and compounds
which can be ultimately destroyed or stabilized by physical, chemical or biologi-
cal processes, natural or induced.

     (o)   "Cumulative" means the effect resulting from a persistent  material
being  exposed to  life forms in the  aquatic  environment and  thereby being
complexed into their metabolism.

Section 3  PURPOSE AND INTENT

     (a)  This part  designates hazardous substances within the meaning of section
12(a) of the Federal Water Pollution Control Act so that any person in charge of a
vessel or of an offshore or onshore facility of any kind shall be on notice that any
substance  discharged  as  a result of  a  pollution  event  has  the potential for
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presenting an imminent and substantial danger to the public health or welfare
depending upon the properties and effects of the substance discharged.

     (b)  This part provides a basis for regulations issued by the United States
Coast Guard which provide for notification of any pollution event resulting in the
discharge of a hazardous substance designated in this part.

     (c)  This part will provide a basis for decisions by qualified persons in charge
of pollution  event response activities to insure  that immediate and effective
actions are taken to mitigate dangers presented to the public health or welfare
from discharges of hazardous substances.

Section 4  DESIGNATION OF HAZARDOUS SUBSTANCES

     (a)  Any element  or compound identified in  section 5 of  this part is
designated a hazardous substance when discharged as a result of a pollution event
which reduces or threatens to reduce the quality of the receiving waters below the
receiving water standards specified for the element or compound in section 5 of
this part.

     The table of elements and  compounds  with receiving  water standards set
forth in section 5  of this  part  may be amended or revised on the basis of
information and data developed or received by the Administrator.

     (b)  Elements or compounds other than the elements or compounds desig-
nated as hazardous substances  in subsection (a) of this section, which possess a
high potential for presenting an  imminent and substantial danger to the public
health or welfare  because  of their nondegradable or persistent nature, or because
they can be biologically magnified, or because they can be immediately lethal, or
because they  otherwise cause or tend to cause detrimental cumulative effects, and
for which insufficient information and data are available to permit the establish-
ment of definitive safe minimum standards which are not to  be  exceeded, are
designated as hazardous substances when discharged in any quantity as a result of
a pollution event, unless the Administrator can be assured by any person responsi-
ble for such discharges that a tolerable negligible risk of imminent and substantial
danger to the public health or welfare is presented: Provided, that at such time as
the Administrator establishes minimum standards in section 5 of this part for such
elements or  compounds,  the provisions  of  this subsection will  no  longer be
applicable to  such elements or compounds, but the provisions of subsection (a) of
this  section will  apply. Elements or compounds designated as hazardous sub-
stances by the provisions of this subsection include:
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     (1)  The following elements in their elemental form or as ions, compounds
or in any combination or mixture including, but not limited to, alloys, ores or
other minerally identifiable forms:  antimony, arsenic, beryllium, boron,  cad-
mium, copper,  chromium, lead, mercury, nickel, selenium, silver, thallium, zinc,
and  other elements  with  similar  properties and  effects except those elements
identified in section 5 of this part.

     (2)  Any element identified in subsection b(l) above which may exist in the
anionic form and other elemental combinations that may  exist in toxic anionic
form such as:  arsenates, arsenites, chromates, cyanide, fluoaluminates, fluorides,
fluosilicates, phosphides and other toxic anions with similar properties and effects
except those toxic anions identified in section 5 of this part.

     (3)  The poisons defined, described, named and classified by the provisions
of 46 CFR  146.25 including extremely  dangerous poisons,  Class A,  such as
cyanogen and phosgene; less dangerous poisons, Class B, such as acetone cyano-
hydrin and sodium arsenite; tear  gases or irritating substances, Class C, such as
bromobenzyl cyanide  and  chloroacetophenone and  other  such poisons  with
similar properties and effects except  those poisons identified in section 5 of this
part.

     (4)  The  radioactive  materials defined, described, named and classified by
the provisions of 46 CFR  146.19  such as uranium 233 and iodine 129 and other
radioactive materials and mixtures with equally dangerous properties and effects
except those radioactive materials identified in section 5 of this part.

     (5)  The  poisons registered  as  economic  poisons  in accordance  with the
provisions of the Federal Insecticide, Fungicide, and Rodenticide Act, as amended
(7 U.S.C. 135 et seq.) including DDT, aldrin,  chlordane, endrin and toxaphene
and  other such poisons with similar properties and  effects except those poisons
identified in section 5 of this part.

     Additional elements  or compounds  may  be designated as hazardous sub-
stances under this subsection when determined appropriate by  the Administrator
on the basis of the  chemical,  physical, biological or radioactive properties and
effects of each element or compound so designated.

     (c)  Any other elements  or  compounds,  other than the  elements  or  com-
pounds designated  as  hazardous  substances in subsections  (a) and (b) of this
section, which  have  physical, chemical, biological, or radioactive properties that
may produce or tend to produce  toxic, corrosive, irritating,  strongly sensitizing,
flammable or other conditions which limit beneficial uses of water are designated
as hazardous substances when discharged as a result of a pollution event which:
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     (1)  Reduces or  threatens to reduce  the  quality of the receiving  waters
below the criteria of applicable water quality standards, or

     (2) If there are no applicable water quality standards, reduces or threatens
to reduce the quality of the receiving waters below the guidelines of water quality
criteria  set forth in the report of the National Technical Advisory Committee to
the Secretary of the Interior entitled Water Quality Criteria dated April 1, 1968,
and any subsequent revisions thereto, or

     (3) If there  are  no  data  specifically addressed  to the elements or com-
pounds  concerned in Water Quality Criteria, results in concentrations or charac-
teristics  in  the  receiving  waters  which  exceed or threaten to exceed limits
determined  in accordance  with test procedures designated  by the Administrator
to predict the potential for physical, chemical or biological damage to shorelines,
beaches  and beneficial water uses. For purposes of this section, fish  bioassay
techniques prescribed  in Standard Methods for the Examination of Water and
Waste Water or as hereafter amended or revised, published by the American Public
Health Association, Inc., using fish and receiving  waters from any geographical
area in  which the potential for the pollution event exists, shall be used as an
interim  technique for determining  96  hour TLm  values under flow-through
conditions. Application factors  of 1/100 for detrimental persistent or cumula-
tive  substances,  and 1/10  for detrimental  degradable, non-cumulative or non-
persistent substances shall be used to establish limits of toxic discharges.

     Provided, that at such  time as  the  Administrator  establishes minimum
standards in section 5 of this part for such elements or compounds, the provisions
of this  subsection  will no  longer be applicable to  such elements  or compounds,
but the  provisions of subsection (a) of this section will apply.

     Elements or compounds  designated  as hazardous substances by the provi-
sions of this subsection include,  but  are not limited  to, the following broad
categories and specific examples:
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                              CATEGORY I
            Inorganic
              Acids
                perchloric acid
                nitric acid
                hydrochloric acid
                phosphoric acid
                sulfurous acid
                         chloric acid
                         chlorous acid
                         hypochlorous acid
                         chlorosulfonic acid
                              CATEGORY II
            Inorganic

              Bases, Alkalies

                potassium hydroxide
                calcium hydroxide
                ammonium hydroxide
                         barium hydroxide
                         sodium carbonate
                             CATEGORY III
Inorganic
  Elements and Salts
     phosphorus
     aluminum
     barium
     bismuth
     cerium
     cesium
     cobalt
     niobium
     gallium
     germanium
     indium
     lanthanum
     magnesium
     manganese
molybdenum
osmium
palladium
platinum
rhenium
rhodium
rubidium
ruthenium
tantalum
tellurium
tin
titanium
tungsten
vanadium
zirconium
strontium
phosphorus pentasulfide
sodium sulfide
sodium hypochlorite
ammonium perchlorate
potassium iodide
ammonium phosphate
sodium hydrosulfite
aluminum sulfate
calcium carbide
ammonium sulfate
zinc chloride
zinc sulfate
calcium phosphate
ammonium nitrate
ferrous sulfate
sodium borate
sodium chlorate
magnesium sulfate
potassium sulfate
sodium silicate
ammonium chloride
sodium sulfate
sulfur dioxide
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                             CATEGORY TV
           Organic

              Hydrocarbons

                isoprene
                ethylene
                pentane
                propylene
                propane
                1-dodecene
                heptane
                hexane
                1-hexene
                1-nonene
                I-octene
                1-pentene
                petrolatum
                1-dodecene
                1-tetradecene
                dicyclopentadiene
                1-tridecene
                turpentine
                cyclohexane
                1-decene
     Organic
                              CATEGORY V
       Halocarbons

         trichloroethane
         carbon tetrachloride
         chloromethane
         chloroform
         trichloroethylene
         dichloropropane
         propylene dichloride
                       dibromochloropropane
                       dichlorodifluoromethane
                       chloroethane
                       ethylene dichloride
                       monochlorodifluoromethane
                       ally! chloride
Organic
Alcohols
  butyl alcohol
  ethyl alcohol
  n-propyl alcohol
  isopropyl alcohol
  isooctyl alcohol
  sorbitol
  cyclohexanol
  hexanol
  propylene glycol
  glycerol
  triethylene glycol
  dipropylene glycol
  tetraethylene glycol
  p-chlorothymol
                              CATEGORY VI
ethylene glycol
amyl alcohol
furfuryl alcohol
n-decyl alcohol
diacetone alcohol
diethylene glycol
diisobutyl carbinol
dodecanol
ethoxylated dodecanol
ethoxylated pentadecanol
ethoxylated tetradecanol
ethoxylated tridecanol
ethyl butanol
2-ethylhexyl alcohol

           214
heptanol
hexylene glycol
isobutyl alcohol
isodecyl alcohol
methyl amyl alcohol
ethyl isobutyl carbinol
nonanol
octanol
pentadecanol
tetradecanol
tridecanol
triethylene glycol
2-undecanol
allyl alcohol
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                       CATEGORY VII
 Organic
   Aldehydes and Ketones

     formaldehyde
     benzaldehyde
     acetaldehyde
     furfural
     methyl ethyl ketone
     cyclohexanone
     methyl isobutyl ketone
     glyoxal
     acetophenone
 Organic
   Acids
     acetic acid
     benzoic acid
     cresylic acid
     oxalic acid
     acrylic acid
     citric acid
     isodecaldehyde
     isooctylaldehyde
     propionaldehyde
     n-valeraldehyde
     n-butyraldehyde
     isobutyraldehyde
     crotonaldehyde
     2-ethyl-3-propyl acrolein
                       CATEGORY VIII
     adipic acid
     fumaric acid
     propionic acid
     lactic acid
     formic acid
     butyric acid
                      CATEGORY IX
Organic
  Esters, Ethers, and Related Substances
     acetyl bromide
     dibutyl phthalate
     vinyl acetate
     methyl methacrylate
     ammonium acetate
     n-butyl acetate
     sodium methylate
     zinc acetate
     propyl acetate
     methyl acetate
     ethyl formate
     ethyl acetate
2-ethyl hexyl acrylate
isopropyl acetate
sec-butyl acetate
dioctylphthalate
ethylene glycol monoethyl
 ether acetate
isobutyl acetate
methyl amyl acetate
n-propyl acetate
n-butyl acylate
isobutyl acrylate
ethyl acrylate
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diethylene glycol
 monoethyl ether
diethylene glycol
 monomethyl ether
 ethylene glycol
 monobutyl ether
ethylene glycol
 monoethyl ether
ethylene glycol
 monomethyl ether
polypropylene glycol
 methyl ether
ethyl ether
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                            CATEGORY X
 Organic

   Aromatic Compounds

     m-cresol
     p-cresol
     nonyl phenol
     benzene
     trichlorophenol
     pyridine
     benzene hexachloride
     ethyl benzene
     pentachlorophenol
Organic
 toluene
 acetophenone
 chlorobenzene
 dodecylbenzene
 dichlorobenzene
 styrene
 tetrahydronaphthalene
 benzoyl chloride
 p-cymene

CATEGORY XI
  Compounds Containing Nitrogen
    trimethylamine
    acetonitrile
    aniline
    cyclohexylamine
    ethylamine
    methylamine
    butylamine
    ethylenediamine
    nitrophenol
    triethanolamine
    monoethanolamine
diethanolamine
nitroaniline
urea
isopropylamine
ethylenimine
diethylamine
morpholine
diamylamine
hexamethylenediamine
pyridine
 cumene
 diethylbenzene
 naphthalene
 nonylphenol
 triethylbenzene
 vinyltoluene
 o-xylene
 m-xylene
 p-xylene
nitrobenzene
adiponitrile
aminoethylethanolamine
diethylenetriamine
diisopropanolamine
dimethylamine
ethylenecyanohydrin
monoisopropanolamine
triethylenetetramine
skatole
  Organic
                          CATEGORY XII
    Compounds Containing Sulfur
      dodecyl mercaptan
      carbon disulfide
      isobutyl mercaptan
      thioglycolic acid
             thiocyanuric acid
             sodium thiocyanate
             dodecylbenzenesulfonic acid
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                        CATEGORY XDI
Organic
  Oxides, Peroxides, and Anhydrides

     phthalic anhydride
     ethylene oxide
     hydrogen peroxide
     nitrous oxide
                  benzoyl peroxide
                  propylene oxide
                  butyl peroxide
                  acetic anhydride
                        CATEGORY XIV
  Miscellaneous Compounds
     Carbohydrates
       dextrose
       lactose
                  starch
                  cellulose
     Proteins
       albumin
                  globulin
     Lipids
       myristic acid
       palmitic acid
       stearic acid
       oleic acid
                  glyceryl trioleate
                  glyceryl tripalmitate
                  glyceryl tristearate
     Medicinal Chemicals
       streptomycin sulfate
       methoxymethyl salicylate
                  atropine methylnitrate
                         CATEGORY XV
   Pathogenic or Toxic Organisms & Groups
     Enteroviruses
     Nodularia
     Anabaenea
     Gonyaulax
     Gymnodinium
     Nostoc
Anacystis
Salmonella typhosa
Salmonella paratyphosa
Vibrio comma
Vibrio cholera
Shigella
   Nuisance Organisms & Groups
     Blue-green algae  Cladophora
     Actinomycetes   Thiobacillus
     Synura          Crenothrix
Leptospira canicola
Brucella melitensis
Staphylococcus aureus
Clostridium botulinum
Endamoeba histolytica
                         Gallinella
                         Enterobius vermicularis
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 Section 5 RECEIVING WATER STANDARDS FOR HAZARDOUS
           SUBSTANCES

     The  receiving water concentrations and characteristics described  for  the
 elements and compounds identified in this section are to be used for the purposes
 of section 4(a) of this part. The substances are specified and numerically quanti-
 fied in Table B-l  to  indicate permissible standards which if violated  present a
 hazard. The permissible standards express effects of discharge  under  normal
 conditions in the aquatic environment.  Under  certain  circumstances such as
 deviations  in pH, temperature, alkalinity,  time of  exposure,  flow  regime,
 synergism or other complicating factors, more  stringent permissible  standards
 than those illustrated in Table 1 may be  required and in such circumstances the
 provisions of subsection 4(c) of this part shall apply.

 Section 6  NOTICE

     Any person in charge of a  vessel or of an offshore or onshore facility of any
kind, as soon as he has knowledge of any pollution event resulting in the discharge
of a hazardous substance designated in section 4 from such vessel or facility, shall
immediately give  notice of such discharge in accordance with regulations issued
by the United States Coast Guard.
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Sulfuric Acid
Ammonia
                                     TABLE B-1

                          RECEIVING WATER STANDARDS

                                            Permissible Standards*



Substance
Phenol

Drinking
Water
Supply
J,C< 0.001
Fresh Water Uses

Plant &
Fish Aesthetics
H>4' A<40.
Salt Water Uses


Fish
A<3.


Shellfish
A <50
                       B>6.
Sodium Hydroxide     B < 8.5
Sucrose
  (molasses)
                      A,J < 0.5
                                     A<3.
                                     A<40.

                                     H>4.
                                     A<200.
                                                  A<20.
                                                                B<8.5
                                                   G,E<0.5     A<6.
                                                                             B>6.7
                                                                             B<8.5
Hydrogen Sulfide
Methanol
Acetone
O-cresol
C<0.05
A < 0.01
C<300.
C< 0.0001
A<1.
H>4.
A < 10.000
H>4.
A < 10,000
A<3.
                                                  C,G<0.05
                                                                             A<2.5
Acrylonitrile
                                     D<5.
                                                  C.E<0.05    A<3.
                                                  G,C<50.     A<15.
         'Undesirable effects
                                   Symbols:  < means less than or equal to
                                             > means greater than or equal to
                                             — no standard
        A Toxicity - mg/l of substance
        B pH - pH units of receiving water
        C Taste-odor to water — mg/l of substance
        D Fish flesh tainting - mg/l of substance
        E Color, turbidity, floating, foaming, settling - mg/l of substance
        F Biologically magnified — mg/l of substance
        G Biostimulatory to certain lifeforms — mg/l of substance
        H Dissolved oxygen — mg/l of dissolved oxygen in receiving water
        I  Salinity fluctuation — change greater than ±10% of normal variation
        J  Reactivity - mg/l of substance
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                           APPENDIX C
                 INDUSTRIAL MUTUAL AID SYSTEM
                      OF TEXAS CITY, TEXAS
                Manual of Procedures during Emergencies
First issue: 1949
Ninth Revision: April 1964
Supersedes All Previous Issues
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                              FOREWORD*

     The subscribers to the Industrial Mutual Aid System and to the Manual of
Procedures recognize that it becomes a civic and moral duty to offer assistance to
another in an emergency, when the ability  to  assist is present and when the
furnishing of assistance would not be attended by undue or unreasonable risk of
personal injury or severe property damage.

     The Industrial Mutual Aid  System and the Manual of Procedures formulated
hereunder are efforts on the part  of neighboring industries and governmental
members in the  Greater Texas  City  Area  to anticipate that one or more of the
subscribers may  be  faced with  a sudden emergency requiring outside assistance
over and  above  such  assistance  that may be  rendered by the governmental
members subscribing hereto  in  the discharge  of their official duties, to the end
that prompt and  efficient assistance can be given.

     The System and the Manual are designed  to determine in advance of any
emergency what  personnel and facilities may be reasonably available.

     Lastly, they provide a method of employing that assistance in a prompt and
efficient manner  in any given emergency.

     It is not intended that the subscribers shall assume or relieve themselves of
the rights, duties, responsibilities, and liabilities which would otherwise attach by
operation  of law, anything to the contrary, whether expressed  or implied in the
System and Manual notwithstanding.

     Nor is it intended that any of the provisions of the System and Manual shall
apply to any governmental agency subscribing thereto when discharging the duties
for which they were created.

     Personnel from any member (governmental or private  enterprise) entering
the premises of another member will be expected to act under the direction of the
affected member, or the governmental member having jurisdiction and authority
as a matter of law, as the case may be. Wherever possible, employees of a member
offering assistance will not enter the affected  plant but will deliver the  assistance
requested  to the main gate of  the affected member. This procedure should be
adhered to almost without exception since insurance  coverages may be invalid in
case of injury. Traveling from one  plant to an affected plant is not the respon-
sibility of the affected plant.
 'There are eight appendixes — I through VIII - included within Appendix C, and the reader
  should not confuse them with Appendixes A through F of this report.
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     It  is expected  that  all members will  cooperate to the fullest extent in
furnishing aid to the affected member; however, there is no obligation to do so if
circumstances within a member plant in their sole judgment do not permit their
lending assistance.
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SCOPE OF THE INDUSTRIAL MUTUAL AID SYSTEM

     The primary purpose of the Industrial Mutual Aid System is the develop-
ment of a plan of cooperative action, whereby assistance of other companies or
members will be made available to any member having an emergency which may
be beyond the ability of the affected member to control. Such aid or assistance
will be available  upon request from the affected member and unless requested,
none of the participating members will respond to the scene of the emergency.

     It shall be expressly understood that any member receiving aid from another
is responsible  for the return in good order or reimbursement for materials or
equipment obtained under this agreement.

     An agreement has been reached between mutual  aid organizations of the
Gulf  Coast  area  whereby assistance will  be rendered on  a reciprocal basis.
Requests shall be made only by officers of the organization in  emergency to
officers of the organization expected to furnish assistance. See Appendix VIII.

OFFICERS AND ORDER OF SUCCESSION

     There shall be  a general chairman, secretary, and five vice-chairmen, to
administrate the activities of the Texas City Industrial Mutual Aid System.

     An election shall be held in the regular meetings of member representatives
in January of even-numbered years  for the purpose of selecting Industrial Mutual
Aid System Officers.  Each member  shall be entitled to one vote. Elected officers
shall  serve  for a period of two years, beginning with the first regular meeting
following the election.

     The general  chairman shall  appoint  first and second alternates  from the
roster of vice-chairmen to succeed him in any absence.

     The vice-chairmen shall each appoint  one  alternate, subject to approval of
the general chairman, to succeed to committee leadership during declared emer-
gencies. Any appointed alternate shall succeed an elected officer during term of
office only in the event of unavoidable removal of that officer.

RESPONSIBILITIES  AND FUNCTIONS

     The general chairman or his ranking alternate, as the case may be, shall direct
all activities of the Texas City Industrial Mutual Aid System.
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                           Executive Committee

     The elected officers shall constitute an Executive Committee. The current
committee consists of:

  Charles Gilmore     General Chairman
  H. C. Reiniger      Secretary
  K. E. Agee         Vice-Chairman — Communications and Public Information
  R. L. DeWalt       Vice-Chairman - Traffic Control
  Gail Atkins         Vice-Chairman — Equipment and Plant Emergency Systems
  Dr. Roy Joyner     Vice-Chairman — Medical Coordination
  Carter Goodwin     Vice-Chairman — Allied Services

     The purpose of the Executive Committee is to develop Industrial Mutual Aid
System policies and to coordinate activities in accordance with such policies.

     Each vice-chairman shall appoint a  committee from the roster of member
representatives and  alternates  to  develop procedures pertinent to his  scope of
responsibility.

CONTROL CENTER

     The Texas  City Police  Department  Headquarters  shall  be  utilized as a
Control  Center during emergencies. Executive Committee members and their
appointed alternates should report there to coordinate emergency activities.

CENTRAL COMMITTEE

     Each participating member of Industrial Mutual Aid System  shall appoint
one person to  serve  as its official representative in Industrial Mutual Aid System
activities. The  appointment of one or more alternates is desirable but optional.
Attendance at  all regular meetings by representatives and alternates is encouraged.

     This group shall be known  as the Central Committee and  will  meet as
directed  to  conduct affairs of the Industrial Mutual  Aid System.  The primary
purpose  of the Central Committee is to  serve as the  liaison  agency  between
member  managements and the Industrial Mutual Aid System  Executive Com-
mittee.

     The roster of Industrial Mutual Aid System members appears as Appendix  I
of this manual.

     The roster of member representatives and alternates shall be maintained by
the secretary.
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THE COMMUNICATIONS COMMITTEE SHALL DEVELOP
PROCEDURES FOR:
(See Procedures, Appendix II)

1. Form of message or code  word  to be used for requesting  help and  for
   dispatching assistance to other members.

2. Method of placing calls from an affected member to the Central Police Station
   of Texas City which will be used as the dispatching station for all incoming or
   outgoing  messages including those that  will cover Red Cross  requirements.
   (The Red Cross Disaster Committee  will separately organize other means of
   communications to meet their detailed requirements.)

3. Dispatching assistance to any member making request for help.

4. Release  of information  to  public through the newspaper,  radio, or other
   desirable means.

5. Education of the public and  controlled publicity relating to  the Industrial
   Mutual Aid System.  The advance publicity will be advantageous at the time of
   an incident by having the general  public realize the importance of their
   coooperation in case of an emergency.

6. The  coordination of telephone and telegraph facilities to assure that mainte-
   nance of service is immediately available if required.

7. Enlistment  of mobile two-way radio equipment, sound trucks, and all other
   modes of communication  which  will be  available  to  supplement existing
   equipment as needed.

8. Maintain  an up-to-date listing of  communications equipment available  and
   publish same to members.

THE TRAFFIC CONTROL COMMITTEE SHALL DEVELOP
PROCEDURES FOR:
(See Procedures, Appendix III)

1. Zoning the greater Texas City area for traffic control purposes.

2. The  coordination of efforts of  all governmental police agencies during an
   emergency  and the control of all  traffic into or out of the  property of any
   member at the time of an emergency.
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 3. The control of all traffic into or out of the  corporate limits of Texas City in
    general emergencies.

 4. Establishing road blocks during  emergencies  and detouring traffic as required.

 5. Permitting member plant personnel to pass road blocks to enter their respec-
    tive plants.

 6. Identification  for member representatives and member  employees for use
    during time of emergencies.

 THE EQUIPMENT AND PLANT EMERGENCY SYSTEMS COMMITTEE
 SHALL DEVELOP PROCEDURES  FOR:
 (See Procedures, Appendix IV)

 1.  Conducting member  plant surveys for purpose of maintaining list  of fire,
    safety, and mechanical equipment.

 2.  Maintaining lists of persons, including their day and night telephone numbers,
    who are authorized to request or  release such equipment.

 3.  Issue the above lists to all member companies.

 4.  Arrangements with each member to designate place or places to which equip-
    ment being requested can be delivered in case of an emergency.

 THE MEDICAL COORDINATION COMMITTEE SHALL DEVELOP
 PROCEDURES FOR:
 (See Procedure, Appendix V)

 1. The development  of procedures  for establishing medical aid at the scene of
   emergency.

 2. The establishment of  a series  of locations in the  Texas City area to  which
   injured personnel can  be taken  so as to remove them from the emergency area.

3.  The establishment of a procedure for alerting hospitals in  Galveston  and
   Houston. The authority to transmit such information should be established.
   (This phase is very important.) By the establishment of these procedures, false
   alarms and unnecessary confusion will be reduced to an absolute minimum and
   yet insure adequate medical facilities.

4.  The coordination of both ambulance and nurse services.
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5. The establishment of a pool of medical supplies which can be drawn upon as
   deemed necessary by the chairman of the Medical Coordination Committee in
   cases of emergencies affecting IMAS members.

ALLIED SERVICES
(See Appendix VII and VIM)

   The vice-chairman, Allied Services shall coordinate development of necessary
intersectional exchange agreements.
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                    APPENDIX I

       THE PARTICIPATING MEMBERS OF THE
      MUTUAL AID SYSTEM ARE AS FOLLOWS:
American Oil Company (Texas)
Amoco Chemicals Corporation

Community Public Service Company

Emken-Linton Funeral Home
WI  5-2311
WI  8-1601

WI  5-2386

WI  5-4444
Galveston County Amateur Radio Club (Bach)    WI  5-4431
Galveston County Medical Society
Galveston County Memorial Hospital           WE  5-2421
Galveston County Sheriff's Department          SO  5-6686

Houston Natural Gas Corporation              WI  5-4471
Houston Pipe Line Company (Houston)         MI  4-5015

Monsanto Chemical Company                 WI  5-4431

Pan American Gas Company                   WI  8-2501
Marathon Oil Company                       WI  5-2331

Radio Station KTLW                         WI  5-4418

Service Pipe Line Company (Houston)          HU  4-2334
Smith-Douglass Company, Inc.                WI  8-1691
Southwestern Bell Telephone Company          WI  5-7481

Texas City Civil Defense                      WI  5-2325
Texas City Fire Department                   WI  5-2325
Texas City Police Department                 WI  8-2525
Texas City Refining, Inc.                     WI  54451
Texas City Sun                             WI  54483
Texas City Terminal Railway Company          WI  5-4465
Texas Highway Patrol (Houston)               OX  4-2374

Union Carbide Chemicals Company             WI  5-7411
Unites States Coast Guard (Galveston)          SO  3-1635

Wah Chang Corporation                      WI  54411
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                             APPENDIX II

           PROCEDURE FOR COMMUNICATIONS COMMITTEE

                         Chairman — K. E. Agee

     The procedure and form of message to be used in requesting assistance from
 the Industrial Mutual Aid System should be known by authorized personnel of
 each  member company. The message will relate the general conditions of the
 situation and will establish positive identification of the member company and
 name of person transmitting the message. Code words will not be utilized.

 |. GENERAL CONDITIONS

 A.  "Alert"

     All members stand by. A  situation  exists but is under control. May create
     hazardous traffic condition or undue public alarm.
     Traffic control required.

 B.  "Emergency"

     Assistance required from other members.

 C.  "All Clear"

     No further assistance required.

II. TO ACTIVATE SYSTEM

 A.  Call Texas City Refining, Inc.

     1.   By IMAS radio network to KFG-92
     2.   By telephone to WI 5-4451.

 B.  Message Form -

     State the following:

     1.   Name of member company and person calling.
     2.   This is an IMAS "Alert" or "Emergency."
     3.   Assistance required - medical, ambulance, fire depart-
         ment, etc.
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III. RESPONSE

A. "Alert Condition" Texas City Refining, Inc.

     1.   Dispatches traffic control
    2.   Alerts Galveston County Memorial Hospital and Emken-
         Linton Funeral Home
    3.   Alerts IMAS Chairman or alternates.
    4.   Checks all IMAS radio units.
    5.   Alerts Sheriff's Department and State Highway Patrol.

B. "Emergency Conditioning"

    Texas City Refining, Inc.:

    1.   Dispatches traffic control.
    2.   Notifies  Galveston  County  Memorial Hospital, Emken-
         Linton,  and Fire Department for  emergency condition.
         Transmits detail message of assistance required.
     3.  Calls  IMAS Chairman or alternates giving location, condi-
         tion, assistance required.

    4.   Alerts Sheriff's Department and State Highway Patrol.

IV. ACTION TO BE TAKEN BY OTHER MEMBERS

A.  Galveston County Memorial  Hospital calls doctors, nurses, and hospitals as
    required.

B.  IMAS Chairman or alternates calls the Equipment Committee Chairman and
    the  Red  Cross  Disaster  Committee Chairman and Communications Chair-
    man, repeating the condition and the location of the emergency.

    The IMAS Chairman or alternates will call those members requiring notifica-
    tion by telephone. These are listed below:

    Amoco Chemicals Corporation                         WI  8-1601
    Community Public Service Company                    WI  5-2386
    Daily Sun                                           WI  5-4483
    Houston  Natural Gas Corporation                      WI  5-4471
    Houston  Pipe Line Company                           MI  4-5015
    Pan American Gas Company                           WI  8-1781
    Radio Station KTLW                                 WI  54418
    Service Pipe Line Company (Houston)                   HU  4-2334


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     Smith-Douglass Company, Inc.                         WI  8-1691
     Southwestern Bell Telephone Company                 WI  5-7481
     Texas City Civil Defense                               WI  5-2671
     Texas City Terminal R.R. Company                     WI  5-4461
     U. S. Coast Guard (Galveston)                          SO  3-1635

C.   The Communications Committee Chairman calls the representative of press
     and radio, repeating the condition and location of the emergency.

V. RELEASE OF PUBLIC INFORMATION

A.   The Chairman of the Communications Committee or a person designated by
     him must cooperate with member officials in order to secure the necessary
     information for the preparation of the news releases.

B.   No information relating  to an incident is to  be issued except that which is
     released by  proper authorization of the affected member. It will be under-
     stood that all information released to IMAS is confidential. This measure will
     be of great assistance in avoiding panic in case of serious emergency.

VI. PUBLIC EDUCATION

     The Communications Committee Chairman or a person designated by him
will issue public educational material only as authorized by the IMAS Executive
Committee.

VII.  EQUIPMENT SURVEY

     The Chairman and his committee shall make  a survey of all communications
companies and their facilities, and  their  locations.  The committee  will also
maintain a list of company officials to be called in  order to maintain constant and
uninterrupted service insofar as possible.

VIII. MOBILE EQUIPMENT SURVEY

     The Chairman and his committee shall make  a survey and list of all available
mobile and portable communications equipment  and shall authorize the use of
such equipment in the event such is needed.
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      MEMBERS OF INDUSTRIAL MUTUAL AID EMERGENCY NET
    Unit No. 1
    Unit No. 2 -KFG-81
    Unit No. 3 - KFG-80
    Unit No. 4 - KFG-94
    Unit No. 5 -KFG-96
    Unit No. 6 - KFG-92
    Unit No. 7 -KFG-98
    Unit No. 8 -KFG-93
    Unit No. 9 - KFG-95
    Unit No. 10 -KFG-83
    Unit No. 11 - KFG-97
    Unit No. 12-KFG-99
Net Control (Communications Chairman)

American Oil Company

City Fire Department (Central or Heights)

Monsanto Chemical Company

Marathon Oil Company

Texas City  Refining, Inc.

Union Carbide Chemicals Company

Wah Chang Corporation

Emken-Linton

Community Public Service Company

City Police Department

Galveston County Memorial Hospital
The above list will be revised and forwarded upon additions or  deletions of
stations in this network.
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                REQUIREMENTS AND PROCEDURES FOR
          TEXAS CITY INDUSTRIAL MUTUAL AID RADIO NET

ORGANIZATION

     The Industrial  Mutual  Aid Radio Net was adopted  by members of this
organization for the purpose of providing an additional form of communication
among heavy industry and service organization members, which will augment our
efforts in the  preservation  of life and  property in the event of man-made or
natural disasters.

AUTHORIZATION

     The Industrial Mutual Aid  Radio Net is authorized to  operate in the Special
Emergency Radio Service.

OPERATING REQUIREMENTS

     1. All persons operating radio equipment on this net  must be an employee
or a member of the Industrial Mutual Aid System.

     2. No person will utter any obscene, indecent or profane language by means
of these radio communications.

     3. No station  in this net shall be used to transmit or receive messages for the
purpose of compensation direct or indirect and shall at no time be used for the
purpose of conducting company business or operations unless such message would
be used directly for the preservation of life and property.

STATION IDENTIFICATION

     When stations of  the Industrial Mutual Aid are engaged in network opera-
tion, each station or unit must fully identify itself at least once  by using the
assigned call of the licensee  in addition to their own assigned unit number. Any
further identification by any station other than the acting control station or unit
during  that period of network operations may be accomplished by the use of its
assigned unit number only.

     The control station  upon closing the network operation shall fully identify
itself by the use of the assigned call sign of the licensee in addition to its assigned
unit number.
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USE OF STATIONS

     In considering the use of the radio emergency net, it is understood that any
member may activate  the network or any portion thereof for the purpose of
requesting aid or transmission of information regarding any emergency which
would effect the preservation of life and property.

     Practice drills will be  conducted at times designated by the Communications
Chairman.

OPERATING PROCEDURES

     1. Voice Transmission

     In order that a message be  received with as much clarity as possible, the
operator  transmitting the  information should train himself to speak slowly and
directly into the  microphone.  The loudness of voice which is normally used on
the telephone is usually sufficient to properly operate the average microphone.

     2. Net Control

     The term NET CONTROL  STATION is that unit which may activate the
network or any portion thereof for the purpose of requesting aid and transmitting
information during an emergency or any unit which has been delegated by the
Communications  Officer to act  as net control  station for the purpose of con-
ducting drills or  tests. In  case of a serious disaster or large scale emergency, the
net  control station will be established by IMAS in the Texas City Police Head-
quarters.

OPERATION

     To alert the net, the following example should be utilized by the operator.
This example assumes that Unit No. 1 is the net control station:

     "Attention all units of the Industrial Mutual Aid Net.

          is*                        Unit No. 1 acting net control.

                                      /   emergency
              This is a(n)             )   stand-by alert
                                       j   practice drill
                                      f   equipment check
              All units stand by."
 *Call sign will be inserted upon assignment.

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    The above transmission should be repeated three times to alert other units
on the net.

    The net control station will then call the roll of member stations as follows:

(This example assumes that Unit No. 1 is the net control station.)

    "Unit No. 2, this is net control*                 Unit No. 1."
       Unit No. 2 (American Oil Co.) will then reply -

    "Unit No. 1, this is*                            Unit No. 2."
       Net control will then acknowledge by answering.

    "Thank you, Unit No. 2."

    "Unit No. 3, this is net control*                 Unit No. 1."
       Unit No. 3 (City Fire Department will  then reply.)

    "Unit No. 1, this is*                            Unit No. 3."
       Net control will then acknowledge by answering.

    "Thank you, Unit No. 3."

                          Etc. for all other units.
*Call sign will be inserted upon assignment
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                LIST OF COMMUNICATIONS EQUIPMENT

Contact                    Business Telephone       Residence Telephone

K. E. Agee - Chairman      WI5-4451               WI 5-2414

                       RADIO STATION KTLW

    At the time of emergency, the radio station will broadcast facts as furnished
by the Mutual Aid Headquarters and render any other assistance possible in
reporting of the news.

Contact                    Business Telephone       Residence Telephone

Station Manager            WI 54418               WI 5-2754

             SOUTHWESTERN BELL TELEPHONE COMPANY

    Personnel will  be available to provide emergency communications and tele-
phone service  as soon  as possible. State assistance required to the Chief Operator,
i.e., mobile telephone,  equipment repairman, etc.

Contact                    Business Telephone

Chief Operator             WI 5-7401

                           THE DAILY SUN

     THE DAILY SUN  will assist  in any way possible in distributing and pub-
lishing news of an emergency.

Contact                    Business Telephone       Residence Telephone

Carl Hooper               WI 54483               WI 8-2643

                    TEXAS ARMY NATIONAL  GUARD
             COMPANY"B" - 111TH MEDICAL BATTALION

     5 - Field Units - AM and FM - range  15 miles - activate on request from
County Judge, Sheriff, or Mayor of City.

Contact

Building 401 - Fort Crockett, Galveston, Texas


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                          U. S. COAST GUARD

2 — Communication trucks with AM equipment.
3 — Mobile two-way FM equipment.

Contact                                            Business Telephone

Captain of the Port                                   SO 3-163 5

                  TEXAS CITY POLICE DEPARTMENT

1 — 250 watt FM transmitter located at 5th Avenue North — 155.37 me.
9 — Police cars — mobile units — 155.37 me.
2 — Mobile unit equipped with public address system
1 — Teletype — State Department of Public Safety
1 - Two-way radio equipment to State Highway Patrol and County Sheriff's
    Department
1 - IMAS receiver-transmitter

                       TEXAS HIGHWAY PATROL

1 - Portable station (transmit-receive) — FM — 42.9 me.
    Relay through patrol unit to 155.37 me.
    Several patrol units with two-way FM radio, available if required.

Contact

Texas City Police Department

                   TEXAS CITY FIRE DEPARTMENT

Central Station

1 - Base station, 250 watt FM - 154.43 me.
4 — Two-way radio equipped trucks.
1 - Two-way radio equipped mobile unit (Chief).
1 — IMAS receiver-transmitter

Heights Station

1 - Base station - 250 watt FM - 154.43 me.
2 — Two-way radio equipped trucks.
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 No. 4 Station (West Texas City)

 1 - Base station - 250 watt FM - 154.43 me.
 2 — Two-way radio equipped trucks

                       AMERICAN OIL COMPANY

 1 - Base station - 60 watt FM - 153.05 me. (relay to mobile).
 1 - Mobile - 30 watt - relay 153.05 me. to Texas City Policy Department on
     155.37 me.

 Contact                   Business Telephone        Residence Telephone
                                                   Dickinson
 H. C. Reiniger              WI 5-2311                534-4029

                COMMUNITY PUBLIC SERVICE COMPANY

 1 - Base station - 120 watt FM - 48.30 me.
     Texas City (2), La Marque, Dickinson, Alvin, Angleton, West Columbia
15 — Two-way mobile units (local)

 Contact                   Business Telephone        Residence Telephone

 G. R. Boyd                 WI 5-2386                WI 5^009

                HOUSTON NATURAL GAS CORPORATION

 8 - Base stations - 60 watt FM - 48.18 me.
     Texas City, Baytown, LaPorte, Freeport,  Alvin, Wharton, Victoria,
     Corpus Christi.
10 — Two-way mobile units (local).

 Contact                   Business Telephone        Residence Telephone

 J. B. Meyers                WI 5-4471                WI 5-6228
 J.S.Sullivan               WI 5-4471                WI 5-9331
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                    PAN AMERICAN GAS COMPANY

 1 - Base station - 60 watt FM.
 7 - Two-way radio equipped mobile units
 1 — Mobile units for battery power or mobile use.

 Contact                   Business Telephone       Residence Telephone

 C. F. Bryce                 WI 8-2501               WI 5-9678

                      SERVICE PIPE LINE COMPANY

 6 — Base stations — two-way FM — 48.70 me.
     Located at Texas City, Alvin, Houston, San Jacinto, Tomball, and Huffsmith.
30 - Two-way FM mobile units at various locations.
     Service Pipe Line Company private phone system Galveston and Harris
     Counties.

 Contact                   Business Telephone        Residence Telephone

 George Speed               WI 5-5762               Alvin OL 8-3950
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                              APPENDIX III

           PROCEDURES FOR TRAFFIC CONTROL COMMITTEE

Texas City Police Department - Chairman - Chief of Police R. L. DeWalt

Texas Department of Public Safety - Highway Patrol

Galveston County Sheriff's Department

La Marque Police Department

I. MAPS

A.   This committee shall maintain  up-to-date  zone maps  of  the Texas City-
     LaMarque area and furnish necessary revisions to members.

B.   This committee shall maintain up-to-date maps of each zone showing prefer-
     able locations of road blocks and routes of detour from various zones in case
     of an emergency.

II. CONTROL

     The control of all traffic into or out of the corporate limits of Texas City
will  be  the responsibility of the available governmental police agencies co-
operating with the Texas City Chief of Police.

III.  COORDINATION

     The Texas City Chief of Police is to be responsible for the coordination of
efforts of all governmental police agencies during an emergency, and the control
of traffic into or out of any member plant at the time of such emergency will be
conducted by the available governmental police agency designated by him.

IV.  IDENTIFICATION CARDS

A.   Normal plant identification cards  or badges of affected member employee
     shall constitute  sufficient identification to permit  passage  through road
     blocks to reach their respective plants.  However, in the event an  emergency
     should develop at or near the time of changing shifts, it may be necessary for
     the affected member and ajoining members to determine  what  portion of
     their respective  personnel will enter or leave their respective plants and to so
     advise the Texas City Chief of Police.



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     V. LIST OF TRAFFIC CONTROL EQUIPMENT
                          Texas City Police Department
                            Police personnel — Thirty-one men
                            Police units - nine cars

                          Texas Highway Patrol
                            Police personnel
                            Police units — Five

                          Galveston Sheriffs Department
                            Police personnel
                            Police units — Four

                          LaMarque Police Department
                            Police personnel
                            Police units — Four
     VI. ROAD BLOCKS AND PATROLS
     Notice:   Permit vehicles of Southwestern Bell Telephone Company,
              Community Public Service Company, and Houston Natural
              Gas Corporation to enter any restricted area.
Streets Restricted to Emergency Traffic Only
A
American Oil Company (Refinery)

1.  5th Avenue South between
   21 st Street and Grant Avenue

2.  Grant Avenue between 5th Avenue
   South and Union Carbide rear gate.

American Oil Company and
Marathon Oil Company (Tank Farms)

1.  Highway 146 (business route)
   between 4th Avenue South and
   junction with Highway 519
                                           Employee Groups Permitted to Pass
                                                1.  American Oil Company
                                                2. American Oil Company
                                                   Pan American Gas Company

                                                1. Amoco Chemicals
                                                1.  Marathon Oil Company
                                                   Amoco Chemicals
                                                   Texas City Refining
                                                   Texas City Terminal RR Co.
                                       243
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    2. 14th Street between
       Texas Avenue and
       American Oil Company gate

    3, 7th Avenue South between
       10th Street and 14th Street
C.  Monsanto Chemical Company

    1.  Bay Street south of
       2nd Avenue South

    2.  2nd Avenue South between
       Bay Street and 3rd Street

    3.  3rd Street between
       2nd Avenue South and 4th Avenue South

    4.  4th Avenue South between
       Highway 146 (business route)
       and 3rd Street

    5.  Highway 146 (business route)
       between 4th Avenue South and
       entrance to Texas City
       Terminal RR Company

D.  Marathon Oil Company and Amoco Chemicals
    (Refineries)

    1.  Highway 146 (business route)
       between 4th Avenue South and
       junction with Highway 519
2. American Oil Company
   Marathon Oil Company
   Warren Petroleum Corporation

3. American Oil Company
   Marathon Oil Company
   Warren Petroleum Corporation
1.  Monsanto Chemical Company
2. Monsanto Chemical Company
3. Monsanto Chemical Company
4. Monsanto Chemical Company
5.  Monsanto Chemical Company
   Amoco Chemicals
   Marathon Oil Company
    2. 4th Avenue South between
       Highway 146 (business route)
       and 10th Street
1.  Marathon Oil Company
   Amoco Chemicals
   American Oil Company
   Sea Train
   Texas City Terminal RR Co.
   Union Carbide Chemicals Co.
   (Crews of docked ships)

2.  Marathon Oil Company
   Amoco Chemicals
                                     244
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E. Texas City Refining, Inc.

    1. Highway 146 (business route)
       between 4th Avenue South
       and junction with Highway 519

F. Smith-Douglass Company, Inc.

    1. Grant Avenue between
       5th Avenue South and
       junction with Highway 519
1. Texas City Refining, Inc.
1.  Smith Douglass Company, Inc.
   American Oil Company
   Pan American Gas Company
   Union Carbide Chemicals Co.
G. Amoco Chemicals - Plant "B"

     1. Highway 519

H. Texas City Terminal Railway Co.
   (Docks and Tank Farms)

     1. Highway 146 (business route)
       between 4th Avenue South and
       junction with Highway 519
I.    Union Carbide Chemicals Company
     (Chemicals Plant)
1.  Amoco Chemicals Corporation
1.  Texas City Terminal RR Co.
  American Oil Company
   Amoco Chemicals
   Marathon Oil Company
   Sea Train
   Texas City Refining, Inc.
   Union Carbide Chemicals Co.
   U. S. Coast Guard
   (Crews of docked ships)
     1. 5th Avenue South between
       Grant and Highway 146

     2. Grant Avenue between
       5th Avenue South and
       Highway 519
 1. Union Carbide Chemicals Co.
 2. Union Carbide Chemicals Co.
   American Oil Company
   Pan American Gas Company
   Smith-Douglass Company, Inc.
                                       245
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3. Highway 146 between
   5th Avenue South and
   junction with Highway 519

4. Texas Avenue cut-off to
   5th Avenue South between
   28th Street and 5th Avenue South
3.  Union Carbide Chemicals Co.
4.  Union Carbide Chemicals Co.
(Barge Terminal)

1. Highway 146 (business route)
   between 4th Avenue South and
   junction with Highway 519
1.  Union Carbide Chemicals Co.
   Texas City Refining, Inc.
   Amoco Chemicals Corporation
VII.  IMAS ROAD BLOCKS FOR THE CITY OF TEXAS CITY TO
     PREVENT ENTRY OF ALL BUT EMERGENCY TRAFFIC

1. Highway 146 at 25th Avenue North
   Turn traffic north to FM 517 to Dickinson and Highway 3

2. Palmer Highway (13th Avenue North) at Highway 3
   Turn traffic north or south

3. 5th. Avenue South (Intercity) at Highway 146
   Turn traffic west to Highway 3

4. Highway 519 (LaMarque Main Street) at Highway 146
   Turn traffic west to Highway 3

5. Junction Highway 3 and Highway 146
   (Texas City business route-Texas City Wye.)

           Turn traffic north and south on Highway 3
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                            APPENDIX IV

        PROCEDURE FOR EQUIPMENT AND PLANT EMERGENCY
                        SYSTEMS COMMITTEE

                   Chairman — Gail Atkins — Wan Chang

I. IN CASE OF EMERGENCY

    To order equipment and Supplies, call Unit No. 11 or WI 8-2525.

A.  State Name of Company and Your Name.

B.  Quantity and Description of Supplies or Materials Required.

II. EQUIPMENT SURVEY

A.  The individual members of this committee are responsible for furnishing lists
    of fire, safety, and mechanical equipment of the respective companies to the
    committee chairman.

B.  The individual members of this committee are responsible for furnishing lists
    of the  names  and telephone numbers  of persons authorized to release
    equipment in case of emergency.

III.  DISTRIBUTION OF INFORMATION

    The above information is to be submitted to the chairman of the committee
whenever revision is  necessary.  The  chairman shall be responsible  for preparing
lists which will be submitted to the secretary of the  IMAS for distribution  to all
member companies.

IV.  See page Nos. 250 - 254 for list of equipment.
                                 247

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   FOR AUTHORIZATION TO RELEASE EQUIPMENT IN
   CASE OF EMERGENCY

   Use IMAS radio (refer to company call designations) or telephone, as conditions
   indicate:
American Oil Company
(KFG-81)
Days           Business      Residence
G. L. Honeycutt WI 5-2311    WI 5-6908
F. K. Webb     WI 5-2311    WI 5-9567
Nights and Week Ends — WI 5-9788 and ask for Night Superintendent.
Amoco Chemicals Corporation
Day or Night    Business
M.S. Weir      WI 8-1601
O.W. Collier    WI 8-1601
Residence
877-2429 (Kemah)
WE 5-6475
Community Public Service Co.   Call WI 5-2386 and give necessary information.
Houston Natural Gas Corporation
Houston Pipe Line Company
Day or Night    Business      Residence
J.S.Sullivan    WI 5-4471    WI 5-9331
E. B. Langford   WI 5-4471    WI 5-7317

Day or Night
Gas Control - Houston FA 3-2984
Monsanto Company
(KFG-94)

Marathon Oil Company
(KFG-96)

Smith-Douglass Company, Inc.
Texas City Refining, Inc.
(KFG-92)
Day or Night
Call WI 5-5022 and give necessary information.

Day or Night
Call WI 5-2331 and give necessary information.

Day or Night
Call WI 8-1691 and give necessary information.

Day or Night
Call WI 5-4451 and give necessary information.
Texas City Terminal R.R. Company     Days
                                   Call WI 5-4461 and give necessary information.
                                   Nights
                                   Call WI 5-5011 or WI 5-5311 and give necessary
                                   information.
                                    248
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U. S. Coast Guard                    Day or Night
                                    Call Galveston SO 3-1635 and give necessary
                                    information.

Union Carbide Company              Days
(KFG-98)                           Call WI 5-7411, Ext. 409 or 491, and give
                                    necessary information
                                    Nights
                                    Call WI 5-7411 and give necessary information.
                                      249

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       LISTS OF FIRE. SAFETY, AND MECHANICAL EQUIPMENT
                     AMERICAN OIL COMPANY
Fire Equipment

   50-50'lengths
   12
    3
    1
    2

  300 - 50 Ib. cans
  300 - 50 Ib. cans
  500 - gallons

Safety Equipment

    2
    4

   80
    1
        2%"fire hose with NST
        Adjustable straight stream and fog nozzles
        National D-25 foam generators (dual powder)
         complete with 4" mixing hose, Siamese and
         nozzles
        52'National hydraulic foam tower
        Goose neck foam maker chambers for hydraulic
         tower (mechanical and chemical)
        National "A" foam powder
        National "B" foam powder
        National 3% foam liquid
      - All-purpose canister gas masks
      - Self-contained air paks (15-minute approval,
         recharging equipment available)
      — Wool blankets
      — Stokes metal splint stretcher

AMOCO CHEMICALS CORPORATION
Safety Equipment

    6
    1
        Self-contained air masks
        Resuscitator

         MONSANTO COMPANY
Fire Equipment

2,000'
    5
   10
    2
  5 00-gallons
        2Vi" fire hose NST couplings
       2'/2" adjustable straight stream and fog nozzles
        21/4"straight stream nozzles (!%" tips)
        \Vi" mechanical foam nozzles with pick up tubes.
        Mechanical foam 6% National "99" for alcohol,
         ether, esters, etc.
                                250
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    1                  -  Portable dual foam generator complete with 4"
                          mixing hose, Siamese and nozzle.
  200 - cans            -  "A" foam powder (10,000) Ibs.
  200 - cans            -  "B" foam powder (10,000) Ibs.
    2                 -  2l/2" mechanical foam nozzles with pick up tubes.

Safety Equipment

    8                 -  Wool blankets
    4                 -  U. S. Army canvas stretchers
    1                 -  Stokes metal splint stretcher
    4                 -  All-purpose canister masks
    1                 -  Fresh air hose mask without blower
    1                 -  Fresh air hose mask complete with hand-operated
                          blower
    1                 -  Pneophore assembly complete - 40 cu. ft.
                          capacity cylinder (to be used for giving oxygen)
    6                 —  Air line respirators
    2                 -  Chemox oxygen breathing apparatus (12 canisters).

                    MARATHON OIL COMPANY

Available Fire Equipment And/Or Supplies

    1                 - 500 gpm Chrysler fire pump mounted on trailer
    2                 — Hydraulic foam towers for mechanical foam
    6                 — 150 Ib. dry powder wheeled extinguishers
1,000'                - 2l/2"fire hose, NSTcouplings
    2                 - 30-minute self-contained air paks
  120-5 gal. cans      - Mechanical foam 3% (600 gallons).

                 SMITH-DOUGLASS COMPANY, INC.

Available Fire Equipment And/Or Supplies

  300"                 - 2W fire hose, NST
     1                  — Adjustable straight stream and fog nozzle
     1                  - First-aid kit complete - additional equipment
                           as needed.
     2                  - Basket stretchers with blankets
     2                  — All-purpose gas masks
     1                  - Pickup truck or station wagon to be used as needed.
                                   251

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                    TEXAS CITY FIRE DEPARTMENT
Fire Equipment

    3
    4
    1
1,000'
8,000'
2,300'
   10
    4
    3

    4
    1
    8-151b.
    6-151b.
Fire Equipment

  250-cans
  250-cans
   40 - cans
  300'
  150'
    2
    2
    2
    2
    3
    3-3501b.
  300 - pounds
    4
    1
 — Bean high pressure trucks
 — 750 gpm — CMC pumpers
 - 750 gpm International (pumper)
 - \W hose, NST
 - 2W hose, NST
 - %" and 1" booster hose
 — Gas masks (smoke)
 — Self-contained air paks
 — Portable electric generators (1500 Watt)
      2-DC; 1-AC
 — Portable floodlights
 — Resuscitator
 — Carbon dioxide extinguishers
 - Dry powder extinguishers.

TEXAS CITY REFINING, INC.
    "A" foam powder
    "B" foam powder
    Single foam powder
    2W fire hose, NST
    1V4" firehose, NST
    2l/z" adjustable straight stream and fog nozzles.
    2V2" deluge guns (2-way)
    21/2"Wyes(l1/2X F/2)
    21/2/' straight stream nozzles
    Single powder foam hoppers
    Dry powder extinguishers (wheeled)
    Dry powder
    Spare nitrogen cylinders for 350 Ib. extinguisher
    Hydraulic (single powder) foam tower.
                                252
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Safety Equipment
   12-pair
    2
    2
    2
    2
Fire Equipment

  100-gallons
    1
Fire Equipment
      — Seiberling Neoprene Gloves — sizes 10 and 11
      - Asbestos suits
      — Air masks and blowers with hose
      — All-purpose gas masks
      - 30-minute self-contained air paks with
           extra cylinders.

TEXAS CITY TERMINAL RAILROAD
      - 3% foam liquid
      — IVi" mechanical foam nozzle with pick up tube.

   UNION CARBIDE COMPANY
  200 - 50 Ib. cans

 1,000'
 1,000'
     1

    4
    4
    4
     1
    3-pair
    2
     1
    6- 15 Ib.

 Safety Equipment

     6
    12-each
    12
    12 - each
         National "99" foam powder (alcohols,
           Ketones, etc.)
         2ti" fire hose, NST
         IW fire hose, NST
         Foam generator (1050 gpm capacity) for "99"
           powder foam
         2W straight stream nozzles
         2W adjustable straight stream and fog nozzles
         P/2" adjustable straight stream and fog nozzles
         Asbestos suit
         Asbestos gloves
         2V21' double female couplings, NST
         2V4" x IW x IW Siamese couplings, NST
         CO2 extinguishers
         All-service gas masks
         Spare all-service gas masks canisters
         Industrial gas masks (any type canister)
         Spare canisters for industrial gas masks for
           protection against any of the following
           gases or vapors:  acid gases, organic vapors
                                  253
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                           acid gases and organic vapors, ammonia or
                           chlorine
    6                  — Blankets
    6                  — Stretchers.

            TEXAS CITY CIVIL DEFENSE ORGANIZATION

Safety Equipment

    3                  — New oxygen breather masks (for use in toxic
                           chemical or toxic sewer emergencies).  This
                           type will run 1 hour to a can of chemical
                           breathing material.
   19                  — Cans of chemical breathing material which will
                           run 19 hours of actual use in the oxygen
                           breather masks.
   24                  — New gas masks, for use in heavy smoke areas, or
                           chemical areas which dissipate gases in the same
                           category as mustard gas or chemical warfare.
                           (Note also that 79 other masks of this type are
                           available within the city-at present assigned to
                           Fire and Police Departments)
   50                  — New cots for emergency use.
  140                  — New wool blankets, for use in rescue, fire,
                           exposure, explosion, and hurricane.
   34                  — Emergency medical kits for nerve gas victims only.
    1                  — Rescue truck, for use in high water emergencies,
                           etc., which is maintained through the auspices
                           of the Texas City Fire Department.

Services Available

             COMMUNITY PUBLIC SERVICE COMPANY

     Electrical assistance and emergency personnel for public service power
lines:

     Call WI 5-2386
                                   254

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              HOUSTON NATURAL GAS CORPORATION

                               and

                  HOUSTON PIPE LINE COMPANY

    Emergency personnel and equipment to care for failure in public service
gas lines:

            Call              Office               Home

        J.S.Sullivan           WI5-4471          WI5-9331
        E. B. Langford         WI 5-4471          WI 5-7317

               TEXAS CITY TERMINAL RAILROAD

    When it is feasible to move railroad equipment that is endangered in an
emergency, equipment and personnel will be made available to move the same
to a safer location.

    Call WI 5-5311
                              255
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                               APPENDIX V

         PROCEDURE OF MEDICAL COORDINATION COMMITTEE
       Chairman — Dr. R. E. Joyner — Union Carbide Chemicals Company

I.  PROCEDURE AT SCENE OF EMERGENCY

A.   If plant physician is employed:

     1.  The physician would follow his present standard operating procedure -
         survey the situation and make request for whatever medical service is
         required and would attach medical tags to victims.

B.   In cases where no plant physician is available, the person in authority should
     evaluate the disaster as follows:

     1.  How many persons are injured?
     2.  What type of injury?
     3.  Are they transportable? If yes — how many?
     4.  Medical personnel needed immediately at site?
     5.  What special medical supplies are needed at site?

     This information should be given to the physician normally called and also
     to the IMAS chairman or the chairman of the Medical Coordinating Com-
     mittee as quickly as possible.

II. FIRST AID STATIONS

A.   Plant first aid stations or dispensaries.

B.   Doctors' offices, clinics, or other necessary facilities depending on the nature
     and  scope of situation. This is to be determined  by  extent of situation by
     plant doctor and chairman of the Medical Coordinating Committee. In event
     aid  stations are  necessary after disaster for use by rescue workers or crews,
     etc., the choice  of the  aid station would be determined  by accessibility, size
     of rooms, availability of electricity, heat, water, and toilet facilities.
                                     256

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III. PROCEDURE FOR ALERTING HOSPITALS

    The chairman of the Medical Coordination Committee, his assistant, or the
plant  doctor will alert  the hospitals and give  information requested in No. 1
above.

IV. PROCEDURE FOR ALERTING AMBULANCES

    Upon receiving information requested in No. I, the hospitals, clinics, or the
chairman of the Medical Coordination  Committee will  direct ambulances as
required.

V. LISTING OF MEDICAL SUPPLIES AND THEIR LOCATIONS ARE AS
   FOLLOWS

    Medical Supply chests for established  First Aid  Field Stations under the
direction of or by a doctor are located as follows:

         American Oil Company                 4 Chests
         City of Texas City                      1 Chest
         Community Public Service Company      1 Chest
         Monsanto Chemical Company            2 Chests
         Marathon Oil Company                 1 Chest
         Smith-Douglass Company, Inc.           1 Chest
         Texas City Refining                     2 Chests
         Texas City Terminal Railway             1 Chest
         Wan Chang Corporation                 1 Chest
         Union Carbide Chemicals Company       4 Chests

1.   These chests will be retained in the locations listed and will be available for
    the use of any company or the Medical Committee of the IMAS.

2.   In the event chests  are used by any company or organization, it is under-
    stood that the user will  be responsible for the immediate replacement  of
    materials used and return  of the chests to the owner or owners.

3.   That the chests will be placed under constant observation within the specific
    locations and the use of supplies except in  cases of extreme emergency will
    be discouraged. These are not First Aid chests in any sense — but treatment
    chests for DOCTORS' USE.
                                257

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4.   That the contents of the chest be checked periodically (at least one time per
     year) and that chests be resealed, keeping a permanent record of the number
     of the seal used.

5.   Dextran in the chests has an indefinite life expectancy. Replacement should
     be  arranged  through the  plant  physician or the clinic, or the  physician
     handling the plant medical work. THIS IS IMPORTANT.

6.   Chests should be stored in a cool location, i.e., normal room  temperature.
                    CONTENTS OF MEDICAL CHESTS
       4 Pints
       1 Pint
       2 Units
       1 Dozen
       2 Dozen
       2x 100
       2x 100
       1 x 90
       2 x 2 oz.
       ITube
       1 Dozen
       1
       1 Package
       1 Dozen
       2
       6
       1
       1 Dozen
       1 Can
       1 Quart Jar
       2
       2
       1
Alcohol
Mercresin
Dextran
Ace Bandage — 4-inch
Yard square
4x4 Gauze sponge
2x2 Gauze sponge
2-inch roller gauze bandage
Sterile cotton
Adhesive tape — mixed cut
Sterile towels (packed in threes)
5Oml Vial sterile H2O
Sterile applicator sticks
Needles
5 ml syringe
2 ml Syringe
50 ml 1% Novocaine
Identification tags and pencils (red)
Stimulants — Coramine
  Caffeine
  Adrenalin

Suture material
Instruments — Thumb forceps
  Mouse tooth
  Hemostats (2)
  Needle holder
  Scissors

Rubber tubing —  15 inches
Dropper bottle pontacaine sol.
Bandage Scissors
Large ear bulb syringe
Flashlight
                                  258
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      MEDICAL SUPPLIES AVAILABLE IN THIS AREA

Anderson and Kolb         Texas City Hospital
Magliolo Clinic             Union Carbide Chemicals Co.
Danforth Clinic            American Oil Company
Beeler-Manske Clinic        Galveston County Memorial Hospital

          EMERGENCY EQUIPMENT AVAILABLE

1 - Portable water chlor-
   inating unit             Water Department
                         City of Texas City
                          259

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                             APPENDIX VI

                  PROCEDURES FOR IMASCHAIRMAN

  I.  Shall determine time and place meetings are to be called and held.

 II.  Shall coordinate  the work of the various sub-committees and distribute
     information and emergency lists to all IMAS member companies.

III.  Shall report to the Texas City Police Department Headquarters in case of
     emergency and coordinate activities incident thereto.

 IV.  Shall maintain liaison between the IMAS and other organizations which may
     function in case of emergency.
                                   260

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                             APPENDIX VII

      INTERSECTION MUTUAL AID ORGANIZATION'S RECIPROCAL
                           AID AGREEMENT
                         TEXAS GULF COAST
                             Adopted 4-25-61

PURPOSE:

    This agreement is intended to clarify method and procedures to employ in
obtaining industrial emergency aid by and from Mutual Aid Organizations listed
below:

                         Names of Organizations

       Channel Industries Mutual Aid                      Houston
       Texas City Industrial Mutual Aid System             Texas City
       Victoria-Calhoun Counties Mutual Aid Organization   Port Lavaca
       Corpus Christi Refinery-Terminal Fire Company       Corpus Christi

DEFINITIONS:

    The word "subscriber" as used, means a Mutual Aid Organization.

    The words "company"  or "member" mean an industry  belonging to, or
within the area of, any Mutual Aid Organization.

METHOD:

    The above subscribers agree that when an emergency occurs in an area of any
individual subscriber and the local supplies are inadequate to control that emer-
gency, the officer in charge of the affected subscriber, upon the authority of the
company or member in emergency,  may request fire  fighting or medical supplies
or equipment from another subscriber.

    Where applicable, the  officer in charge of the affected subscriber will inform
the State Civil Defense Coordinator, through the State Highway Patrol Captain at
the emergency area, of the requests made of other subscribers.

    Transportation of such equipment and supplies shall be from the location of
the lending subscriber to a point designated by the borrowing subscriber with the
express understanding that at no time shall transportation facilities and operators
be subjected to undue hazard by reason of location of destination.
                                  261

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 RESPONSIBILITY:

     A request for equipment and supplies originating from the officer in charge
 of the affected subscriber at the request of the member or company in emergency
 shall  be  the  binding agreement between the member or company lending re-
 quested assistance, to the extent that the receiving member of the  company shall
 make reimbursement either in cash  at current  prices or  in kind,  to the lending
 member or company for equipment and supplies received.

     In the implementation of the Agreement,  officers of Mutual  Aid Organiza-
 tions  whose names and telephone numbers  are listed below must understand that
 no call for assistance should be  originated without the request of a responsible
 official of the distressed company.  This entails  the probability  of being sub-
poenaed to testify concerning the authenticity of the request.

    Since reimbursement for any aid furnished is to be based upon supplies and
equipment received, Mutual  Aid officers should  advise  company  officials who
request aid that they should make inventory and  give receipts upon delivery.
                                 262

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LIST OF OFFICERS AUTHORIZED TO MAKE ASSISTANCE REQUESTS:

Channel Industries Mutual Aid:


       Name


L. S. Buenger, Chairman

W. T. Crouse, Vice-
 chairman & Specialist
T. C. Smith
 Communications Officer
Baytown
Humble Oil & Refining Co.
                                                                Telephone
City
Pasadena
Pasadena
Organization
Diamond Alkali Company
Rohm & Haas Company
Day
GR 9-2301
GR 9-2861
Night
GR 2-50 17
GR 2-6 150
                                                                                       583-7461
                                                                                                        583-1465


L. J. Grossheim
CIMA Specialist
Houston

Shell Oil Company

GR 9-23 II

WA6-S52I

Texas City Industrial Mutual Aid System:

10
W

C. L. Gilmore, Chairman
Carter Goodwin, Vice-
Chairman
K. E. A£«:, Vice-
Chairman
Texas City
Texas City
Texas City

Monsanto Chemical Company
Marathon Oil Company
Texas City Refining. Inc.

WI 5-4431
WI 5-2331
WI 5-4451

WI 5-6903
WE 5-2659
WI 5-2414

Victoria-Calhoun Counties Mutual Aid Organization:







>
1
D
cr
T.H. Kinney

1. E. Ebensberger

Corpus Christi Refinery — Terminal
L. K. Grove
G. W. Stephcnson
R. R. Reed
A. J. Besselman
H. E. Ammerman
Port Lavaca

Port Lavaca

Fire Company:
Corpus Christi
Corpus Christi
Corpus Christi
Corpus Christi
Corpus Christi
Union Carbide
Chemical Co.

Union Carbide
Chemical Co.


Great Southern
Chemical Company
Southwestern Oil &
Refining Company
Pontiac Refining Corp.
General American Tank
Storage Terminals
Corpus Christi Refinery
Terminal Fire Company
(Victoria)
HIS-6411
-Ext. 234
(Victoria)
HI 5-641 1
-Ext. 413

TU 3-9286
TU 4-8863
TU 2-8871
TU 4-5285
TU 3-8062
(Victoria)1
HI 3-2670

(Victoria)'
HI 3-7329


TE 5-0642
TE 5-8 157
TU 4-9563
TU 2-4786
UL 3-2 135

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      LIST OF SUPPLIES AVAILABLE FOR LOAN THROUGH THE
         INTERSECTIONAL MUTUAL AID ORGANIZATION'S
                   RECIPROCAL AGREEMENT

 I.   CHANNEL INDUSTRIES MUTUAL AID

               1,000 Ibs. - "A" foam powder
               1,000 Ibs. - "B" foam powder
              72,000 Ibs. - Single foam powder
              10,000 gal. - 3% foam liquid

              Dow Chemical Company

               5,000 Ibs. - "A" foam powder
               5,000 Ibs. - "B" foam powder

 II.   CORPUS CHRISTI TERMINAL FIRE COMPANY

              37,500 Ibs. - "A" chemical foam powder
              37,500 Ibs. - "B" chemical foam powder

III,   TEXAS CITY INDUSTRIAL MUTUAL AID SYSTEM

              American Oil Company

              29,000 Ibs. - "A" foam powder
              29,000 Ibs. - "B" foam powder

              Monsanto Chemical Company

               5,000 Ibs. - "A" foam powder
               5,000 Ibs. - "B" foam powder
                 500 gal. - 6% "National 99" (alcohol) liquid

              Marathon Oil Company

                 300 gal. - 3% Mechanical foam liquid

              Texas City Refining, Inc.

              16,750 Ibs. - "A" foam powder
              16,750 Ibs. - "B" foam powder
               2,000 Ibs. - Single  powder
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               Union Carbide Chemicals Company




               10,000 Ibs. - "National 99" (alcohol) powder




IV.    VICTORIA-CALHOUN COUNTIES MUTUAL AID ORGANIZATION




               Alcoa




                  40 gal. - Liquid foam chemical




               Union Carbide Chemicals Company




                 200 gal. - Unox wet penetrant foam liquid




               Du Pont




               12,500 Ibs. - "National 99" (alcohol) foam powder
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                            APPENDIX VIII

                     CO-OPERATIVE AGREEMENT

                    I.  PARTIES TO THE AGREEMENT

       (A)    Texas City Industrial Mutual Aid
                  F. A. Randall, Chairman
                  C. L. Gilmore, Alternate Chairman
                  J. M, Eason, Alternate Chairman
                  H. B. Williams, Secretary

       (B)    Gulf Area Water Works and Sewerage Association
                  Allan Wood, President
                  Guy Wilkinson, Secretary-Treasurer
                  H. D. Winkler, Program Chairman

II. PURPOSE

(A) The Texas City Industrial  Mutual  Aid System  agrees to serve only as
    communication liaison between the Gulf Area Water Works and Sewerage
    Association  and Texas  City  industries to transmit messages through  its
    system of communications within the  industrial complex, requesting assis-
    tance in the form  of heavy  hoisting equipment, gasoline power units,
    compressors, etc., during emergencies.

(B) The Gulf Area  Water Works and Sewerage Association,  because of the
    strategic locations of its  sources of potable water, can supply drinking water
    to Texas City industries during emergencies which cause contamination of
    normal supply sources.

III. UNDERSTANDING

    PARTIES TO THIS AGREEMENT  understand  that when emergency  re-
quests  are made by  authorized  officers of either party for assistance, diligent
effort will be exercised  toward compliance, however, this agreement does not
constitute a binding contract upon either party.
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 IV. REIMBURSEMENT

    PARTIES  TO  THIS AGREEMENT understand that reimbursement  for
equipment and/or service supplied shall be incumbent upon the individual mem-
ber requesting available assistance and the same shall be made promptly, directly
to the supplying member.

    Neither party to  this agreement shall be held liable for costs of equipment
and/or supplies delivered by request of any one of its members.

    This agreement may be cancelled by written notice from either party.

      Signed on this 6th day of September 1962
                              (SIGNED)       F.A. RANDALL
                              FOR PARTY A - Texas City Industrial
                                             Mutual Aid System
                              (SIGNED)	ALLAN WOOD	
                              FOR PARTY B - Gulf Area Water Works and
                                             Sewerage Association
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                 APPENDIX D

HANDLING OF CHEMICAL SPILLS IN PUBLIC WATERS
           Amoco Chemicals Corporation
               Texas City, Texas
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         HANDLING OF CHEMICAL SPILLS IN PUBLIC WATERS
                 PLANT ADMINISTRATIVE BULLETIN
Purpose
    To minimize contamination  of public waters by spills of chemicals in or
adjacent to public waters and to provide a reporting procedure to be followed by
plant supervisors and management in reporting such spills.

I.  Materials and Equipment

    A. The Texas City industrial complex has mutually provided certain materi-
als and equipment and  has call on  other materials and equipment to minimize
public  waters contamination by a spill of chemicals and/or hydrocarbons. The
equipment consists of:

         2450 feet  of slickbar oil boom (in sections) stored at the
         docks
         Kidde-Hi ex foam generator (stored in City Fire Station
         #1)

         Catamaran  equipped with polyurethane foam oil extrac-
         tion device (available from American Oil)

         Boats for placing slickbar,  etc. (Texas City Boatman's
         Association)

         Vacuum trucks to pick up spill (Malone and Weeren)

     B. The Company maintains the following equipment to contain and remove
small spills:

         200 feet of floating boom

         2 barrels dispersant

         25 bales of straw

         life jackets (available at docks)

         hand tools as needed from warehouse
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II. Procedure to Follow

     A. In case of a spill at any dock area or adjacent public waters, the person
discovering the spill shall notify the process supervisor in charge of the source unit
to initiate corrective action, if this is not already in progress. If he cannot locate
the unit supervisor quickly, he will contact the night superintendent or operations
supervisor, as appropriate.

     B. The  process supervisor  or  his  representative  shall notify  one of the
following, in the following preference order:

          1.   Superintendent, Operations

          2.   Operating Supervisor, Process II

          3.   Operating Supervisor, Process I

                Note:  The engineer responsible for Air and Water
        Conservation  at the plant  should be notified  as soon as
        possible.

     C. In the event of a spill of 50 gallons or more, the process supervisor should
also notify the Plant Manager, who will in turn notify the Vice President or senior
executive of the department.

     D. The supervisor in (B) who is contacted shall judge whether the spill is
significant enough to  warrant notifying the authorities.  If so, he  will call the
following as  soon as possible and advise them of the time, cause, location, type of
material, hazard involved, estimated general magnitude of the spill, environmental
conditions, and of the corrective measures being taken as well as people notified,
and name of vessel, if any involved.

     1.   Mr. R. Z. Fincham
          Parks & Wildlife Department
          Office - SO2-0732 (Galveston)
          Home - 534-3384 (Dickinson)

     2.   Mr. John  Latchford
          District Supervisor
          Texas Water Quality Board
          Office - 471-0384 (LaPorte)
           (Call during normal working hours)
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     3.   U.S. Coast Guard
         Officer of the Day
         Phone -713-763-1635

     4.   Company coordinator of Air and Water Conservation,
         Chicago office.

     E.  In addition, the person notified will immediately carry out the following
procedures:

         1.  Small Spill:
             If the location and magnitude of the spill is such that it
             can be  contained  and removed by Company personnel
             and available equipment  (including vacuum trucks)
             immediate steps should be taken to put this procedure
             into action.

         2.  Medium Spill:
             a.  Call  the Texas City Boatman's Association, giving
             details and securing assistance to contain the spill by use
             of the slick bar, if required.
             DAY — Texas City Boatman's Association
                     945-3496 (days only)
              NIGHTS, HOLIDAYS, WEEKENDS
                     - Troy Wright - 945-9336
                     - Angelo Amoto - 948-2375

              b.  If the spilled material  is readily flammable (below
              80° flash point such as benzene), the Kidde-Hi ex foam
              generator shall be secured from the Texas City Fire
              Department to be operated by Company personnel to
              cover the area of the spill with foam and minimize flash
              hazard.

              c.  Vacuum trucks shall be secured if this method of
              pickup is practical.

              d.  The catamaran should  be secured from American Oil
              if that be a more practical way of picking up the spilled
              material. This is  to be operated by the Boatman's Asso-
              ciation.
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         3.  Large Spill:
              In case of a spill or any loss beyond the capabilities of
              local facilities, where large  areas may suffer extensive
              contamination, the Vice President or senior executive
              will be notified immediately and will be responsible for
              directing the clean-up action.

     F.  Only as a last resort should a dispersant be used on the spill.

     G.  A  report  of any such spill will be prepared  by the  process supervisor
involved, describing the occurrence,  when discovered,  to whom reported, the
amount and type  of material lost, corrective measures taken, and disposition of
material if picked  up. This shall be sent to  the Plant Manager for information and
file.

III. Press Relations

     All relations with the  news media  will  be  handled locally by the Plant
Manager or his designee, or the Superintendent, Industrial Relations.

IV. Objective

     The objective at all times is to prevent or minimize contamination, and, also,
to prevent fires. The procedure  should be put into effect as soon  as possible.
Failure  to  notify the proper Federal authorities of harmful spills could result in a
penalty of $10,000 fine or a year's imprisonment, or both.
Revision 1 - June 1, 1970
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                        APPENDIX E


                   RESOLUTION NO. 68-65


PRESCRIBING REQUIREMENTS FOR TWENTY-ONE WASTE DISCHARGES

      BY CALIFORNIA AND HAWAIIAN SUGAR COMPANY INTO

  CARQUINEZ STRAIT NEAR CROCKETT, CONTRA COSTA COUNTY
                      State of California
               Regional Water Quality Control Board
               San Francisco Bay Region, California
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         WHEREAS THIS REGIONAL BOARD HAS CONSIDERED

REPORT ON WASTE DISCHARGE

   1. California and Hawaiian Sugar Company, called the discharger below, filed a
Report on Waste Discharge dated April 4, 1968, with this Regional Water Quality
Control Board pursuant to Section 13054 of the California Water Code.

   2. That report and other data describe these waste discharges as follows:

     Waste "A" is about 28 mgd of industrial waste only, consisting of barometric
     cooling water from evaporators used in sugar refining. It is not treated and is
     being discharged into Carquinez Strait at a point about four feet below mean
     low water and about 15 feet inshore from the outer edge of the discharger's
     wharf, via a 24-inch pipe identified herein as Outfall "A.'

     Waste "B" is  about 7 mgd of industrial waste only, consisting of closed
     cooling water from steam turbine heat exchanger.  It is not treated and is
     being discharged into Carquinez Strait at a point below mean low water and
     about 10 feet inshore from  the outer edge of the discharger's wharf, via a
     ten-inch pipe identified herein as Outfall "B."

     Waste "C" is about 4.4 mgd of industrial waste only,  consisting  of  baro-
     metric cooling water from evaporators used in sugar refining. It is not treated
     and is  being discharged into Carquinez  Strait at a point above mean low
     water and about  40 feet inshore from  the outer edge  of the discharger's
     wharf, via a 14-inch pipe identified herein as Outfall "C."

     Waste "D" is about 3 mgd of industrial waste only, consisting of barometric
     cooling water from evaporators used in  sugar refining and sodium carbonate
     cleaning chemical; sodium carbonate cleaning solution is added one day each
     14 days. It is not  treated  and is being discharged into Carquinez Strait at a
     point about 4 feet below mean low water and about  14 feet inshore from the
     outer edge of the discharger's wharf, via a  14-inch pipe  identified herein as
     Outfall "D."

     Waste "E" is about one  mgd of industrial  waste only,  consisting  of filter
     backwash  and process tank cleaning waste. It is not treated  and is  being
     discharged into Carquinez Strait at a point below mean low water and about
     15 feet inshore from the  outer edge of  the discharger's wharf,  via a 14-inch
     pipe identified herein as Outfall "E."
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Waste "F" is about 0.78 mgd of industrial waste only, consisting of waste
from bone char de-ashing column. It is not treated and is being discharged
into Carquinez Strait at a point above mean low  water and about 50 feet
inshore from the outer edge  of the discharger's wharf, via  a 10-inch  pipe
identified herein as Outfall "F.'

Waste "G" is about 0.5 mgd of industrial waste only, consisting of baro-
metric cooling water from evaporators used in sugar refining. It is not treated
and is being  discharged into Carquinez Strait at a point about 4  feet below
mean low water and  about  25 feet inshore from the outer edge  of the
discharger's wharf, via a 14-inch  pipe identified herein as Outfall "G."

Waste "H" is about 0.5 mgd of industrial waste only, consisting of closed
cooling water, boiler blow down, effluent from silica reactor, and effluent
from ion exchanger backwashing; ion exchanger backwashing operates one in
7 days. It is not treated  and is being discharged into Carquinez Strait  at a
point above mean low water and about 25 feet  inshore from the outer edge
of the discharger's wharf, via a 10-inch pipe identified herein as Outfall "H."

Waste "I" is  about  15,000 gpd intermittent industrial waste only, consisting
of rail car washings and steam rack waste. It is treated by a trap for oil and
grease removal and is being discharged into Carquinez Strait at a point above
mean low water and  about 30 feet inshore from the outer edge of the
discharger's wharf, via an 18-inch pipe identified herein as Outfall "I."

Waste "J" is about 6,000 gpd intermittent industrial waste only, consisting
of waste from washing trucks used for carrying processed  sugar. It is not
treated  and  is being discharged into  an  unnamed creek  west of the  dis-
charger's plant, via a ditch identified herein as Outfall "J"; the waste flows
about 250 feet to Carquinez Strait.

Waste "K" is about  13,000 gpd of  intermittent industrial waste only,
consisting of magnesium chloride cleaning solution and sulfamic acid.  It is
not treated and is being discharged into Carquinez Strait at a point above the
surface  and about 120 feet inshore from  the outer edge of the discharger's
wharf, via a 10-inch pipe identified herein as Outfall "K.'

Waste "L" is about 300 gpd  of industrial waste only, consisting of waste
containing traces of battery acid  and grease from discharger's garage. It is not
treated  and is being discharged  into Carquinez  Strait at a point above the
surface  and about 75  feet inshore from  the outer edge of the discharger's
wharf, via a 4-inch pipe identified herein as Outfall "L."
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Waste "M" is about 200 gpd of intermittent industrial waste only, consisting
of waste  from laboratory.  It is not treated and  is being discharged  into
Carquinez Strait at a point above the surface and about 50 feet inshore from
the outer edge of the discharger's wharf, via a 4-inch pipe identified herein as
Outfall "M.'

Waste "N" is about 150 gpd of intermittent industrial waste only, consisting
of filter press leaf cleaning with sulfamic acid, hydrochloric acid and hydro-
fluoric acid solution. It is not treated and is being discharged on alternate
days into Carquinez Strait  at a point above the surface and about 50 feet
inshore from  the outer edge of the discharger's  wharf, via a 3-inch  pipe
identified herein as Outfall "N.'

Waste "O" is industrial waste only, consisting of runoff from the discharger's
plant and storage area.  It  is not  treated  and  is being  discharged  into
Carquinez Strait at a point above the surface and about 30 feet inshore from
the outer edge of the discharger's wharf, via a 10-inch pipe identified herein
as Outfall "O."

Waste "P" is industrial waste only, consisting of runoff from the discharger's
plant and storage area.  It  is  not  treated and  is being discharged into
Carquinez Strait at a point above the surface and about 50 feet inshore from
the outer edge of the discharger's wharf, via an 8-inch pipe identified herein
as Outfall "P."

Waste  "Q" is less  than  100 gpd  of  intermittent industrial waste only,
consisting of roof runoff and soda tank washings. It is not treated and is
being discharged into Carquinez Strait at a point above the surface and about
 120 feet inshore from the outer edge of the discharger's wharf, via a 4-inch
pipe identified herein as Outfall "Q."

Waste  "R" is about 30,000 gallons each two weeks of intermittent industrial
waste only, consisting of sand filter backwash.  It is not treated  and is being
discharged one day each  14 days into Carquinez Strait at a point above the
surface and about 50 feet inshore  from the outer edge of the  discharger's
wharf, via a 10-inch pipe identified herein as Outfall "R."

Waste "S" is about 9,000 gpd of industrial waste only consisting of miscella-
 neous refinery washings. It is not treated and  is being  discharged into
 Carquinez Strait at a point above the surface and about 50 feet inshore from
 the outer edge of the discharger's wharf, via a 4-inch pipe identified herein as
 Outfall "S.'
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    Waste "T" is less than 100 gpd of intermittent industrial waste only con-
    sisting of wash-water from the wharf. It is not treated and is being discharged
    into Carquinez Strait at a point above the surface and about 15 feet inshore
    from the  outer edge of the  discharger's wharf, via a  4-inch pipe identified
    herein as Outfall "T."
    Waste "U" is about 200 pounds of raw sugar each five days, and is washed
    from unloading conveyors by immersing them in the Strait at the edge of the
    wharf.

CORRESPONDENCE

  The Regional Board has considered recommendations about this matter from:

     State Department of Fish and Game in its memorandum dated August
     15,1968

     State Department of Water Resources in its memorandum dated August
     6, 1968.

STAFF INVESTIGATION

   1.  These  wastes can affect  the following  present beneficial water uses in
Carquinez Strait and contiguous water bodies:

     Industrial cooling water supply year-round

     Water-skiing, pleasure boating, marinas, fishing, and hunting

     Fish and wildlife propagation and sustenance, and waterfowl and migra-
     tory birds habitat and resting

     Esthetic appeal.

   2. Land  within  1000 feet of the Outfall is used for residence, industry, and
 transportation.
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                 RESOLVED BY THIS REGIONAL BOARD

BOARD INTENT

   1. Protect public health as it may be affected by this waste discharge.

   2. Prevent  nuisance, as defined in Section 13005 of the California Water Code.

   3. Recognize waste disposal,  dispersion, and assimilation as economic benefi-
cial water uses which shall be regulated to protect other beneficial water uses.

   4. Protect  the beneficial water uses listed under "Staff Investigation," above.

WASTE DISCHARGE REQUIREMENTS - RECEIVING WATERS

   The discharge of these wastes shall not cause:

     1. Atmospheric odors recognizable as being of waste origin at any place
       outside the discharger's property.

     2. Unsightliness, odors, nor damage to any of the protected beneficial water
       uses resulting from:

          Floating, suspended,   or  deposited macroscopic particulate matter,
          foam, oil, or grease in waters of the State at any place; floating oil shall
          be  considered present  if in enough quantity to cause iridescence;

          Bottom deposits at any place outside the discharger's wharf;

          Aquatic growths at any place outside the discharger's wharf;

     3. Temperature,  turbidity  or apparent color beyond present natural back-
       ground  levels in waters of the State at any place outside the discharger's
       wharf.

     4. Waters of the State to exceed the following  limits of quality at any place
       outside the discharger's wharf:

                 pH                                7.0, minimum
                                                   8.5, maximum

                 Dissolved oxygen                   5.0 mg/1, minimum
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       Any one or more  substances in concentration that impair any of the
       protected beneficial water  uses or make aquatic life or wildlife unfit for
       consumption.

WASTE DISCHARGE REQUIREMENTS - WASTE STREAMS

  The wastes as discharged shall meet these quality limits at all times:

     1. In any grab sample:

         Settleable  matter in Wastes "A," "B," "C," "D," and "G" shall not
         exceed that in the discharger's intake water from Carquinez Strait, and
         settleable matter in the other wastes shall not exceed:

         The arithmetic average of any six or
         more samples collected on any day          0.5 ml/l/hr, maximum

         80% of all individual samples
         collected during maximum daily
         flow over any 30-day period               0.4 ml/1 /hr, maximum

         Any sample                               1.0 ml/1 /hr, maximum

     2. In any representative, 24-hour composite sample:

         5-day, 20°C BOD removal shall be sufficient to maintain the dissolved
         oxygen concentration prescribed above, but BOD removal is not re-
         quired to exceed:

         Average, during any 21 or more days        90%

         Not more than two consecutive daily
         determinations shall indicate BOD
         removals less than                        80%

     3. The  discharge  of Wastes  "D" and "E"  shall not cause the  waters of
       Carquinez Strait at any point outside the outer edge of the discharger's
       wharf to exceed the following limit of quality:

         Toxicity:  the concentration of the
         waste itself in the receiving waters           10 percent of the 96-hour
                                                 TLm concentration of
                                                 the waste as discharged
                                                 maximum;


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      The  discharger  may use the following  as an  optional alternate  to the
      toxicity requirement on Wastes "D" and "E" prescribed above:

        Toxicity: survival of test fishes
        in 96-hour bioassays of the wastes
        as discharged

           Any sample                            75%, minimum

           Average of any three or more
           consecutive samples collected
           during any 21 or more days              90%, minimum

    4. In any sample of Wastes "F," "H," "K," "M," "N," "Q," and "S."

        Toxicity: survival of test fishes
        in 96-hour bioassays of the wastes
        as discharged

           Any sample                            75%, minimum

           Average of any three or more
           consecutive samples collected
           during any 21 or more days              90%, minimum

OTHER REQUIREMENTS AND CONDITIONS

  1.  If the discharger elects the toxicity requirement limiting the concentrations
of Wastes "D" and "E" in the waters of Carquinez Strait, instead of the optional
toxicity requirement on  those wastes themselves, this Board requires him  to file a
written report on the dilution of those wastes which is achieved at the offshore
edge  of his wharf under the least  favorable tidal and/or current conditions. That
report shall  be based upon actual observations as part of  a  study for which
specifications shall be developed pursuant to the Board's Resolution No.398.

  2.  This Resolution includes items numbered 1, 2, 3, 4, 5, 6, 8, and 11 of the
attached "Requirements and Conditions" dated October 2, 1968.
                                       JEROME B. GILBERT
                                       Chairman

                                       December 18, 1968
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I, Fred H. Dierker, hereby certify that the foregoing is a true and correct copy of
Resolution No. 68-65 adopted by the Regional Water Quality Control Board of
Region No. 2 at its regular meeting on  December 18, 1968.
                           FRED H. DIERKER
                           Executive Officer
                           REGIONAL WATER QUALITY CONTROL
                           BOARD NO. 2
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                   APPENDIX F

INDUSTRIAL SPILLS AND HAZARD ALERT PROCEDURES
            Department of Natural Resources
              Division of Water Resources
                State of West Virginia
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            STAT« OP              DEPARTMENT OF NATURAL RESOURCES
                               DIVISION OF WATER RESOURCES
                    t?0» WASHINGTON ST.. CA«T  .  CHARLESTON \. W. VA.  .  TtU.! M5-44II. IXT. 2107

                               STATE WATER RESOURCES BOARD
                        INDUSTRIAL SPILLS AND HAZARD ALERTS
                                    SECTION  I
                           RECORD or  INDUSTRIAL REPORT
                          (APPLICABLE ANYWHERE  IN STATE)
NAME OF REPORTING COMPANY
    LOCATION (CITY	(RIVER BASIN)
    PERSON REPORTING  (NAME)                                 (TITLE)
DATE REPORTED                                  TIME REPORTED	
SPILL STARTED (DATE)	(TIME)_
SPILL STOPPED (DATE)
NAME OF MATERIAL SPILLED
QUANTITY OF UNDILUTED MATERIAL  LOST                                          POUNDS
    SOLUBILITY	SPECIFIC GRAVITY
RIVER CONCENTRATION
CAUSE OF SPILL	
ACTION TAKEN  TO STOP  SPILL AND PREVENT RECURRANCE
RIVER FLOW (CFS)	RIVER GAGE (LOCATION)
ESTIMATED  RIVER VELOCITY                                                MILES/HOUR
ESTIMATED  TIME  OF ARRIVAL AT (LOCATION)	WATER PUNT
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HAZARD ESTIMATE
    TOXICITY TO HUMANS
    ToxiciTV TO FISH
    TASTE AND OOOR
    NUISANCE
COMPANY'S RECOMMENDATION FOR SAFEGUARDING PUBLIC WATER SUPPLIES  (ir  SAFEGUARDS
    ARE NEEDED)	____»»_
COMPANY^ PLAN FOR MONITORING (SAMPLING &. ANALYSIS),  IF DEEMED NECESSARY
COMMENTS (INDICATE HERE IF SIGNIFICANCE OF SPILL WAS NOT GREAT ENOUGH TO  WARRANT
    NOTIFICATION OF OTHER AGENCIES).	___«_».	
STATE WATER RESOURCES DIVISION REPRESENTATIVE TAKING REPORT
                                   (SIGNATURE)
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            STATE OP              DEPARTMENT OF NATURAL RESOURCES
              WESTVIKGINIA         DIVISION OF WATER RESOURCES
                    170S WASHINGTON ST.. CAST  -  CHARLESTON I. W. VA.  .  TCL.: 343-4411. CXT 2107

                               STATE WATER RESOURCES BOARD
                       INDUSTRIAL SPILLS AND HAZARD ALERTS
                                    SECTION  II

                                      PART B

REPORT OF IMMEDIATE ACTION BY THE STATE WATER RESOURCES COMMISSION ON  INDUSTRIAL
SPILLS OCCURRING IN AREAS OUTSIDE THE KANAWHA RIVER.
  I.  CHECK RIVER CONCENTRATION
      QUANTITY OF MATERIAL SPILLED                                           POUNDS
      GAGE HEIGHT                      FEET AT  (LOCATION)
      (INFORMATION FROM WHATEVER SOURCE AVAILABLE;  I.E.,  LOCKMASTER, USGS,
       THE REPORTING  INDUSTRY OR OTHER SOURCE)
      A.  RlVER FLOW  FROM RATING TABLE, REPORTING  INDUSTRY  OR FROM U.S.G.S.,
          	CFS
      B.  RIVER FLOW  IN POUNDS PER  HOUR
              (3,600  x  62.H)  x   (A)	«	LB/HR
      C.  MATERIAL SPILLED  IN POUNDS  PER  HOUR
              QUANTITY SPILLED       	LB
                                                                              LB/HR
              DURATION  OF SPILL                     HRS
      0.  RIVER CONCENTRATION
               (C)   	LB/HR
              _-ZIZZZIZZZ=II_-.  x  1,000,000  «  	PPM
               (B)	             LB/HR
  II.  ESTIMATED ARRIVAL TIME AT  NEAREST WATER PLANT
      A.  RlVER FLOW  FROM I. A.  ABOVE  »                                       CFS
          MILE POINT  OF SPILL  =                                             MILES
          SUBTRACT MILE POINT  OF
               NEAREST WATER PLANT  a                                         MILES
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      B.   MILES BETWEEN SPILL AND WATER PLANT  at                             MILES

      C.   IF RIVER VELOCITY DATA ARE AVAILABLE FIND AVERAGE VELOCITY IN RIVER

              REACH                                                  MPH/1,000 CFS
      0.   TlHE REQUIRED TO TRAVEL TO WATER PLANT
              1,000  X  (B)	
              (C)	x (A)	        	
III.   NOTIFICATION
      A.   CASE I  (FISH KILL)
          I.   NOTIFY FISH DIVISION IF FISH KILL DEVELOPS (EXT. 2786); OR LAW
               ENFORCEMENT DIVISION (EXT. 278*1)
              TIME NOTiFiED                  ,  DATE NOTIFIED
              CHECK NAME OF PERSON NOTIFIED:
              ( )  ED KINNEY,  RES.  Dl 6-2256
              ( )  RAY CLEMENS,  RES. WA 5-7907
              ( )  ROBERT LEESON, RES. Wl  9-22^7
              ( )  ALLEN WOODBURN  (Do NOT  CALL RESIDENCE)
          2.   IF  INTERSTATE PROBLEM IN OHIO BASIN NOTIFY ORSANCO (CINCINNATI,
               GARFIELD 1-1151)
              TIME NOTIFIED                  ,  DATE NOTIFIED
              PERSON NOTIFIED
                                                                               HRS
              IN  POTOMAC  BASIN,  NOTIFY POTOMAC RIVER COMMISSION (WASHINGTON, D.C.,
               EXECUTIVE 3-1978 OR 3-1979)
             TIME  NOTIFIED                   , DATE NOTIFIED
             PERSON  NOTIFIED
         3.   IF  FISH  KILL  DEVELOPS NOTIFY SANITARY ENGINEERING DIVISION
             TIME  NOTIFIED	f  DATE NOTIFIED
             CHECK NAME  OF PERSON  NOTIFIED:
             ( ) JOHN MILLAR,  EXT. 2970
             ( ) G. 0. FORTNEY,  EXT.  2981
             ( ) RAY  LYON,  EXT.  2983
                                      290

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B.  CASE II (TASTE & ODOR ONLY)
    I.  NOTIFY SANITARY ENGINEERING DIVISION
        TIME NOTIFIED                 , DATE NOTiTIED
        CHECK NAME OF PERSON NOTIFIED:
        ( ) JOHN MILLAR, EXT. 2970
        ( ) G. 0. FORTNEY, EXT. 3981
        ( ) RAY LYON, EXT. 2983
    2.  IF  INTERSTATE PROBLEM
        IN OHIO BASIN, NOTIFY ORSANCO (CINCINNATI, GARFIELD  l-l
        TIME NOTIFIED                   , DATE NOTIFIED
        PERSON NOTIFIED
         IN POTOMAC BASIN, NOTIFY POTOMAC  RIVER  COMMISSION  (WASHINGTON,  D.C.,
          EXECUTIVE 3-I978)(OR 3-1979)
        TIME NOTIFIED	, DATE  NOTIFIED
        PERSON NOTIFIED
C.  CASE  III (TOXICITY)
     I.   IMMEDIATELY NOTIFY SANITARY  ENGINEERING DIVISION
        TIME NOTIFIED                   ,  DATE NOTIFIED
        CHECK NAME OF  PERSON  NOTIFIED
         (  ) JOHN MILLAR; OFF:  EXT 2970,  RES:  Dl 2-3060
         (  ) G. 0. FORTNEYJ OFF:  EXT  2981, RES:  WA 5-lUl8
         (  ) RAY LYON;  OFF: EXT 2983,  RES: PA  7-3635
     2.   IF INTERSTATE  PROBLEM
         IN OHIO BASIN,  NOTIFY ORSANCO (CINCINNATI, GARFIELD I-1150
        TIME NOTIFIED	,  DATE NOTIFIED____	
        PERSON NOTIFIED
         IN POTOMAC  BASIN,  NOTIFY  POTOMAC RIVER COMMISSION (WASHINGTON, D.C.,
          EXECUTIVE 3-1978 OR  3-1979)
        TIME  NOTIFIED                   , DATE NOTIFIED
        PERSON  NOTiFiED
                                291

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     0.  CASE IV (NUISANCE)

         PERSON NOTIFIED                        DEPARTMENT
         TIME NOTIFIED	, DATE NOTIFIED
         3.   REMARKS,  INCLUDING SUMMARY OF ACTION TAKEN BY SANITARY ENGINEERING

             DIVISION
IV.  ATTACH  ADDITIONAL REMARKS,  REPORT OR FOLLOW-UP ACTION, MEMOS, CORRESPOND*
    ENCEj FISH  KILL  REPORTS,  LABORATORY DATA AND OTHER INFORMATION.

                                        SIGNATURES:
                                   292

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