THE CHEMICAL SAFETY AUDIT PROGRAM:
A STATUS REPORT
APPENDIX C: CHEMICAL SAFETY AUDIT REPORT PROFILES
Prepared for
Chemical Emergency Preparedness and Prevention Office
U.S. Environmental Protection Agency
Washington, D.C.
Prepared by:
ICF Incorporated
December 1990
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
PoLysar Incorporated, Plastic Division
Facility Location:
Indian Orchard, MA, Region I
Date(s) Audit Conducted:
March 22, 1989
Description of Facility:
SIC Code(s):
Location:
Products manufactured,
produced, or distributed:
Proximity to
sensitive population:
Reason for Facility Selection:
ARIP Reports:
SIC 2821 - Plastic materials, synthetic
resins, and non-vulcanizable elastomers
Residential area in the Chicopee River
Valley, near Springfield in western
Massachusetts
Rubber polystyrene and polystyrene
pellets
There are approximately 180 residential
dwellings within one mile of the facility
to the east On the north side of the
facility are the Chicopee River and the
Massachusetts Turnpike
The facility was chosen because it
utilizes high-hazard chemicals (e.g.,
styrene) which present a risk of releases
with off-site consequences. It is located
in a highly populated area and situated on
the banks of the Chicopee River. In
addition, there was a major accidental
release of approximately 10,000 pounds of
styrene in 1988.
None prior to audit.
Focus of Audit:
Hazardous Substance(s)
Examined:
Styrene monomer (inhibited)
t-butyl peroxyacetate
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Physical Area(s) Examined at the Facility:
Process Area(s)
• Polystyrene manufacture
Feed stock of styrene, rubber, and other additives are processed with a
combination of heat, time, and pressure to produce continuous strands of
polystyrene which are chopped into pellet lengths for storage and
shipment. The chemicals are pumped into a closed reactor for
processing. No further processing or manufacturing is performed at this
facility.
Summary of Audit Findings and Recommendations:
Conclusions:
Process Information
• There is no temperature monitoring and limited pressure monitoring
for Reactors 1 and 2. There is also no water contamination
monitoring in the reflex condensers.
• The calibration of the controls and detectors is not regularly
conducted to ensure accurate monitoring.
• Much of the equipment observed at the plant appeared to be old and
corroding.
• The reactor monitoring system does not monitor all aspects of
plant operations
Chemical Accident Prevention
• The facility does not have a formal preventative maintenance
program.
• The facility does not have formal tag out procedures.
• Outside consultants and Internal Company Audit Teams conduct
safety audits annually.
Facility Emergency Preparedness and Planning Activities
• Although there are continuous safety and process operations
training courses held for employees and supervisors, the workers
at Polysar are not trained to deal with a chemical accident at the
plant. During the 1988 accident, the workers did not know how to
respond properly.
• The plant holds emergency drills on a regular basis.
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Community and Facility Emergency Response Planning Activities
• Plant tours are conducted for the local fire department.
• Polysar has developed an emergency plan to supplement the City of
Springfield's Integrated Emergency Response Plan for hazardous
materials incidents
• Polysar has a representative on the Local Emergency Planning
Committee
Recommendations:
Process Information
• Additional temperature and pressure monitors should be installed
in Reactors 1 and 2 for backup measurements and the establishment
of temperature profiles should be considered. An increase in the
amount of water contamination monitoring in the reflex condensers
should also be considered.
• Increasing calibration frequency should be considered for controls
and detectors to ensure that measurements critical to process
safety are monitored accurately. In addition, basic
meteorological monitoring equipment and recorders should be
installed on site.
• A backup utility study should be considered for the following
process parameters steam supply, nitrogen blanketing, and
reactor material pumps
Chemical Accident Prevention
• Modernization and upgrades of the process controls and control
rooms in hazardous material service should be considered. In
addition, procedures to ensure follow-up action on computer
generated out-of- tolerance reports should be improved.
• Corrosion allowance testing should be upgraded for equipment in
hazardous materials service
• Formalized equipment parameter monitoring, prevention practices,
training, and equipment replacement procedures are helpful in
minimizing the potential for future accidents.
• Improvements in tag out procedures need to be considered to ensure
that equipment, is not operated without proper safeguards. In
addition the preventative maintenance program should be upgraded
and formalized. This may include the replacement of condensers
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Facility Emergency Preparedness and Planning Activities
• Process specific emergency response team training should be
improved to enhance accidental release mitigation techniques
Community and Facility Emergency Response Planning Activities
• The facility should consider assisting the LEPC in conducting
vulnerability analyses for the chemicals used at Polysar.
Audit Team Member Composition:
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Ray DiNardo
EPA - Region I
Coordinator
Environmental Engineering
Norm Beddows
EPA - Region I
Chemical Systems
Toxicology
Ken Ferber
EPA - Region I
Mechanical Systems
Environmental Engineering
Follow-up Activities:
By the Facility:
• N/A
By the Regional Office:
• N/A
By State and Local Authorities:
N/A
Regional Contact:
Ken Ferber
(617) 860-4382
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
W.R. Grace & Co , Organic Chemicals
Division
Facility Location.
Nashua, New Hampshire, Region I
Date(s) Audit Conducted:
April 10-14, 1989
Description of Facility:
SIC Code(s):
Location:
Products manufactured,
produced, or distributed:
Proximity to
sensitive populations:
SIC 2869 - Industrial Organic Chemicals
not elsewhere classified
Urban area of Nashua The plant is
bordered on che east by the Merrimack
River.
A variety of chemical products, including
commercial industrial products such as
caustic soda, formaldehyde, amines, and
sulfuric and hydrocyanic acids, most of
which are based on hydrocyanic acid (HCN)
chemistry
There is an average buffer zone of 387
feet to the densely populated areas.
Across the Merrimack River lies a golf
course and a multi-family residential
area. A 5,000 home residential housing
complex is proposed to be constructed
across che river. On the western edge,
the facility is bound by commercial
development (including a motel, a day-care
center, and three restaurants), and by
additional commercial property on the
north. The total population within a 5-
mile radius is approximately 108,000.
Reason for Facility Selection:
The facility was chosen because it is
located in a highly populated area and
produces several high-hazard chemicals
which present the risk of an airborne
release with significant off-site
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ARIP Reports:
consequences There were several
accidental releases reported for the
period, 1987-1988.
3/15/88 hydrocyanic acid release; 8/5/88
hydrochloric acid release.
Focus of Audit:
Hazardous Substance(s)
Examined:
Hydrogen Cyanide (HCN)
Anhydrous Ammonia
Phosphorous Trichloride (PC13)
Sodium Cyanide (NaCN)
Physical Area(s) Examined at the Facility:
Storage and Handling
• Storage Systems
• Shipping/Receiving
• Material Transfer
The HCN is stored in two fully insulated 30,000 gallon storage tanks
which have no bottom outlet, are fully insulated, and are within a
partially below-grade dike enclosure. These tanks are equipped with a
scrubbing system which operates from an electric driven pump without
emergency power backup.
The PC13 is stored in a 6,000 gallon tank situated over a concrete pit
and housed in a diked building with chain link fence walls. An empty
tank is situated next to the full one for use as a transfer vessel when
necessary.
The high strength ammonia is held in two 30,000 gallon pressure tanks
equipped with relief valves, and the low strength ammonia is kept within
several atmospheric pressure tanks which are not diked for spill
containment.
A new tank and dike system is currently being built to hold the NaCN.
The chemicals are brought on-site either by tanker trucks or by rail and
then pumped into their storage tanks.
The HCN is transferred in stainless steel piping from the storage tanks
to the individual processes by submerged pumps in the storage tanks.
There is a newly installed circulating loop HCN feed system which
conveys HCN to individual reactors within the facility. Other chemical
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transfers are accomplished by similar mechanical pumps or gravity-driven
feed pipes
Process Area ("si
• Ketone Amino Nitrile (KAN) Process
• Iminodiacetic Acid (IDA) Area
• Nicrilotriacecic Acid (NTA) Area
HCN is supplied through a take-off line from the HCN loop originating at
the B HCN storage tank. After the HCN has been charged to the reactor,
the HCN line is blown back with nitrogen. This line is sloped for
proper drainage preventing the collection of product in the line The
reactor uses an agitator to mix chemicals The reactor is on load cells
so that chemical additions can be measured and verified by weight.
This process takes place inside a building to minimize danger that the
solution will freeze, this also allows the possibility of vapor
accumulation. The building has a ventilation system and HCN detection
devices. Product storage tanks are outside, and are not diked.
The NTA area has a HCN feed system that minimizes the quantity of HCN
introduced to the NTA process This process takes place inside of a
building. A pipeline supplies HCN from the storage tank to the reactor
and then there are both a wash back with water and a purge of the HCN
line back to the tank with nitrogen. This feed-wash-purge system
eliminates vapors.
Summary of Audit Findings and Recommendations:
Conclusions:
Process Information
• Grace has a recently improved system for the storage and transfer
of HCN The total HCN storage capacity at the facility has been
reduced from over 100,000 gallons to a present capacity of 60,000
gallons, divided equally among two storage tanks. When this new
system was constructed, Grace installed mew piping, pumps, and
tank monitoring instrumentation.
• In the HCN area, leakage has occurred near a cell flange at the
bottom of a holding tank. The volume of the tank suggests the
potential for a much larger spill in the event of flange leakage
• The HCN area has water monitors designed to remove HCN vapor from
the air in the event of an accident. The monitors do not reach
all areas in which a spill may occur, and there are not backup
systems in the event that the monitors do not fully clean the air
• The number of HCN ambient monitoring devices in the IDA and NTA
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buildings may not provide coverage considering the amount of the
chemical Grace handles.
The hazardous material railcar unloading area is in close
proximity to the Merrimack River and it was noticed that railcars
were not always secured prior to a materials transfer operation
The railcar unloading area is poorly lit. The signs in and around
the area may not be numerous enough to help prevent unauthorized
entry or mishandling of the unloading equipment.
Trucks unloading PC13 are not completely secured during transfer
operations.
The PC13 storage tank is in a diked area that is not fully
enclosed, and thus, there is potential for precipitation and water
accumulation within the diked area. Also, scrubber water can
accumulate in the diked area. When PC13 comes into contact with
moisture, hydrogen chlorine gas is produced.
The NaCN tank is not diked, and the tank is surrounded by a low
curb Any leakage or overflow would be directed to a drainage
system which was blocked with soil.
Neither the high nor low strength ammonia tanks are diked for
spill containment. Grace is planning to dike the low-strength
tank.
The process operations at the facility are supplied by only one
main 34 5 KV power service line. Provisions have not been made
for emergency backup power for critical process equipment.
According to discussions with several NTA operators and a
review of the data, the NTA control room uses outdated,
miscalibraced, and sometimes inaccurate instruments which
are not always trusted by operators.
The NTA process alarms systems are considered unreliable by
operators interviewed and are ignored in some situations.
Reactor No. 5 does not have a continuous pressure monitoring
device or backup valves.
Several pipes at Reactor No. 5 were mislabeled.
The control room at Reactor No. 5 is too small to allow for
additional safety controls and proper operation.
Instruments in the control room do not provide information or
control for all operating parameters of the reactor.
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• The continuous air pollution monitoring equipment for the lime
waste treatment, and fluidized bed incinerator exhibited clogged
scrubbers and malfunctioning instruments
• According to Grace memoranda on the subject, there appear to be
approximately 1,000 feet of pipe insulation known to contain
asbestos that should be removed because of the potential for
exposure Approximately 550 feet of ACM insulation has already
been removed and disposed of properly
• Drum labeling was deficient, including drums missing labels
entirely, in the hazardous waste drum storage area and an
unknown number of waste drums were buried at the northern
end of the facility.
• Pipes for PC13 were poorly marked or unmarked
Chemical Accident Prevention
• Grace currently uses ultrasound inspection to check storage tanks
for decay or deposit.
• The plantwide sewer system is divided into separate north and
south systems of surface drains and underground sewers, both of
which feed the wastewater treatment facility on-site. Stormwater
from parking lots discharges directly into Spit Brook
• Operating and monitoring records for the on-site wastewater
treatment plant indicate potential excesses of the permit
conditions in 1987 and 1988.
• On August 5, 1988, Grace accidently released approximately
108 pounds of HC1 into the atmosphere According to Grace,
this incident was caused by equipment failure and human
error. The accident was exacerbated, according to Grace,
because of a lack of a coherent information-sharing effort
on the part of different plant personnel and the failure to
follow a standard procedure to identify the problem.
• Hazards analysis techniques are not routinely used to predict
likely hazards or prepare for them.
• The operating maintenance policy at Grace is to repair equipment
when it fails rather than on a regular schedule.
• Lock-out and tag-out standard procedures for out-of-service
equipment are not followed consistently. Auditors observed
equipment which was inoperable, out of service, and not containing
a proper lockout device.
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Accident Release Incident Investigation
• According to information provided by Grace, Leaking flanges
resulte'd in accidental releases of both NaCN and HCN.
• Existing accident investigation techniques do not fully assess
system reliability, corrective technology, or the probability of
an incident reoccurring.
Facility Emergency Preparedness and Planning Activities
• The plant has two distinctly separate alarm systems. One is
dedicated to fire incidents, while the other is to be used for
non-fire emergencies. There are color coded alarm pull stations
strategically located throughout the facility. The alarm system
and emergency equipment are tested and/or inspected on a weekly
basis
• The sound alarm is not fully audible in the KAN process area.
• A "contingency plan" has been developed which covers
responses by the two designated facility emergency
response teams to any type of emergency which might
occur on the plant.
• Firefighting water pumps use city water and do not have access to
river water. A failure in city water supply would leave the pumps
dry.
Community and Facility Emergency Response Planning Activities
• Grace does not conduct regular emergency exercises with local
emergency responders or the community.
Recommendations:
Process Information
• Grace should study the possibility of eliminating all but the most
vital flange systems in the HCN process and replacing the jointed
flanges with wielded seams. Critical holding tank and transfer
systems should use the circulating loop HCN and the three valve
option of feed, wash, and purge to decrease the chances of
accidental flange leakage.
• Additional HCN ambient monitoring devices should be installed.
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Grace needs to reevaluate Che size and locations of emergency and
pressure reLief vents and assess whether or not relief devices
should be vented to a flare, other air pollution control
equipment, or secondary containment. Currently, relief vents go
to open air
A diked pad with a collection sump should be installed at both
railcar unloading stations to minimize the environmental and
safety impact from a catastrophic railcar failure or release
during bulk unloading operations. In addition, wheel chocks muse
be used to prevent movement of hazardous materials railcars during
unloading operations
More warning lights and signs are needed during railcar unloading
Unloading trucks must be firmly secured when hoses are being
connected and product is being transferred.
To minimize the potential that the PC13 will come in contact with
moisture, Grace should consider fully enclosing the storage area
All scrubber overflow and standing water should flow outside the
PC13 storage area and the scrubber water drain should be covered
The NaCN storage tanks should be diked to avoid run-off and the
potential for environmental contamination from an accidental spill
or release.
The facility should consider installing a dike around the
high strength ammonia tanks. Grace should complete its
current plan to dike the low-strength tank.
Backup power for the HCN scrubbing system must be assured and the
proper level and percent of caustic solutions should be available
in the scrubber ac all times
Grace should initiate a study to determine what backup utilities
are needed in the event of a power failure or the loss of a
critical utility for hazardous and extremely hazardous materials
process lines.
The amount of chemicals present at the facility demands a
higher number of accidental gas release monitors than Grace
currently has. Therefore, a study should be conducted to
assess the adequacy of the number and locations of the
continuous monitors to detect accidental gas releases.
At Reactor No. 5. the site of the August 5, 1988, HC1
release, a permanently mounted pressure monitoring device
with continuous recordings should be installed on the
reactor, along with interlocks and backup valves.
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• Ac Reactor No. 5, pipes need to be labeled more accurately
• The Reactor No. 5 control room should be bigger and equipped with
controls, check lists for critical operation parameters, and
gauges for agitator operation.
• Grace should undertake a comprehensive asbestos survey and
initiate immediate removal of all friable material in remaining
affected areas.
• There is need for improved drum inspection and leak detection
procedures. In addition, the waste drums buried at the northern
end of the facility warrant prompt removal.
• Labeling of tanks and color-coding of hazardous materials process
piping should be improved in the PC13 storage area.
Chemical Accident Prevention
• While Grace currently uses ultrasound inspection to check
tanks, they should also undertake periodic visual inspection
of tank interiors to check for solids build-up, corrosion,
pitting, and impingement erosion to prevent tank leakage or
decay which may not appear on ultrasound.
• Due to potential groundwater and soil contamination conditions,
the plant-wide sewer system for the on-site wastewater treatment
plant should be reviewed and evaluated.
• Formal hazards analysis techniques, such as hazards and
operability studies, failure modes, effects, and criticality
analysis muse be routinely used to identify existing plant hazards
before an accident occurs.
• The preventative maintenance program for equipment used with
hazardous chemicals should be upgraded to include routine
replacement of critical parts based on a history of failure,
rather than on observation of actual signs of failure.
• Lock-out and tag-out programs for out-of-service equipment need to
be improved to prevent human error or equipment failure that could
lead Co accidental release.
• An in-depth hazard review of the No. 5 Reactor and its operations
should be performed. The major focus of the review should be the
potential for water to accidentally enter and mix with PC13.
• The facility should consider conducting a hazard analysis of
the storage systems in general.
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Accidenc Release Incident Investigation
• Accident investigation techniques at Grace must be improved and
formalized using a systems approach to minimize the potential of
an accident reoccurring or a failure in other parts of the hazards
material line
Facility Emergency Preparedness and Planning Activities
• The emergency warning and public address systems need to be made
more audible in all areas of the plant.
• In addition to the existing fire prevention system, Grace should
consider installing a pumping system to enable equipment to pump
water from the river to fight a major fire, and deluge systems in
high risk areas.
• Grace should consider installing a water gun with a fog
nozzle at the HCN storage tanks and a spark ignition system
which could ignite HCN during a catastrophic failure.
Stabilizer acid should be available in case of emergency.
Community and Facility Emergency Response Planning Activities
• Grace needs to work more closely with local emergency responders
to increase knowledge, capabilities, equipment, and coordination
An effective way to coordinate more closely with local emergency
responders is by conducting regular emergency exercises
Audit Team Member Composition:
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Ray DiNardo, Team Coordinator
EPA - Region 1
Coordinator
Environmental Engineering
Ken Ferber, Assistant Team Coordinator
EPA/AARP - Region 1
General processes'
Environmental Engineering
Paul O'Connell, Safety Advisor
OSHA - Region 1
Safety
Industrial Hygiene
Fred Malaby, Industrial Hygiene
OSHA - Region 1
Employee Safety
Toxicology
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Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Jeff Goodman, Environmental Control/
Planning Consultant
ICF Technology, Inc
RCRA
RCRA
William Jenks
Consultant
Chemical Safety/Processes
Cyanides
Tom Walsh, Technical Assistance Team
Member
Ecology and Environment
Response Procedures/Containment
Chemical Engineering
Mark Dahm, Technical Assistance Team
Member
Ecology and Environment
Chemical Systems
Chemical Engineer
Nermin Ahmad, Technical Assistance Team
Member
Ecology and Environment
Technical Information
Writing
Follow-up Activities:
By the Facility:
• N/A
By the Regional Office:
• N/A
By State and Local Authorities:
• Fire Marshall conducted safety inspection.
Regional Contact:
Ken Ferber
(617) 860-4832
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name,
Fall River Waste Water Treatment Plant
Facility Location:
Fall River, Massachusetts, Region I
Date(s) Audit Conducted:
August 3, 1989
Description of Facility:
SIC Code(s)
Location:
Products manufactured,
produced, or distributed:
Proximity to
sensitive populations:
SIC 9511 - Air and water resource and
solid waste management
Residential area of Fall River, on the
shore of Mount Hope Bay, near Providence,
Rhode Island
The facility treats sewage and also
accepts septage delivered by tank trucks
There are residences on the property line
to the north and east, as well as a large
apartment complex to the east (across Bay
Street). The population within a 3/4 mile
radius is 4,781. The area includes five
schools.
Reason for Facility Selection:
ARIP Reports:
The facility was chosen because of an
October 18, 1988, fire in a fiberglass
reinforced tank which resulted in the
release of sodium hydroxide and the
evacuation of forty local residents, and
its location within a residential area
10/18/88 sodium hydroxide release
(questionnaire completed 7/7/89)
Focus of Audit:
Hazardous Substance(s)
Examined:
Caustic (sodium hydroxide)
Chlorine
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Physical Area(s) Examined at the Facility:
Storage and Handling
• Storage-Systems
• Shipping/Receiving
The sodium hydroxide is not stored on the facility. It is only
delivered to the plant when regeneration procedures for pollution
control equipment are being carried out. The liquid sodium hydroxide is
brought to the facility in trucks and transported by pump into the
process areas.
The chlorine is received by truck in steel containers each containing
2,000 pounds of liquid chlorine. Within the facility the cylinders are
moved by a 5-ton monorail crane.
Process Area(s)
The basic sequence of operations is as follows: grit removal, primary
clarification, aeration with pure oxygen, secondary clarification,
chlorination of effluent prior to discharge to Mount Hope Bay,
dewatering and incineration of sludge, and operation of an exhaust air
scrubbing system.
During the exhaust process, noxious and odorous gases are treated with a
sodium hydroxide spray and then flow through fiberglass ducts, each of
which contains a damper, to a scrubbing system. Each scrubber is a
fiberglass tank which has a 10,000 gallon capacity. Air which flows
into the tanks passes through three layers of activated carbon which
remove organic gases. Every 1.5 years the carbon must be regenerated by
subjecting it to a cleaning process. This process requires complete
submergence and soaking of each scrubber unit in sodium hydroxide The
Calgon Carbon Corporation manufactures the Calgon Carbon Type IV P
Granular Activate Carbon and provides recommended regeneration
procedures.
Summary of Audit Findings and Recommendations:
Conclusions:
Process Information
• Carbon bed temperatures are not consistently monitored or
recorded.
• Chlorine levels are not continuously monitored and recorded in the
chlorine storage area and no monitoring equipment is present at
the plant
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Chemical Accidenc Prevention
• Carbon regeneration procedures are often modified without full
clarifi-cation from Calgon or appropriate training for the workers
• The facility does not follow recommended regeneration procedures
provided by the manufacturer, Calgon; this may have caused the
fire of October 18, 1988
• There no warning system in the event that the carbon beds
overheat.
• The scrubber units are not diked, which increases the possibility
of an uncontained chemical release
Facility Emergency Preparedness and Planning Activities
• Workers who participate in the chlorination of effluent processes
wear ordinary clothing and do not have access to totally
encapsulated suits. In the event of a chlorine release, it
appears that the operators' equipment would prohibit effective
response.
Community and Facility Emergency Response Planning Activities
• The plant does not have a response plan to be used in the event of
a major chlorine leak or spill.
Recommendations:
Process Information
• The facility should consider installing temperature sensors in
each carbon bed to warn of overheating and to establish a record
of temperatures in the bed.
• Chlorine levels should be continuously monitored and recorded. In
addition, wind monitoring equipment should be installed in the
immediate area of the chlorine storage tanks to enable responders
to track Che path of a potential release more accurately.
Chemical Accident Prevention
• Regenerations of carbon beds should be scheduled to minimize the
time that a carbon bed remains in a drained condition and any
changes in the regeneration procedure should be accompanied by
-- Written documentation from the scrubber units
manufacturer and carbon adsorbent suppliers.
• - An assessment of hazards associated with changed
procedures.
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-- Training of all personnel who will use changed
procedures.
• The facility should consider developing detailed operating
procedures for the operation and regeneration of the scrubbers
These procedures should be carried out under supervision of
knowledgeable personnel.
• All plant personnel should receive training for response to a
chlorine release.
• The scrubbers should be mounted on a concrete pad surrounded by a
dike sufficient to hold the contents of both scrubbers if
completely full. This would prevent the possibility of an
uncontaminated chemical release.
Facility Emergency Preparedness and Planning Activities
• Proper personal protective equipment should be available and
located throughout the facility
Community and Facility Response Planning Activities
• A response plan should be developed for use in the event of a
major chlorine leak or spill. This plan should be developed with
the assistance of the Fall River LEPC, Fire and Police
Departments, and local hospitals.
Audit Team Member Composition:
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Ray DiNardo
EPA - Region I
Coordinator
Environmental Engineering
Russell A. Hemstreet, AARP
EPA - Region I
Chemical Systems
Chemistry
Ken Ferber, AARP
EPA - Region I
Mechanical Systems
Environmental Engineering
Norman Beddows
EPA - Region I
Safety
Industrial Hygiene
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Follow-up Activities:
By the Facility:
• N/A
By the Regional Office.
• N/A
By State and Local Authorities:
• N/A
Regional Contact:
Ken Ferber
(617) 860-4832
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
The Upjohn Company Fine Chemical Division
Facility Location:
North Haven, CT, Region I
Dates Audit Conducted:
August 7-LI, 1989
Description of Facility:
SIC Code(s):
Location:
Products manufactured,
produced, or distributed:
Proximity to
sensitive populations:
SIC 2869 - Industrial Organic Chemicals
not elsewhere classified.
North Haven, Connecticut The plant is
bordered on the east by the Quinnipiac
River
Intermediates for use in the
pharmaceutical, dyestuff, and pesticide
industries.
The facility, which occupies 15 acres on a
76-acre plot on the west bank of the
Quinnipiac River, is bounded by private
property, medium-sized industrial
manufacturing and commercial operations,
and a small chemical operation Average
buffer zone is approximately 0.25 miles
Across the river is Interstate 91, beyond
which lie several residential areas, which
are within five miles of Upjohn. The
total population within a five-mile radius
is approximately 130,000
Reasons for Facility Seleccion:
ARIP Reports:
The facility was selected because it is
located in a highly populated area and
utilizes several high-hazard chemicals.
Four accidental releases were reported
between January 1988 and August 1989
There is also a history of chemical odor
complaints, according to the Connecticut
Emergency Response Commission.
None prior to audit
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Focus of Audit:
Hazardous Substance(s)
Examined: Sulfuric Acid
Phosgene
Hydrogen Chloride
Anhydrous Ammonia
Benzene
Physical Area(s) Examined at the Facility:
Storage and Handling
• Storage Systems
Phosgene is purchased in one-ton cylinders and used for a variety of
processes Large numbers of one-ton phosgene gas storage cylinders are
stored in an open air storage area and are manually handled with hoists
and transport equipment. The storage area is not monitored to detect
leaks, unauthorized entry, or improper handling procedures.
Sulfuric acid, used as a raw material, is stored in a bulk storage tank
located several yards from the point of use and transported to the
production buildings by pipeline on pipe bridges.
Process Area(5)
• Phosgene
• Sulfuric acid
• Ammonia
In most reaction sequences, phosgene is added to other chemicals and
solvents in the reaction vessel with the vessel vented through
condensers and scrubbers prior to being released to the atmosphere. On
rare occasions the reaction is run under pressure with the vent closed,
in which case the operator is instructed to carefully monitor the vessel
pressure and vent the vessel's phosgene to the scrubber if the pressure
exceeded that specified by the process.
In the phosgene system, the reactors are manually controlled and are not
equipped with high pressure alarms and proper safety interlock systems
for automatic alert or shutdown in the event of an emergency. Rupture
discs are not directed to containment or secondary control to prevent
small quantity releases. Critical air pollution control equipment
operating parameters on the scrubbers are not properly detected,
recorded, verified, or remotely monitored to assure proper operation and
correct contaminant removal efficiency.
Sulfuric acid is used as a raw material in many of the chemicals Upjohn
produces. A pump on top of the storage tank brings sulfuric acid to che
21
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building a few yards away Remote switches in the production buildings
allow the distribution pump to be turned on and off The storage tank
has a level gauge. The operating practice is not to allow the tank to
be filled abdve 90 percent of capacity
Ammonia is used at the site as a refrigerating media It is compressed
and cooled to a liquid, then allowed to vaporize through an expansion
valve, providing a cold gas. This gas is used to cool a brine solution
which is pumped for process cooling The gas is continuously recycled
to the compressor, which allows some oil to pass into the ammonia The
oil is separated in an oil trap and periodically drained.
Summary of Audit Findings and Recommendations:
Conclusions•
Process Information
• Upjohn releases 23,000 pounds per year of benzene to the
atmosphere The concentrations of benzene, a known human
carcinogen, at Upjohn may present a public health concern.
• Large numbers of one-ton phosgene and chlorine gas storage
cylinders are stored in an open air storage area and are manually
handled with hoists and transport equipment. The storage area is
not monitored to detect leaks, unauthorized entry, or improper
handling procedures.
• Air pollution control equipment operating parameters on the
scrubbers are not detected, recorded, verified, and remotely
monitored to assure proper operation and correct contaminant
removal efficiency
• The phosgene system control room has old equipment and the
temperature, pressure, flow, and other critical gauges and
recording devices have not been updated.
• Phosgene system pressure and the agitator are not remotely
monitored, controlled, or verified by backup personnel.
• Hazardous materials pipes, valves, and equipment are not all
marked.
• The reactors are manually controlled but do not have automatic
safeguards for high pressure alarms and proper safety interlock
systems.
Chemical Accident Prevention
• A new operating procedure for phosgene has been instituted which
requires the operator to check that the emergency pressure release
22
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vent is open and free from obstruction The operation which
required a closed vent will not be run again, and the use of
phosgene may be discontinued by Upjohn in the near future
• Some storage tanks and unloading areas do not have secondary
containment equipment.
• Maintenance routinely occurs on an as-needed, post-failure basis
• Inadequate maintenance directly resulted in two of the four
accidents evaluated by EPA.
• Based upon release reports, operator error directly resulted in
two of the four accidents evaluated by EPA. Hazardous material
training for plant employees does not center on release prevention
and mitigation.
Public Alert and Notification Procedures
• Notification procedures do not provide the North Haven Fire
Department with information about the circumstances surrounding a
particular incident and the nature of the chemicals involved prior
to their arrival at the facility.
Recommendations:
Process Recommendations
• Upjohn should take immediate steps to reduce fugitive benzene
emissions, continuously monitor benzene levels in the facility,
and provide sound documentation of benzene concentrating at its
property line.
• Chlorine and phosgene gas cylinders should be stored in a dry area
away from excessive heat or danger of fire and protected from
accumulation of snow and ice.
• Upjohn currently plans to permanently shut down the phosgene
processes, which would mitigate the deficiencies listed above If
Upjohn reverses its plan to stop using phosgene, immediate steps
must be taken to address the deficiencies listed above. One of
these steps should be an update of the temperature, pressure,
flow, and other critical gauges and recording devices in the
phosgene system control room.
• Upjohn should consider clearly labeling and color-coding all pipes
and vessels in hazardous materials service to minimize the
potential for human error and increase the efficiency of emergency
response operations.
23
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• The reaccors should be equipped with high pressure alarms and
safety incerlock syscems for automatic alert or shutdown
• The facility should consider conducting a safety interlock study
for critical lines and vessels in hazardous material service to
determine if proper automatic shut down devices are installed and
operational
Chemical Accident Prevention
• Spill containment dikes are needed for all chemical storage tanks
This improvement is especially necessary given Upjohn's proximity
to wetlands and the Quinnipiac River. A priority construction
schedule should be developed and followed.
• The facility should consider implementing a prevencative
maintenance program. Currently, maintenance occurs only after
equipment failure Monitoring, testing, or flow indicators should
be employed along with visual pipe inspections to insure the
integrity of critical hazardous material transfer lines
• Hazardous material training programs should be reviewed and
upgraded, as evidenced by the human errors which resulted in two
accidents. The upgraded training program should focus on specific
high hazard chemical processes and associated release prevention
and mitigation techniques. Training certification programs should
be reviewed and upgraded.
Public Alert and Notification Procedures
• Notification and response procedures need to be designed to
provide full and accurate information to the North Haven Fire
Department.
Audit Team Member Composition:
Name and Title Donald Mackie, Audit Team Coordinator
Affiliation EPA-Region I
Area of Responsibility Coordination
Expertise Environmental Scientist
Name and Title Norman Beddows
Affiliation EPA-Region I
Area of Responsibility Health and Safety
Expertise Industrial Hygiene
Name and Title Ken Ferber
Affiliation EPA-Region I/AARP
Area of Responsibility Chemical Syscems
Expertise Environmental Engineering
-------
Name and Tide
AffiLiacion
Area of Responsibilicy
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Ray DiNardo
EPA-Region I
Mechanical Systems
Environmental Engineering
Tom McCusker
EPA-Region I
Air Pollution
Environmental Engineer
Renata Wynnyk
EPA-ERT
Monitoring
Field Chemist
Theresa Nutry
EPA-ERT
Meteorology
Environmental Scientist
Jack Harvanek
EPA-Region I
Monitoring
Environmental Scientist
Scott Clifford
EPA-Region I
Chemical Systems
Chemist
Jack Doolittle
Connecticut DEP
Air Pollution
Environmental Engineer
Follow-up Activities:
By the Facility:
• N/A
By the Regional Office:
N/A
By State and Local Authorities:
• N/A
25
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Regional Contact:
Ken Ferber
(617) 860-4832
26
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
The Original Bradford Soap Works
Facility Location:
Wesc Warwick, Rhode Island, Region I
Date(s) Audit Conducted-
November 29, 1989
Description of Facility:
SIC Code(s):
Location:
Products manufactured,
produced, or distributed:
Proximity to
sensitive populations:
SIC 2841 - Soap and other detergents,
except specialty cleaners.
The facility is on the banks of the
Pawtuxet River outside of Providence, RI,
in a highly populated area.
Bar soap
The facility is located in an industrial
and residential area with a population of
approximately 100,000 people within a five
mile radius of plant It lies on the
banks of the Pawtuxet River.
Reason for Facility Selection:
ARIP Reports:
The facility was chosen because it uses
high hazard chemicals such as HC1,
muriotic acid, aqueous caustic soda,
sodium hydroxide, and aqueous ammonia,
which present the risk of releases with
significant off-site consequences. There
was one accidental release of HC1 in 1989
The facility was also selected because it
is located in a highly populated area on
the banks of the Pawtuxet River.
None prior to audit.
27
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Focus of Audit:
Hazardous Substance(s)
Examined:
Hydrochloric Acid (HC1)
Aqueous Ammonia
Caustic (Sodium Hydroxide)
Physical Area(s) Examined at the Facility:
Storage and Handling
• Storage Systems
• Material Transfer
The outside HC1 storage vessel is a 4,000 gallon tank made of
translucent polypropylene, located about 20 feet from the building
entrance. Bradford is in the process of diking the storage area, at the
time of the audit the tank was not diked Acid is drawn from the tank
by gravity flow; the line running from the tank into the building Ls
flexible and supported by a pipe bridge.
The aqueous ammonia is contained in 55 gallon drums and stored in a
warehouse with paper (cardboard) packaging material. There are never
more than six full drums in storage. The drums are moved from the
warehouse to the floor above with a lift, and the reaction vessel is
charged with ammonia from the storage tank by means of a pump.
The caustic is stored indoors in a cramped room in open vats supported
on wooded blocks. The rims of the vats are encrusted with a solid which
is presumed to be sodium hydroxide, and there was a pool of off-white
liquid on the floor near the vat (also probably caustic). The caustic
is delivered to the plant by truck and pumped into the vats in a hose
through an open window. It is transferred to the reaction vessels
through a pipe and valve system with one person located at the reaction
vessel and one at the storage tank.
Process Area(s)
The basic sequence of operations is as follows: purification of tallow,
reaction of fats and oils with caustic to produce soap, purification and
drying of soap, recovery of glycerine (requires use of HC1 to neutralize
caustic). In a separate operation, small amounts of specialty soap are
produced requiring use of aqueous ammonia. During the soap making
process, the soap components are pumped in through mechanized pumps
which were working at the time of the audit but were observed leaking
28
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Summary of Audit Findings and Recommendations-
Conclusions:
Process Information
• The facility uses small quantities of HC1 in the glycerine
recovery operation, however large quantities of the acid are
stored on-site.
• The pipes are not color-coded or labeled to indicate contents or
flow direction
• In the event of a material-transfer accident'involving HC1, there
would be a large quantity of material lost due to the gravity fed
supply line.
• The aqueous ammonia is stored in a warehouse containing flammable
materials In the event of a fire, drums could rupture and
present a threat to fire fighters.
• In the caustic storage area.
-- Area is congested.
-- Diking is not designed to contain the worst-case release
scenario.
-- The wooden block supports are makeshift and unstable.
-- Piping and pumps frequently leak, and no interlocks and color-
coding of pipes and equipment are present.
-- Dried caustic residue is present in large amounts throughout
the area.
-- An open window is used for filling the storage tanks
Chemical Accident Prevention
• Bradford has an old maintenance system. In addition, Bradford has
no systematic analysis of its operations which use hazardous or
toxic chemicals. This type of analysis is necessary to identify
components which are vulnerable to failure, to develop contingency
plans for responding to failures, and to institute changes to
mitigate the consequences of failures.
• The HC1 storage tank is not properly diked, does not have a level
indicator, and has unprotected outlet valves and lines.
Facility Emergency Preparedness and Planning Activities
• Bradford has no formalized emergency response training and
emergency contingency planning programs.
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Community and Facility Emergency Response Planning Activities
• The auditors met with staff level personnel from the facility
The management of Bradford Soap Works did not appear to take too
much interest in the audit or their responsibilities under SARA
Title III.
Public Alert and Notification Procedures
• The public address system in the glycerine recovery area was not
readily audible and the general internal communication system is
makeshift. In one area of the plant, SOPs require workers to beat
on the side of a storage drum 3 times to communicate or warn
others.
Recommendations:
Process Information
• Because of the relatively small quantities of HC1 used at any one
time at the facility, Bradford should consider reducing inventory
of HC1 to 55 gallon drums
• Most of the facility's equipment needs increased maintenance and
repair. In some cases, the equipment should be replaced entirely.
• The facility should consider replacing the gravity fed supply line
with a pump for withdrawing acid from the top of the tank, to
minimize material lost in the event of a material transfer-related
failure.
• The storage facility for aqueous ammonia should be modernized and
updated to eliminate the threat of fire within the warehouse.
• The technology in the caustic storage area should be modernized
and updated to minimize accident potential. A state of the art
unloading system with proper coupling and accident prevention
safeguards should be installed for use when filling the storage
tanks.
• Pipes and valves should be properly labeled and coded for easy
reference in the event of an emergency.
Chemical Accident Prevention
» The facility should develop a more sophisticated preventative
maintenance program which could include a database allowing for
the replacement of components before failure occurs.
• Bradford should consider evaluating hazards, including "What If"
scenarios, to identify components which are vulnerable to failure
30
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• The HCL cank should be diked and a level indicator should be
installed In addition, the outlet valve and line should be
hardened and better protected
Facility Emergency Preparedness and Planning Activities
• The facility should formalize their emergency response training
and contingency planning to communicate emergency conditions more
efficiently and prepare the workers for proper response
• Bradford should consider evaluating hazards to develop contingency
plans for responding to failures and institute changes to mitigate
the consequences of failures.
Community and Facility Emergency Response Planning Activities
• The management of Bradford Soap should make every effort to obtain
a comprehensive knowledge of their responsibility under SARA Title
III To do this they should keep informed through reports and
through interaction with their SERC and LEPC representatives.
• Bradford needs to work with the LEPC to become more involved in
the community aspects of planning.
Public Alert and Notification Procedures
• The facility needs a more efficient means of identifying and
communicating emergency conditions both to the workers and to the
outside community.
Audit Team Member Composition:
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Ray DiNardo
EPA - Region I
Coordinator
Environmental Engineering
Ken Ferber. AARP
EPA - Region I
Mechanical Systems
Environmental Engineering
Russell A. Hemstreet, AARP
EPA - Region I
Chemical Systems
Chemistry
Norman Beddows
EPA - Region I
Safety
Industrial Hygiene
31
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Name and Title John Aucotc
Affiliation Rhode Island SERC
Area of Responsibility SARA Title III
Expertise Planning and Response
Follow-up Activities:
By the Facility:
• N/A
By the Regional Office:
N/A
By State and Local Authorities:
N/A
Regional Contact:
Ken Ferber
(617) 860-4382
32
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Rhone-Poulenc Ag Company (RP)
Facility Location:
Date(s) Audit Conducted:
Institute, Kanawha County, West Virginia,
Region III
July 30 - August 3, 1989
Description of Facility:
SIC Code(s)-
Location:
Products manufactured,
produced, or distributed-
Proximity to
sensitive populations:
SIC 2879 - Pesticides and agricultural
chemicals, not elsewhere classified
Twelve miles west of Charleston, West
Virginia
Manufacturer of intermediate methyl
isocyanate
Sensitive populations and/or activities in
the adjacent community include: WV State
College, Shawnee Hills Regional Center
School, WV Rehabilitation Center, FMC
Carbofuran Unit, and Reagent Chemical
Reason for Facility Selection:
ARIP Reports:
The facility was chosen because it is one
of the few manufacturers of the
intermediate methyl isocyanate in the
United States. Methyl isocyanate and the
raw materials used in its manufacture are
all highly hazardous. The "state-of- the
art" equipment at the facility and the
invitation extended by the management,
however, were the primary reasons for the
selection of the facility for audit
Furthermore, knowledge was already
available in the Region about the facility
because it was the prototype chemical
safety audit which took place immediately
after the Bhopal incident in 1984
6/23/87 and 6/24/87 chlorine releases
33
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Focus of Audit:
Hazardous Substance(s)
Examined: Phosgene
Monomethylamine (MMA)
Chloroform
Methyl Isocyanate (MIC)
Hydrochloric Acid
Physical Area(s) Examined at the Facility:
Storage and Handling
• Storage Systems
• Material Transfer
Due to the extremely hazardous nature of the chemicals involved, storage
and handling processes are all closed loop systems Bulk chemical
transfer of phosgene, MMA, CO, chlorine, and MIC is performed on site by
pipeline from storage tanks and railcar Currently, all MIC produced on
site is used in-house to manufacture agricultural pesticides or is
transferred by above ground pipeline to the adjacent FMC facility.
Notable storage facilities at the MIC unit include four converted
railcars used to store MMA. The maximum amount of MMA stored onsite is
570,000 pounds. Also, three underground storage tanks are used to store
MIC prior to being pumped to other production units
Process Area(s)
• Methyl isocyanate production and phosgene and syngas manufacture
The audit focused on the isolated MIC unit and the pre-MIC production
operations of phosgene and syngas manufacture. MIC is produced during
the vapor phase reaction of phosgene and MMA. A dedicated, in-house
syngas product unit produces carbon monoxide which is reacted with
chlorine to generate the phosgene feedstock for the MIC unit. The
chlorine and carbon monoxide are reacted in a heated, activated carbon
converter co form phosgene.
The phosgene and MMA are passed through a reaction vessel in vapor phase
and the end products are MIC and hydrochloric acid. The MIC is then
cooled and gravity fed into tanks where it is tested for purity. It is
then piped to other RP production units or to the neighboring FMC
facility for use in the manufacture of agriculture products. Chloroform
is utilized as a system solvent and as a coolant in process heat
exchangers.
-------
Summary of Audit Findings and Recommendations:
Conclusions: .
Process Information
• Storage of excess MIC is kept to minimum to reduce the chances of
a catastrophic release of large amounts of MIC. In addition, the
facility has reduced the possibility of transportation-related
incidents involving MIC by restricting production of this
intermediate for on-site use or for shipment via pipeline to an
adjacent facility
• The above ground MIC storage tank area is covered by steel cable
mat This mat was installed to prevent projectiles from damaging
these tanks if there was an explosion in another, nearby area of
che plant
• Several scorm sewer grates were in close proximity to chemical
storage or containment areas. While curbing and diking are used
throughout the unit, a catastrophic liquid release due to a tank
failure in the right direction would splash over the containment.
The audit team was informed that process sewers are directed to
the wastewater treatment plant, but that storm sewer empty
directly into the Kanawha River. A release, as described above,
could reach a storm sewer and flow unchecked into the river.
• Redundant diverse critical equipment is found throughout the MIC
units Examples of this instrumentation include duplicate
temperature gauges which feed into separate instrument panels on
the control board.
• The facility has an integrated parameter monitoring system and
concise, explicit Standard Operating Procedures (SOPs).
Monitoring instruments feed information electronically into the
control room computer. Critical operating parameter indicators
have an audio and visual alarm which activate when the parameters
exceed safe levels.
• Monitoring systems are in place at the MIC production, unit to
detect and quantify both MIC and phosgene releases. A 16 point
flame ionization detector/gas chromatograph (FID/GC) air sampler
can detect MIC at 0.1 ppm, and an 8 point colormetric air sampler
can detect phosgene at 0.05 ppm. However, neither of these
detection systems has a backup. Most often small leaks are
detected by worker eye irritation.
• No perimeter monitoring systems exists at the plant for either MIC
or phosgene at the present time.
35
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Chemical Accidenc Prevention
• Critical operating parameters (COP) have been established to
ensure that a process unit will be immediately shut down if any
COP reaches abnormal specifications These actions are
automatically or manually initiated and can only be countermanded
by department head authorization. Any unit operator, without
having to obtain prior authorization, can initiate emergency
shutdown procedures if any COP has reached warning levels
• The facility uses a combination of formalized classroom training
and on-the-job training to educate new hire employees on the
specifics of unit operation and safety on the MIC production line
• Training is important for contractor personnel, such as
maintenance staff, to ensure that they are cognizant of the
correct safety procedures Contractor training procedures are not
specifically addressed in the plan.
• Management is committed to comprehensive preventive maintenance
programs. The maintenance staff at this facility consists of
nearly one-third of the entire work force (566 workers out of
1,600). Each month, approximately 4,500 preventive maintenance
work requests are processed for the plant. All safety valves and
rupture discs are inspected on a rotating basis each month. A
computer database has been developed to track all maintenance
records and to identify continuing trouble spots.
• The facility requires the use of formal Hazard/Risk Management
Procedures. The facility uses both "what if" and "HAZOP"
evaluation techniques
• Hazard modeling is routinely performed at the facility using
either SAFER or WHAZAN.
• A number of release prevention systems have been incorporated in
the plant, starting in raw material storage and extending through
product storage. For example, phosgene is stored underground and
is cooled with brine to -5° to minimize vapor generation.
• Release prevention is also evident in process design; for example,
having fail safe control valves in the event of loss of instrument
air, and directing the process vents to the scrubber/flare system
to prevent hazardous vapor release from process vessels.
• Flow detectors have been installed to detect abnormally high flow
in the MIC or phosgene flare lines. The detectors trigger alarms
which automatically increase fuel delivery to the flare from
approximately 400 pounds/hour to 2,900 pounds/hour- An infrared
scanner monitors the flame continuously and will automatically re-
ignite the flare The flare has had no flame-out in four years
36
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• Boch active and passive mitigation systems exist in the MIC
process. The major active systems are the emergency vent scrubber
and the flare Passive mitigation systems are used primarily co
control small releases. For example, activated carbon, which is
stored in 55 gallon drums throughout the unit, is available for
spill absorption
• The facility is adding another mitigation system, an incinerator
to minimize chloroform releases.
Facility Emergency Preparedness and Planning Activities
• There exist two facility organizations for dealing with on-site
emergencies, emergency squads and an emergency operations center
(EOC). The emergency squad includes a hazmat team that responds
to chemical releases that occur within the facility confines,
unless directed by facility management to respond off-site In
generally, the EOC serves to provide additional help, expertise
and material necessary to more effectively manage an emergency
• Procedures are provided in the emergency plan for responding to
releases of flammable and toxic vapors
• Emergency squads have monthly drills on selected subjects Each
year, two plant scenario drills are conducted which include
activation of the EOC and community involvement
• Visitors report to the Reception Center Building, where the
visitor must view a ten minute video of certain facility safety
rules
Community and Facility Emergency Response Planning Activities
• Rhone-Poulenc is an active member of the Kanawha Valley Emergency
Planning Council.
• The emergency plan contains procedures for activation of the KVEPC
during an emergency.
• The plan includes procedures and responsibilities for
communication to the media during and following an emergency,
including pre-designated spokespersons.
Recommendations:
Process Information
• The audit team noted that chemicals located in the chemical
storage or containment areas could reach storm sewers in the event
of a catastrophic liquid release due to a tank failure. The audit
team recommended that storm sewer grates in potential problem
37
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areas be relocated or additional containment downstream be
constructed which could be utilized as a holding area in the
of a chemical release.
evert
• Because the detection system at the MIC unit does not have a
backup, it is recommended that several chemical specific portable
personnel monitors be utilized as a backup. These small units can
be hung on worker's neck or hung easily at a specific location
where a leak is suspected. They provide a redundance to the
automatic monitoring system These smaller units are weather
sensitive and would not be useful as primary detection system, but
they would be adequate as a secondary system.
Chemical Accident Prevention
• It is recommended that the orientation video developed by RP more
closely address the various types of emergencies, notifications.
and respective actions to be taken during a facility emergency
It is also recommended that non-company safety training (i e ,
provided by the contractor for contractor personnel) be specified
and tracked by RP.
Audit Team Member Composition:
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Walter Lee, Senior OSC/Audit Team Leader
EPA - Region III
Technical
Chemist
Karen Brown, Regional CEPP
EPA - Region III
Management
Title III
Philip Younis, On-Scene Coordinator
EPA - Region III
Technical
Civil Engineering
Kurt Eisner, Regional Toxics Release
Inventory Coordinator
EPA - Region III
Technical
Chemical Engineering
Rick Horner,
EPA - Headquarters
Management
Chemical Engineering
38
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Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Deborah Lukesh.
EPA - Headquarters
Management
Environmental Science
Peter Lydens, Chairman
Kanawha and Putnam County Local Emergency
Planning Committee
LEPC
Title III
Jeffrey Lieberman, TAT
Roy F. Weston
Technical
Chemical Engineering
Rita Sammons, TAT
Roy F. Weston
Technical
Chemical Engineering
Follow-up Activities:
By the Facility:
• N/A
By the Regional Office:
• N/A
By State and Local Authorities:
• Because of a release on February 2, 1990, a second inspection was
conducted in conjunction with OSHA. Citations were issued by OSHA
and a report was prepared. The focus of the investigation was
contractor injuries.
Regional Contact:
Joe Popp
(215) 597-1357
39
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
LCP Chemicals
Facility Location:
Moundsville, West Virginia, Region III
Date(s) Audit Conducted:
August 14 - 16, 1989
Description of Facility:
SIC Code(s):
Location:
Products manufactured,
produced, or distributed:
SIC 2812 - Chlor/alkali production.
Twenty five miles south of Wheeling, West
Virginia, on State Route 2, along the Ohio
River
Chlorine and caustic soda in mercury
cells, chloromethanes (methyl chloride,
mechylene chloride, chloroform, and carbon
tecrachloride).
Proximity to
sensitive populations:
LCP Chemicals is located within one mile
of the Washington Lands community, an
elementary school, and a country club.
Reason for Facility Selection:
ARIF Reports:
The facility had several reportable
releases of CERCLA hazardous substances
Between August, 1988 and August, 1989, 15
incidents had occurred, some which
resulted in significant releases of
hazardous materials.
10/30/88 hydrochioric acid release
(questionnaire completed 8/13/89); 4/1/87
chlorine release, 4/29/87 sodium hydroxide
release; 6/4/88 methyl chloride release;
and 10/3/88 zinc chloride release.
40
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Focus of Audit:
Hazardous Substance(s)
Examined. Chlorine
Sodium Hydroxide
Sodium Hypochlorice
Hydrochloric acid
Hydrogen
Sulfuric acid
Mercury
Physical Area(s) Examined at the Facility:
Storage and Handling
• Storage Systems
• Shipping/Receiving
• Material Transfer
Sodium hydroxide is stored in four tanks totalling 600,000 gallons
These storage tanks are surrounded by a 7 foot containment dike and
there is a dedicated NaOH transfer unit for loading railcars from these
tanks. Chlorine is stored in 50.000 pound receivers, which usually
contain between 5 and 10 tons each. A dedicated chlorine transfer unic
is used to load the railcars. There are also four 150 ton C12 storage
tanks from which barges are loaded. Transfer lines extend from these
tanks to the barge loading dock at the river
Process Area(s)
• Chlor/alkali Process
The focus of the survey was the chlor/alkali process. The two products
of this process are chlorine and caustic soda Brine, the raw material,
is drawn from on-site wells approximately 6,500 feet deep and
transferred via pipeline to the process area. The first step is brine
purification Hydrochloric acid is added to remove the hydrogen sulfide
and sodium hydroxide and soda ash are added to facilitate metal removal
The brine solution is gravity fed to the electrolyzer, which deionizes
the sodium chloride (NaCl) into Na and Cl The Na is attracted to the
cathode, which is mercury lined. The amalgam that is formed is reacted
with deionized water to form a 50 percent NaOH solution which is then
sent to storage.
The Cl is attracted to the anode, where it forms C12 gas. This gas is
pulled from the electrolyzer by chlorine compressors for cooling and
drying After this process, the chlorine gas is compressed and then
liquified, after which it is sent to storage.
-------
Summary of Audit Findings and Recommendations-
Conclusions: .
Facility Background Information
• From 1982 to 1986, as the market for chlorine and caustic produces
was poor, the plant deteriorated as a result of limited funds for
capital investments. Since 1986, new management personnel has
been in place at LCP with plans to reinvest and improve conditions
on site through a Capital Projects Priority List.
Process Information
• The facility has an emergency generator and LCP personnel stated
that all critical equipment had backups The audit team noted.
however, that many pieces of duplicate equipment were under
repair. It was not clear if any of these pieces were also a
backup to critical equipment.
• Most operational parameter monitoring controls require physical
monitoring by the operator, although a few digital feedback
displays were in place Further, there is no central control
area.
• A damaged chlorine monitoring system will be replaced.
• LCP Chemicals owns a computerized meteorological weather station.
which has not yet been installed.
Chemical Accident Prevention
• The company instituted an Unsafe Condition Report procedure to
allow employees to identify unsafe conditions within the facility
The procedures require middle- and upper-management response and
follow-up actions within specified time frames. All reports and
follow-up actions are tracked on a computer database
• LCP has incorporated standard operating procedures (SOPs) into
plant operations and made several capital improvements, such as in
the waste water treatment plant. The SOPs did not always reflect
changes in the plant, nor were they located in all areas of the
plane.
• The maintenance department has instituted a comprehensive training;
program for its employees. A written test and four practical
tests, requiring a 70 percent score for passing, are given to new
employees before they are admitted to the maintenance department
Advancement within the department is contingent on results from
continued tests.
-------
LCP has instituted new hire and basic operator training programs
Most of chese training programs are new and are still in the
implementation stages. Many workers have received on-the-job
training rather than formal written and practical training
While it appears that most expenditures have been directed toward
organization and training, an analysis of past releases indicates
that most releases have been attributed to equipment failure.
Due to the corrosive environment and lack of maintenance from 1982
through 1988, the general structural integrity of the plant is
poor The audit team noted a number of structural problems in the
plant that require attention, including structural corrosion in a
number of the buildings There were a number of areas the audit
team felt were unsafe to work in.
LCP had begun a preventative/predictive maintenance program,
however, due to start-up of a new process at the plant and due to
the age'and condition of most of the equipment, plantwide
maintenance has been 20 percent scheduled and 80 percent
emergency This overwhelming number of emergency maintenance has
prevented the establishment of a preventative maintenance program
Tank inspections are not done by the maintenance department, but
by che individual process departments. There are few, if any.
written maintenance procedures
In 1986, a maintenance program was established to test the fans in
the boiler house for vibration every 60 days. The fan used to
fail every eleven months but since che institution of this
maintenance program, there has not been a fan failure
In response to a number of incidents at the site, some release
prevention systems have been incorporated into plant design and
operation. For example, as the result of a spill due to a faulty
transfer hose, transfer hoses are tested before each use, as
opposed to every six months.
The facility has incorporated release prevention measures in the
railcar loading area and the barge loading area.
The plane had no hazard identification procedures/practices
There were few markings on any tanks, vessels, or lines indicating
the materials contained inside or the hazards associated.
There are two main mitigation systems in the plant, both geared to
handle chlorine releases. The first is the bleach plant which
takes vencs from chlorine liquefiers, tanks, barges, and railcars,
typically "high quality" chlorine gas. and converts it to sodium
hypochlorice. The other system is called the destruct system and
is similar to the bleach production unit, except it handles "weak
gas." which comes from cells that are being cleaned, and the
evacuation system, for example
-------
• Other mitigation devices include rupture disks and safety valves
which vent back to the chlorine system
• Any containment dikes in the plant were old or breached or
appeared to be of inadequate capacity to control discharge of
tanks contained inside.
• Some spill control techniques were available in the plant For
example, lime was available to control acid spills
• Plant personnel carried cartridge respirators designed to filter
out chlorine and mercury and emergency fresh air supplies were
evident
Accident Release Incident Investigation
• The number of accidental releases at LCP in the last few years is
very high The most recent of these occurred four days after the
audit was completed The chloromethane plant was damaged in an
explosion that resulted in hydrochloric acid, methyl chloride, and
chlorine releases
Facility Emergency Preparedness and Planning Activities
• The "Plant Emergency and RCRA Contingency Plan" addresses alert
procedures, emergency shutdown procedures, media responsibility,
MSDS listings, and evacuation procedures. At present, however.
routine emergency response exercises are not conducted
• The plan does not address personnel roles and responsibilities
during various hazardous material incidents.
• Facility Emergency Crews (E-Crews) have been organized to respond
to all on-site emergencies.
• The plane's SCBAs and air-line regulators have been benched tested
and inspected. All equipment was repaired and new equipment has
been purchased to replace and/or upgrade some of the existing
equipment.
Community and Facility Emergency Response Planning Activities
• The safety manager is also the laboratory manager as well as the
training manager and the SARA Title III plant coordinator
Public Alert and Notification Procedures
• The facility has developed procedures for notifying the public
during an emergency. They have a siren warning system in the
Washington Lands community, but there seems to be no other back-up
other than phone calls to citizens.
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Recommendations•
Process Information
• A chlorine perimeter detection system and a monitoring system
within the plant buildings and transfer areas should be installed
Such a system will allow quicker response action and better
protect worker safety and health.
• The process monitoring and control systems should be completely
overhauled. More automation and continuous monitoring should be
emphasized, especially in the high hazard areas such as chlorine
handling One control room with centralized digital displays and
remote corrective action would be ideal.
• Backup equipment should be repaired as soon as possible when taken
out of service, equipment should be connected to the emergency
power system due to recent power supply problems
Chemical Accident Prevention
• In light of the physical deterioration of the plant and equipment,
LCP might refocus its expenditures from organization and training
to equipment maintenance
• LCP should consider seeking additional corporate resources to help
finance scheduled capital improvement projects.
• Capital investment in plant structural and equipment improvements
should be reviewed by a professional engineer
• All SOPs and material safety data sheets should be available in
every area of the plant, including storage and transfer areas
These should be reviewed and updated to reflect changes in the
plant, as should all plant documentation.
• Equipment improvements and replacement are needed throughout the
plane. These improvements should take into account the highly
corrosive nature of the process Containment around storage and
process areas and of the NaOH storage area need improvement
• Proposed training programs should be instituted as planned,
including basic operator, maintenance, and supervisory training
• Preventive maintenance should be established. This is a major
investment effort, both of time and money. 'Written maintenance
procedures should be devised Tank inspections according to
American Society of Mechanical Engineers standards should be
incorporated into the plant maintenance program. The computer
system for scheduling of maintenance should be expanded to include
preventative maintenance
-------
• A hazard identification system should be employed in the plant,
and communicated to all employees
Facility Emergency Preparedness and Planning Activities
• The facility response plan, as presently organized, needs to be
updated to effectively deal with the wide range of hazardous
situations that could occur.
• Although LCP has had an abundance of "real" emergencies, a lack of
simulations/exercises is a major deficiency in their response
plan.
• Personal protective equipment should be easily accessed and
carefully maintained
Public Alert and Notification Procedures
• Tests of the alarm systems and other notification procedures
should be regularly scheduled and conducted, and the effectiveness
of the system in reaching the desired areas should be determined
Audit Team Member Composition:
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Phil Younis/Audit Team Leader
EPA - Region III
Management
Civil Engineering
Jerry Saseen, On-Scene Coordinator
EPA - Region III
Management
Environmental Protection Specialist
Karen Brown, Preparedness Coordinator
EPA - Region III
Management
Title III
Dennis Matlock, TAT
Roy F. Weston
Management
Environmental Planning
Joe Popp, AARP
EPA - Region III
Management
Occupational Safety & Health/Management
Policy
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Name and Tide
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
James Fenske
West Virginia Department of Natural
Resources
Air and water emissions
Clean Air/Clean Water
Marjorie Easton
EPA Region III
Technical
Chemist
Rita Sammons, TAT
Roy F Weston
Technical
Chemical Engineering
Mrinal Biswas, TAT
Roy F Weston
Technical
Structural Engineer
James Gaston
West Virginia Department of Natural
Resources
Water emissions
Clean Water
Tim Carroll
West Virginia Air Pollution Commission
Air emissions
Clean Air
Follow-up Activities:
By the Facility:
N/A
By che Regional Office:
N/A
By State and Local Authorities:
• OSHA conducted an investigation and issued citations
Regional Contact:
Joe Popp
215-597-1357
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Purolice Corporation
Facility Location:
Philadelphia, Pennsylvania, Region III
Date(s) Audit Conducted:
September 11 - 12, 1989
Description of Facility:
SIC Code(s):
Location:
Products manufactured,
produced, or distributed:
Proximity to
sensitive populations:
SIC 2821 - Plastics materials, synthetic
resins, and nonvulcanizable elastomers
Industrial/residential area in
Philadelphia, Pennsylvania.
Cation exchange resins and brominates
anion exchange resins
Residences located within 1,000 feet of
the property, approximately six hundred
residents live within 1/4 mile of the
site. The facility is bordered by
railroad tracks to the south and by other
industrial complexes to the north and
west.
Reason for Facility Selection:
ARIP Reports:
The facility came to the attention of EPA
Region III through the Philadelphia Fire
Department (PFD), which had responded to a
number of spills/releases from the plant
On March 21, 1989, for example, a spill
that was later traced to Purolite
Corporation resulted in the evacuation of
employees at the Northeast Philadelphia
Water Treatment Plant.
None prior to audit.
-------
Focus of Audit-
Hazardous Subscance(s)
Examined:
Styrene
DivinyL Benzene 55 (DVB)
PropyLene dichlonde (PDC)
SuLfuric acid
Hydrochloric acid
Bromine
Sodium Hydroxide
Purolice C-100 ion exchange resin
Physical Area(s) Examined at the Facility
Storage and Handling
• Storage Systems
Storage of the reactants and products varies a great deal The
reactants, styrene and DVB, are stored outside the plant building in two
10,000 gallon capacity tanks PDC is also stored outdoors in a 6,000
gallon tank. Sulfuric acid is stored in a number of tanks inside the
building, in concentrations varying from 99 percent to 10 percent
Bromine is received and stored in 200 pound cylinders The products.
ion exchange resins, are stored in plastic bags, contained in 1,000
pound cardboard boxes.
Process Area(s) Examined
• Production of cation exchange resins and the sulfonation of the
resins
The process audited was the production of cation exchange resins and the
sulfonation of the resins. From storage, styrene and DVB are measured
into a 1,000 gallon monomer holding tank. The monomers are fed into the
polymerizer where water, wetting agents, and catalysts are added. The
mixture is heated and the monomers react with approximately 100 percent
completion. When the mixture is polymerized, i-t is pressurized and
blown into the polymer wash tank
The small, hard beads that are produced are downwashed and backwashed
several times to remove residual monomer. The water is sent to the
wastewater sump and beads are pressurized to a centrifuge where they are
spun clean with water. The beads are then fed through a dryer, to
evaporate the water, and through a screener, to separate the coarse from
the fine beads.
The sulfonation process begins with 3,000 to 4,000 pounds of beads being
sent to the sulfonator PDC is then added to the beads and heated. The
PDC is brought to its boiling temperature and begins distilling
-------
Sulfuric acid, at a concentration of 99 percent, is added to the
sulfonator at the beginning of PDC distillation The spent acid is sent
to a storage tank and the beads are rinsed with decreasing
concentrations (from 60 percent to 10 percent) of sulfuric acid The
beads are then washed with water and caustic acid is added to neutralize
the residual acid
Summary of Audit Findings and Recommendations:
Conclusions:
Process Information for Hazardous Chemicals
• Bromine is received and stored in 200 pound cylinders There were
35 empty cylinders (containing less than 3 pounds of bromine) and
10 full cylinders at the time of the audit. These empty bromine
cylinders cannot be returned to the manufacturer. Purolite
accumulates a number of these cylinders and decontaminates them
together.
• PFD raised concerns about crowding in the storage areas of the
warehouse. Items were stacked very high and there was little
aisle space.
• Equipment backup exists; however, spares are not usually in line
but must be put into service. There is no backup system for the
scrubber; several incidents that occurred in the past were due to
scrubber component failure.
• Parameter monitoring is widespread in the processes. A control
board allows the operator to monitor a number of systems
concurrently, while physical displays at the vessels allow an on
location operator instant knowledge about the process
• There are few environmental monitoring systems in place; pH of
waste water is monitored. However, there are no in-plant systems
or perimeter systems to quantify the levels of organic vapors or
acid vapors in or leaving the plane.
Chemical Accident Prevention
• Batch sheets used by operators as guides on equipment operation
are one or two pages and do not explain the process, nor do they
explain problems that may occur in the process.
• Process flow and instrumentation diagrams reviewed by the audit
team did not reflect recent changes in the plane operations
• There is no formal classroom training at the Purolite plant,
training occurs on the job.
50
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• The audit team noted that operators were eating and drinking in
the process areas
• There is a specified maintenance period at Christmas time during
which the plant is shut down. Maintenance during the rest of the
year is performed through a work order system Maintenance
requests usually run 75 percent work orders and 25 percent
emergency requests Preventative maintenance includes quarterly
inspections of valves, pumps, and agitators.
• The facility is not using any formal hazard evaluation techniques
(e g "what if." HAZOP, etc ) nor is the company acquainted with
air modeling
• Overflow tanks are found throughout the process to prevent spills
Release prevention devices are also incorporated into the
sulfonation process. For example, temperature of the sulfonacor
is carefully monitored and sulfuric acid concentrations are
manually checked before each sulfonation batch
• Several tanks vent volatile organic emissions directly to the
atmosphere, including the monomer storage tanks, the
polymerization condenser, the polymer dryer, and the scrubber A
cursory examination of an emissions test showed that limits set by
Philadelphia Air Management were exceeded
• Following a spill, the company installed a new storm drainage
system which controls the flow of liquid wastes towards the storm
water drains A culvert routes these wastes to several waste
water holding tanks for treatment.
Facility Emergency Preparedness and Planning
• Prior to the audit, Purolite had hired a consultant to develop a
preparedness, prevention, and contingency plan. At the time of
the audit, the Emergency Response Plan was in the draft stage and
under review
• The facility has some emergency equipment, including fire
extinguishers, a sprinkler system, gas detectors, explosimeters. a
public address system, and a hand-powered siren, but does not have
an emergency lighting system, emergency medical supplies, or
protective clothing
Community and Facility Emergency Response Planning Activities
• The facility has not worked with the community to determine its
vulnerabilitv
51
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Public Alert and Notification Procedures
• The facility does have a chain of command and a list of agenci.es
to contact in an emergency, but does not have specifically written
procedures for notification of the public Decision to evacuate
the community has been relegated to Philadelphia Emergency
Response officials.
Recommendations:
/
Process Information for Hazardous Chemicals
• PFD concerns including crowding in storage areas of the warehouse
items being stacked too high, and lack of aisle space should be
addressed.
• "Empty" bromine cylinders in the warehouse should be cleaned and
discarded and the number of full bromine cylinders in the plant
should be limited. Bromine is received and stored in 200 pound
cylinders.
• Process flow and instrumentation diagrams should be updated.
Those reviewed by the audit team did not reflect recent changes in
the plant
• Environmental monitoring systems should be established both in the
plant and around the perimeter. There are few environmental
monitoring systems in place at the plant.
Chemical Accident Prevention
• Standard operating procedures should be developed beyond batch
sheets so operators have a reference available to consult in the
event of problems. Batch sheets used at the facility do not
explain the process, nor do they explain problems that may occur
in the process.
• A strong training program should be established, including formal
classroom instruction, to educate operators about the materials
they are handling, process design, and the safety systems of the
process. Training occurs on the job at the facility.
• Eating and drinking by operators in the process areas should be
eliminated.
• A formal hazard evaluation/modeling system should be developed at
the plant. The facility is not using any formal hazard evaluation
techniques.
52
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Volatile organic emissions from tanks should be reduced through
installation of another scrubber system or other destruction or
absorption systems This may be necessary to meet current city-
discharge requirements There is no backup system for the
scrubber, several incidents that occurred in the past were due to
scrubber component failure
Purolite should rebuild (a six-alarm fire destroyed the plant tvo
weeks after the audit) to the standards it had established before
the fire with respect to process safety, and incorporate
improvements in the areas of training, preparedness, hazard
modelling, and environmental monitoring
Audit Team Member Composition:
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Walter Lee. On-Scene Coordinator/Audit
Team Leader
EPA - Region III
Management
Chemist
George English, On-Scene Coordinator
EPA - Region III
Fire Codes
Fire Prevention
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Karen Brown. Preparedness Coordinator
EPA - Region III
Management
Title III
Joe Popp, AARP
EPA - Region III
Management
Occupational Safety and Health/Management
Policy
Rita Sammons, TAT
Roy F. Weston
Technical
Chemical Engineering
Follow-up Activities:
By the Facility:
N/A
53
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By the Regional Office:
• N/A
By State and Local Authorities:
• Subsequent to the audit, there was an explosion at the facility
As a result, the PFD conducted an investigation of the explosion
Regional Contact:
Joe Popp
(215) 597-1357
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Facility Location:
Carl Falkenstein, Inc
Philadelphia, Pennsylvania, Region III
Date(s) Audit Conducted:
September 25 - 26, 1989
Description of Facility:
SIC Code(s):
Location:
Products manufactured,
produced, or distributed:
Proximity to
sensitive populations:
SIC 3648 - Lighting equipment, not
elsewhere classified
Downtown Philadelphia
Designs, casts, decorates, and
electroplates castings for the portable
lamp industry
Dense residential, commercial, and
industrial area.
Reason for Facility Selection:
ARIP Reports:
The facility was chosen based on
information provided by the Philadelphia
Fire Department (PFD). Numerous problems
were identified during a PFD inspection
following a chemical spill on August 26,
1989.
None prior to audit.
Focus of Audit:
Hazardous Substance(s)
Examined:
Ammonium Hydroxide
Copper Cyanide
Sodium Cyanide
Zinc Cyanide
Hydrochloric acid
Sodium Hydroxide
Potassium Hydroxide
55
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Physical Area(s) Examined at the Facility:
Storage and Handling
• Storage Systems
During the audic, all chemicals were segregated into two storage areas
the caustic/cyanide storage area and the acid storage area These two
areas have wire screen walls, dikes, and are kept locked
Process Area(s)
• Electroplating and finishing lamp bases and wastewater treatment
The plant manufactures and finishes lamp bases and columns and sells
them for assembly at another plant The base metal LS a 95 percent zinc
- 5 percent aluminum alloy known as "white metal " The process consists
basically of five steps casting, grinding and polishing,
electroplating, finishing, and wastewater treatment
White metal ingots are purchased as a raw material and then melted in
pots Preformed dies are filled with molten metal and cooled by water
spray After casting, the rough product is sent to a different floor
for grinding and polishing by motor driven, belt operated machinery
After being prepared in an acid bath, the bases and columns of the lamps
are brass plated in a brass plating bath. The operation is completed
after final rinses The objects are finished by either being oxidized,
to create different shades of color on the pieces, or painted.
The cyanide bearing wastewater from the plating baths and the acid
bearing wastewater from the rinse tanks are separately pumped into three
evaporator units which heat the water and emit steam from a thirty-foot-
high stack.
Summary of Audit Findings and Recommendations:
Conclusions:
Process Information
• A pool of liquid was noted inside the diking of the
Caustic/Cyanide Storage Area on the second day of the audit
• Many problems were noted related to deterioration and breakdown of
process equipment. Individual tanks and vats had valves which
were leaking, presumably due to corrosion and deterioration
There were no locks or emergency shutoffs observed.
56
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• All wastewater from the process area Ls handled as one waste
scream The wascewacer conCained in che dike was ac ics maximum
liquid level, and several overflows or leaks were observed Cicv
sewer drains are locaced jusc oucside of che concainmenc system
• Mumerous occupacional hazards exisc in che grinding and polishing
areas
• The lunchroom facilicy is noc complecely enclosed and chere are
holes in che walls
• There were no observed monicoring or dececcion syscems in place
for chemical releases Leak dececcion and level indicacion could
only be performed visually Air monicoring devices for cyanide
and ammonia gases and acid fumes would dececc dangerous levels in
che work acmosphere and procecc worker healch
Chemical Accidenc Prevention
• Coffee drinking and smoking in work areas was observed by che
audic team
• The SOPs were found co be concise inscruccion liscs written co fie
Che noncechnical educacional background of che general produce ion
scaff They did noc address operacional procedures per se buc
racher maincenance and general safecy rules.
• Although Macerial Safecy Data Sheecs exisc in certain areas
employees who do noc underscand English are noc be able co read
che chemical information
• The only training is "on che job" craining
• The Hazard Communication Program and che Preparedness, Prevention
and Contingency Plan, boch in the process of being revised,
include a training program to instruct new employees about che
hazards of chemicals used in the plant. Several employees,
however, were smoking in front of "No Smoking" signs and several
coffee cups were set down on edges of placing canks.
• No preventative maintenance is performed. Standard policy
dictates that repairs be made after a breakdown has occurred
rather than maintaining che machinery on a regular basis.
• The facility is not using any formal hazard evaluation techniques
(i.e., "what if," HAZOP, etc ), nor is it acquainted with ail-
modeling.
• Diking is in place in the placing room, che storage areas, and che
evaporator and holding tank rooms
57
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• Manual shutoff buttons for the pump were noted Ln the holding tark
room, however, there v/as not a dedicated operator
• The mixing of cyanide-containing compounds and acid-containing
compounds might also occur in the evaporator room The three
evaporators operate with only one containment dike which drains
back into the plating shop
• No pumps were noted in the evaporator room to backup the sump nor
in the plating room to backup sumps beneath the floor planks No
other backup systems of equipment were observed to be available
• The evaporators had an exhaust stack without a scrubber The
exhaust was released directly in front of an open, second-story
window.
• The only active mitigation system in place is the sprinkler
system. Although the plan lists emergency equipment, the
designated storage location for this equipment was not found
during the inspection
• There were no automatic shutoffs for pumps leading to the
evaporators.
• The eye washing facility in the process area was not functioning
and was in a remote location.
• The facility uses no hazard identification system for the tanks in
the process area
Facility Emergency Preparedness and Planning Activities
• The emergency response plan, in the form of a Preparedness
Prevention and Contingency (PPC) plan, has been finalized and is
expected to be implemented immediately. Plot plans and maps of
the surrounding community are noc maintained in a updated
condition. No simulation exercises have been conducted and no
emergency response training courses are provided There is no on-
site meteorology station.
• The facility operates 40 hours per week and only has electronic
off-hours security. The facility has no procedures for
communicating hazards information to emergency responders in the
event of an emergency incident during off-hours.
• An audible alarm system which was observed on various floors was
manually operated.
58
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Community and Facilicy Emergency Response Planning Activities
• The facility does not have active participation with the LEPC,
although it has submitted reports and notifications as required by
SARA Title III
Public Alert and Notification Procedures
• No formalized procedures have been developed for notifying the
public of a release, nor are there any lists of community contacts
showing applicable telephone numbers
Recommendations:
Process Information
• Several leaking valves on vats and tanks should be repaired or
replaced Locks on valves should also be considered
Deteriorated valves and tanks are the most likely places for
releases to occur and should therefore be a maintenance priority
• Ventilation of the process area should be improved wich fans of
higher CFM (cubic feet/minute) Extending the evaporator stack
above the roof line or other ventilation enhancing methods should
be pursued
• Numerous occupational hazards in the grinding and polishing areas
should be rectified, e g , unguarded wheels, clogged or
malfunctioning exhausts on some machines, nonexistent goggle signs
(these should highly visible and bilingual) and unenforced
measures for hearing protection
• Lunchroom facilities need improvements, rooms should be completely
enclosed and holes in the walls should be repaired Restriction
of coffee drinking and smoking in work areas should be better
enforced.
Chemical Accident Prevention
• An incentive program may be helpful to increase the employees'
adherence to the facility's stated policies and improve their
overall attitude toward safety
• Not only should MSDSs be made available, but the chemical hazard
information should be part of all SOPs taught during orientation
training.
• Preventative maintenance should be performed on a regular basis on
all equipment.
-------
. A formal training program for new employees and periodic refresher
training for site specific chemical hazards is recommended to
promote safety awareness of the facility's employees.
• Hazard identification of tanks in the process area could be
improved by utilizing the Hazardous Materials Identification
System.
• "Separate diking should be constructed on the plating floor for
acid areas and cyanide plating solution areas to avoid continuous
mixing of spillage Also, the liquid level in the diked areas
should be kept at an absolute minimum Adequate backup storage
for untreated wastewater is not available and this could
contribute to a potentially hazardous discharges into the city
sewer system.
• Evaporators should have separate diking and sump systems to
prevent an accidental mixing of incompatible materials on the
plating shop floors. Better controls and monitors should be
installed to avoid spills
Facility Emergency Preparedness and Planning Activities
• Because the facility operates 40 hours per week and the only
available off-hours security is electronic, a lock box system
containing emergency information placed outside the building or
fence might be considered Emergency information such as MSDS
sheets, a hazardous materials inventory and their location, and
the names of emergency contacts would be invaluable to first
responders.
• Many major issues needing resolution have been identified by the
Pennsylvania Department of Environmental Resources (PA DER) with
respect to preparedness an planning activities. PA DER recommends
that Falkenstein Inc include in their plan, for example, a
topographic and a site map in the plan and address such elements
as maximum inventory amounts and the distance between the acids
and the cyanides.
• Accessibility and usability of the eye washing facility in the
process area should be improved
• The manually-operated audible alarm system may need to be
supplemented with visual alarms due to the noise level'inherent to
the machinery used. The installation of a visual alarm system,
i.e., flashing lights, would be useful for alerting personnel in
high-noise areas in the event of an emergency It would also
serve as a backup should e\:st:ng alarms malfunction
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Audit Team Member Composition.
Mame and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Dr Walter Lee, On-Scene Coordinator/Audi;
Team Leader
EPA - Region III
Technical
Chemist
Jack Owens, On-Scene Coordinator
EPA - Region III
Management
Fire Prevention
Joe Popp, AARP
EPA - Region III
Management
Occupational Safety & Health/Management
Policy
Jerry Janda. Battalion Chief, Hazmat
Administrative Unit
Philadelphia Fire Department
Fire codes
Fire/Hazmat
Joe McAleer, Captain, Hazmat
Administrative Unit
Philadelphia Fire Department
Fire codes
Fire Prevention
John Hadalski, Chief Analyst with the
Managing Director's Office
Philadelphia Office of Emergency
Management
LEPC
State and local
Jeffrey Lieberman, TAT
Roy F Weston
Technical
Chemical Engineering
Dennis Matlock, TAT
Roy F Weston
Management
Environmental Planning
Michelle Fox, TAT
Roy F Ueston
Technical
Chemical Engineering
61
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Follow-up Activities
By the Facility
• M/A
By the Regional Office:
• N/A
By State and Local Authorities
• N/A
Regional Contact-
Joe Popp
215-597-1357
62
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Aucomaca, Inc
Facility Location
Sterling, Loudon County, Virginia, Region
III
Date(s) Audit Conducted:
January 31 - February 2. 1990
Description of Facility:
SIC Code(s):
Location:
Products manufactured,
produced, or distributed:
Proximity to
sensitive populations:
SIC 3471 - Electroplating, plating,
polishing, anodizing, and coloring.
Suburban area 30 miles outside of
Washington, D C
High quality, multi-layer printed circuit
boards.
The following facilities are within
approximately one mile of Automata
Loudon Hospital Center. Reston Hospital
Center, Fair Oaks Hospital Center, and
Medex (Corporate Care)
Reason for Facility Selection:
ARIP Reports:
The facility was chosen because of a
facility explosion and resulting employee
death. A machine used for surface
treatment of printed circuit boards needed
additional sulfuric acid, and an operator
mistakenly added sodium chlorate. These
incompatible materials generated hydrogen
gas which ignited and exploded One
worker was fatally injured.
None prior to audit
Focus of Audit:
Hazardous Substance(s)
Examined:
Sulfuric Acid
Nitric Acid
63
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Hydrochloric Acid
Fluoboric Acid
Sodium Hydroxide
Ammonium Hydroxide
Sodium Chlorite
Sodium Persulface
Sodium Chlorace
Physical Area(s) Examined at the Facility:
Storage and Handling
• Storage Systems
• Shipping/Receiving
All stock chemicals are stored in locked, segregated storerooms
Incompatible materials are separated by distance but not always by
diking. Stock chemicals chat are not immediately used are stored OP che
shop floor Bulk chemicals are brought in by tanker truck and pumped
into tanks
Process Area(s)
• Wet processes of plating and etching multi-layer printed circuit
boards
After receiving digital data specifications from a customer. Automata
designs a circuit board using a graphical database Automata then
chooses the appropriate panel laminated with epoxy glass coated with
copper plate. The panels are first cleaned with sodium persulfate acid
and are then laminated with a dry film monomer. After using ultraviolet
(UV) light to polymerize the laminant, the surface of the board is
prepared with sodium carbonate An ammonium hydroxide etch then removes
excess copper from between or around the desired circuit paths After
this, the UV polymerized laminate can be stripped off.
After inspection, the panels are run through the Black Oxide process
and then the layers are bonded together using heat and pressure. Holes
are drilled to act as interconnections between the layers and copper is
deposited into the drilled holes to establish the circuits between the
layers. The plated panels are again laminated and hardened or cured
with UV light.
To protect the copper circuitry, a tin-lead solder plate is used to coat
the circuitry. Any excess copper can be etched off with ammonium
hydroxide, and excess solder can be removed with ammonium bifluoride
-------
Summary of Audit Findings and Recommendations.
Conclusions:
Process Information for Hazardous Chemicals
• In several instances acids were scored near oxidizers Access Co
_the flammable storage cabinet in che storage area was limited
The backup supply of ammonium hydroxide is kept in drums in a
hallway restricting access through the hallway
• Waste storage areas have been established outside of the facility
building Some drums are stored under shelter, but many drums
containing waste materials incorrectly labelled, and not stored
under cover
• The gravity fed drainage line in the plating area backs up A
major tank release would flow across the floor, bypassing che
treatment area due to the overflow
• The plating area is provided with a centralized control panel
through which critical parameters can be monitored
Chemical Accident Prevention
• A variety of controls are built into the standard operating
procedures as safeguards against spill and process shut down For
example, a tank leak will be detected because heaters
automatically shut off when the liquids in the tank falls below a
specified level
• General employee training is conducted for all new employees prior
to assignment to their work areas and at least annually
thereafter.
• All employees are required to attend a one-hour communication
program describing in detail the chemicals and chemical hazards at
the facility. Passing an English exam is also a requirement to
ensure that all personnel can read and understand operating
procedures and Material Safety Data Sheets.
• A designated Chemical Maintenance Team (CMT) has been trained to
manage waste treatment, chemical handling, and bath QA/QC.
• Preventive maintenance is a management priority because
production schedules and contractual obligations make any
unscheduled shutdown a major problem
• The facility is not using any formal hazard evaluation techniques.
nor does the facility have any air modeling data.
65
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The plant is equipped with a trench system
potential spill that may occur in the plant The tank area is
diked to contain the chemicals in the eventuality or a uan.
collapse
The waste stream to the Automata effluent treatment system is
Segregated into acidic, basic, and chelating solution steams
Accident Release Incident Investigation
A review of Automata's accident records revealed only minor
incidents - excluding the one fatality in May, 1988
Facility Emergency Preparedness and Planning Activities
Automata has a draft Emergency Response Contingency Plan that
defines and outlines planning, execution, and follow-up or
response operations for emergencies occurring at or attec^n§ ^
facility The draft emergency plan does not include a map to ,he
nearest hospital, a detailed site map, a schedule for simulations
with local responders, nor does the plan establish a backup
communications system or designate an alternate command post
Currently, the facility depends on external resources provided by
Loudon County for emergency response situations
An evacuation drill will be held at least semi-annually for each
shift
Automata has a safety network which includes an audio and visual
fire alarm system with available backup power, complete fue
Jorinkler coverage within the plant, well-marked evacuation and
exit routes prominently displayed material safety data sheets.
ana" use of the Hazardous Materials Information System labelling
system.
The spill team will be trained and prepared by April 1990 At
*• " . „ *__•-.»,.*. *r\A col F-rontained breai
proper use. A medical monitoring program has not been
established.
Community and Facility Emergency Response Planning Activities
Automata's "emergency response plan" provides for communication,
coordination, and mutual aid with the community
The management at the facility «^eVh"ar? •^"
industrial hygiene surveys, and regularly coordinates
community and the LEPC.
66
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Public Alert and Notification Procedures
• The facility, through the LEPC, has developed procedures for
notifying the public when a releases has occurred The procedures
have not yet been used in an actual emergency One constraint
associated wich on-site procedures and systems is that
communication with local government officials requires a long-
distance phone call.
Recommendations:
Process Information for Hazardous Chemicals
• Acids should not be stored near oxidizers These materials should
be separated, for example, by an individually diked acid storage
area For efficient leak detection and ease of movement, all
drums should be kept on pallets Access to the flammable storage
cabinet in the storage area should be cleared in case fire
fighting is required. Fire detection in the main chemical storage
area could be improved with the installation of smoke detectors
The backup supply of ammonium hydroxide that is kept in drums in a
hallway could be moved into the containment structure for the bulk
tank of ammonium hydroxide to avoid restricting access through the
hallway
• Drums in the in-process chemical storage areas on the plant floor
should also be placed on pallets for more efficient leak
detection Incompatible materials could be more effectively
separated; for example, by building open ended storage stalls with
the epoxy coated bricks used for diking in the main storage area
Access to this area should be restricted perhaps by several posts
strung with rope or chain as a physical barrier to avoid
mishandling of chemicals.
• The drums stored in the waste storage areas outside of the
facility should be stored on pallets in a clearly marked storage
area and labelled as to whether they are empty or contain trash or
chemical waste. Trash cans should not be stored near containers
of chemical waste.
• There should be some effort to improve drainage capacity in the
placing area; for example, deepening the trench or installing
small pumps.
• Drums taken from chemical inventory should be clearly marked as to
their contents and potential hazards.
• Simple monitoring could be performed with a pump kit and
appropriate colorimethric tubes at critical wet process areas, if
a release is suspected, to give valuable chemical information to
responders.
67
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Facilicy Emergency Preparedness and Planning Activities
• The waste storage areas should appear on all planning maps to aid
response efforts to fires or chemical accidents
• Training for the Chemical Maintenance Team members in spill
handling and mitigation is encouraged as is the use of personal
protective equipment. A medical monitoring program should be
established for personnel
• Planning and preparedness efforts could be aided by the following
additions/modifications to the current emergency plan
Include a map to the nearest hospital,
Include a more detailed site map;
Schedule simulations with local responders,
Design an alternate command post,
Establish a backup communication system, and
Include discussions of "what if" scenarios to weekly and
monthly safety meetings
Audic Team Member Composition:
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Walter Lee, On-Scene Coordinator/Audit
Team Leader
EPA - Region III
Technical
Chemist
Philip Younis, On-Scene Coordinator
EPA - Region III
Management
Civil Engineering
Kevin Shine
Loudon County Health Department
Technical
Emergency Planning
Jeffrey Lieberman, TAT
Roy F. Weston
Technical
Chemical Engineering
Thomas Barsley, TAT ,
Roy F Weston
Technical
Chemical Engineering
68
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Name and Title
Affiliation
Area of Responsibility
Expertise
Dennis Matlock, TAT
Roy F Weston
Management
Environmental Planning
Follow-up Activities-
By the Facility:
• N/A
By the Regional Office:
• N/A
By State and Local Authorities
N/A
Regional Contact:
Joe Popp
(215) 597-1357
-------
CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Mobay Corporation
Facility Location'
New MartinsvLLle, Marshall County, Vest
Virginia, Region III
Date(s) Audit Conducted:
February 12 - 16, 1990
Description of Facility:
SIC Code(s):
Location:
Products manufactured,
produced, or distributed:
Proximity to
sensitive populations:
SIC 2816 - Inorganic pigments, SIC 2869 -
Industrial organic chemicals, not
elsewhere classified
100 miles east of Columbus, Ohio, in a
rural, residential area of the Ohio Ri"er
The four major divisions are polyurethane
inorganic chemicals, coatings, and
plastics and rubber
Air Products Corporation and PPG
Industries are just to the north The
small communities of Kent and Proctor are
within several miles to the north and
south, respectively
Reason for Facility Selection:
ARIP Reports:
The facility was chosen because Mobay
Corporation reported nine significant
releases of hazardous materials, such AS
nitrogen dioxide, Freon-12,
toluenediamine, and sulfuric acid vapor
8/29/87 ethylene oxide release; 3/25/8'?
dichlorodifluoromethane release
(questionnaire completed on 8/21/89).
3/6/89 nitrogen dioxide release
(questionnaire completed on 8/21/89)
4/29/89 nitrogen dioxide release
(questionnaire completed on 8/21/89) .
6/9/89 nitrogen dioxide release
(questionnaire completed on 11/20/89)
70
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Focus of Audit:
Hazardous Subscances(s)
Examined:
Carbon Monoxide
Chlorine
Dinitrotoluene (DNT)
Hydrochloric Acid (HCL)
Hydrogen
Mechanol
Nitric Acid (NA)
Nitrogen Dioxide
Orthodichlorobenzene
Phosgene
Sulfuric Acid
Toluenediamine (IDA)
Toluene Diisocyanate (TDI)
Physical Area(s) Examined:
Storage and Handling
• Storage Systems
• Material Transfer
Ammonia is stored in railcars on-site and in a 28,000 gallon, insulareo
vessel. Pressure relief valves vent approximately sixteen feet abo1 e
ground level to reduce potential worker exposure
Toluene is stored in 600,000 and 300,000 gallon tanks, which have cla -
lined dikes that drain to the wastewater treatment unit
Dinitrotoluene is stored as a liquid in two 20,000 pound, insulated
tanks within a wire mesh cage to restrict access. The tanks have hear
sensors and deluge systems which activate automatically in case of
overheating -- temperature and level is carefully controlled.
Sulfuric acid is held in diked 80,000 gallon and 40,000 gallon tanks
Approximately 100,000 pounds of methanol is stored near the TDA unic
TDA is scored under nitrogen (to prevent moisture from contaminating ;
TDA) ac 110 degrees centigrade in an 80,000 gallon storage tank thac -^
insulated and steam heated
Two 300,000 gallon and one 20,000 gallon tank hold TDI product. Tar'r.s
are set on a concrete base and sloped so that spills drain into the
process trenches. TDI storage tanks are maintained on a monthly
maintenance schedule, inspected every five years for thickness, and
their pressure indicators are checked weekly.
71
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On-sice oxygen scorage is being eliminated by construction of a pipeline
from the nearby Air Products facility
Toluene is brought to the facility in barges and transferred using
submersible pumps, a checklist is completed to ensure secure
connections The toluene level is checked every two hours by the
operators, who maintain radio communication with the barge and the plant
control room Pumps are used to transfer toluene from storage to the
processing unit, and in case of leaks, the pump valves can be closed
from the dike by remote control
DNT transfer pumps have heat sensors that automatically shut che pumps
if overheating occurs
Sulfuric acid is transferred into the plant by tank trailers Tank
level indicators are maintained at the tanks and in the control room, so
that levels can be monitored at both locations
Natural gas is purchased from the local utility for use throughout the
plant
Carbon monoxide is transported through a closed system to the TDI unit
and hydrogen is transported through a closed system to the TDA unit
Bulk transfer of chlorine, TDA, and TDI is conducted by pipeline from
storage tanks and/or railcars. TDI is handled in a completely closed
system from storage tanks to railcars. The TDI system has one line for
the liquid product and one for TDI vapor.
Carbon monoxide and hydrochloric acid off-gas are transferred by
pipeline to the HCL unit.
Liquid chlorine is transferred from stationary railroad cars to process
pipelines, strict procedures exist to ensure safe handling, including a
checklist for unloading rail cars.
Process Area(s)
• NA Unit
• Nicrations/Sulfuric Acid Concentration (N/SAC) Unit
• Reformer Unit
• TDA Unit
• TDI Unit
Nitric acid is produced in an oxidation reaction between ammonia and
oxygen, which are purchased by Mobay as feedstock for the reaction The
nitric acid becomes feedstock for the N/SAC unit.
The nitrations unit produces DNT when toluene undergoes two consecutive
nitration reactions with nitric acid in the presence of sulfuric acid,
which is used as a dehydrating agent to remove water produced as a
72
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byproduct in the formation of DNT The SAC unit reconstitutes che scene
sulfuric acid used within the DNT unit.
The reformer unit produces hydrogen and carbon monoxide gas through the
reaction of natural gas (methane) and steam (water). The hydrogen is
used as feedstock in the TDA unit and carbon monoxide is used as
feedstock in phosgene production in the TDI.
The TDA unit receives DNT from the nitrations unit and hydrogen from the
reformer unit as feedstock TDA is produced by the hydrogenacion
reaction of DNT and hydrogen.
The TDI unit produces the TDI from a reaction between TDA and phosgene
The phosgene is produced within the TDI unit by the reaction of carbon
monoxide from the Reformer unit, and chlorine Approximately seventy
percent of the TDI prod'.. i is used to manufacture polyurethane products
in a separate unit of th lant.
Hydrochloric Acid is produced as a byproduct from the reaction of TDA
and phosgene It is sent to a separate unit within the plant where it
is diluted and then sold or used as final product.
Summary of Audit Findings and Recommendations:
Conclusions:
Facility Background Information
• The current TDI unit was constructed in 1963, and capacity is nov
approximately 100 million pounds per year. Most of the TDI
produced is used for the manufacture of specialty products for the
furniture, appliance, and automobile industry.
• Mobay has a permitted wastewater outfall to the Ohio River, with
approximately 4 million gallons of wastewater processed each day
and released into the river at a rate of 2,800 gallons per minute
• DNT building windows, made of explosion proof glass, are designed
to drop out to minimize flying glass in an explosion.
Process Information
• There are problems with drum storage practices at the facility
One empty-drum storage area contained drums stacked five tiers
high leaning precariously Unlabeled, deteriorating drums were
scattered a various places throughout the plant. Drum storage
areas were not clearly marked as to type of .storage or drum
contents. Unclear labeling also occurs with storage tanks Plant
employees may be well aware of tank contents, but a lack of clear
labeling could pose a problem for uninformed or contractor
personnel during a release incident
73
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Tank farms are checked visually, there is no backup alarm syscem
The epoxy coating protecting the containment structure at the tank
farm is worn and deteriorating
Nitric acid unit equipment can be drained into a leak tank, and
subsequently pumped back into the process
Distances between equipment and shutoff valves have been minimized
to reduce potential worker exposure
A proprietary scrubber system collects nitrogen dioxide not
consumed in the process for reuse
Operators monitor the nitric acid process and routinely inspect
the equipment each shift, guards monitor video cameras placed at
strategic points
Oxygen sensors are placed along the Mobay-Air Products property
line, and an alarm sounds in the control room if an abnormally
high level of oxygen is detected
Nitrogen dioxide emitted from the stack is analyzed every three to
five minutes; the sensor is recalibrated weekly.
Critical pumps in the DNT unit contain heat sensors, so that an
automatic shutdown will occur in case of overheating
The DNT control room has its own breathing air supply (as does the
TDI control room), bottled air SCBAs, and escape packs
Two sets of controllers are used to monitor COPs and are linked to
a deviation alarm. Backup safety systems are part of the controls
and shutdown the plant automatically in case of an emergency
Critical electronic controls have battery backup systems so that
they are operational in case of a power failure.
Logs are kept for COPs in the control room and readings are
recorded every two hours. Operators also perform a walk-through
of the plant every two hours
Plant perimeter monitoring is done by personnel in vehicles, some
of which are equipped with SCBAs
Monitoring systems in the reformer unit have a two-phase warning
system --an alert status for all deviations and a unit alarm
status for emergency shutdown.
Because of the significant explosive hazards, leak detection in
the reformer unit is performed by monitoring pressure within the
unit, carbon monoxide levels, and combustibility levels.
-------
• Operating or maintenance personnel working within the reformer
unit for 15 minutes or longer are required to carry personal
carbon monoxide monitors.
• The TDI unit has color-coded pipelines to simplify identification
of chemicals that could be leaking
• A laboratory near the reformer unit is poorly ventilated A
build-up of fumes due to the lack of ventilation devices such as
fans or vents was noted during the audit
Chemical Accident Prevention
• Capital or policy changes required are supported by management as
a priority.
• Standard operating procedures for the nitric acid unit are
maintained in the control room, critical steps are highlighted
• Standard operating procedures for the N/SAC unit are available IP
the control room They are updated periodically, with interim
additions inserted manually. SOPs are systematic and contain
contingency plans for probable emergencies
• Standard operating procedures for the reformer and TDA units are
available to operators in the control room The SOPs are complete
and comprehensive, and address process and equipment operating
procedures, general unit operating procedures, operation
parameters, and emergency procedures. Each section lists
procedures separately, and is organized for quick reference
• Reformer and TDA unit emergency procedures provide for a safe and
uniform response to specific emergency situations.
• Standard operating procedures for the TDI unit follow stringent
safety guidelines Critical operating parameters are set to
ensure immediate shutdown of the unit if any parameter reaches
abnormal levels. Shutdowns are either automatic or manual, and
can be executed by any operator.
• TDI operating manuals are located in the control rooms and
emergency procedures are posted on the control panel board
• Line management is responsible for training their own people. The
training department employs both full and part time trainers, with
various experience and backgrounds.
• New employees receive in-unit training. The training modules are
reviewed annually and modified as needed. Tests are administered
to ensure trainee competence and a checklist tracks individual
performance. Hazardous chemical training is based on exposure to
specific chemicals in the unit
75
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Unit foremen are usually promoted from below, and receive
supervisory training and a three-year program of technical
courses Other training, such as on spill response and
environmental legislation, is available on- and off-site
Training is tracked by the training department. Training due to
major process modifications or new equipment is provided either
-annually or as needed
Mobay uses a system called Maintenance Management Information
System to track and monitor preventive maintenance The program
generates work schedules, tracks equipment history, issues v.ork
orders, maintains spare parts control, and does cost reporting
Maintenance shutdowns have become more efficient Fault
indications can also be recorded and tracked, and trend histories
can be generated and analyzed to determine problem areas
Maintenance inspections and preventive maintenance are performed
with varying frequency depending on the criticality of the unit
Areas for lubrication are checked twice a week to avoid equipment
burnouts About 250 out of 1,100 employees are maintenance staff
and four are employed full-time for preventive maintenance
Mobay routinely performs HAZOP studies to evaluate process safety
hazards for capital additions and process modifications HAZOP
studies are also conducted regularly at all facilities and after «
release or near miss.
The HAZOP team, consisting of line, maintenance, and management
personnel, develops a list of significant deviations from
operating parameters to address with new procedures or equipment
Routine reviews are planned for existing units every five years
lasting from one-half to a full year depending on the complexic/
of operations For minor modifications, a checklist version of
HAZOP is used to streamline the process and avoid repetition
HAZOP studies are part of the larger project safety review whicn
is performed during unit start-up and are typically performed
while the model/layout of the unit is being reviewed
Internal audits and HAZOP studies ensure that SOPs and safety
equipment are in accordance with current production parameters
Mobay uses the CHARM software package for dispersion modeling
The model is used occasionally for realtime response data, but is
more often used to run worst-case scenarios for planning purposes
Computer simulations and real life emergency response experience
has provided Mobay personnel with familiarity with typical plume
dispersions under normal weather conditions.
76
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The company has containment booms and a boat to deploy them in
case of a toluene spiLl at the unloading area
Reformers may be shutdown independently, either manually or
automatically, and backup generators can provide sufficient pov/er
to conduct an emergency shutdown
Each reformer is equipped with flare stacks as a primary
mitigative system in the event of a pressure increase
Reformers are also equipped with a nitrogen gas purge system to
mitigate threats associated with a gas leak resulting from an
equipment or piping failure
Each hydrogenator in the IDA unit vents to the steam quench tank
in the event of a pressure build-up Materials in the steam
quench tank then enter the process trench, and any solids are
removed and burned in the on-site fluid bed incinerator
The process trench system surrounds every production unit at the
site and directs liquid flow to the wastewater treatment unit
Relief valves discharge phosgene through a closed system to an
ammonia-steam whistle stack for neutralization.
TDI unit phosgene release mitigation systems are the steam-ammonia
curtain used only for major releases, the emergency tank and tower
dump system for malfunctions within the phosgene section, ard the
spot vent decomposition system to collect and decompose small
leaks and emissions from sampling and maintenance
TDI unit monitoring systems include a perimeter monitoring system
for phosgene; a control room monitoring system for phosgene and
chlorine; and portable carbon monoxide, phosgene, and chlorine
monitors for inspections or to identify known leaks
The storm sewer which is not continuously piped and at certain
spots, piped drainage runs across graveled areas toward another
pipe connection. A chemical spill that breaches containment would
percolate down through the soil upon hitting the graveled areas
All storage tanks in the unloading area are properly diked and are
lined with impermeable clay to minimize groundwater contamination
DNT unit drains are stainless-steel lined to minimize seepage
The nitric acid storage tank is surrounded by a concrete wall, has
a brick-lined floor, and a stainless steel trench to the facility
wastewater treatment plant
77
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Facility Emergency Preparedness and Planning Activities
• The Mobay Emergency Action Plan is updated on a regular basis, at
least once per year or as needed to address potential accidents
• If an emergency escalates beyond in-plant resources, there is a
cooperative agreement with the Northern Ohio River Industrial
.Mutual Aid Council (NORMAC) A hotline telephone network can
mobilize member industrial facilities or local and state agencies
• The plan clearly specifies a chain of command to ensure all
responders receive authorized assignments in order to maximize
safety during a large-scale response
• The local area has been divided into three zones for the purposes
of efficient traffic diversion
• The emergency plan is routinely exercised through plant
simulations and drills within the community co maintain a high
level of preparedness
• Operators in the TDA unit are trained and have mock drills
quarterly to ensure emergency preparedness
• Mobay has designated both a Plant Emergency and a Fire and Gas
Brigade, maintained on all shifts, to handle fire and chemical
emergencies. The team receives annual training at the Corporate
Hazardous Material School, and training is also conducted on-site
in the classroom and in mock drills.
• DNT unit process and storage areas are equipped with fire
protection equipment. Fire stations, heated to minimize freezing,
house water headers and firefighting equipment near each unit
Portable firefighting equipment is also available.
• The water supply is the Ohio River and backups are diesel-powered
pumps which operate automatically in the event of pressure loss or
a power failure There is a facility fire truck
• There are heat sensors and a deluge sprinkler system in the DNT
storage system and in the toluene storage area and the nitrators.
and foam can be connected to the systems in the toluene unloading
and storage areas. The unloading area has three fire nozzles to
supply foam or water
• In addition to safety showers and eyewashes, there are "jump
tanks," horse-trough-sized containers filled with water and heated
for employees exposed to nitric acid.
-------
Response equipment is maintained ac fixed locations and in mobile
units to facilitate quick response The response teams have
access to personal protective gear, monitoring/detection
instruments, leak patching kits, and decontamination gear
There are seven fixed fire monitors on the perimeter of the TDA
unit and another near the methanol storage tank. There are also
cv/o hand-held foam stations near the methanol tank dike area
All equipment is maintained and checked on a regular basis, and
all personnel using the gear must be certified according to OSHA
regulations
A supply of vermiculite/lime is maintained within the TDI unit to
neutralize liquid phosgene releases within the unit perimeter
Tergitol is stored adjacent to the TDI storage tanks and is used
to neutralize TDI in the event of a spill
The Emergency Operations Center (EOC) is a well-equipped
communications center and command post Internal and external
radio systems are available, and data from the plant weather
station is fed directly into a computer for aid modeling
Computer and hardcopy files store chemical hazard information.
The EOC also has its own air supply in the event of a release
Plant emergency procedures are reviewed by new personnel upon
hiring, on a semi-annual basis, during a plant or department
drill, in the event of job transfer or appointment to new
responsibilities which involve specific plant alert actions
A plant evacuation flow sheet is posted in every department for
quick reference.
During a general plant alarm, there are three means of
communication to initially warn personnel of an emergency
The fire and gas alarm sounds a primary alarm;
The public address s>stem can broadcast announcements co the
entire plane for notifications, partial evacuations, or
complete evacuations,
Most plant radios are used to monitor transmissions for
first hand information and are designated as having a
"listen only" function ^o avoid confusing crosstalk
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Community and Facility Emergency Response Planning Accivicies
• Mobay publishes an annual community newsletter to inform the
public of its emissions inventory, plans and programs to reduce
the storage volume of chemicals, and news of the emergency teams
available to protect Mobay and the surrounding communities
• -Mobay has regularly submitted section 304, 311, 312, and 313
reports as required under SARA Title III
Public Alert and Notification Procedures
• A community alert/notification system was installed to communicate
warnings or emergencies to area residents This warning system is
also available for use in the event of natural disasters There
is, however, a discrepancy between the plant-wide alarm signal and
the community signal
Recommendations:
Process Information
• The facility should address problems with drum storage practices
One empty-drum storage area contained drums stacked five
tiers high leaning precariously High winds from the ri"ei
could have caused them to fall over
Unlabeled, deteriorating drums were scattered a various
places throughout the plant Drum storage areas were not
clearly marked as to type of storage or drum contents This
could lead to problems during a fire fighting effort by
agencies outside of the plant resources
Unclear labeling also occurs with storage tanks. Plant
employees may be well aware of tank contents, but a lack of
clear labeling could pose a problem for uninformed or
contractor personnel during a release incident.
• Tank farms are checked about once every two hours. This visual
check might be better suited as a backup for an automated alarm
system because a dependance on visual checks could allow a leak :>•>
go unnoticed for up to two hours.
• The epoxy coating protecting the containment structure at the r.-i. 'r
farm is worn and deteriorating. This should be replaced and
serviced regularly to prevent breakdown of the concrete.
• A laboratory near the reformer unit is poorly ventilated A .
build-up of fumes due to the lack of ventilation devices such *•>
fans or vents was noted during the audit
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Chemical Accident Prevencion
• The facility should address the storm sewer which is not
continuously piped At certain spots, piped drainage runs across
graveled areas toward another pipe connection. A chemical spill
that breaches containment would percolate down through the soil
upon hitting the graveled areas
• During emergency venting, ammonia is released co the atmosphere
A scrubbing or recovery system would reduce the environmental
impact of these releases.
Accident Release Incident Investigation
• While plant reporting and notification procedures are commendable
Mobay may want to consider a mechanism for internal reporting of
spills under one pound if they qualify otherwise as "significant "
This ensures that management is always fully aware of the impact
of a spill, no matter how small
Public Alert and Notification Procedures
• There is currently a discrepancy between the plant-wide alarm
signal and the community alert signal The signals for emergencv
and all clear between the plant and the community should match -o
avoid any confusion during an emergency.
Audit Team Member Composition:
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Dr. Walter Lee, Senior OSC
US EPA Region III
Technical
Chemist
Philip Younis, OSC
US EPA Region III
Management
Civil Engineering
Marjorie Easton, OSC
US EPA Region III
Technical
Chemist
Joseph P. Popp, AARP
US EPA Region III
Management
Occupational Safety and Health
Specialist/Management Policy
81
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Name and Tide
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Jeffrey Lieberman, TAT
US EPA Region III
Technical
Chemical Engineer
Nona Khalil, TAT
US EPA Region III
Technical
Chemical Engineer
Thomas Barsley, TAT
US EPA Region III
Technical
Chemical Engineer
Joseph Demmler, TAT
US EPA Region III
Technical
Chemist
James Wilcox, TAT
US EPA Region III
Technical
Chemical Engineer
Roger Pauls
WV Department of Natural Resources
Emergency planning
State and local
James Geston
WV Department of Natural Resources
Emergency planning
State and local
Follow-up Activities:
By the Facility:
Mobay will practically eliminate its daily chlorine inventory of
1.2 million pounds upon completion of a one-mile chlorine pipeline
from PPG Industries to the TDI unit.
The addition of an extra storage or "dump" tank for nitric acid
which can be reused later, will improve chemical management during
shutdowns and emergencies and reduce the chances of a release
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Two transformers are co be replaced with newer models with an
improved design; if one fails, the ocher can supply electricity co
select equipment to reduce the possibility of a release An
uninterruptible power supply is scheduled for installation to
provide electricity to unit instruments during power dips
Power distribution to the pump motors will be altered, thus
.preventing the failure of one pump from interfering with the
motors of the other pump
Process interlocks will be transferred to a Programmable Logic
Controller
Mobay is planning to replace existing pipes after a failure of a
sulfuric acid pipe resulted in a spill next to a kettle, which
heated the acid and sent the vapor out through the stack
IDA unit instrumentation will soon be upgraded to a computer
system; a similar unit is being installed in the TDI unit
The emergency tank and tower dump system is being replaced due to
its failure during a 1988 release The new system will contain a
more sophisticated piping arrangement
Instrument modernization in the TDI unit includes a battery backup
for instruments to ensure power for an emergency shutdown.
By the Regional Office:
N/A
By State and Local Authorities:
• N/A
Regional Contact:
Joe Popp
(215) 597-1357
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Olin Corporation
Facility Location:
South Charleston, Kanawha County. West
Virginia, Region III
Date(s) Audit Conducted:
March 26-28, 1990
Description of Facility
SIC Code(s):
Location.
Products manufactured,
produced, or distributed:
Proximity to
sensitive populations.
SIC 2841 - Soap and other detergents,
except specialty cleaners
Approximately
West Virginia
miles west of Charleston,
Manufactures cyanuric acid, an
intermediate in the bleach manufacturing
process, and chlorinated dry bleaches
(sodium dichloroisocyanurate), made in a
varietv of concentrations
The chlorine railcar transfer point is
located approximately 800 feet from a
small shopping center.
Reason for Facility Selection:
ARIP Reports:
Three significant releases of hazardous
materials were reported in 1989 The
chemicals released include chlorine,
ammonia, and sulfuric acid. These
incidents as well as the sensitive
location of the plant, prompted the audit
of the facility.
6/12/89 Ammonia release (questionnaire
completed on 11/6/89); 5/19/89 chlorine
release (questionnaire completed 11/6/89)
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Focus of Audit1
Hazardous Substance(s)
Examined:
Anhydrous Ammonia
Chlorine
Cyanuric Acid
Hydrogen Peroxide
Sodium Dichloroisocyanurate
Sodium Hydroxide
Sulfuric Acid
Trichloroisocyanuric Acid
Urea
Physical Area(s) Examined at the Facility.
Storage and Handling
• Storage Systems
• Shipping/Receiving
• Material Transfer
Feedstock for the cyanuric acid unit includes urea and sulfuiic acid
Urea is stored and initially handled in its solid state. It is
transported into the facility by railcar and/or truck, and then sent to
urea dissolution tanks, where it is converted to a urea solution This
system is classified as a closed loop system, however, some solid urea
LS airborne within the baghouse
Sulfuric acid 93 percent is also transported into the facility by
railcar and/or truck. A closed loop system exists that transfers the
sulfuric acid from the railcars to its proper storage tank by the use of
air pressure A detailed unloading procedure is available to all
employees. Furthermore, a comprehensive check list of all connections
within the closed piping system must be completed before the sulfuric
acid is transferred. The capacity of sulfuric acid tank is
approximately 20,000 gallons and sulfuric acid is unloaded every three
to four days from railcars.
The raw materials used in the manufacture of chlorinated dry bleach are
cyanuric acid, chlorine, and sodium hydroxide Chlorine is transported
by railcar. One railcar containing approximately 90 tons of chlorine is
used within a three- to five-day time period. No excess storage of
chlorine is kept on site. A closed loop cascade system is used to
transfer the chlorine liquid from the railcar to the process unit An
extensive check list is required to be filled out by employees unloading
chlorine to ensure that all connections are secure and valves operate
appropriately before chlorine is unloaded.
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Sodium hydroxide 50 percent is received by either truck or railcar It
LS transferred wichin a closed loop system to two storage tanks withn
the facility The daily capacity of both tanks is approximately 36,000
to 37,000 gallons As with unloading of all chemicals, proper
protective equipment must be worn
Proces"s Area(s)
• Cyanuric Acid Unit/Plant
• Sodium Dichloroisocyanurate Unit/Plant
Cyanuric Acid Unit/Plant Cyanuric acid (CA) is produced by pvuolysis
of urea solution in rotary kilns Material is constantly recycled to
obtain optimum conversion of urea to CA. The crude CA is cooled and is
then reacted with dilute sulfuric acid, initially at 93 percent
concentration, within a high pressure digester The product is then
cooled in a flash tank where the remaining sulfuric acid is recycled
Excess ammonium sulfate and water are purged The purified CA is then
bagged, each bag containing approximately 3400-3500 pounds of product
The bagged CA is stored in a designated building for shipment to other
facilities
The ammonium-nitrogen is removed from the purged acid in a two-stage
process with the use of 50 percent sodium hydroxide and steam The
ammonia generated in this removal process is vented to the ammonia
burners located in the calcination area.
Sodium Dichloroisocyanurate Unit/Plant. The manufacturing of
chlorinated dry bleach at various concentrations is achieved by reacting
cyanuric acid with sodium hydroxide and chlorine. The process involves
feeding the dry cyanuric acid granules into a feed make-up tank
(reacting sodium hydroxide with cyanuric acid) and then feeding the
make-up material into one of two chlorinators. An emergency separator,
which vents to a scrubber, is present within the process to prevent a
significant chlorine release The material from the chlorinators is
then passed through a centrifuge to a salt make-up tank. The feed
material reacts with 50 percent sodium hydroxide to form CDB 56
CDB 56 is further handled through the drying section of the unit It is
finally compacted into sheets of CDB 56 and then ground and screened
into six different particle sizes The final product is then placed in
tote bins, each containing approximately 3,700 pounds of CDB 56
Approximately 75 percent of the CDB 56 produced is stored in tote bins
and the remaining product is stored in fiber drums.
The production of CDB 63 is obtained by loading CDB 56 into a fluidized
bed drier, where the water molecules bonded to the CDB 56 are removed
The unreacted chlorine gas from the chlorinators is sent to a chlorine
scrubber, where it reacts with excess sodium hydroxide and is then
vented into the atmosphere
86
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Summary of Audit Findings and Recommendations
Conclusions:
Facility Background Information
• In 1985, Olin acquired the CDB facility from FMC All production
-facilities were operating at that time with the exception of
building 90, the trichloroisocyanurate (TCCA) production line
The two remaining chlorination lines operated until mid-1986
• CDB 63 and CA granular production facilities were added in early
1987. Various waste treatment, emergency recovery, emergency
containment, and yield improvement facilities have been
implemented by Olin.
Process Information
• A deluge system and photoionization detectors have been installed
within the storage buildings
• Oversized emergency holding tanks have been installed at the waste
treatment unit, which are used if a major upset has occurred
within the process.
• The facility has instituted a waste minimization program where
products which do not meet specification are recycled back into
the process. This eliminates disposal of refuse materials
• Olin has replaced jacketed pipes with stainless steel pipes
containing heat traces to improve leak detection, and uses highly
identifiable markings and placards on buildings, tanks, and pipes
• The audit team believes that the most significant accident
scenario involves the raw materials used in the bleach production
train, including chlorine and sulfuric acid or the byproducts of
cyanuric acid production, ammonia
• The audic team found that the plant area with the highest
potential for a significant accident is the chlorine loading area
• Seventy five (75) percent of the production controls are part of a
computerized, distributed control system, and Olin plans to switch
the remaining analog controls co computer. The plant power for
the control room is backed up with emergency generators
• The deluge trigger systems have backup alarms.
87
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• Several monitoring systems are in place at critical points in the
process to detect leaks or malfunctions (i e , remote cameras,
critical parameter alarms, and Draeger pumps and chemical specific
calorimetric tubes) However, there was no air monitoring
systems
• Excess dust was noted, particularly in the sodium
-dichloroisocyanurate unit The dust particles can possibly cause
chronic health effects to personnel sustaining long term exposure
The audit team also observed personnel in the unit handling
material without adequate personnel protection
• Excess water was noted on the floors throughout the entire plant
During the plant tour the audit team noted several eye wash and
shower units running unnecessarily This excess water can be a
hazard particularly when temperatures are below freezing and ice
forms.
Chemical Accident Prevention
• A statistical process control program, manually accomplished by
operators, has been established to identify problem trends within
the units The program assists in achieving maximum plant
efficiency.
• Material Safety Data Sheets are available in various areas of the
plant Workers seemed to exhibit clear understanding of safety
rules and regulations during the audit team's visit
• Critical Operating Parameters (COP) have been incorporated within
the computer base control system in order to secure proper
shutdown of the CA unit if any of the COP reaches abnormal
specification
• The CA unit can be shutdown from the control room computer system
and manually within the unit.
• The standard operating procedures within the CDB unit are more
stringent than those in the cyanuric acid unit due to the presence
of chlorine.
• In general, management, supervisors in particular, are responsible
for training their own people All personnel are trained within
six months of their employment or assignment to a position
involving hazardous waste management. Training includes general
plant safety training, RCRA draining, contingency plan training,
job-specific training, and annual refresher training.
38
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• OlLn uses a mainframe computer syscem called IMPACT to crack che
critical safecy devices and monitor preventive maintenance The
computer-generated work orders initiate routine preventive
maintenance based upon predetermined frequencies Approximate 1;.
65 of the 187 employees are on the maintenance staff
• Operating procedures for unloading all materials from the railcars
.and/or trucks are also available within the block house at the
loading station
• Olin routinely performs Hazard and Operability (HAZOP) studies co
identify and minimize hazards, to increase system reliability, co
reduce environmental vulnerability, and to continue upgrading
existing operations. However, operators are not fully involved in
these HAZOP studies
• Olin has not obtained any computer modeling capabilities and
relies heavily on the modeling programs available through che
Environmental Affairs Department located in Charleston. Tennessee
• During loading/unloading operations, a checklist is used to
monitor critical steps
• One important release prevention system is the separation of che
purged acid waste stream and the chlorinated waste stream
• At several points along the bleach production train, scrubbers are
utilized co mitigate releases of hazardous materials
• When the cyanuric acid is fed into the chlorinated dry bleach
reactor with chlorine and sodium hydroxide, an emergency separator.
and chlorine causcic scrubber are online to mitigate chlorine
releases
• After the chlorinated dry bleach is produced, it is staged in a
storage building for 24 hours prior to transfer to warehouse and
shipping preparation areas This ensures that no adverse reaccion
has occurred for a particular batch prior to shipment off-site
• Plan management does not control and track contractor training
Accident Release Incident Investigation
• Between 1985 and the present, chlorine' and ammonia were released
from the facility several cimes per year. The causes were varied
including line breaks, pover failures, and faulty valves Olin
has been concentrating on upgrades to the chlorine transfer syscem
because of its release hisrorv
-------
• Olin has been concentrating on upgrades to the chlorine transfer
system because of its release history A consultant has been
hired to study the system and to make recommendations One action
Olin has already taken to reduce the risk of release is to limit
the volume of chlorine at the facility to a single railcar
Facility Emergency Response Planning and Procedures
• The "escape masks" provided by the facility were air purifying
respirators and were not response ready in the event of an
accident
• All emergency equipment are inspected on a monthly basis and
training is held annually
• Due to the limited manpower at the plant, particularly on off-
shifts, the objectives of the emergency squad personnel are
limited to controlling minor spills, leaks, fires in initial
stages only, or other incidents which can be effectively
controlled by the available resources For larger emergencies.
the primary objective of the squad is to assist outside agencies.
such as the South Charleston Fire Department, in emergency
control, but not to fight or assist in fighting interior
structural fires.
• Since the plant is largely dependent upon outside organizations
for emergency response, measures have been taken to familiarize
fire/police department personnel with the plant layout, principal
hazards, and fire protection facilities Frequent contact bec-ef-
Olin personnel and outside agencies as well as joint training ard
planning sessions have been established to ensure cooperation ana
improve response capabilities
• All shift workers attend monthly training sessions to cover
different aspects of the facility's emergency plan
• Monitoring of chemical releases in handled by Olin's analytical
lab personnel as defined in the emergency plan. The facility
emergency plan was totally revised in 1989
• Emergency drills are held quarterly, including table-top, walk
through, and planned simulations. Drills are held during nonral
day shift working hours as well as weekends and nights. Through
critiques and discussions with other emergency planning personne:
revisions in the emergency plan have evolved.
• Emergency communication within the plant consists of 60 plus
portable hand-held radios for operators and supervisors.
90
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Community and Facility Emergency Response Planning Activities
• A designated pick-up truck and specified SCBA's are used by the
lab personnel to monitor areas of the community as needed
• Weekly classes are held with different shifts to assure complete
knowledge of emergency plan procedures on coordinating with
outside agencies
• Emergencies which require outside assistance activate an on-site
Emergency Operations Center which includes che Plant Manager
Safety Manager, Operation Superintendent. Production Engineers
Environmental Engineer, Industrial Relations Manager and local
city and county emergency responders on-hand Emergency
Operations Center personnel relieve operators of reporting arc
notification responsibilities to the local emergency communication
center and also assist in providing technical information to
response personnel. They work with local officials in handling
emergency situations on site and keep the media informed with ap-
to-date information during emergencies
• Olin has an active radio broadcast system for contacting all local
area emergency response agencies. This system is checked on a
weekly basis to ensure its operability
• LEPC personnel, county emergency services personnel, and the Loc«L
fire chief were consulted in the preparation of Olin's Emergenc-.
Plan
Public Alert and Notification Procedures
• Plant emergency procedures mandate calling 911 when there j.s r.p
emergency situation. Updates are to be made to the Metro
Emergency Communication Center (ECC) approximately every 15
minutes or when the status or incident changes.
• Communications are also made to the ECC each time a drill is
conducted.
• A specific room in the Administration Building has been
predesignated as a media room during an emergency
Recommendations:
Process Information
• The most significant deficiency observed by the audit team -.r.s
lack of air monitoring systems These systems include stack
monitoring for gases vented into the atmosphere and monitorir-;
unit perimeter/bulk transfer operations, in particular the
unloading of chlorine from railcars An air monitoring system
91
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could possibly dececc leaks more quickly and effectively then the
use of cameras currently in place The camera system in place LS
an adequate first step in spill identification, however, depending
on the position of the camera a leak may not be detected until a
significant quantity has been released Furthermore, an air
monitoring system could possibly further procect personnel wichir
an area where a release has occurred, by signaling personnel to
.evacuate the area
• Olin could improve its safety program is to prevent excess dust
from being liberated, particularly in the sodium
dichloroisocyanurace unit The audit team observed personnel in
the unit handling material without adequate personnel protection
• Plant personnel should eliminate excess water on the floors
throughout the entire plant
Chemical Accident Prevention
• Operators should become more involved in Hazard and Operability
(HAZOP) studies The involvement of personnel with hands-on
experience in a particular unit would bring the HAZOP team
information about actual events that occur on a day-to-day basis
and how these events were handled by the operators
• Plan management should control and track contractor training If
contractor training is maintained by Olin's staff, the contractors
will be cognizant of the correct safety procedures adopted by the
facility and will be able to respond more effectively in case of
an emergency
Facility Emergency Preparedness and Planning Activities
• The "escape masks" provided by the facility were air purifying
respirators and were not response ready in the event of an
accident. This policy is not permitted under EPA's standard
operating procedures, since level C protection is not to be used
where the concentration of the contaminate in the atmosphere is
unknown. Air purifying respirators should only be used when the
concentration of the contaminate is known, and in such cases the
cartridges should be preattached and then wrapped to preserve the
shelf life of the cartridges
• EPA encourages more formal critiques of drills/exercises as a
learning tool. Olin's initiative in the development of
drills/exercises to evaluate its safety policy was highly regarded
by the audit team; however, without complete documentation,
mistakes cannot be corrected or response procedures improved to
better prepare for an actual event.
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Audit Team Member Composition:
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Dr Walter Lee/Audit Team Leader
U S. EPA Region III
Technical
Chemist
Jeffrey Lieberman, TAT
U S EPA Region III
Technical
Chemical Engineer
Mona Khali1 TAT
U S EPA Region III
Technical
Chemical Engineer
Dennis Matlock, TAT
U S EPA Region III
Management
Environmental Planner
Luis Loarca, TAT
U.S EPA Region III
Technical
Chemical Engineer
Joseph Demmler, TAT
U.S EPA Region III
Technical
Chemist
Christopher Gatens
WV Department of Natural Resources, Waste
Management Division
Emergency Planning
State and local
Larry Cox, Fire Chief
Fire Department of South Charleston, WV
Emergency planning
State and local
Henry Morris
Public Safety Office of Kanawha County
Emergency planning
State and local
93
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Follow-up Activities-
By the Facility
• N/A
By the Regional Office:
• N/A
By State and Local Authorities
• N/A
Regional Contact.
Joe Popp
(215) 597-1357
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Royster Phosphaces, Inc
Facility Location:
Piney Point, Manatee County, Florida,
Region IV
Date(s) Audit Conducted:
March 20 - March 24, 1989
Description of Facility
SIC Code(s):
Location-
Products manufactured.
produced, or distributed:
Proximity to
sensitive populations.
SIC 2874 - Phosphatic fertilizers
SIC 2873 - Nitrogenous fertilizers
SIC 2875 - Fertilizers, mixing only
South Tampa Bay area approximately nine
miles north of Bradenton, Florida
Diammonium phosphate (DAP), a widely used
fertilizer material
Located within a residential/business
area, on U S Highway 41.
Reason for Facility Selection:
ARIP Reports:
The facility was chosen as a result of c
documented extremely hazardous substance
(EHS) releases. The first occurred on
February 17, 1988, when a release of
88,000 pounds of sulfur trioxide formed a
cloud of sulfuric acid mist near U S
Highway 41. On August 21, 1989, a second
release, this time of 158 tons of sulfuric
acid that had leaked into an on-site
containment area, reacted with periodic
rain and thundershowers. The resulting
vapor cloud forced the closure of Highway
41 and the evacuation of the surrounding
residential and business community Only
the second release occurred under Royster
management
None prior to audit
95
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Focus of Audit:
Hazardous Substance(s)
Examined. Ammonia
Hydrogen sulfide
Phosphoric acid
Sulfur dioxide
Sulfur trioxide
Sulfuric acid
Vanadium pentoxide
Physical Area(s) Examined at the Facility:
Storage and Handling
• Storage Systems
• Shipping/Receiving
• Material Transfer
Molten sulfur is stored in a sulfur pit prior to the oxidation process
Sulfuric acid is stored below capacity in two 5,000 ton storage tanks
and in ten 100 ton rail cars Approximately 1,500 tons of phosphoric
acid are stored on site in up to ten rubber-lined tanks. Phosphate rock
is stored freely in the on-site warehouse. For the final reaction in
the process, ammonia is stored on site in two bullets of 183 tons
capacity each All other utilized chemicals are used as intermediaries
in the processes and are not stored for any length of time Sulfur (IP
solid form) is delivered to the facility by rail, and ammonia by rail
and truck. Materials are transferred between the linked process areas
by a series of pipes.
Process Area(s)
• Sulfuric acid plant
• Phosphoric acid plant
• DAP plant
In the production of DAP, there are three separate process steps the
creation of sulfuric acid from sulfur, the formation of phosphoric acid
from phosphate rock and sulfuric acid, and the production of DAP from
ammonia and phosphoric acid. Solid sulfur is first melted by steam and
combusted in the furnace to form sulfur dioxide Next, sulfur dioxide
reacts with air triggered by catalysts, and is converted to sulfur
trioxide in five stages at a temperature of about 1,100 degrees
fahrenheit. The sulfur trioxide is then absorbed by sulfuric aci.d in an
"interpass absorption tower" creating sulfuric acid of a higher
concentration (critical to the process) In this absorption tower,
water influx and temperature must be carefully controlled to contain che
process
96
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Phosphace rock is ground into fine powder and mixed with sulfuric acid
in a reactor co form phosphoric acid and gypsum (calcium sulface) The
reactor consists of a single tank with nine separate sections in which
the slurried ground rock, sulfuric acid, and recycled phosphoric acid
are added. Inside the reactor, the temperature of the slurry is lowered
by a vacuum cooler to control the process The resulting mixture is
passed through a tilting pan filter which removes solid gypsum from the
reacted mass, and transfers the discharge as a water slurry to a gypsum
settling pond The phosphoric acid is then concentrated to about Si-
percent in a bank of three forced circulation evaporators operating
under vacuum The concentrated acid is allowed to settle to reduce
suspended impurities.
A vessel called a "preneutralizer" receives the phosphoric acid, ground
phosphate rock, liquid ammonia, and undersize materials from screenings
downstream In the preneutralizer, a slurry of ammonia phosphates of
low moisture content is formed and fed to a rotating drum called the
"ammoniator-granulator " The heat from this drum evaporates all the
water from the granular product. Excess gaseous ammonia is collected
and recovered in a scrubber The granular DAP is then fed to an oil
fired dryer, completing the drying process. The hot DAP product is
screened and then cooled to about 120 degrees fahrenheit Air containing
DAP dust from the cooler is recovered by a cyclone dust collector, a wet
scrubber, and finally by a tail gas scrubbing system
Summary of Audit Findings and Recommendations:
Conclusions:
Facility Background Information
• Some of the prominent features of the original 1966 plant design
contain potential risks by today's standards Royster Phosphates
has a documented record of long term repair and upgrade of the
facility, but some original design problems remain Dikes,
containments, and spill controls are absent from the sulfuric acid
storage area. No protection wall or guard rail exists around the
sulfur pit. Clogging has occurred in some of the drainage and
process sewer lines, and not all pipes or tanks are identified
with labels.
Process Information
• All alarms and safety shutoffs are functional and operators appear
knowledgeable of safety systems The sulfuric acid plant is
extensively equipped with alarms and automatic shutoffs, as the
facility considers that it has che highest potential for
accidental release. The phosphoric acid plant is less equipped
with such safety devices, .rd '.he DAP plant has no audible alarms
but rather an automatic sh'iro:: -..stem designed to shut down all
equipment downstream if arv 4 -?:\ piece of equipment fails.
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Chemical Accident Prevention
• The Director of Safety also serves as Traffic Manager and Manager
of Security, and as a result less than 50 percent of his time is
devoted to safety issues
• Just two key managers are identified as responsible parties in the
event of an emergency, only one of which lives in the immediate
vicinity of the facility Facility management personnel are not
trained on CERCLA and SARA Title III emergency release
notification requirements
• Physical security of the plant is lacking, as the audit team found
itself well within the plant grounds before anyone was able to
give directions to the plant office
• Royster has no formal emergency response training for employees
visitors, or contracting personnel General plant safety
instruction is given, then the employee goes to his station for
on-the-job training. The facility does not offer any continuing
safety courses or seminars
• Problems were noted with respect to housekeeping and maintenance
No process or instrumentation drawings for the facility exist
Some welds are loose in the phosphoric plant, and standing water
has helped corrode some of the floor grates in the facility. No
corrosion monitoring system currently exists Other maintenance
problems include bulging sulfuric acid process tanks, leaky
bearings on select pumps, thin insulation of steam piping in the
sulfur pit area, dirt build-up on the instrumentation panels, and
piping partially obstructing walkways.
• Royster employees had no basic understanding of the techniques for
hazards analysis, nor had one been conducted for the facility
Further, the facility has no protocol for identifying the presence
of specific hazards, and has no knowledge of the population or
resources at risk, nor the consequences of exposure in the event
of a release.
• Royster has plentiful and assured supply of water from deep water
wells drilled in 1986 for emergencies
Facility Emergency Preparedness and Planning Activities
• Emergency planning has been outlined in broad terms. There are no
detailed written emergency procedures for protecting personnel and
for communicating with the surrounding residential and business
sectors. The facility has no published guidance on safety from
the corporation's headquarters
-------
• Fire fighting equipment includes a supply hose, a portable pump in
a central fire shack, and a number of fire extinguishers
distributed throughout the facility There are no emergency
vehicles and no piping diagrams for the fire water system No
formal chain of command for combatting fires, explosions, or
releases exists
• Problems were noted with the emergency communication equipment
The page system works only in part, and the emergency alarm system
does not work at all
Community and Facility Emergency Response Planning Activities
• Community interaction by Royster has been very limited The
company has no systematic procedures for public notification and
alerting. Royster Phosphates has no membership in either the LEPC
or CAER community awareness programs (Manatee County initially had
no LEPC body) The facility has not conducted any emergency
exercises or drills with the community, and has not identified
emergency corridors for access, evacuation, or rescue
Recommendations:
Facility Background Information
• The facility should investigate possible improvements for the
plant design Dikes, containments, or spill controls could be
added to the sulfuric acid storage area. Guard rails and warn-*
lights should be considered for key points in the plant (e g
sulfur pit, reactors, etc) The facility may also want to
consider clearing drainage and process sewer lines regularly ~o
prevent clogging Use of concrete or other permanent floors •• ov.'.'..
permit free drainage and easy cleaning. Pipes and tanks should >~
labelled or color coded In general, any new design for the
facility should meet modern safety standards.
Process Information
• Although the facility has a number of alarms and safety shutoffs
Royster has no routine monitoring capability for the presence o:
hazardous chemicals The facility should consider such monitor
particularly for hydrogen sulfide, and for ammonia at one or c»o
points in the ammonia unloading and handling area. Hydrogen
sulfide may not pose a threat to the community, but emission fron
sulfur pits should be of concern to personnel working in these
areas.
99
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Chemical Accident Prevention
• Royster should consider developing a safety doctrine on the
corporate level, and standardize it throughout the company A
list of standard safety procedures for all employees covering all
aspects of the workplace should be included.
• The facility should consider hiring a full time Health and Safety
Manager, due to the lack of available time that the current
Director of Safety can devote to purely safety-related issues
• On-the-job training without initial formal safety training
provides the employee with a narrow focus only on his particular
task. Along with an initial course on plant safety, the facility
should consider offering continuing courses and seminars related
to safety issues. Royster should either implement a standard
safety training procedure for contractors and visitors to the
facility or conduct full time monitoring of such contractors a"G
visitors
• The facility should re-evaluate their maintenance program A
complete set of process and instrumentation drawings should be
created and maintained General housekeeping details such as
securing of loose welds in the phosphoric plant, cleaning of anv
standing water, and bracing of corroded floor grates, as veil r.s
other maintenance considerations should be given regular
attention. The facility should particularly consider installing
corrosion monitoring system for measuring piping and vessel ^all
thicknesses and equipment integrity
• Royster should conduct an internal hazard analysis of the
chemicals in the facility and, based on the results of the
analysis, revise its emergency response plans After completior
of such an analysis, Royster should evaluate the facility and c
-------
The notification procedures ac Royscer Phosphates are adequately
conceived but may be insufficiently staffed (e g only f/o
managers responsible for emergency situations) The facility
should require all shifts to have several personnel designated to
initiate notification procedures in case of emergencies Facility
management personnel should be trained on emergency release
notification requirements under CERCLA and SARA Title III
• The facility should consider improving its fire fighting
capability Proper equipment should be provided, a fire brigade
could be organized and trained (including personnel from all
shifts), and fire water lines and hydrants should be clearly
marked throughout the facility
• The facility should evaluate their communications systems
Existing telephone systems should be expanded so that every plant
operator has access to a telephone Because the page system is an
inherently slow form of emergency notification, it should be
restricted to use by only facility management personnel far
removed from the facility at a given time The facility might
establish a radio network and coordinate its use with local
response agencies The emergency alarm system should be placed in
working order and tested periodically by means of drills
Community and Facility Emergency Response Planning Activities
• The facility should re-evaluate their emergency response
capability with respect to notification of local authorities
Royster should consider strengthening relations with the LEPC, and
could coordinate site specific future mock release drills with
these local agencies.
Audit Team Member Composition:
Name and Title Henry Hudson, Team Leader
Affiliation EPA Region IV
Area of Responsibility N/A
Expertise N/A
Name and Title Pat Steed, Deputy Leader
Affiliation EPA Region IV
Area of Responsibility N/A
Expertise N/A
Name and Title Gaines Boone
Affiliation EPA Region IV
Area of Responsibility N/A
Expertise N/A
101
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Name and Tide
Affiliation
Area of Responsibility
Expertise
N7ame and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Rita Ford
EPA Region IV
N/A
N/A
Rick Horner
EPA Headquarters
N/A
N/A
Waynon Johnson
EPA Region IV
N/A
N/A
Andy Roberts
TAT
N/A
N/A
Bill Ross
EPA Region IV
N/A
N/A
Russell Schilling
TAT
N/A
N/A
Phyllis Warrilow
EPA Region IV
N/A
N/A
Follow-Up Activities:
By the Facility:
• The facility plans to hire a full time Health and Safety Manager,
due to the lack of available time that the current Director of
Safety can devote to purely safety-related issues.
By the Regional Office:
N/A
By State and Local Authorities.
• N/A
102
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Regional Contact:
Henry Hudson
3^7-1033
L03
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Ascrocech
Facility Location
Titusville, Brevard County, Florida,
Region IV
Date(s) Audit Conducted:
April 4 - April 5, 1990
Description of Facility:
SIC Code(s):
Location1
Products manufactured,
produced, or distributed:
Proximity to
sensitive populations:
N/A
Within che Spaceport Florida Industrial
Park across che Indian River and about
three miles from the Kennedy Space Cencer
and Cape Canaveral Air Force Station
Commercial payload processing facility
Near airport, a residential housing
development, and several state roads
Reason for Facility Selection:
ARIP Reports:
The Lieutenant Governor of Florida
requested an impartial and focused review
of the Astrotech facility and operations
in response to public questions concerning
its safety
None prior to audit
Focus of Audit:
Hazardous substance(s)
examined:
Anhydrous Hydrazine (AH)
Monomechyl Hydrazine (MMH)
Nitrogen Tetroxide (N204)
-------
Physical Area(s) Examined at the Facility
Storage and Handling
• Storage Systems
• Material Transfer
Activities which comprise the preparation of che payload for flight are
grouped into non-hazardous and hazardous operations Buildings 1 and
1A, 4, and 5 comprise the designated non-hazardous areas and Buildings 2
and 3 are in the hazardous operations area Building 4 is used for
storage of equipment that does not require a controlled environment.
such as shipping containers and certain ground support equipment
Building 3 is the storage facility designed for short- or long-term
storage of payloads, solid rocket motors (SRMs), any other ordnance-
containing flight hardware, and other environmentally sensitive flight
hardware, as required. Building 3 contains six identical storage bays
which are environmentally controlled but do not have "clean room"
conditions (with specific limits on the amounts of dust and particles in
the air) The building is also designed to store three perigee kick
motors (PKMs) called payload assist module (PAM) solid rocket motors ard
three smaller unspecified solid rocket apogee kick motors C.-.KMs) all
using solid propellant
No liquid propellants are stored at the Astrotech facility Liquid
propellants are present only as long as required to condition, sample,
load the liquid fuel or oxidizer into the spacecraft, and transport the
spacecraft to the launch pad These substances are brought on site and
are placed in Building 2 either on a fueling island or in a propellanc
cart storage room.
Liquid propellants are transported to Astrotech from the Cape Canaveral
Air Force Station (CCAFS) and from the Kennedy Space Center (KSC), and.
therefore, the transport route is a short one. Propellants are
transported from the CCAFS Liquid Propellant Supply Depot to Astrotech
for fueling payloads, and fueled payloads are transported from Astrotech
to launch pads at KSC and CCAFS. The propellants are transported in
DOT-approved transport containers. A maximum of one cylinder of
nitrogen tetroxide (3600 pounds) or two 55-gallon drums of fuel
(approximately 925 pounds of anhydrous hydrazine or approximately 800
pounds of monomethyl hydrazine) is allowed in any one shipment On
occasions when it is necessary to load propellant into the propellant
carts from the bulk storage facility, the carts are transported to
Astrotech under the protection of a security escort and in accordance
with the applicable DOT transport approval. Transport of fuel and
oxidizer never occurs at the same time.
Only enough liquid propellant is brought on site for loading the payload
with allowance for ullage in the storage cart and sampling Following
completion of a fueling operation, any residual propellant is drummed
and returned to CCAFS for reuse or disposal A maximum of three nearly
empty drums, containing residual fuel, can be transported at one time
105
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Process Area(s)
• Non-hazardous process buildings
• Hazardous process buildings
Pavloads are satellites chac are launched inco space co be used in
communication systems, for remote sensing, in weather systems, for
planetary exploration and as scientific experiments Pavloads have
various types of motors fueled by either solid or liquid propellants
Generally, both the PKM, when required, and the AKM contain solid
propellant Orbit position control propulsion systems use either a
single liquid fuel (anhydrous hydrazine), or a combination of liquid
fuel and liquid oxidizer (monomethyl hydrazine and nitrogen tetro\Lde)
depending on the requirements of the spacecraft
Astrotech processes such payloads prior to launch through both non-
hazardous and hazardous operations These operations require "clean
room" conditions and stringent controls on hazardous activities
Astrotech1s services also include local transportation of propellants co
and from Kennedy Space Center, transportation of the processed pa/load
to the launch site, and off-load and on-load of spacecraft parts and
other equipment, as needed.
Activities within Buildings 1 and 1A in the non-hazardous work area
include final payload assembly, leak tests, installation of solar
panels, antennas, insulation, and other equipment, function testing.
cleaning and inspection, and monitoring and checking of payload
electronic systems
Hazardous operations include handling and loading of both liquid
propellants (anhydrous hydrazine, monomethyl hydrazine, and nitrogen
tetroxide) and explosive devices used for motor ignition and payload
separation, mating of motors and payload, dynamic spin balancing, and
transporting of the fueled spacecraft from the complex to the Kennedy
Space Center launch pad. The typical sequence of operations in the
hazardous work area is divided between work on the "perigee kick motoi."
(PKM), and that of the remainder of the payload and take place in
Building 2 of the Astrotech complex. PKM operations begin approximately
two weeks before the payload operations and take approximately six weeks
to complete. Upon completion of the processing stage, the PKM either
remains in a high bay separate from that used for the payload
operations, or it is moved to Building 3 for temporary storage
Completion of PKM processing occurs several days before completion of
the non-hazardous satellite processing operations in Building 1, leaving
building 2 available for the ne
-------
The final seep in assembling che payload is to mace Che sacellice
che PKM. Before cransporcacion Co che launch pad che payLoad is eicher
encapsulaced in che launch vehicle "fairing" (casing used Co procecc
payload during launch.and chrough che escape of che dense acmosphere of
che earch), or placed in a concainer designed co procecc che payload
during transport
Summary of Audit Findings and Recommendations:
Conclusions:
Facility Background Information
• Buildings 2 and 3. where hazardous materials are handled, are
separaced from che public and from non-hazardous work areas by
distances determined using DOD and ATF explosives siting criteria
These buildings were designed and constructed such thac, if an
accidenc involving an explosion were to occur, the public would
not be exposed to any primary explosion effects (i e., blast
overpressure, flying fragments, or fire)
• Perimeter access is restricted by a chain link fence topped with
barbed wire. Access through the main entrance gate is controlled
24 hours a day in order to regulate employee, customer, and
visitor traffic through conventional sign in, verification, and
numbered badge assignment procedures. Access to operations
buildings is restricted by cipher/key locks on all personnel doois
and all visitors must be escorted. An additional badge exchange
guard station limits access to the entire hazardous work area when
certain operations are taking place in Building 2
Process Information
• Astrotech has not modified the sequence of processing operations
to reflect recent industry changes The presently-used sequence
was established when payloads were loaded and pressurized on che
launch pad. However, in recent years the final payload propellanc
loading, pressurization, and integration with large AKMs has
shifted location and now occurs within a payload processing
facility (e.g., Astrotech) Also, the amounts of liquid
propellants and the size of SRMs have increased considerably
• Ordnance and associated flight items are required to be the
natural color of the device while non-flight items require color
coding and submittal of che coding key co Astrotech. The color
code facilitates idencificacLon
• Audit team did not perform i r:-jpsportation risk assessment
-------
• Astrotech occasionally uses a leak check procedure chac uses
helium containing a small amount of krypton-85. a gas chac is a
source of ionizing radiation
• Astrotech has recently acquired portable toxic vapor detectors
chat supplement the traditional Draeger tube vapor analyzers in
monitoring liquid propellant handling and loading operations
-These detectors are extremely sensitive and are microprocessor-
controlled for speed, accuracy and specificity The detectors are
encased in special explosion-proof clear plastic boxes for use in
flammable/potentially explosive atmospheres
• Explosion-proof observation windows were installed between che
control rooms and bays in Building 2 to reduce the number of
monitoring personnel in the bay during propellant sampling and
loading
Chemical Accident Prevention
• Astrotech has prepared a corporate policy regarding desired levels
of safety, and criteria against which customers' safety plans are
assessed.
• Joint safety inspections by both Astrotech and customer safety
representatives are generally performed prior to and immediately
after payload and ground support equipment installation at che
facility, before initiation of hazardous operations, and after an
modification to the facilities or equipment An additional
external safety inspection is performed by an inspector
representing Astrotech1 s insurance company approximately t'.;ice
each year
• Written operating procedures are required for all hazardous
operations that are performed at the Astrotech facility and are
reviewed and approved by Astrotech prior to operations Standard
operating procedures include attention to all aspects of
operations including customer safety plans and documentation noi:
hazardous operations, careful weather and lightning storm
monitoring, proper use of personal protective equipment,
inspection and maintenance of facility equipment, and emergency
planning. These formal, documented procedures for processing
payloads meet accepted standards established by DOD and NASA
• No operations sequencing limitations can be found in the Ascrocei ".
Safety Standard Operating Procedure (SOP). However. Astrotech's
scrubber procedure checklist does indicate that there are
operational sequencing limitations by stating that fuel must be
processed before oxidizer.
• Astrotech provides continuous safety monitoring during all
hazardous operations by the Safety Officer and he is empowered :••
stop an operation if he deems it unsafe or problems are indica:-
108
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Ascrotech places heavy reliance on che knowledge and presence of
cheir Safety Officer in dealing with emergencies Currently, in
che event of an emergency occurring in che absence of the Safety
Officer or one chat injured him/her, LC was unclear who would
assume leadership responsibility
Employees «ho have responsibility for handling hazardous
jnacenals, and who are assigned Co response duties, have training
equivalent co chac required by NASA personnel who perform similar
ducies ac KSC. This training exceeds the requirements of Training
Standards for Hazardous Technicians Level III and Level IV as
designed under OSHA, Ticle 29 CFR Seccion 1910 and EPA Title iO
CFR Part III, and is applicable Co a wide variety of induscnes
chac use hazardous macerials
Ascrocech requires chac payload owner/operacor personnel be
"properly" crained and chat the payload owner/operacor "cercifv"
chac chis craining has caken place. However, Ascrocech safety
policies do noc decail che requiremencs, that, if met, ensure
proper craining.
Ascrocech regularly inspeccs and cests all equipmenc chac ic
provides. Daily visual checks are common as are semi-annual
syscem-wide verificacions
Hazard analyses, performed by che audic ceam, indicated chac no
explosion effects, including primary overpressure effects and
secondary effects such as glass breakage and flying debris, voflc1
occur beyond the facility boundary. The ceam also concluded c.v:
chere would be no adverse impaccs on che public from exposures ~>~>
ground level concentrations of toxic gases.
Ascrocech has recencly ordered a closed-loop discillacion sys^e^
for recovery of freon concaminaced during equipmenc cleaning
operations Co minimize che generation of hazardous waste.
AC Ascrocech, all leak check procedures chac use che helium-
krypcon mixture cake place within Building 1 in a sealed cent :o
preclude exposures wichin che building. The majoricy of che
krypton is recovered and che remainder is vented ouc chrough nn
exhaust duct above the roof. The exhaust concentration is
sufficiently limited to rapidly diffuse in the atmosphere and
dissipates before reaching the facility boundary.
The floor in the high bays and North Airlock in Building 2, •»!•&.«-•
hazardous processing operations are performed, is covered with
vinyl tiles, impregnated with graphite and bonded to the concLrti
with conductive mastic. This dissipates static eleccricicy to
building grounding grids, reducing che threat of electrostatic
discharge that might ignite SRMs or flammable liquid
109
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• Containment and scrubber systems within Building 2 provide
protection to the public from any incidental exposures during
normal operations. The containment system consists of oxidizer
and fuel-holding tanks, separated by appropriate valving and
manually-switched piping connected to a vapor scrubber. Following
a complete processing operation, the contents of the tanks are
neutralized, and after testing by the city, are discharged to the
city sewer.
• A recirculation fan was installed inside Building 2 to agitate :he
air and to aid in diluting and breaking down propellant vapors in
the event of a major spill
• Propellant loading operations are conducted on "fueling islands
which are in the center of a work area and are surrounded by a
stainless steel collection trench that slopes underground and
drains to the containment and neutralization tanks outside the
building If a spill occurs, it is directed into the trench
drainage system, confining the spill and making cleanup easier
In the event of a fuel spill involving a fire, the trench system
would also serve to confine the fire to the fueling island and
help prevent its spread to other areas
• A computer-controlled fire suppression system was installed
requiring two independent events for activation, first, smoke/heat
detection alarm signal from any of the detectors mounted in the
air bays, airlocks or the heating, ventilating and air
conditioning (HVAC) system or from a manual pull station, and
second, sufficient heat to melt the fusible link in the sprirklei-
head. The first opens a valve releasing the water to the
sprinkler system, the second releases the water from the sprinkler
head to wet the area. This system design provides protection for
sensitive payloads and other equipment in case there is a false
alarm or other problem.
Accidental Release Incident Investigation
• No accidents or incidents have occurred at the Astrotech facility
since it began operations in 1984 that have required reporting to
the National Response Center. In the course of operations, only
one spill of anhydrous hydrazine, amounting to less than a
teaspoonful, had occurred there. This particular spill was
completely neutralized by the tank and scrubber systems
Facility Emergency Preparedness and Planning Activities
• Astrotech has a written emergency response plan updated in 1988
that addresses emergency response procedures for incidents that
may occur either at the facility or while transporting liquid
propellant from and returning any excess to the storage facilities
at KSC and CCAFS.
no
-------
• The exacc sequencing and timing of response procedures in che
event of an unconcrollable spill is noc documented in Astrotech's
emergency plans or procedures.
• Identification and management of emergency situations on site
•,ould be handled by Astrotech's small and closely-coordinated
staff, under the direction of the facility Safety Officer
Procedures are in place and communication equipment is available
to protect and evacuate workers in hazardous situations, to summon
a facility emergency response team, and to call for off sice
assistance should it be required.
• In the event of a fire or explosion, there are fire protection
systems designed and installed to meet strict National Fire
Protection Association (NFPA) code requirements. Safe operations
are also enhanced by having backup power for critical functions
like facility lighting, the fire protection system, and vapor
monitors
• There are three Astrotech safety personnel who are always
available to respond to incidents or accidents during critical
periods of handling SRMs, ordnance or liquid propellants They
all have pagers and can be reached at anytime during the day or
night. All three individuals are familiar with payload processing
operations and have worked at Astrotech since the facility opened
If a problem arises after work hours, the guard has a full set of
notification procedures to follow, that include calling the
appropriate Astrotech personnel.
• The only communication link from the fuel and oxidizer cart
storage rooms is to the control room through an intercom mounted
in each storage room
• Alarms are automatically sent to the Astrotech guardhouse at the
front gate via computer link for various parameters and systems at
use at the plant The alarm panel indications displayed to the
guard allow prompt identification of potential problems and
notification of appropriate personnel.
Community and Facility Emergency Response Planning Activities
• Astrotech has worked closely with local, county, and state
emergency response and planning officials in familiarizing them
with the facility, its safety systems, operations performed,
materials handled and their hazards, and the personal protective
equipment necessary for personnel responding to emergency
situations. Through detailed planning, training, and equipping,
the public safety officials assisted by Astratech management have
been provided means for responding to an accident should one
occur.
Ill
-------
• Astrocech's current wricten emergency plan has been furnished to
local emergency planning and response officials
• No joinc exercises wi.ch county emergency personnel have yet been
conducted
Public Alert and Notification Procedures
• Three chemicals which are on-site periodically at Astrotech
depending on the specific spacecraft being processed, have been
designated as hazardous substances under CERCLA Two of these
chemicals are also listed as EHSs under SARA Title III Specific
reporting provisions require facilities to follow in notifying the
public when designated amounts of these substances are
accidentally released into the environment. Astrotech does not
identify these substances or reporting provisions specifically in
its plans and procedures
• Astrotech1s procedures depend solely on the emergency telephone
number 911 as an entry point into the outside emergency system
Astrotech1s emergency plan does not include a list of contact
persons and telephone numbers for its nearest industrial
neighbors
• Astrotech does not.have a local media spokesperson available to
furnish information in coordination with local emergency
management officials should an emergency occur Astrotech's
corporate media contact is normally stationed away from the plant
and the Safety Officer's duties would likely be so time consuming
that a different person would be preferable for the media contact
Recommendations:
Process Information
• Given the changes in recent years in payload processing
operations, Astrotech should consider evaluating the feasibility
and safety of modifying the sequence of processing operations
dealing with loading liquid propellants, lifting and mating the
satellite with the SRM, pressurizing tanks, and spin balancing
operations so that the operations sequence minimizes the chance of
a worst case release.
Chemical Accident Prevention
• The facility should include operational sequencing limitations for
propellant loading in Astrotech1s Safety Standard Operating
Procedure (SOP) so that payload owners/operators can properly plan
their operations.
112
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• Ascrotech should also consider formalizing che Safety Officer
back-up by assigning a specific person Co develop che same
detailed familiarity with Ascrocech's plans and procedures By
formalizing a Safecy Officer back-up, either one person or several
individuals would rotate depending on the shift
• Astrotech should ensure proper training for payload owner/operator
personnel
Facility Emergency Preparedness and Planning Activities
• Astrotech may wish to develop written guidelines for sequencing
and timing of emergency response activities following an
"uncontrollable" spill including a definition of incident(s) chac
initiate an uncontrollable spill, proper mitigation and evacuation
activities, and steps and requirements for re-entry.
• Ascrotech may want to install an additional communication link ouc
of the cart storage rooms (e g . a telephone with an outside line,
or an internal connection to the guard house) so that if an
individual needed to make outside contact, and no one was present
in the control rooms, there would be a communication link
Community and Facility Emergency Response Planning Accivities
• The facility should perform a simulated exercise of the emergency
response plan with emergency responders, even if only a table-cop
exercise.
Public Alert and Notification Procedures
• Astrotech needs to identify CERCLA hazardous substances and SARA
Title III EHSs specifically in its plans and procedures and
indicate the reporting requirements and appropriate notification
procedures
• The facility may want to expand its emergency contact list to
include critical contacts beyond the 911 system (e g , the county
emergency management director), and the phone numbers and contact
persons for the nearest industrial neighbors.
• Ascrotech should consider establishing a local media spokesperson
posicion at the facility
Audit Team Member Composition:
Name and Title Ron Cress
Affiliation Office of Commercial Space Transportacion
(OCST)
Area of Responsibility Audit Team Leader
Expertise Physicist/Operations Research Analyst
113
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Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Gaines Boone, AARP
EPA Region IV
Emergency Preparedness and Planning
Chemical Engineer
Tom Yatabe, AARP
EPA Region IV
Emergency Preparedness and Planning
Chemical Engineer
Deborah Shaver
ICF Incorporated
Transportation and Hazardous Materials
Chemist, Hazardous Materials Management
Phil Collyer
ICF Kaiser Engineers
Environmental Permits and Site Evaluations
Geologist
Ually Boggs
RTI
Payload Processing Operations
Physicist/Operations Research Analyst
Loyd Parker
RTI
Safety/Hazards Analysis
Safety Engineer
Follow-Up Activities:
By the Facility:
• N/A
By the Regional Office:
• N/A
By State and Local Authorities:
• N/A
Regional Contact:
Henry Hudson
347-1033
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Facility Location.
Koppers Industries
Cicero, IL, Region V
Date(s) Audit Conducted:
July 25-28, 1989
Description of Facility:
_ SIC Code(s)-
Location:
Products manufactured,
produced, or distributed:
Proximity to
sensitive populations:
SIC 2865 - Cyclic organic crudes and
intermediates, and organic dyes and
pigments
The facility occupies 39 acres in Cicero
Illinois Koppers Stickney Terminal
leases 7 additional acres at 4900 South
Laramie Street The surrounding community
is 25 percent industrial and 75 percent
residential The Stickney Terminal is
adjacent to the Chicago Sanitary &
Shipping Canal Site access is limited by
the canal from the south, however, the
sice is readily accessible from the other
directions
Pencil and roofing pitch, creosote,
tarmac, road tar, saturated felt,
distilled naphthalene, phthalic anhydride
& polyester resin
The average buffer zone around the
facility is 1,000 feet. Twelve
communities within a 5 mile radius are
potentially at risk from off-site
releases; This population of 62,000
includes significant population centers
(eg. nursing home).
Reason for Facility Selection:
The facility was selected following
releases of 560 pounds of creosote on
February 3, 1988, 500 pounds of creosote
on February 12, 1988, and 300,000 pounds
of • iph:h.ilene on February 21, 1988 The
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ARIP Reports-
accidencs occurred as a result of operator
and equipment errors during material
transfer
None prior to audit
Focus of Audit
Hazardous Substance(s)
Examined:
Phchalic Anhydride
Creosotes
Naphthalene
Sodium Hydroxide
Sulfuric Acid
0-Xylene
Physical Area(s) Examined at the Facility:
Storage and Handling
• Storage Systems
• Shipping/Receiving
• iMaterial Transfer
Primary storage of materials is in any one of approximately 110 on-site
above-ground storage tanks, ranging in size up to 2 5 million gallops
Drums and tank cars are the primary types of containers for creosote and
naphthalene
Shipments by truck are the most frequent, followed by rail and then
barge Crude tars are delivered by truck from coking operations in the
Greater Chicago area. The end product, carbon pitch, is shipped in
insulated tank cars or trucks. Pencil pitch (solid carbon pitch) is
shipped in railroad cars. The phthalic anhydride plant uses a
combination of o-xylene, received by barge from the Gulf Coast and
naphthalene, from Follensbee, West Virginia. Finished phthalic
anhydride is shipped in 10,000 and 20,000 gallon railroad cars or 5,000
tank wagons. Materials received and shipped from the facility are
placarded. Personnel in the various operating departments are
responsible for shipping and receiving
Large quantities of pumps, piping, and related appurtenances (e g .
process receiving vessels, tank farms, loading docks) are used to move
materials within the plant Although some apparatus and loading areas
are enclosed in buildings, most are external and weather-proofed as
necessary They are not off-site accessible
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Process Area(s)
• Coal Tar Distillation
• Phthalic Anhydride Production Oxidation
• Distillation
Coal Tar Distillation. Crude tar is pumped from blended storage tanks
to the fractioning columns where it is distilled to produce a light
overhead product (chemical oil), a middle distillate oil (creosote), and
a residue (pitch) Fractionation is conducted under vacuum, and
vertical tubeheaters provide the needed heat for distillation
Phthalic Anhydride Production: Oxidation. Filtered air is compressed
and in each of the parallel trains, passed through an air heater Each
train then feeds two of the four reactors The naphthalene or xylene
feedstock is pumped from storage tanks and vaporized by injection into
the hot air stream This feed mixture then passes through the catalyst
filled tubular reactors where the oxidation to phthalic anhydride cakes
place
Cooled gases leaving the gas coolers pass to the separation system vhere
phthalic anhydride sublimes in switch condensers. When a quantity of
solid crude product has collected in the condensers, the operation is
switched from condensing to melting Off-gases are discharged to the
atmosphere through a 100-foot stack
Distillation. Crude phthalic anhydride is pumped from the intermediace
crude storage tanks through a preheater to a continuous heat treat^e:^
system Vapors leaving the pretreatment pass through a knock-back
condenser to reduce the phthalic anhydride losses. The condensate is
returned to the preheaters. The treated crude phthalic anhydride
product goes to a preflash heater, and then to a preflash condenser
Preflash condensate then goes to the distillation stripper columns
The bottoms from the stripper column are fed to the still column in
which the final product is withdrawn as an overhead distillate and
collected in storage tanks. Residue is combined as waste material arc1
pumped to a thermal oxidizer where it is burned.
Summary of Audit Findings and Recommendations:
Conclusions:
Process Information
• Material transfers are typically supervised by Koppers employees
however, routine operating procedures have allowed non-facilic.
truck operators to transfer materials unsupervised in many areas
of the plant.
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• In che phchalic anhydride plane, mosc information and instructions
between supervisors and operators appears co be communicated
verbally Supervisors maintain a log book in the process office
for the communication of information between shifts, however, no
method of recording information is present in the control room
Chemical Accident Prevention
• Employees receive the following safety training new employee
orientation, OSHA hazard communication, operator orientation, step
of operation training, and maintenance training Production and
maintenance training programs are competency based, completion of
training depends not on che amount of time in training, buc rather
on the participant's understanding of the safety issues
• Based on a review of facility release reports and other records,
ic was determined chac che safety deparcment has limiced staff and
fiscal resources allocated to coordinate all safety training
• The facility maintains files documenting the occurrence of
reported releases. However, the file documentation does not
provide evidence of investigations of either reportable releases
or near misses.
• Standard sources of information such as log books, standard
operating procedures, standing orders, fire instructions,
emergency notification procedures, and safety manuals do not exist:
in either of the two processing plants.
• Koppers does not have a formalized hazards analysis procedure
employing accident simulations. Such simulations require experts
in the plant Co evaluate the consequences of accidents.
• The facility has installed three explosimeters which are located
in the internal sewer collecting system to detect spills.
However, no air monitoring and/or deteccion systems are in place
for ongoing or episodic releases.
Facility Emergency Preparedness and Planning Activities
• A chemical safety contingency plan was developed by plant safety
staff in cooperation with corporate safety and environmental
representatives from Pittsburgh, PA. It does not contain a
listing of Che chemical substances which may be released at ere
facility. Information on the probable nature and routes of anv
releases of such substances (e g , plume dispersion pathways; v <.'.
the possible causes of such releases are also not included.
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• There is no mention of regulatory requirements (federal, state,
and local) for emergency situations in the facility's contingency
plan Furthermore, Koppers has neglected to communicate with LEPC
officials concerning citizen complaints and the Community Right-
To -Know Act
Community and Facility Emergency Response Planning Activities
• Area fire departments have limited training, equipment, and
response capabilities for a large-scale chemical release involving
off-site public health and environmental consequences The City
of Chicago's Hazardous Material Response Team has specially
equipped response vehicles, chemical protective gear, and
computerized release plume dispersion pathway tracking
capabilities Following notification of a release, the fire
department is responsible for alerting and notifying the public
Mutual aid agreements with area fire departments and the city's
Response Team are not clearly delineated in Kopper's contingency
plan.
• According to the City of Stickney Fire Chief, the facility has
never coordinated with him in developing plans or procedures to
handle potential chemical emergencies Furthermore, these groups
have not drilled or exercised together in preparation for such
events.
• According to the LEPC and other local officials, there are
numerous citizen complaints of odors from the plant Koppers has
taken no action with regard to these complaints
Recommendations:
Process Information
• The facility should reexamine its raw material and finished
product shipping and receiving procedures to improve control
This may prevent future releases from occurring during material
transfer.
• A log book should be used to pass information between supervisor
and operator in each operating area. This would help prevent
confusion and avoid potentially dangerous situations that result
from conveying orders verbally
Chemical Accident Prevention
• The facility should reexamine budget priorities to allow for more
complete safety training, especially in the area of operator
training at the coal tar plant
119
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• A comprehensive hazard analysis program should include
participation by operating, engineering, and maintenance personnel
in accident simulations
Accident Investigation
• Documentation of reportable releases and near misses provides
important information in preparing for and preventing potential
accidents Files should be developed and maintained on all
investigations of releases and near misses
Facility Emergency Preparedness and Planning Activities
• A comprehensive listing of potentially hazardous substances should
be included in the emergency response plan The plant's chemical
safety contingency plan could also include information on the
probable nature, causes, and routes of such releases
• In order to clarify Kopper's responsibility in reporting chemical
releases, the regulatory requirements (federal, state, and local;
should be included in the contingency plan 'This may help to
foster a better relationship with local officials who are
concerned about Kopper's reporting and general communication with
the community
Community and Facility Emergency Response Planning Activities
• A written mutual aid agreement between Koppers, area fire
departments and the City of Chicago Fire Department's Hazardous
Materials Response Team would ensure the organized response to ap;-
chemical fire at the plant
• Practiced procedures may mitigate a potentially dangerous
situation. Koppers should therefore coordinate emergency
procedures and conduct routine drills with the local fire
department.
• The facility should conduct a study on point sources of odors and
consider containment measures in response to on-going citizen's
complaints of odors
Audit Team Member Composition:
Name and Title David Napierski, Team Leader
Affiliation U S. EPA/Region V
Area of Responsibility Management interviews and practices
Expertise Environmental Scientist; experienced and
trained environmental employee
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Name and Title
AffiLiacion
Area of Responsibility
Expertise
Name and Tide
Affiliation _
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Cosmo Caterino, Deputy Team Leader
Roy F Weston/Technical Assistant Team
Management interviews and practices
Chemical Engineer, trained environmental
employee
Donald Klopke, Technical Reviewer
Illinois Environmental Protection Agency
Plant practices
Environmental Scientist, trained
environmental employee
John Elkmann, Supporting Technical
Reviewer
U S EPA/Region V, AARP
Plant practices
Industrial experience, trained
environmental employee
Follow-up Activities:
By the Facility:
• No verbal or written comments were given on the final draft of the
audit.
By the Regional Office:
• Region does not intend to perform follow-up activities.
By State and Local Authorities:
N/A
Regional Contact:
Mark Horwitz, Chief OCEP
(312) 886-1964
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Besc Foods, A Division of CPC
International, Inc
Facility Location:
Chicago, Illinois, Region V
Date(s) Audit Conducted:
August 8-11, 1989
Description of Facility:
SIC Codes (s)
Location.
Products Manufactured,
Produced or Distributed:
Proximity to
Sensitive Populations:
SIC 2079 - Shortening, table oils,
margarine, and other edible fats and oils
noc elsewhere classified
6.5 miles southwest of downtown Chicago
Food products (e.g., mayonnaise, carcar
sauce).
A four-acre facility parking lot is
located to the south, and residential
properties are located to the east,
directly across the street from the
facility.
Reason for Facility Selection:
ARIP Reports:
The facility was chosen because (1) 60,000
pounds of sulfuric acid were released from
the facility on July 24, 1988, (2) the
facility is in the metropolitan Chicago
area; and (3) the release occurred at a
food processing facility, a type of
facility not normally associated with
hazardous chemical releases.
7/23/88 sulfuric acid release.
Focus of Audit:
Hazardous Substance(s)
Examined:
Sulfuric Acid
Chlorine
Ammonia
Sodium Hydroxide
Hydrogen
Acetic Acid
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Physical Area(s) Examined at the Facility.
Storage and Handling
• Storage Systems
• Shipping/Receiving
• Material Transfer
The facility has an extensive tank farm with tanks located in various
areas of the plant adjacent to process areas and/or unloading
operations. Pipes for material transfer are identified by cags and/or
color codes; placards describing the hazards are displayed on the
containers. The majority of the tankage is devoted to crude or refined
vegetable oils, the facility's primary raw material Sulfuric acid and
sodium hydroxide are received by tank truck and maintained in two
storage areas, adjacent to the waste treatment plant and to the refinery
department Acetic acid is received by tank truck and maintained in a
diked storage area adjacent to the dressings department Liquid
hydrogen and liquid nitrogen are stored at a cryogenic storage site
Ammonia is maintained in a closed refrigeration system under the
supervision of stationary engineers, facility personnel who operate the
power plant. System losses of approximately 4,000 pounds per year are
replaced by vendor tank truck deliveries periodically throughout the
year. Chlorine is received in 150-pound cylinders and is stored
adjacent to its use point in the waste treatment area These materials
are received by both rail and truck delivery and transferred to storage
areas.
Process Area(3)
The oil refinery receives crude soy bean oil by tank car. A number of
process steps, including hydrogenation, are required to strip
impurities, deodorize, decolorize, and adjust viscosity. Hydrogenation
involves bubbling hydrogen gas into a reactor vessel containing the
refined oil and a finely divided nickel catalyst. The catalyst material
is removed by filtration and sold for recovery of the nickel. Small
amounts of sulfuric acid and sodium hydroxide are used for pH
adjustment. Explosimeters detect potentially explosive hydrogen
concentrations and will subsequently alarm and/or shutdown the system.
Additional detectors are installed to detect high levels of chlorine and
ammonia and will alarm and/or shutdown the compressors. Procedures are
in place for the routine inspection of these detection systems.
The operation of the dressing and syrup departments is very similar,
although the processing steps are simpler in the syrup department. In
the respective departments, food grade ingredients (e.g., soy bean oil,
vinegar, eggs and sugar; corn syrup and flavoring) undergo batching and
mixing processes, which are highly instrumented and automated to
maintain quality and minimize contamination. After processing in
stainless steel equipment and piping, the finished product is
automatically packaged and boxed. An important adjunct to the process
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is the sanitizing of the equipment by a clean-in-place (CIP) process
utilizing circulating cleaning solutions during the off shift.
All process and storm effluents are taken from the facility and pre-
treated to conform with water quality criteria and to minimize certain
contaminants (i.e., fats, oils, and grease). A number of processing
steps involve the breaking of emulsions, the skimming of oils, and the
capture of foams To minimize organic growths in the sewer piping,
chlorine is added on a shot feed basis; currently, only one person
removes and replaces exhausted chlorine cylinders with new 150 pound
cylinders. Sulfuric acid is used to reduce the pH of the incoming
sewage stream to prevent saponification during processing and for the
acidulation of oil bearing streams to break the oil-water emulsion
Sodium hydroxide is subsequently used to raise the pH of the final
discharge to meet water quality requirements A routinely inspected
monitoring system will alarm in the event of an abnormally high or low
PH
The facility's power plant is located in the basement of the oil
refinery building and contains fuel fired steam boilers, air
compressors, and an ammonia refrigeration system. Operation is under
the control of stationary engineers.
Summary of Audit Findings and Recommendations:
Conclusions:
Process Information
• A storage tank containing sulfuric acid, a corrosive, has a
threaded and plugged bottom drain connection
• Limited floor space and poor lighting in the facility's power
plant has created a crowded and dark work place.
Chemical Accident Prevention
• The facility does not have one safety manual on all practices
within the facility; instead, areas and procedures of concern are
addressed by memorandum. A safety training program has been
established for management and staff.
• Only one person is responsible for removing and replacing
exhausted chlorine cylinders in the waste water treatment plant
with new 150-pound cylinders.
• The waste water treatment plant is the only plant at the facility
having a detailed operating manual and log book procedure for
documenting communication between operators and supervisors.
Other plant operating areas do not have such a manual and rely on
equipment manuals and oral instruction.
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• The facility has a safety and loss prevention program.
• Operating personnel receive on-che-job training There was no
evidence of an operator training or certification program
• Contractors perform a variety of services (e.g., servicing of fire
equipment or instrumentation) at the facility
• The audit noted little evidence of work order systems, equipment
history, or maintenance documentation.
• The facility's preventative maintenance program focuses primarily
on lubrication
• The facility has installed systems to (1) monitor the pH level of
discharge into the Metropolitan Water Reclamation District and (2)
detect dangerously high levels of hydrogen, chlorine, and ammonia
Procedures are in place for the routine inspection of the various
monitoring and detection systems.
• The facility does not use a formal hazard evaluation technique as
a predictive or planning tool.
• The facility does not make use of modeling techniques.
Accidental Release Incident Investigation
• The trigger incident involved a small leak in a pump line from the
sulfuric acid storage tank at the waste water treatment plant
The leak enlarged in response to initial attempts at corrective
action, requiring the facility take additional steps to mitigate
the release. The release was discovered by an employee conducting
a routine investigation
• Following the trigger incident, the company concluded that
contingency plans, such as the availability of resources, did not
meet expectations.
Facility Emergency Preparedness and Planning Activities
• The facility has plans, procedures, training, and equipment in
place for response to and mitigation of chemical releases.
• The facility's emergency response plan addresses potential
emergency situations and stresses an orderly evacuation of the
facility, if required. The plan also establishes protocol for
both on- and off-shift response. The plan does not address the
mandated reporting of chemical releases.
• The facility's power plant, housing the plant's steam boilers, air
compressors, and ammonia refrigeration system, could be a source
for a chemical release due to its limited floor space.
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Recommendations
Process Information
• Threaded connections are more susceptible to corrosive failure
chan flanged connections To prevent such failure, the threaded
drain coupling in the sulfuric acid storage tank should be
"changed out" or replaced during the next scheduled outage
Chemical Accident Prevention
• Safety procedures and policy (e g., tank entry procedure) should
be incorporated into a corporate safety manual which reviews all
procedures necessary for effective operation.
• During the removal and replacement of 150-pound chlorine cylinders
in the waste water treatment plant, a second person should
maintain visual contact with the operation at all times
• Log book procedure for communication between operators and
supervisors, similar to that developed for waste water treatment,
should be initiated in all operating areas.
• It is questionable whether the facility's service contracts
adequately specify the services required and the results to be
obtained by contractors. The facility should confirm whether or
not its service contracts (e.g. contracts for servicing fire
equipment and instrumentation) are comprehensive.
• The facility should formalize and implement the work orders system
and maintenance documentation.
• The facility should investigate expanding its preventive
maintenance program to include the following elements (1)
identify all process control and safety release devices and
establish schedules for both maintenance and testing (e.g., either
bench testing or functional tests, as appropriate); (2) extend
lubrication program to all plant areas and improve scheduling and
documentation; and (3) formalize machinery and equipment
inspections and investigate non-destructive testing devices such
as metal thickness indicators and vibration monitors
• Plant management should periodically employ some form of formal
hazards analysis (e.g., "What If?" analysis) as a routine part of
management and/or operations. Use of such analysis would enable
the facility to identify and plan for potential emergency
situations
126
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Accident Release Incident Investigation
• Facility management should discuss che appropriateness of the
initial response to the trigger incident involving leaking
sulfuric acid (i e, applying water to acid and steel and delaying
response to a leak of a hazardous chemical) with all relevant
plant personnel.
• Based on the results of the company's review of the incident, the
contingency plan should include a back-up resources for responding
to emergencies.
Facility Emergency Preparedness and Planning Activities
• The confined and dark conditions of the power plant, an area in
which an ammonia release is likely, could hinder the evacuation of
operators in the event of a release Steps should be taken to
upgrade this area, such as improved lighting and/or painting.
• The emergency response directive to staff should list those
chemicals requiring release notification, including SARA Title III
EHSs and CERCLA hazardous substances, and their RQs. A phone
number for contacting the LEPC, SERC, and NRC should be included
in both the directive and the wallet sized card issued to
employees.
• Ammonia compressors are located in a confined basement power
facility. Five-minute escape masks should be readily available to
the operators in the event of an uncontrolled release of gaseous
ammonia.
Audit Team Member Composition:
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
David Napierski, Team Leader
EPA, Region V
Management Practices
Environmental Scientist
Glenn Cekus, Deputy Team Leader
EPA, Region V
N/A
N/A
John Elkmann, AARP
EPA, Region V
Technical Reviewer
Plant Operations
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Name and Title Byron Maggos, AARP
Affiliation EPA, Region V
Area of Responsibility Technical Reviewer
Expertise N/A
Name and Title Alan Bauman
Affiliation EPA, Region V
Area of Responsibility Verifier
Expertise N/A
Follow-up Activities:
By the Facility:
• N/A
By the Regional Office:
N/A
By State and Local Authorities:
• N/A
Regional Contact:
Mark Horwitz
(312) 886-1964
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name•
Western Extrusions Corporation
Facility Location:
Carrollton. Texas. Region VI
Date(s) Audit Conducted:
June 13, 1989
Description of Facility:
SIC Code(s):
Location:
Products manufactured,
produced, or distributed:
Proximity to
sensitive populations:
SIC 3442 - Metal doors, sash, frames,
molding, trim.
SIC 3471 - Electroplating, plating,
polishing, anodizing, and coloring
SIC 3354 - Aluminum extruding produces
10 miles northwest of Dallas, TX, close to
businesses and commercial properties
Aluminum extrusion
There is a residential neighborhood one-
half mile to the south
Reason for Facility Selection:
ARIP Reports:
The facility was chosen because of a spill
of sulfuric acid that occurred in February
1989. Three workers were injured as a
result of the accident, one worker was
burned and two inhaled sulfuric acid
fumes. OSHA cited Western for four
violations.
None prior to audit.
Focus of Audit:
Hazardous Substance(s)
Examined:
Sulfuric acid
Hydrochloric acid
Nitric acid
Phosphoric acid
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Physical Area(s) Examined at the Facility.
Scoraee and Handling
• Scorage Systems
• Shipping and Receiving
The primary storage system at the facility consists of a storage tank
farm located at the west end of the plant This farm contains 5 storage
tanks of 5,000 gallon capacity each. These tanks are usually filled to
4,000 gallons each. The chemicals are stored at ambient atmospheric
pressure and ambient temperature. The five tanks store sulfuric acid.
phosphoric acid, nitric acid, spent phosphoric acid, and caustic soda
Most of the chemicals that are used by the facility are shipped in via
tank truck. Paved and unpaved roads provide access to most areas on the
facility There is limited access to the backside of the plant where
the hazardous chemical storage tanks are located
Process Area(s)
• Extrusion process
• Painting process
• Anodizing process
Aluminum ingots are pressed into various shapes, cut, stretched, and
heat treated at 350 degrees Fahrenheit for 8 hours and buffed for
anodizing or painting, or packed and shipped.
The aluminum shapes that are to be painted are placed on painting racks,
cleaned by a five-stage washing system, and then painted on a bell paint
line. The paint is statically applied and then baked in a 65-70 foot
long baking oven. The paint is cured during the baking process
The anodizing process is used to create various finishes on the extruded
aluminum. The racks are passed through vats of chemicals to produce the
finished product. Chemicals used in the various processes included
phosphorous acid, nitric acid, sulfuric acid, and sodium hydroxide
Anhydrous sodium hydroxide is currently used to adjust pH prior to
discharge.
Summary of Audit Findings and Recommendations:
Conclusions:
Chemical Hazards
• Material Safety Data Sheets are only available in English for a
primarily Spanish-speaking workforce. The on-duty supervisors and
lab technicians are able to translate MSDSs into Spanish for non-
English speaking workers.
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Chemical Accident Prevention
• Western is in the process of placing sump pumps into the diked
area of the tank farm to pump rain water out of the area All
acid chemical tanks and alkaline chemical tanks are now cross-
diked to prevent mixture of chemicals during an incident
• Many workers were walking under fork lifts carrying racks of
aluminum without wearing hard hats.
• The tops of the anodizing vats are just 40 inches above the
surrounding walkway, and the lack of protective railings and the
presence of obstructions on the walkway increase the possibility
of an accident.
• New employees are given an orientation on safety and emergency
procedures before they begin working Workers are trained to
evacuate the plant during any chemical incident and not to handle
the spill themselves
Facility Emergency Preparedness and Planning Activities
• Western began developing a new emergency response plan after the
February 1989 release.
Recommendations:
Chemical Accident Prevention
• Because acids react violently with caustics, the OSC at the site
after the sulfuric acid release suggested that these incompatible
materials be segregated during storage. The plant manager agreed
to subdivide the secondary containment dikes.
• The walk-ways around the annodizing vats should be cleared of all
obstructive materials and routinely checked for spills that could
cause workers to slip.
• MSDSs should be translated into Spanish so that all employees will
have direct access to them.
Facility Emergency Preparedness and Planning Activities
• The emergency plan for the facility should be updated and expanded
from the existing emergency notification plan to provide emergency
procedures for employees.
• The facility should develop an exercise schedule to routinely test
their contingency plan once the suggested updates are completed
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• Workers should noc walk under fork lifcs carrying racks of
aluminum wichout wearing hard hacs
• Protective ratling should be installed around che annodizing vacs
co procecc workers who might accidentally crip on che walkways
Communicy and Facility Emergency Response Planning Activities
• The company should complete a follow-up notification in writing co
che SERC and LEPC as ouclined in Section 304(b) of SARA for the
sulfuric acid release of February 1989.
Public Alert and Notification Procedures
• An off-sice warning syscem or sirens should be considered by che
facility to notify che public of an incidenc, especially in che
storage area which is adjacent to a highway
Audit Team Member Composition:
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expeucise
Name and Title
Affiliation
Area of Responsibility
Expertise
Craig Caflton, OSC
EPA - Region VI
Mechanical/Chemical Systems
N/A
Steve Mason, Title III Coordinator
EPA - Region VI
Health & Safety Hazard Communication
N/A
Fendol Chiles
EPA - Region VI
Chemical Systems/Process Analysis
N/A
Follow-up Activities:
By the Facility:
• Western held a safety meeting on 9/20/89 and employees have been
instructed to not walk under fork lifts carrying aluminum.
• Western completed a follow-up notification in writing to the SERC
and LEPC as required by Section 304(b) on 10/10/89.
By the Regional Office:
N/A
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By State and Local Authorities
. N/A
Regional Contact:
Steve Mason
(214) 644-2266
L33
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name.
Great Lakes Chemical Corporation
Facility Location:
El Dorado, Arkansas, Region VI
Date(s) Audit Conducted:
August 30 and 31, 1989
Description of Facility:
Location:
SIC Code(s)•
Products manufactured
produced, or distributed:
Proximity to
sensitive populations:
4 miles southeast of El Dorado, Arkansas
SIC 2819 - Industrial inorganic chemicals
not elsewhere classified
SIC 2869 - Industrial organic chemicals,
not elsewhere classified.
Bromide based products for the"plastics,
fire fighting, consumer products,
agricultural, petroleum, water treatment,
and chemical industries.
N/A
Reason for Facility Selection:
ARIP Reports:
The facility was chosen because of its
prior release history and because it
produces and stores bromine, a hazardous
chemical. The latest release consisted of
10 pounds of bromine vapor that escaped
through vents in the tail brine line An
outlet from the dryer plugged, causing the
brine to back into the tail brine line
The hot tail brine vaporized the bromine,
causing a vapor release through the vents
The release was neutralized immediately
and there was no injury
10/20/88 bromine, sulfur trioxide. and
sulfur dioxide release (questionnaire
completed 4/4/89); 11/1/88 bromine release
(questionnaire completed 4/12/89),
11/11/88 bromine release (questionnaire
completed 4/12/89); and 2/8/89 chlorine
release (questionnaire completed 7/9/89)
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Focus of Audit.
Hazardous Substance(s)
Examined- Bromine
Chlorine
Sodium hydroxide
Sulfuric acid
Sulfur dioxide
Phosgene
Methylene chloride
Physical Area(s) Examined at the Facility:
Storage and Handling
• Storage Systems
• Shipping/Receiving
• Material Transfer
The facility stores bromine in 11 tanks with capacities between 2,000
and 17,000 gallons The tanks have secondary containment and are lead
lined for corrosion resistance. They are coded for 75 psig air padding.
A pipeline and well system extends for miles into the surrounding area,
supplying the facility with bromide bearing brine from an underground
limestone formation.
The company owns a subsidiary that transports bromine only The truck
tankers are specially designed to transport bromine and the drivers are
trained and equipped with personal protective equipment to deal with
bromine leaks in transit.
Currently, bromine is shipped by the following methods:
1) 1800-gallon truck tankers
2) 120-gallon cylinders (for export)
3) 25-gallon upright containers
4) 10 gallon containers
5) 1/2 gallon glass bottles, 4 per case
The facility is equipped to have returned tankers and cylinders cleaned
and refurbished for reuse. Defective containers are cleaned per RCRA
regulations and disposed of by crushing and sold as scrap material
Within the facility bromine is moved by tanker and by pipelines. Other
chemicals are used directly out of their shipping containers.
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Process Area(s)
Brine, containing bromine and other substances, is pumped from the
pipeline system and is transported in gaseous form to the sodium
hydrosulfite plant There it is stripped to. remove hydrogen sulfide,
carbon dioxide, nitrogen, methane, and other dissolved gases. Once
stripped of volatile gases, the brine is pumped to the top of a granite
tower where the bromine is separated through a reaction with chlorine
To recover the bromine, the resulting gas is condensed and then treated
with sulfuric acid to remove water. It is then vented to the atmosphere
through a scrubber stack The scrubber stack is the main air emission
point for the plant. The plant by-products are discharged in the waste
brine, which is injected back into the Smackover formation.
Summary of Audit Findings and Recommendation.
Conclusions:
Chemical Hazards
• For the purpose of removing liquid bromine from the skin in the
event of employee exposure, barrels of "Hypo" solution, containing
water, sodium carbonate, and sodium thiosulfate (water is not as
effective as a wash for bromine), are located throughout the
facility. A facility testing and maintenance program samples the
barrels to ensure their viability and replaces them as necessary
• Under extreme upset conditions, facility emergency procedures call
for the release of ammonia vapors to knock-down bromine vapors
Process Information
• There is no system that matches the serial number and the
contaminant for the drums in the hazardous waste storage area.
i.e., there is no serial numbered drum for each generator
• By utilizing smaller storage tanks, the company has reduced the
maximum quantity of bromine that could be released or spilled.
• Shipping stations are equipped with scrubbers to control bromine
vapors from escaping into the atmosphere; procedures for loading
and unloading bulk chemicals are given in the safety manuals.
• The plant control system is personnel oriented, relying on the
operators to make corrections and adjustments. Operators must
maintain visual contact with instrumentation and video monitors
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• The scrubber is monitored using a video camera and monitor in che
plant control room. The plant has experimented with analytical
detectors with bromine but did not find them as reliable as the
video monitor system.
Chemical Accident Prevention
• The facility has an ongoing program linking safety training to the
progression and promotion of operators
• The facility safety department conducts spontaneous safety
inspections on a regular basis
• Equipment is inspected and monitored during operation. Operators
were noted to be carrying radios for quick communication.
• Monthly employee safety meetings are held with the content
arranged by the facility safety department
• The maintenance group at the bromine plant operates extensively
using preventive maintenance and predictive techniques
• Based on interviews, personnel working at the hazardous waste
storage area had limited knowledge of the location of the waste
streams generated by the plant.
• Facility work rules cover vessel entry permits; work on hot
operating equipment; and use of different colored hard hats by
company and contractor employees
• New hires receive four hours of safety-related training, including
use of full-face respirators. Contractors have their own safety
programs consisting of a review of the Great Lakes safety program
and facility work and safety rules.
• Because of the staff's emphasis on corrosion control, equipment is
checked more often than is normal in the chemical industry For
example, relief valves are checked every three months, as opposed
to 1 to 3 years, and recertified annually in accordance with the
National Boiler Codes.
• The maintenance staff are involved in a program to continually
test new materials and products that will help to increase the
operating life and safety of equipment at the facility.
• The facility has developed a small, shirt-pocket-sized booklet for
all employees and contractors to provide easy reference to all
site work and safety rules.
• The facility has conducted an evaluation of vulnerability zones
using the CAMEO system in the event of a bromine release, although
a spill of the magnitude examined is considered unlikely
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• The main process area in che bromine plane is covered in concrete
contained, and drained to catch and hold any spilled materials for
treatment and to limit uncontrolled emissions
Accident Release Incident Investigation
• Great Lakes' policy is to investigate unusual plant emissions of
unknown cause The facility has made process and mechanical
changes in the past in response to these investigations in order
to reduce the likelihood of a recurrence.
Facility Emergency Preparedness and Planning Activities
• The facility safety department conducts weekly fire drills
• No SCBA was readily available in vulnerable parts of the plant
• No alarms and emergency telephones were identified in the
hazardous waste storage area.
• The facility alarm system provides the same type of notification
for releases and natural disaster incidents
• Facility fire brigade staff are sent to the State University Fire
Academy for training courses. The facility also holds joint
training programs with the local hospital to review various types
of medical problems such as bromine chemical burns and inhalation
Community and Facility Emergency Response Planning Activities
• Great Lakes sponsors the local volunteer fire department and many
of its employees are volunteer firemen.
• The management has coordinated safety programs with the local
hospital's emergency staff It has also undertaken simulation
spills to test company and local emergency preparedness
capabilities.
Public Alert and Notification Procedures
• Employees are issued wallet cards with a listing of plant and
community emergency telephone numbers.
Recommendations:
Process Information
• The facility should install a numbering system that would record
the serial number of the drum for each generator. Such a system,
if incorporated under the facility's satellite generator system
would improve record keeping
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• The video monitoring cechnique for the bromine scrubber is
vulnerable co human error and attention lapses Installing an
alternative would reduce the potential for accidents due to human
error
Chemical Accident Prevention
• Increasing the documentation level for the SOPs for both plant
operation and maintenance would assist cross- training of
maintenance and safety personnel
• Training personnel working at the hazardous waste storage area in
the location of waste streams in the plant would facilitate and
expedite containment efforts in case of a spill or release
Facility Emergency Preparedness and Planning Activities
• Consider installing SCBA storage in areas of the facility
vulnerable to releases to improve access to such emergency
equipment
• The facility should determine if a centralized emergency control
center is feasible to replace existing plan with satellite EOCs
Having a single point for communications could reduce the amount
of time spent notifying emergency personnel
• The management should consider upgrading the alarm system in a
manner that would communicate the specific nature and location of
an emergency to personnel. Such a measure would speed containment
operations when the alarm sounds.
• The installation of alarms and rgency phones in the hazardous
waste storage area would improv .id speed communication in case
of an accidental release
Audit Team Member Composition:
Name and Title Greg Fife
Affiliation EPA - Region VI
Area of Responsibility Mechanical/Chemical Systems
Expertise
Name and Title George Allman
Affiliation EPA - Region VI
Area of Responsibility Title Ill/Health & Safety/Training
Expertise
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Name and Title Fendol Chiles, AARP
Affiliation EPA - Region VI
Area of Responsibility Chemical systems/Transportation, handling
Expertise N/A
Name and Title Russell Shilling, Technical Assistance
Team
Affiliation N/A
Area of Responsibility Health & Safety, & Documentation
Expertise N/A
Follow-up Activities:
By the Facility:
• N/A
By the Regional Office:
• N/A
By State and Local Authorities:
• N/A
Regional Contact:
Steve Mason
(216) 655-2277
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:.
Farmland Industries Enid Ammonia Plane
Facility Location:
Enid, Oklahoma, Region VI
Date(s) Audit Conducted:
August 15 and 16, 1989
Description of Facility:
SIC Code(s):
Location:
Products manufactured,
produced, or distributed:
Proximity to
sensitive populations:
SIC 2873 - Nitrogenous fertilizers
70 miles north of Oklahoma City in a
lightly-populated rural area
Anhydrous ammonia.
Major highway is one-half mile to the
north and airport is within one mile.
Reason for Facility Selection:
ARIP Reports:
Focus of Audit:
Hazardous Substances(s)
Examined:
The facility was selected as a result of a
series of small releases (100-200 Ibs ) of
ammonia over a short period of time for
which no ARIP questionnaire was prepared
9/30/88 ammonia release (questionnaire
completed 4/12/89); 12/28/88 ammonia
release (questionnaire completed 4/12/90),
and 2/6/89 ammonia release (questionnaire
completed 7/7/89)
Ammonia
Chlorine
Formaldehyde Solution
Urea
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Physical Area(s) Examined at the Facility
Storage and Handling
• Storage Systems
• Material Transfer
Storage Units The primary storage system at the facility consists of
two 30,000 ton atmospheric pressure storage units which are located
north of the urea plant in a somewhat isolated and bermed location on
the property During normal operation, the two tanks hold an average of
14,000-17,000 tons combined, or 7,000-8,000 tons each. Peak amounts
reached 39,800 tons combined during FY 88 and 28,400 tons combined
during FY 87 Ammonia which is to be shipped directly off-site is moved
to two bullet storage tanks in the loading area, each with a capacity of
200 tons. All four storage tanks are clearly marked and display an NFPA
Fire Diamond
Transfer Operations The plant's loading facilities can fill tank
trucks, each at a capacity of 20 tons, or load rail cars, each with a
capacity of 80 tons, within the confines of a completely closed system
Approximately 24 eighty-ton cars, and anywhere from 50 to 100 tank
trucks are shipped daily; the fluctuation being dependant upon seasonal
demand for anhydrous ammonia. Ammonia is also moved through the 8"
pipeline connecting the Enid facility with Farmland storage facilities
in Kansas, Nebraska, Iowa, and Minnesota. Farmland Industries transfers
custody of approximately 700 tons of ammonia to Mapco, the pipeline
owner, and takes back the product at each respective destination point
for distribution on a daily basis
Process Area(s)
• Haber Ammonia Manufacturing Process
Raw Material Production. Methane gas is preheated and desulfurized, air
from the atmosphere is filtered and compressed, and water is
demineralized for use in steam generation.
Hydrogen Generation. Methane gas is mixed with steam and passed through
a primary reformer furnace A catalytic reaction occurs in the furnace
resulting in the partial conversion of the methane gas and steam mixture
to carbon dioxide and hydrogen. The hydrogen conversion is complete
when the gas mixture is passed through a secondary reformer. The
process air is introduced in the secondary reformer to provide nitrogen
in the exact amount required in the synthesis stage for the ammonia.
Gas Purification. The gas mixture is then passed through a shift
converter and the carbon dioxide removal towers During this phase,
carbon monoxide is converted to carbon dioxide and removed by
absorption. Because some carbon monoxide and carbon dioxide remain in
the gas stream, the gas is passed through a methanation unit in order co
catalytically remove these impurities.
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Ammonia Synthesis The gas is brought to a high pressure by a
compressor prior to being fed into an ammonia converter In this
converter, ammonia is being formed by the reaction between hydrogen and
nitrogen
Refrigeration Ammonia is separated from the manufacturing process by
refrigeration to 28° Fahrenheit Anhydrous ammonia at this temperature
is a liquid, and can be stored in either of two 30,000 ton atmospheric
pressure storage units.
Summary of Audit Findings and Recommendations:
Conclusions:
Process Information
• The two primary and two secondary ammonia storage tanks are
clearly marked and display an NFPA Fire Diamond
• The majority of the instrumentation in each control room is
electronic, operating within the basic process parameters patented
by M.W. Kellogg Co
• In nearly all cases, process and control design drawings were
accurate and current with regard to process parameters, generally
representative of present operations, and marked with proper
design and safety documentation for all changes in hazardous
materials process lines and valves.
• If a failure occurs in the primary electrical supply system,
uninterruptible power is supplied by a similar but separate backup
system.
• A review of valve fail-safe and interlock conditions indicates
that the previous releases were the result of overpressure
conditions leading to direct venting of ammonia to the atmosphere
through the main process stack.
• There are no release mitigation procedures for these incidents,
but the facility is in the process of developing procedures and
identifying equipment to address these concerns.
Chemical Accident Prevention
• Pre-employment physical exams are administered to initially
certify employees' ability to wear respiratory protection, but no
follow-up certification is performed because there is limited job
turnover and they have rarely needed the equipment.
• Formal procedures, as recommended by Kellogg, exist for failure
mode analysis and emergency operations procedures.
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, Formal, written SOPs exist to address emergency operations.
on-the-job training, start-up/shut-down procedures, and
maintenance requests
• Formal training for Farmland response personnel includes fire
training at Oklahoma State University, as well as in-house
training and cross-training with the Enid Fire Department
» Several training programs are in place at the plant and are
maintained due to an unusually low turn-over rate within the
facility.
All new hires and contractors are presented with an eight
hour chemical handling course.
All employees are required to attend a one hour monthly
safety meeting
Training in chemical handling, basic process parameters.
start up/shut down procedures, maintenance procedures,
emergency communications, and use of respiratory protection
devices is provided to new plant personnel, including
contractors Plant office personnel also receive
appropriate sections of this training.
There is a cross-training program between operators and
control room personnel to improve the ability to handle an
emergency situation effectively during late shifts when
there are fewer personnel on duty.
• Anv design change within the system is subject to a detailed
analysis in order to assure compatibility with the basic process
parameters and licensing procedures
• Farmland HQ personnel conduct an in-depth, annual audit at the
facility to ensure regulatory as well as corporate compliance with
environmental programs, personnel health and safety, and
permitting standards. Audit results are developed from a
comprehensive checklist as well as a formal report, after which
Farmland management personnel discuss the results and agree on any
remedies to be initiated.
• While the audit team did not perform an in-depth evaluation of the
facility's scrubber systems, the company has performed stack tests
on all systems to determine removal efficiency and emission levels
under current operating and emergency conditions.
Accident Release Incident Investigation
• In most of the five recent reportable releases of ammonia, a
detailed evaluation of the incident was performed, recommendations
were made, and remedies were implemented.
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Facilicy Emergency Preparedness and Planning Accivicies
• Farmland's emergency response plan for cacascrophic or major
release events is not routinely updated
• Farmland's emergency response plan, including the planning guide
for coordinating with local emergency responders, has never been
exercised or drilled within the facility other than in a table-cop
exercise
• There are approximately 150 respiratory protection devices in the
urea plant, which are maintained by the safety department SOPs
require that after a respiratory device is used it must be
sanitized, and the used canister discarded and replaced. The
safety department documents these activities
• A siren alarm exists only in Unit No 1, the plant relies on radio
communications for emergency notification throughout the remainder
of the facility -- all operators and plant personnel are required
to carry hand-held radios
Public Alerc and Notification Procedures
• The plant technical superintendent is Che LEPC chairman and has
conducted cross-training with the local civil defense, fire,
police, sheriff, and the Oklahoma SERC, as well as facility tours
and reviews of MSDSs for on-site hazardous substances.
• While the NRC was notified for recent releases, the SERC and LEPC
were not notified as required by SARA Title III section 304
because the facility believed that there had been no off-site
exposure. The facility believed that the releases would have
significantly dispersed before they reached the facility boundary
1/4 mile away.
Recommendations:
Facility Emergency Preparedness and Planning Activities
• It is recommended that a schedule be designed for updating the
emergency action plan.
• Ic is recommended that an exercise be conducted to test the
updated plan.
Community and Facility Emergency Response Planning Activities
• If at all possible, local emergency responders should be involved
in the exercise simulation to ensure their familiarity with
emergency procedures and the identification of weaknesses, if any,
which exist in the plan.
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Although ic may noc be required by current rules or regulations,
it LS recommended that Farmland contact the SERC and LEPC for any
release thac requires reporting to the NRC under CERCLA in order
to alleviate any doubt in whether any person outside the facility
boundary is exposed
Audit Team Member Composition:
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Greg Fife, OSC -- Audit Team Leader
US EPA Region VI
Mechanical and Chemical Systems
Civil Engineer
Steve Mason
US EPA Region VI
Health and Safety Hazard Communication
Training/Health and Safety/Releases
Fendol Chiles, AARP
US EPA Region VI
Chemical Systems/Process Analysis
HazMat Transportation and Emergency
Response
Kathleen Kennedy, TAT
Region IV
Health and Safety and Documentation
Training
Larry Edmison
Oklahoma SERC
Chemical Systems
SERC Observer
Follow-up Activities:
By the Facility:
• Farmland intends to implement a computerized recall system to
preclude similar instances of failed equipment from occurring.
• Farmland intends to notify the SERC and the local fire department
of all releases that exceed the RQ even if off-site exposure may
not occur.
By the Regional Office:
• N/A
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By State and Local Authorities
o N/A
Regional Contact:
Sceve Mason
(214) 655-2277
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Ferraenca ASC Corporacion
Facility Location-
Houston, Texas, Region VI
Date(s) Audit Conducted:
September 12-13, 1989
Description of Facility:
SIC Code(s)
Location:
Products manufactured,
produced, or distributed:
Proximity to
sensitive populations*
SIC 2879 - Pesticides and agricultural
chemicals, not elsewhere classified.
Greens Bayou area in eastern Houston, TX
Dacthal, Daconil, Isophthalonitrile,
Arsonate, and Bravo.
A small residential area is located
approximately 1/4 mile to the north of che
facility. Cloverleaf Elementary School is
within one mile, and Tidelands General
Hospital, North Shore Elementary School,
junior and senior high schools, and the
Northshore Medical Plaza Hospital are
within two miles of the facility
Reason for Facility Selection:
ARIP Reports:
The facility was chosen because of the
release of chlorine gas on 10/08/88
None prior to audit.
Focus of Audit:
Hazardous Substances(s)
Examined:
Chlorine
Ammonia
Xylene
Isophthalonitrile
Chlorothalonil
Hydrochloric Acid
Caustic Soda
Sodium Hypochlorice
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Terephchalic Acid
Methanol
Arsenic Trioxide
Methyl Chloride
Mono Sodium Mechyl Arsenace
Physical Area(s) Examined at the Facility:
Storage and Handling
• Storage Systems
• Shipping/Receiving
Over 50 hazardous materials (raw), intermediates, and wastes are handled
on a daily basis. Their properties and degree of hazard vary widely
Material Safety Data Sheets (MSDSs) are available for all employees and
they have been trained to interpret the data These materials are
received in bags, drums, tank trucks, tank cars, and hopper cars There
are three different rail car and tank truck unloading facilities
plantwide for the different chemicals
Chlorine, one of the major raw materials used in both Chlorothalonil and
Dacthal manufacturing, is brought to the site in rail cars (each with a
capacity of 200,000 pounds) from various sources. On average 25 to 30
tank cars are on site at any time. Chlorine is kept in the railcar
until needed; other raw materials are stored in different containers
Four unloading stations are used to unload liquid chlorine to
vaporizers. The pad vaporizer pressures the liquid chlorine from the
rail car to the feed vaporizer, where it is vaporized for transfer to
the process units. An emergency dump tank is used to transfer chlorine
if the vaporizer develops a leak. Chlorine vented during the transfer
is routed to the transfer vent scrubber or the emergency dump scrubber
The vaporizers and dump tank are equipped with high pressure release
valve and rupture disks connected to the emergency dump scrubber. A
caustic soda solution is kept circulated through the scrubber to
neutralize the chlorine, and begins automatically when a pressure
increase occurs in the relief valve discharge header. An alarm also
sounds in the control room alerting the operator to adjust the make-up
of caustic soda solution from storage.
Products are loaded at unit production locations. Personnel receive
product-specific training for loading and formulations. Products are
shipped in tank trucks, rail cars, and motor freight boxes. Products
that were prepared for shipments were properly classified, described,
packaged, marked, and labeled per DOT regulations.
Process unit storage areas usually store newly packaged wastes for a few
days before it is moved to a central location, where drums are
accumulated prior to shipment to an approved commercial hazardous waste
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disposal facility. For special projects, bulk storage bins are brought
in to hold contaminated soil and construction debris
Process Area(3)
• Isophthalonitrile (IPN)
• Chlorothalonil
• Daethai
• Arsonates
Isophthalonitrile. IPN is produced by the catalytic ammoxidation of
metaxylene in a fluidized bed. The process is divided into reaction,
product recovery, and ammonia recovery. In the reaction zone, metaxylene
and recycled hydrocarbons from the product distillation section are
mixed and partially vaporized using steam The vapors and ammonia are
treated using steam or dowtherm vapors and fed to the reactor containing
a fluidized bed of solid catalyst to form product dinitrile IPN is
then scruboed from the vapors using xylene rich quench solution The
vapors are mixed with ammonia recycled stream, and the quench solution
is distilled to separate the IPN product, which is melted and flaked
Chlorothalonil. The process consists of reaction/product recovery, off
gas absorption, chlorine recovery, and pollution abatement Molten IPN
is heated with superheated chlorine in the presence of an activated
carbon catalyst to manufacture Chlorothalonil Chlorothalonil,
entrained catalyst, unreacted chlorine gas, underchlorinated IPN, and
other impurities rise up from the catalyst bed and pass through two
cyclones in series which knock down the entrained catalyst. The gases
are then sprayed with cold carbon tetrachloride to desublime the product
into a powder and then passed through baghouse filters which remove the
entrained Chlorothalonil powder. The product Chlorothalonil passes
through a conversion process to form the desired form of the material,
and then through a rotary valve and ribbon blender before packaging
Dacthal The production involves four batch reactions and five
purifications steps. First, paraxylene is reacted with superheated
chlorine gas in the presence of ultraviolet light to form hexachloro
para xylene and hydrogen chloride gas. Next, terephthalic acid is
reacted with these products to form terephthaloyl dichloride (TPC).
Then the TPC is reacted with chlorine in the pcesence of ferric chloride
to form cecrachloroterepthaloyl dichloride (TTD). The TTD is treated
with caustic and mechanol in a xylol solution to form Dacthal and salt
The reaction mass is transferred to a methanol water still pot and the
methanol is removed; the slurry is then centrifuged to remove salt
formed during reaction. The remaining solution is fed to a xylol
stripper to separate xylol from Dacthal. The Dacthal is concentrated,
purified, and flaked. The flakes are mixed with dispersants, wetting
agents, and clay in a series of blenders and mills and then packaged.
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Arsonates Production consists of four reaction steps -- digestion,
methylation, oxidation, and acidification -- followed by evaporation and
centrifugation. First, liquid caustic and water are sent to the
arsonate digester, and powdered arsenic trioxide is added to form sodium
arsenite and water. Next, the sodium arsenate solution is sent to an
autoclave reactor and liquid methyl chloride is added to form disodium
methyl arsenate (DSMA) and salt. The autoclave is then vented, and the
product is drained into a slurry tank. Sodium hypochlorite is then
added to the slurry to convert the residual trivalent arsenic to the
less toxic pentavalent. The slurry is drained to the acidifier, where
concentrated sulfuric acid is added to convert DSMA to mono sodium
methyl arsenate (MSMA). Once the desired pH is reached, the acidified
slurry is cooled and centrifuged to separate the solids from the MSMA
solution. Finally, the MSMA solution is concentrated in two single
effect evaporators until the desired concentration is reached, it is
then cooled, solids are centrifuged again, and the concentrated MSMA is
formulated into four different products
Summary of Audit Findings and Recommendations:
Conclusions:
Facility Background Information
• The facility employs approximately a total of 330 contract and
regular employees. The oldest part of the facility was built in
1967 and the newest part was built in 1979
Process Information
• As many as 30 railcars containing chlorine are on site at any
time. The company leases a rail engine to move the rail cars
During an emergency, such as a major fire, the rail cars will have
to be moved.
• The xylol and methanol tanks are within a single dike in the
Dacthal plant.
• All units have centralized control rooms where critical process
parameters are monitored and recorded continuously. Critical
systems are connected to audio-visual alarms which are activated
when parameters exceed safe levels. There are periodic
inspections and preventive maintenance to minimize breakdowns
• At present, the emergency dump scrubber and waste chlorine
scrubber in the chlorine vaporizer area do not have a back up
power supply.
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• The rupture disc vents in the Dacchal and che Daconil plants are
open to the atmosphere In case of a rupture, the contents of the
reactors, including chlorine, could be released to the atmosphere
• A dump tank, which is kept empty and at low pressure, is available
to receive liquid chlorine in the event of a leak in the ch.lori.ne
vaporizer process.
• In case of an emergency, the chlorine flow can be cut off and the
chlorine remaining in the system can be vented to neutralizers and
environmental vent scrubber (EVS) rather than released to air
The EVS was installed in 1986 to reduce the number of reported
releases at the facility The EVS was specifically designed and
periodically upgraded to anticipate a major release of chlorine
based on the design capacity of the relief valves and rupture
discs.
• Fermenta has backup power for most essential systems
• Most groundwater monitoring has been done to comply with RCRA
regulations and the areas to be monitored for groundwater quality
are determined internally. These areas currently include the
sludge drying basins, the neutralization ponds, a storm water
basin, and a closed plant landfill.
Chemical Accident Prevention
• Fermenta performs a formal safety and loss prevention audits with
a goal of three annually A group of 10-12 people spend 2-3 days
reviewing procedures for a specific area, causes of accidents,
etc, and the safety department prepares a report.
• Clearly written and detailed operating procedures were available
at various sections of the plant.
• The chlorine vaporizer operating manual was systematic and
included a description of emergency shutdown procedures, critical
operating parameters, as well as general operating procedures
• The operating procedures for the chlorine unloading area cover all
aspects of the operation. The operator has specific instructions
for preparing to transfer chlorine, and there are similar
instructions for disconnecting the railcar. The operator is
required to wear a respirator during these operations
• Operating logs are mandatory and time and various parameters must
be entered periodically Readings from various equipment
locations are also taken periodically.
• There is a weekly preventive maintenance checklist for all
controls and alarms to minimize breakdowns. The sensors are
checked and cleaned during annual shutdowns.
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Fermenta's maintenance department, including five different
maintenance shops, is given internal and external training
including a video tape based hands-on instruction program
Maintenance is planned and scheduled as far as possible in
advance Work orders are initiated from the section requesting
maintenance and scheduled by computer. An up-to-date equipment
history is maintained for reference. About half of maintenance
work is scheduled. There is also a computerized on-site central
store for spare parts.
There is also a preset frequency for maintenance of critical
equipment based on service conditions and the degree of hazard
The company also employs predictive and preventive maintenance
techniques to reduce breakdowns.
As part of its preventive maintenance program, Fermenta has a
system of checking flanges in its chlorine system with ammonium
hydroxide sprays. The ammonium hydroxide forms dense white fumes
with even trace amounts of chlorine Operators are specifically
instructed to check all connections with weak ammonium hydroxide
before transferring chlorine.
Training addresses MSDSs, personal and plant safety rules,
communication rules, evacuation procedures, and process overviews
for personnel who might enter each process area Training
programs are designed to meet OSHA and other regulatory standards
and many are mandatory for all plant personnel. Certain programs
are repeated frequently so that personnel are informed of changes
If process changes occur, Fermenta puts additional staff on-site
until the operation is proceeding smoothly; they do piggyback
training and may have a double staff of operators during start-up
Ferraenta has a classification of utility helper to fill positions
that open up due to employee turnover.
Fermenta does not have a master qualifications list showing
different individuals who are qualified Co carry out different
jobs/tasks. Fermenta does not keep documents pertaining to each
position that reflect all of the duties of individual personnel
Employees receive performance evaluations annually to ensure that
they are qualified for their assigned tasks.
Modeling is not a part of Fermenta's SPCC plan, but air modeling
has been performed for catastrophic releases of chlorine Most of
this information focused north of the plant, where the worst-case
scenario could reach a residential area and elementary school
Fermenta has used modeling to compare with stack sampling.
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• Fermenta continues to use the CHARM system to evaluate the impact
of chlorine system failures to gauge the effectiveness of the
existing mitigation systems and evaluate the need for additional
systems Fermenta has also performed catastrophic modeling on
methyl chloride.
• The chlorothalonil and dacthal plants are equipped with chlorine
neutralization systems. The units in the chlorothalonil plant are
capable of neutralizing the entire chlorine release, and the
system in one plant can be used for another plant in case of
emergency. The system in the dacthal plant consists of three
scrubber units
Accidental Release Investigation
• The environmental department at the Fermenta plant track all
releases even if below a reportable quantity
• The facility has developed a Spill Reporting Procedures Manual, an
Environmental Release Notification report, and a Spill and Air
Pollutant Release Report to assist in the proper reporting of
spills and releases
• Annual section 313 release estimates are available for internal
and external use as computer printouts.
Facility Emergency Preparedness and Planning Activities
• The facility has a spill prevention, containment and
countermeasures (SPCC)/contingency plan which serves as its
emergency response plan. The plan describes procedures in the
event of a fire, explosion, or accidental release.
• The plan also references the facility Safety and Health Manual,
which contains emergency policies and procedures, training
provisions, and details on receiving and supplying aid outside the
plant
• There is no set schedule for updating the plan; the last major
update was in 1988
• Personnel appear familiar with the emergency response procedures
• Fermenta has conducted annual exercises in the last few years, and
starting in 1989, management has sec a goal of quarterly
exercises.
• An exercise conducted in March 1989 revealed that the facility
needs to concentrate on the establishment of a command structure
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• Personal protective equipment and fire fighting equipment are
placed at many locations in the plant, and there are also
provisions for breathing air supply.
• Response equipment, SCBA gear, medical supplies, and protective
clothing is maintained in good working order Each area of the
plant inspects their equipment weekly.
• The Safety Department performs monthly inspections and maintains
written records on all safety equipment. Once a year, a private
contractor is brought in to check this equipment.
• During an emergency the shift supervisor for the half of the plant
involved in the incident becomes the on-scene coordinator. The
other shift supervisor becomes the emergency coordinator and also
serves as a replacement for the on-scene coordinator if he is
unable to serve in that capacity.
• Information during an emergency is communicated by telephone (to
managers), by radio communication, and within the central command
post, an emergency response truck. Most employees use radios and
in an emergency there is a designated communications frequency
• Fermenta's response team is designed to handle almost any
emergency, and the facility estimates that it would depend upon
outside help for only ten percent of all incidents.
• Fermenta's emergency team is composed chiefly of volunteer plant
personnel with special emergency response training.
• Refresher emergency response training courses are provided
quarterly to the Emergency Response Team personnel, and on an
annual basis for all other employees. Topics covered include
alarm identification and response, use of emergency response
equipment, evacuation procedures, and response to a hazardous
substance release.
• There is an on-site meteorology station run by the Maintenance
Department which records wind speed and direction attached to a
time recorder. Several wind socks are also strategically located
around the plant.
Community and Facility Emergency Response Planning Activities
• The environmental and safety departments are actively involved in
the community through the LEPC. The plant participates in the
Community Awareness and Emergency Response program even though
they are not a member of the Chemical Manufacturers Association
• The facility has three regular representatives on the LEPC that
have served on the steering and public information subcommittees
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• The company was involved with the community in emergency drills on
06/07/88 and 07/09/89
• The facility has developed a list of response equipment and staff
that may be used during an incident. This equipment will be made
available to other facilities only under the Channel Industries
Mutual Aid (CIMA) agreement Fermenta has interactive training
for response personnel with CIMA.
Public Alert and Notification Procedures
• There is no formalized interaction between the facility
spokesperson and the broadcast media. No rapport with the media
has been developed.
Recommendations:
Process Information
• The switch engine should be secured in a fenced area inaccessible
to the public
• Track switches should be checked and locked into position and not
assumed to be opened or closed in interplant operations.
• The gates that allow entrance to the plant for rail tracks or spur
tracks should be secured after inbound switches have been
performed.
• It is recommended that the facility have back up power available
for the emergency dump scrubber.
• It is recommended that two operators work in the railcar unloading
area in view of the hazard potential of the operation.
• Color coding of piping system should be implemented in process
areas to assist fire fighters or operators who are not familiar
with the system in case of an emergency.
• Containment measures should be implemented for the rupture disk
vents that are otherwise open to the atmosphere in the Decthal and
the Oaconil plants.
• It is recommended that the xylol and methanol tanks that are
within a single dike be spaced and diked separately to minimize
the chance of a major fire.
• It is recommended that the environmental and safety departments
become more familiar with fence line monitors and their upkeep.
The maintenance department is currently responsible for upkeep
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• Ic is suggested chac additional personal monitoring instruments
in addition to the Draeger tubes, would be beneficial to employees
when determining whether it is safe to re-enter a release area
• It is recommended that chlorine monitors be placed inside the
plant to improve environmental monitoring of this acute hazard
• The environmental chlorine monitoring system for the railcar
unloading area should be modified and connected to the existing
alarm system in the Daconil II unit or to the water treatment
control room.
Chemical Accident Prevention
• More formal communication and cooperation is needed between the
safety and environmental departments, which share certain duties
• A company sponsored, detailed chemical safety audit to look into
the various aspects of safety is desirable in view of the nature
of the chemicals being handled. Many other companies of this size
have a corporate audit policy
• The training records maintained in the safety, environmental and
human resource department should be consolidated >and computerized
for quicker access and proper tracking of the training on each
employee. The consolidation of training records will allow the
safety office to better track employee training to meet OSHA
training requirements.
Facility Emergency Preparedness and Planning Activities
• During an emergency, such as a major fire, the rail cars located
on site will have to be moved. Procedures for this should be
included in the emergency plan.
• It is recommended that the level A hazardous materials suits have
sufficient backup to provide every two man operation with a back-
up of two people, if this level of equipment is to be used
properly. This type of suit requires annual training.
• The facility should specifically identify the person(s)
responsible for the maintenance and development of that plan since
there are no existing procedures for reviews or updates.
• The facility should assign a specific time span for plan
revisions, reviews, and updates, e.g., every six months, annually,
biannually, etc
• Dispersion models should be used more in plan development.
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• Although the facility has a viable emergency plan, management
personnel should be more aware of how their plan coordinates wich
Harris County's Basic Emergency Plan.
• The facility should consider holding several different types of
exercises on a rotating basis annually
• The facility should develop their own maps of the community rather
than rely on out-of-date community sources.
• It is suggested that an employee information officer should be
designated to update site personnel during an emergency
Community and Facility Emergency Response Planning Activities
• Existing modelling efforts need to be expanded and shared with the
LEPC, and a hazard analysis should be completed for the plant to
improve in-plant risk analysis.
• The facility should consider sponsoring training for the local
fire department and Emergency Medical Services members and also
invite these local officials to participate in more on-site
exercises.
• Discrepancies found during exercises should be reviewed and
emergency plans updated to formally address those issues
Presently, discrepancies found during drills are not used to
revise the existing plan.
• It is strongly suggested that more work be done in the area of
media relations. More management level personnel should be
trained in that area although there are designated public
information personnel.
• It is suggested that those responsible for emergency plans and
procedures familiarize themselves with the Harris County response
plan, and determine how it would work in conjunction with the
facility emergency plan.
Audit Team Member Composition:
Name and Title Greg Fife, OSC
Affiliation US EPA Region VI
Area of Responsibility Operations and Processing Units
Expertise N/A
Name and Title Fendol Chiles, AARP
Affiliation US EPA Region VI
Area of Responsibility RCRA and Shipping
Expertise N/A
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Name and Title
Affiliacion
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Dusty Pruitt
US EPA Region VI
SARA Title III Reporting
N/A
Tom Barsley
TAT, US EPA Region III
Operations and Processing Units
N/A
Linda Ziegler
TAT, US EPA Region III
SARA Title III Reporting
N/A
Paula J McKinney
Texas Department of Health
Safety/Health and Emergency Response
N/A
Dr. Harvey J Houng
Texas Department of Health
Safety/Health and Emergency Response
N/A
Captain K.W. Berry
Harris County Sheriff's Office
Safety/Health and Emergency Response
N/A
Tanwir Badar
Cloverleaf - Channelview LEPC
RCRA and Shipping
N/A
Follow-up Activities:
By the Facility:
N/A
By the Regional Office:
• N/A
By State and Local Authorities:
N/A
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Regional Contact:
Steve Mason
(214) 655-2277
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Chief Supply Company ("Chief")
Facility Location:
Haskell, Oklahoma, Region VI
Date(s) Audit Conducted:
October 16-17, 1989
Description of Facility:
SIC Code(s).
Location:
Products manufactured,
produced, or distributed:
Proximity to
sensitive populations:
SIC 2841 - Soap and other detergents,
except specialty cleaners.
45 miles southeast of Tulsa, OK
Industrial organic chemicals, primarily
solvents, soaps, detergents, lubricants
and other similar cleaning compounds and
sanitation goods
N/A
Reason for Facility Selection:
ARIP Reports:
The facility was chosen because of a
suspected release on September 27, 1989,
and other suspected releases reported by
citizens living in proximity to the plant
None prior to audit.
Focus of Audit:
Hazardous Substances(s)
Examined:
Mineral Spirits
Methylene Chloride
F001 - F005 Solvents
D001 Wastes
Fly Ash
1,1,1-Triehloroethane
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Physical Area(s) Examined at the Facility:
Storage and Handling
• Storage Systems
• Shipping/Receiving
• Material Transfer
The Chief Supply storage facility consists of one-third incoming spent
solvent wastes drum storage and two-thirds controlled industrial waste
product storage from the distillation process.
The facility foundation and floor are concrete, and the floor perimeter
is also rimmed with continuous concrete curbing, the secondary
containment system, which has a volumetric capacity equal to 69 percent
of the facility's maximum storage capacity A chain-link fence
surrounds the building, which is accessed through padlocked fence gates
and lockable building doors.
A "Controlled Industrial Waste Drum Storage Log" records all incoming
spent solvent waste drums, even those which are immediately processed
and not sent to the storage facility, as well as all outgoing drums for
the various recycling processes.
Spent solvent wastes destined for recycling via drum distillation are
loaded onto trucks at the storage building and then transported to the
plant, where they are placed on a roller track system that carries them
to the drum distillation unit.
Spent solvent wastes destined for recycling via reactor distillation are
pumped into a vacuum truck at the storage building, and then transported
to the plant, where they are pumped directly into the reactor
distillation unit
Spent solvent wastes destined for recycling via incineration for energy
recovery are pumped into a vacuum truck at the storage building, and
then transported to and loaded into an on-site tanker trailer vessel,
which transports these wastes to an off-site industrial furnace.
Process Area(s)
• Reclamation processes of D001 and F001 - F005 solvents
• Fly Ash operations
• Waste Fuels process
There are two primary processing methods. The Drum Distillation Process
converts liquid spent solvent wastes into a vapor utilizing steam-
generated heat, condensing the solvent vapor, and recovering the solvent
condensate as product to be retailed for further use. This is
accomplished while the wastes remain in the original container, by
placing a steam jacket around the drum exterior, inserting a copper
steam coil inside the drum, or injecting live steam into the drum. The
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Reactor Disci.llati.on Process converts liquid spent solvent wastes into a
vapor, condensing the solvent vapor, and recovers the solvent condensace
as product to be retailed for further use. Under the convection method.
spent solvent wastes are placed into the reactor kettle and heated by
circulating steam or Dowtherm oil throughout the reactor jackets
surrounding the kettle, and under the live steam method, they are placed
into the kettle and live steam is then injected directly, the condensace
is allowed to stand for phase separation, after which the water is drawn
off
Summary of Audit Findings and Recommendations:
Conclusions:
Process Information
• Workers wore hard hats and safety glasses, but several did not
wear safety shoes for working around drums and heavy equipment
• Bulk shipments of similar chemical wastes are combined in the
storage area.
• Process areas and tanks throughout the plant have secondary
containment -- hazardous waste storage areas have concrete floors
rimmed with continuous concrete barriers; however, breaches in
containment around doorways could occur because of the lack of
raised curbing in these areas.
Chemical Accident Prevention
• Chief Supply has implemented a basic health and safety program
with management support, addressing first-aid procedures
• Training records for employees were up to date; interviews with
employees indicated they were knowledgeable and well-informed of
the hazards associated with their job functions.
• The storage and maintenance of personal protective equipment --
breaching apparatus - - may have inadvercencly led to component
decerioration.
Facility Emergency Preparedness and Planning Accivities
• Chief Supply has a contingency plan in Che evenc of a hazardous
macerials release or spill which ouclines chain of authority,
response and notification procedures, and Che resources available
for response. However, che concingency plan does not show a date
of promulgation or a schedule of revisions.
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• The contingency plan lists the type of materials chat may cause
hazards in an emergency, how these chemicals should be handled in
an emergency, and what response workers should take, depending on
whether the spill is considered large or small
• The eyewash station in the laboratory was not easily accessible
• Safety equipment was present in key areas of the plant, but was
not stored in accordance with requirements and cleaning and
maintenance were needed.
Community and Facility Emergency Response Planning Activities
• The contingency plan has been distributed to the local fire,
police, and health department, the local hospital, and two
emergency medical service providers, and there are arrangements
with these organizations for response assistance
Recommendations•
Process Information
• Chief Supply needs to supply locked storage containers for the
chemicals maintained in the laboratory area.
• Chief Supply needs to develop an improved system for tracking
waste to show the location or disposition of any specific barrel
within a bulk shipment.
• Chief Supply needs to improve security procedures at the plant to
deter intruders and to assist workers during an emergency
Chemical Accident Prevention
• Chief Supply needs to develop a more comprehensive Health and
Safety plan for their employees which includes respiratory
protection.
• Chief Supply should provide managers and 'supervisors with more
specific and detailed training in hazardous materials spill
prevention and control.
• Chief Supply needs to update maintenance records on equipment used
in the laboratory to insure maintenance schedules are met.
Facility Emergency Preparedness and Planning Activities
• Chief Supply needs to more clearly define waste storage and
handling areas to eliminate mixed storage conditions.
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• Chief Supply needs to improve vencilacion and provide additional
escape routes from the lab area because there is only one door
• Chief Supply needs to improve maintenance and care of personal
protective equipment, such as breathing apparatus, to insure the
components do not deteriorate
• Chief Supply needs to move safety and fire equipment to more •
visible areas and to install large-scale chemical fire
suppressants in all buildings housing ignitable materials
Community and Facility Emergency Response Planning Activities
• Chief Supply should review reporting procedures for accuracy,
timeliness, and follow-up, and refine the contingency plan to
reflect CERCLA and SARA requirements to insure that any time an RQ
is exceeded during a spill or release, the NRC, SERC, and the LEPC
are notified immediately.
• Chief Supply needs to improve community awareness and public
relations by continuing to offer open houses for the public and as
much technical and resource support as feasible to fire department
local emergency responders.
Audit Team Member Composition:
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Tide
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Steve Mason, Team Leader
US EPA Region VI
Title III and Public Relations
N/A
Greg Fife, OSC
US EPA Region VI
CERCLA Investigation and Emergency
Notification and Response Procedures
N/A
George Allman
US EPA Region VI"
Health & Safety and Employee Training
N/A
Fendol Chiles. AARP
US EPA Region VI
Transportation and Shipping
N/A
Kishor Fruitwala
TAT. US EPA Region VI
Chemical Systems and Process Evaluation
N/A
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Name and Title Curtis Franklin
Affiliation TAT, US EPA Region VI
Area of Responsibility Technical Assistance Support and
Documentation
Expertise N/A
Name and Title Juan Corpion
Affiliation US EPA Region VI
Area of Responsibility RCRA Inspector
Expertise N/A
Name and Title Suzy McKinney
Affiliation US EPA Region VI
Area of Responsibility RCRA Enforcement
Expertise N/A
Name and Title Catherine Sharp
Affiliation Oklahoma Health Department
Area of Responsibility Public Health Evaluation
Expertise N/A
Follow-up Activities:
By the Facility:
• Chief is committed to developing a more comprehensive health and
safety plan for its employees no later than May 1, 1990
• Chief implemented a comprehensive tracking system for managing
hazardous wastes on-site in December 1989.
• Chief implemented a maintenance program for its employees'
personal protective equipment in February 1990.
• Chief updated its maintenance records on the equipment used in the
laboratory in February 1990.
• Chief has more clearly defined its waste and product storage and
handling areas through the preparation of a facility site plan
• Chief will improve the ventilation system for the laboratory as
well as the solid waste storage building, and install a second
doorway and stairway to the laboratory no later than May 15, 1990
• Chief intends to increase its public awareness program by
communicating more frequently with the Haskell and Stone Bluff
communities -- offering its employees as volunteer firemen
following the appropriate training and attending LEPC meetings.
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• Chief has increased ics security chrough che installation of
floodlights and fencing around most of the facility and the
acquisition of the services of a security guard to patrol the
facility after normal business hours
• Chief has equipped the laboratory storage areas with doors in
order to minimize access to the various chemicals and intends to
equip these doors with locks no later than May 1, 1990
• Chief has moved its safety and firefighting equipment to more
accessible areas so that employees may find them more easily, and
intends to acquire a consultant's services by June 1, 1990 to
advise Chief on large-scale chemical fire suppressant systems
• Chief will amend its contingency plan to reflect CERCLA/SARA
reporting requirements and distribute copies by June 1, 1990
• Chief recently sent its vice-president to a hazardous materials
spill prevention and control course and intends to send other
personnel (supervisors) to similar courses as they are offered
By the Regional Office:
By State and Local Authorities:
N/A
Regional Contact:
Steve Mason
(214) 655-2277
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Phillips 66 Houston Chemical Complex
Facility Location:
Pasadena, Texas, Region VI
Date(s) Audit Conducted:
November 6 and 7, 1989
Description of Facility:
SIC Code(s):
Location:
Products manufactured,
produced, or distributed:
Proximity to
sensitive populations:
SIC 2841 - Plascic materials, synthetic
resins, and non-vulcanizable
elastomers
Heavily industrial district near Houston,
Texas, 20 miles west of Galveston Bay
along the Houston Ship Channel
Polyethylene
Polypropylene
K-Resin
Deepwater Elementary, Deepwater Junior
High, and Red Bluff Elementary schools are
located two miles south of the facility
Pasadena General Hospital is located two
miles southwest of the facility, and there
is also a senior center nearby. None of
these locations are in the prevailing
downwind direction from the facility
Reason for Facility Selection:
ARIP Reports:
The facility was chosen because of the
explosion, fire, 'and release of hazardous
substances that occurred at the
polyethylene plant on October 23, 1989
Two dozen people died and more than one
hundred were hospitalized as a result of
the fire and explosion. The audit was
conducted only three weeks after the
incident, prior to the return of many
employees and without certain records that
had been lost in the fire.
None prior to audit.
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Focus of Audit:
Hazardous Substances(s)
Examined:
300 hazardous chemicals on-sice, buc only
Che following fifteen were examined.
1,3-Butadiene
Activated Catalyst
Polyolefin Catalyst
Chlorine
Cyclohexane
Diethylzinc
Ethylene
Hexene-1
Hydrogen
Nitrogen
Isobutane
Polyethylene/Polypropylene
Stadis 450
Styrene
Sodium Dichromate
Physical Area(s) Examined at the Facility:
Storage and Handling
• Storage Systems
• Shipping/Receiving
• Material Transfer
Plants IV and V, where polyethylene is produced, were the focus of the
audit based on the significance of the explosion/release and the
hazardous properties associated with the chemicals stored and produced
in that area.
Two single ton cylinders of chlorine were located in plant V for use in
the cooling water towers. Process catalysts and co-catalysts are stored
in the plant in drums or tanks.
Fluff polyethylene is stored in 400,000 pound storage silos on the west
side of the production plant -- plants IV and V contain six and 21 such
silos, respectively. Pelletized polyethylene is also stored in silos,
located to the north of the fluff PE silos.
Rail lines cut across the center section of the site, and there are also
several spur lines and a siding yard on facility grounds. The siding
yard is used for the storage of rail cars used to transport raw
materials to the K-Resin plant and to transport finished products from
the facility.
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Phillips has dockage facilities along the adjacent Houston Ship Channel
primarily for barge unloading operations. There is also a slip dockage
along the eastern boundary of the facility where cargo and tanker ships
may turn
Pipelines (ethylene, hydrogen, and nitrogen) and rail tank cars (all
others) bring hazardous substances into the facility Finished
polyethylene is shipped via rail cars and hopper trucks
Raw materials are transferred within the plant by various piping systems
which are detailed in process diagrams. Unpelleted polyethylene is
sometimes temporarily held in storage tanks and then transferred to
extruder feed tanks
Process Area(s)
Polyethylene (PE) is manufactured in PE plants IV and V Reactors were
brought into operation as follow.
Plant IV was completed in 1968 and consists of two loop
reactors, they were modified in 1978 to increase their
manufacturing capacity by increasing the height of the loop
Plant V reactors 1 and 2, completed in 1974, are capable of
producing 17,000-19,000 pounds of polyethylene per hour
Plant V reactors 3 and 4, completed in 1978, are capable of
producing 17,000-19,000 pounds of polyethylene per hour
Plant V reactors 5 and 6, completed in 1982, are capable of
producing up to 40,000 pounds of polyethylene per hour
Reactor Start-Up and Pressure Testing. Prior to start-up, a reactor is
pressure tested to ensure that there is no leak in the system Various
steps in pressure testing involve: filling the reactor with nitrogen,
if no oxygen is detected in the reactor, then proceed with pressure
testing with nitrogen at a specified pressure; if no leak is detected
using a commercial soap solution and pressure gauges, then proceed to
pressure testing at the reactor's operating pressure with ethylene
Once two consecutive ethylene pressure tests show no leaks, the reactor
is filled with isobutane, leading to normal reactor operations.
Feed Purification and Drying. Prior to feeding any material into a
reactor, it is purified and dried. This is essential because any
presence of water or oxygen in the feed severely affects the catalyst,
and hence, the polymerization reaction. The feed streams consist of
ethylene, hydrogen, isobutane. and hexene. The purification and drying
involve degassing and/or passing the feed through dryers. The catalyst
is arrives at plant V in pressurized sealed tote bins, which is
transferred to the catalyst system using dry nitrogen.
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Polymerization Reaccion, Produce Transfer, and Extrusion PoLyechyLene
is produced by che addition reaction of ethylene monomer or co-monomers
in the presence of a catalyst within a diluent-polymer slurry in a loop
reactor The material is circulated in the reactor at a very high
flowrate using a pump. Feedstocks are continuously added while reaction
products are continuously withdrawn to a low pressure flash chamber
Flashed gases are recovered, purified, and returned to the reactor PE
powder is pneumatically conveyed to storage tanks having an inert purge
From these tanks, the powder is pneumatically conveyed, and loaded
either into rail cars, hopper trucks, or to extruder feed tanks After
adding appropriate additives, the mixture is fed to an extruder via a
mixer. The polyethylene is pelletized and sized in the extruder
Pellets are then pneumatically conveyed to storage blending or loading
tanks
Summary of Audit Findings and Recommendations:
Conclusions:
Facility Background Information
• The facility is located in the Texas Gulf coastal plain, which
causes it to be susceptible to hurricanes and associated flooding
• The climate of the site is subtropical, with over 35 inches of
rainfall each year and southeasterly winds at 10 to 15 mph
• The Phillips 66 environmental department staff is smaller than
that of other similarly-size facilities.
Process Information
• The polyethylene plant processes the very flammable chemicals
ethylene and isobutane. These hydrocarbons are under pressure in
the reactors and/or storage vessels and if there is a rupture, a
vapor cloud will form. If the cloud drifts close by one of the
potential ignition sources, ana explosion and fire may occur
• Process parameters which may lead to accidental releases include
temperature rises above the set parameters for process operation
Overpressurization of a reactor could lead to a release through
the release systems; in the unlikely event that the relief systems
were to fail, there could be a catastrophic release.
• In the K-Resin plant, butadiene, an extremely flammable substance,
is stored under pressure in a liquid state, and if involved in a
fire or rupture, the storage tanks may explode violently.
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Chemical Accident Prevention
• Phillips 66 Company conducts a Corporate Safety Review and a
Corporate Environmental Review at each of its facilities every
four years, except after an excellent rating, in which case the
interval may be five years, or in the event of a major release.
when the interval is shortened. The review teams consist of
Phillips Petroleum Company employees at the corporate level or
from other facilities.
• The primary objective of the Safety Review audit is to provide
facility management with a current assessment of the safety
conditions within the facility. The safety audit manuals outline
29 different areas or systems to be checked during the week-long
audit, including training, emergency response, fire protection and
prevention, and equipment safety A corporate safety review was
conducted in 1986, and the next was scheduled for 1990
• The Environmental Review audit focuses on compliance with Phillips
66 environmental policy and practices, federal laws and
regulations, city and state laws, and the environmental policies
and practices of Phillips Petroleum Company and its subsidiaries
A corporate environmental review was conducted in 1986, and the
next was scheduled for 1989.
• Line management is responsible for safety and environmental
performance, and facility managers are responsible for making
action plans based on corporate audit conclusions and
recommendations. Facility managers must make quarterly reports
until any problem found in the audit is solved
• The Environmental Director sends a monthly environmental
compliance report to corporate HQ, and immediate notification of
any violations. There is no formal safety or environmental review
process internal to Phillips 66 HCC Ongoing environmental and
safety oversight consists of weekly walk-through inspections of
each individual plane. Problems are identified and corrected, and
persons responsible for repeated violations are disciplined A
Central Safety Committee meets monthly to discuss safety policy
• A certified industrial hygienist periodically visits to advise and
consult on personnel monitoring.
• An asbestos personal air sampling program, initiated because of an
ongoing asbestos removal project in the plant, has continued
during search and cleanup operations following the explosion
because of the possibility of asbestos in the plant IV area
• Safety training program requirements are established by the
Central Safety Committee. Each employee receives initial safety
orientation training, and attends refresher courses and monthly
safety meetings throughout his career. The effectiveness of the
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safety training is determined by test drills, which are critiqued
by supervisory personnel
Hazard communication training is provided generically to each new
employee by a training officer, and then the unit supervisor gives
more detailed and specific hazard communication training related
to the operations of the unit and related hazardous materials
Phillips 66 designates a primary contact to act as liaison between
the facility and each contractor. One contractor indicated that
its company is responsible for training its own employees in
safety and health aspects of their job assignments. There is no
evidence that the facility conducts oversight of the contractor
training programs to ensure their effectiveness or equivalency
with that provided to regular Phillips employees.
The "DuPont Process Hazards Review" and the "Hazards Analysis Risk
Assessment" are used in the training of management representatives
in hazard evaluation and accident prevention.
Operator training is the responsibility of the area in which an
employee is assigned. Area superintendents coordinate and log the
employee's training.
Maintenance training is coordinated with the training group and
area representatives. Both classroom and on-the-job training is
given to each maintenance employee depending on their craft
responsibilities
Training is conducted by experienced Phillips HCC employees, none
of them are certified by any educational institution as trainers
For maintenance workers, 80 to 84 hours of training over four
years is required to become a First Class Qualified worker.
Maintenance workers have refresher training as needed or for new
or changed conditions. Millwrights are given 64 additional hours
of training in addition to on-the-job training. Operators have a
total of 74 to 100 hours of initial training and 20 hours of
refresher training after three years.
A computer leg is kept of all formal employee training. Because
of the size and complexity of facility operations, there have been
problems in keeping the log current. As a result, the computer
record do not always reflect an employee's most recent training.
Every access gate has either automatic or manual security checks
and controls. Visitors are required to report to the
administration building, the construction guard gate, the north
guard gate, or the main guard gate prior to entering the plant.
Specific monitoring for hydrocarbons is conducted in the
polyethylene plant area by plant personnel using an organic vapor
L73
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analyzer as well as industrial hygiene monitoring on a periodic
basis Explosimecers are also available. The plant subscribes co
an air monitoring service, the Houston Regional Monitoring
network, run by the Radian Corporation.
Automatic hydrocarbon detectors are between the polymerization
reactor and the fluff storage silos, and between these storage
silos and the finished feed tank. There are no other systematic
programs or air monitoring instruments permanently installed at
the facility to monitor fugitive or accidental releases.
There are no fence line monitors except at the San Jacinto water
treater which has two monitors for chlorine.
All instrument maintenance records were maintained in the plant
and were destroyed due to che explosion.
The force of the 10/23/89 explosion destroyed a power distribution
station which supplied power to the electric driven fire water
pumps and severely damaged above ground water supply lines, which
severely hampered the initial efforts to control the fires
A Hazard Assessment and Risk Analysis•(HARA) is performed on^each
process plant before it is started up. The HARA includes pro'cess
hazard review, design and hazards review, and pre-start up safety
audit, with an additional emphasis on the impact of a multi-plane
site on individual plants. HARAs are subsequently performed only
when modifications are made.
During the summer of 1989, air release modeling was carried out
using CHARM software to determine appropriate off-sice emergency
response procedures for a vapor cloud release. Nine chemical
compounds were used in worst-case scenarios to provide information
for the development of emergency actions and to identify pertinent
health and safety concerns. The results were included in the
Pasadena vulnerability and risk assessment evaluation. No surface
or ground water modeling has been done.
The facility has a flare system to prevent or manage releases
There are three flares located on-site in the polyethylene plant
and the system has performed according to design.
Reactor leaks are identified in two possible ways during routine
visual inspections by reactor operator, or by observing the level
of sealant in the "Sealant Pot," which is checked twice during
each shift. If the sealant level drops significantly, the reactor
is shutdown immediately.
Reactor operations include a kill system, activated automatically
with loss of the circulation or coolant pump or manually, and
emergency dump procedures.
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• In the evenc of a large-scale release, chere are cwo systems
available Co assist in mitigating the release. The first is the
fixed firewater monitor nozzle system designed to provide cooling
water and firewater to specific structures and areas There are
also a series of fixed and portable aqueous film forming foam
nozzles designed to suppress a fire and remove the oxygen support
Accidental Release Incident Investigation
• The Emergency Procedures Manual (EPM) includes a summary of
environmental notifications made pursuant to SARA Title III,
CERCLA, and the Clean Water Act, along with telephone numbers and
sample forms identifying the information to be provided The
completed incident form is sent to the environmental office
• General procedures, applicable to both non-reportable and
reportable spills or releases, are defined for incidents that
occur during office hours and for those that occur at other times
• For incidents occurring during off hours, the Area Superintendent
should send a detailed report to the environmental office, but
there are no instructions on the information required for this
report. There are no written follow-up investigation procedures
• Prior to the October 23, 1989, incident, six releases in excess of
the RQ had been reported to the National Response Center and 22
spills had been reported to the Texas Water Commission or the NRC
Facility Emergency Preparedness and Planning Activities
• Evacuation procedures are detailed in the Plant Preparedness
section of the EPM. This includes instructions for total
evacuation of the facility, as well as individual evacuation of
specific plants within the facility. Evacuation plans are to be
updated annually for each plant, or more often as needed
• The total evacuation signal is one continuous blast on the steam
whistle, which can be activated by a call through the emergency
radio system. The back-up is the telepho-ne system.
• Supervisors of each area in the plant are responsible for
notifying contractors and visitors to evacuate. The plan requires
that "non-plant" personnel exit the facility through the same
security gate they had entered.
• Maps indicating evacuation routes are in the EPM, but no
indications are given as to whether symbols or other markings for
evacuation routes are inside the facility.
• The facility emergency communication system is a radio system with
support from in-plant telephones. Radio notification to CIMA can
initiate assistance from industry and government. Procedures for
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emergency notification are detailed in the EPM Weekly integrity
checks on the radio network are to be performed by the main gate
security guard. Quarterly checks are made on the designated
command post base station, and the facility communications
committee checks the entire emergency radio network quarterly
• The main gate security guard takes emergency calls, locks in
various notification systems, and informs the plant of the
particular emergency Main gate security checks the CIMA radio
daily. A service contract is in place, and radio repairs are done
as needed.
• The facility emergency response team communicates internally by
portable and mobile radios. Radio checks are made each Monday
morning after the emergency alarm test
• Audio alarm systems at the facility consist of a siren system,
steam whistle, emergency radio, and a pager system. In addition,
each operating unit has a manual system (an air horn for plants IV
and V), and some areas contain loud speakers
• A phone call to main gate security will activate the siren system.
If a power failure occurs, the call will be routed to security,
who will contact the boiler house to sound the steam whistle If
both networks are non-functional, emergency radios are used The
warning system is tested on a weekly basis.
Community and Facility Emergency Response Planning Activities
• The Phillips 66 HCC Manager is the emergency manager for the
entire facility and the facility fire chief is in charge of the
actual incident scene.
• The EPM provides employees with guidelines for dealing with
internal and external emergency situations. The EPM is maintained
and updated by the Phillips emergency preparedness subcommittee,
with the latest revision dated March 28, 1989.
• An Emergency Response Team Manual (ERTM) -is used by Phillips fire
brigade and rescue and first aid teams to insure high performance
standards and compliance with government regulations while
responding to plant emergencies. The ERTM is maintained by the
Phillips Emergency Response Subcommittee, with the latest revision
dated May 4, 1987.
• Phillips has EHSs above the TPQ at the facility and has notified
the Pasadena LEPC and the Texas SERC that they were subject to the
planning provisions of SARA Title III. The facility has
designated an emergency coordinator and an alternate to work with
the LEPC and section 303 notification was also provided to the
Texas SERC
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Phillips notified the Pasadena LEPC and the scace immediately, and
the National Response Center 11 hours after the 10/23/89 incident
(A concerned citizen had already notified the NRC.)
Phillips has submitted information under SARA Title III section
311 and 312 to the local fire department, Pasadena LEPC, and Texas
SERC, and has submitted Form Rs for reporting years 1987 and 1988
They have also submitted a Texas Workplace Chemical List and
chemical inventories under the Texas Hazards Communication Act
The facility has actively served on several LEPC subcommittees and
has participated in various exercises sponsored by Pasadena The
facility has held open houses for the Pasadena City Council and
for its employees, is a member of the CMA, and has participated in
the CAER program, and is heavily involved with CIMA, a group of
over 100 companies and government agencies in the Houston Ship
Channel which has developed a mutual aid agreement for personnel
and equipment in the event of a hazardous materials incident
The last full-scale exercise, involving CAER, LEPC, and CIMA, was
conducted in September, 1988, and was a coordinated effort between
all of the emergency response groups which would be involved in a
large-scale emergency. A similar exercise had been scheduled for
November 1989, but was canceled after the October 23rd incident
Training courses are available in-house and training requirements
for emergency personnel include fire brigade training, team leader
training, first aid training, hazardous material training,
Incident Command System, total emergency management, and Phillips
Emergency Procedures. All plant personnel are trained in the use
of fire extinguishers.
The annual training schedule is prepared by the Phillips Fire
Chief and Safety Officer, and details specific training,
preplanning, and associated activities for the Phillips Emergency
Response Team. Other activities, such as the annual community-
type response and drill, are planned separately by individuals
representing community and industry
The EPM lists the equipment and transportation available for
emergency situations except for fire brigade equipment, and gives
the Service Chief responsibility for equipment such as cranes and
bulldozers, and transportation for the injured as well as
transportation needs such as motor fuel.
Each emergency response team member is supplied with equipment and
is responsible for maintaining it; all protective equipment
purchased will be in accordance with 29 CFR 1910 156. The
Phillips Fire Chief or his designee is in charge of all
inspections of response equipment, and the safety department is
responsible for repairs and recharging
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• Fire fighting equipment and manpower will be released under
agreement with Channel Industries Mutua^l Aid (CIMA) for an
incident external to the facility
Public Alert and Notification Procedures
• Phillips can notify locations outside the facility by radio and
telephone Notification can be made to the public through the
Pasadena Office of Emergency Preparedness and thus over the Cicy
of Pasadena Emergency Broadcast System; the CAER Hotline, which is
available to the public; or the news media.
• Inspection of the area reveals a shortage of exit roads outside
the facility boundary for evacuation of non-injured personnel In
the initial hours that followed the explosion on 10/23/89,
evacuations were hampered by traffic problems created by incoming
response personnel and equipment
Recommendations:
Facility Background Information
• The Phillips 66 HCC facility, with three individual plants, is a
very large complex. The environmental department staff of three
should be expanded to help meet the needs of a growing complex
Process Information
• The facility does not have stationary monitoring equipment capable
of detecting hazardous substance releases from different plants
The audit team is concerned that CERCLA hazardous substances, such
as chlorine, are not continuously monitored around the plant area
Hydrocarbon monitors, such as those planned for plant VI, should
be installed in existing plants, and fenceline monitoring should
be carried out to detect release migrating off-site The
monitoring systems should be interfaced with the alarm system to
provide warning of releases.
Chemical Accident Prevention
• The vulnerability and risk analysis report prepared by Pasadena
indicates explosive chemicals, but notes that most damage caused
by an explosion would be to the facility itself. Based on the
explosive potential of butadiene and other chemicals not involved
in the 10/23/89 incident, it is reasonable to assume that the
potential impact to the surrounding community could have been
greater. The dangers posed by explosive chemicals should thus be
reevaluated by Pasadena and the facility.
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Accident Release Incident Investigation
• The emergency procedures manual states that releases should be
followed up by a report to the environmental division Phillips
66 HCC should make it a mandatory policy for each release to be
investigated internally and a thorough report pn the nature and
reason for the release documented
Facility Emergency Preparedness and Planning Activities
• There is an inconsistency between the emergency procedures manual
and the emergency response team manual in regard to the number to
call to announce an emergency. The assignment of one number for
all emergencies should be considered
• The emergency procedures manual should be revised to better
reflect CERCLA reporting requirements if the RQ is exceeded
• It was indicated that one of the manual alarm systems in plant IV
had not been operating for some time and a phone in the electric
shop adjacent to plant V that could have activated an alarm had
been disconnected. As a result, initial warnings to some
employees were solely verbal. The weekly safety checks should
have detected the missing or inoperative equipment. The facility
should ensure detailed and accurate testing of all alarm systems
and strict compliance with the safety procedures.
• Facility evacuation plans were inappropriate for the 10/23/89
incident. The plan appeared to be based on the assumption that
the event causing the evacuation would already have occurred, be
in the process of occurring, or would be controllable enough to
all.-v for orderly evacuation. The plan requires that "non-plant"
pe.. -iel exit the facility through the same security gate they
had ;ered. This benefits personnel accountability, but could
increase the time required to exit the facility
• There is no distinction made between planning for imminent danger
situations and post-release alerts. Additional evacuation plans
should be made for imminent danger situations. The primary
consideration in such a plan would be immediate evacuation of all
personnel, to a minimum safe distance, by the most expedient means
possible. The alarm system for this procedure should.
contain the minimum practical number of communication nodes
necessary for activation,
be readily activated by all personnel,
utilize an alarm that is distinguishable from all other
audible signals, and
be exercised routinely to ensure personnel familiarity
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• The emergency procedures manual prescribes evacuation rouces for
various categories of personnel, but such rouces could be blocked
by chemical plumes depending on wind direction The facility
should consider Graining employees in flexible evacuation
procedures and rouces based on various faccors, such as wind
direction. Additional wind socks should be installed around the
complex co insure chac a sock will be visible from any location
Community and Facility Emergency Response Planning Activities
• The shortage of exit roads outside the facility boundary hampers
personnel evacuation with traffic problems created by incoming
response personnel and equipment. The facility should work wich
Pasadena to develop and construct additional access roads
• Traffic control on the area perimeter was less than effective
during the 10/23/89 incident. There needs co be better control co
minimize danger co onlookers if the release plume shifted Law
enforcement agencies should review their interactive procedures
within their own contingency plans to ensure better coordination
with other agencies having traffic control responsibilicies
• Evidence from Tide III Section 313 reports suggest that past
releases of CERCLA hazardous substances above the RQ may not have
been reported to the NRC in a timely manner. Additionally, the
facility reported spills involving CERCLA hazardous substances to
the Texas Water Commission which were not reported to the NRC
• The list of CERCLA hazardous substances in che emergency
procedures manual was illegible, and should be replaced by a
legible, current copy of the list.
• Notification co Che NRC of the 10/23/89 release event,
notwithstanding che severity of che explosion and che resulcanc
confusion, should have occurred in a more timely fashion.
Public Alert and Notification Procedures
• Procedures for notifying neighboring CIMA facilities should be put
into the emergency procedures manual because surrounding industry
is at greater risk from a chemical release Chan the general public
of Pasadena because of their proximity to the facility.
Audit Team Member Composition:
Name and Title Jim Staves, Team Leader
Affiliation US EPA Region VI
Area of Responsibility N/A
Expertise
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Name and Tide
Affiliation
Area of Responsibility
Expertise
Name and TicLe
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibilicy
Expertise
Mike Ryan, OSC
US EPA" Region VI
CERCLA Investigation and Emergency
Notification and Response Procedures
N/A
George Allman
US EPA Region VI
N/A
N/A
Dusty Pruitt
US EPA Region VI
N/A
N/A
Steve Mason
US EPA Region VI
N/A
N/A
Del Krehbiel
US OSHA Region VI
N/A
N/A
Mary Ann Garrahan
US OSHA/DOL HQ
N/A
N/A
William Elliott
Texas Department of Health
N/A
N/A
Winona Henry
Texas Air Control Board, Region 7
N/A
N/A
Elizabeth Gonzalez
Pasadena LEPC/City Emergency Preparedness
Office
N/A
N/A
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Follow-up Activities:
By the Facility:
• The new design of plant VI, under construction at the facility,
include hydrocarbon detection instruments in the plant area
By the Regional Office:
• After the audit team left the facility, a conference call was held
to interview a supervisor from one of Phillips' contractors The
supervisor indicated that they conduct training orientation in
safety by in-house personnel • The trainers for this orientation
have no specific safety background and there was no specific
process equipment safety training for contractors Phillips
conducted no oversight of contractor employee training on safety
or process equipment, nor did they review contractor employee
training records. Contractor employees were required to sign che
standard Phillips safety booklet
By the State and Local Authorities:
• N/A
Regional Contact:
Steve Mason
1214) 655-2277
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Texas Instruments Inc (T.I ),
Central Expressway Facility
Facility Location.
Dallas, Dallas County, Texas, Region VI
Date(s) Audit Conducted:
November 14, 1989
Description of Facility:
SIC Code(s):
Location:
Products manufactured,
produced, or distributed:
Proximity to
sensitive populations:
SIC 3829 - Measuring and controlling
devices, not elsewhere classified
10 miles north of downtown Dallas, Texas
Mercury - Cadmium - Telluride (MCT), a
ternary semiconductor material used to
make photoconductors and infrared detector
devices.
Surrounded by one-half mile radius of
commercial and industrial properties, and
located at major highway intersection
Reason for Facility Selection:
ARIP Reports:
The facility was chosen as a result of che
September 21, 1989, release of a very
small quantity of elemental mercury from
the semiconductor building within the MCT
production area. An array of MCT quartz
ampules ruptured during a fire caused by a
faulty temperature control unit
None prior to audit.
Focus of Audit:
Hazardous Substance(s)
Examined:
None.
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Physical Area(s) Examined at the Facility:
Storage and Handling
• Storage Systems
• Shipping/Receiving"
Procedures for the storage and handling of elemental mercury at the
facility were not available in the audit report.
Alcohols and solvents are stored separately from acids and bases Each
of the materials is stored in 10 thousand gallon vertical tanks enclosed
in a concrete diked area with sufficient capacity to hold all of the
product should the tanks fail From the tanks, the materials are pumped
via pipeline into containers of one, three, five, fifty-five, one
hundred, or two hundred gallons within the warehouse area.
Alcohols, solvents, acids, and bases are received in common carrier
trucks and company owned tankers of five to six thousand gallon
capacities. Training sessions on driver safety are scheduled
periodically at the T.I. facility, and all interstate trucking
operations use the team driving concept. Each loading area has overhead
pull showers and eye wash units which are checked monthly. Washwater
and accidental product releases are collected into vats and floor sumps,
then pumped into holding tanks outside the warehouse for disposal.
Process Area(s)
• Mercury - Cadmium - Telluride (MCT) production area
• Drum Storage Yard
Elemental mercury, cadmium, and telluride react under high temperature
and pressure to form MCT crystals, which are then tempered to form a
semi-finished product. The furnace temperature control unit controls
the crystallization process within the DRA furnace hood. After the
crystallization process is complete, the materials are tested for
purity, and slices of the MCT product are then re-annealed and fashioned
into the infrared detector devices to be used in military and law
enforcement imaging systems.
The drum storage yard is used as a staging area for the collection and
transfer of waste solvents, corrosives, and varrbus other by-products
Drums are segregated and stacked in designated locations; small lot
materials are stored for consolidation into larger containers. Certain
solvents, mixed liquid corrosives, and solid wastes are held for
shipment to disposal facilities. A fuel/solvent blending facility
recycles certain solvents collected at the yard These solvents are
blended and segregated into other solvents, and stored in aboveground
tanks before being pumped into transport tankers for sale to recyclers
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Summary of Audit Findings and Recommendations:
Conclusions:
Facility Background Information
• Security guards, trained in emergency release procedures, patrol
the fence surrounding the plant. While gates remain open to allow
movement of employees, bulk storage pumps are locked and only
accessible to authorized personnel, and terminal loading and
unloading connections are capped or blind-flanged when not in use
• Based on audit interviews, personnel concerned with the shipping,
receiving, handling, and distribution of hazardous materials
appear to be experienced and knowledgeable. The manager in charge
of these areas has thirty-five years of experience with T I
Other personnel have service time from six months to ten years
Personnel that supervise these operations are either degreed
chemists or engineers
Process Information
• All chemical storage areas were clean and orderly during the
audit, and the outside appearance of the storage tanks indicated
proper maintenance.
• An on-site environmental analytical laboratory was established to
conduct analysis relating to water and wastewater, hazardous and
non-hazardous waste, waste minimization, environmental
contaminants, and pollution abatement materials for all T I
facilities. During an emergency, the lab can conduct contaminant
and concentration level analysis.
• On-site equipment includes mercury vapor detectors, CO analyzers,
Halide detectors, oxygen meters, aerosol dust monitors, and a
variety of other monitoring and detection devices.
Chemical Accident Prevention
• The receiving and distribution area maintains written procedures
for receiving hazardous materials. Personnel are periodically
trained in these procedures and are required to know all loading
and unloading guidelines
• Detailed routine inspections are performed by plant personnel on
storage and transfer facilities and equipment An inspection log
is maintained, and all potential problems are reported to the
Spill Prevention Committee for review.
• A preventive or precautionary maintenance program has been
implemented to correct or prevent equipment failure indicated by
the inspection process. This program involves additional periodic
185
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inspections and periodic casting of equipment, maintenance as
appropriate, and complete equipment performance records.
• T.I's Corporate Safety & Environmental organization performs
annual site audits to monitor operations
• T.I has not conducted any kind of comprehensive "HAZOP" fault
tree, or failure mode analysis to help prevent future incidents
Accident Release Incident Investigation
• A spill reporting system has been designed to insure appropriate
response actions are taken immediately, written spill reports are
prepared, revisions are made to the spill control program, and the
appropriate governmental agencies are notified
.• As a result of the September 21, 1989, incident, T I has
installed remote furnace emergency cut-off switches outside
the DRA room,
replaced the Plexiglass furnace shields with Lexan fire
retardant shields,
installed ampere coded fuses in each circuit controller,
enclosed furnace rooms to ensure a negative pressure
atmosphere within the DRA room,
increased the airflow within furnace hoods,
installed mercury monitors inside the furnace room, and
provided work specific clothing for employees
Exhaust abatement filters are being designed on each furnace hood
Facility Emergency Preparedness and Planning Activities
• The facility's Spill Prevention, Control, and Countermeasure
(SPCC) plan addresses administration, response, reporting,
training, inspections and records, preventive maintenance,
housekeeping, and security.
• Employee training in the SPCC plan consists of process and
materials hazards, spill prevention practices, safety hazards, and
proper response procedures. A training log is maintained
• The Spill Control Committee addresses facility hazards, reporting
procedures and training programs, inspections, incident reviews,
prevention and mitigation measures, and cleanup coordination.
• All supervisory employees have been trained to wear SCBA
equipment. Their instructions for emergency incidents are to
evacuate the area and call the fire and hazmat team to mitigate
the incident.
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Material Safety Data Sheets are available on-site and all
employees are instructed on how to access them via computer
terminals located throughout the facility, and also how to
interpret the information they contain
Texas Instruments provides training programs for personnel
involved with emergency management, response, health, and safety
The following are mandatory training requirements for the members
of the facility hazmat response team
80 hours of hazardous materials training
40 hours of confined space and rope rescue training
24 hours of training coordinated with police and fire
departments from surrounding cities
24 hours of hazardous materials training exercises hosted by
a specific fire department
40 hours of Emergency Care Attendant (EGA) training
24 hours of fire brigade training
8 hours every three months with the HAZMAT division of the
fire department
Miscellaneous sixteen hours of training by Regional EPA on
first response capabilities
8 hours each quarter of training in emergency truck roll
over, acid tanker cylinder leaks, drum patching,
containment, and decontamination procedures
Recommendations
Chemical Accident Prevention
• The facility should continue its commitment to hazardous materials
safety and response demonstrated throughout the audit process
• The facility should consider establishing a HAZOP fault tree, or
failure mode analysis to identify further activities that will
help prevent future accidents.
Community and Facility Emergency Response Planning Activities
• T.I. should continue to provide hazardous materials response
training to local emergency response personnel.
Audit Team Member Composition:
Name and Title Greg Fife, OSC--Audit Team Leader
Affiliation EPA Region VI
Area of Responsibility Mechanical and Chemical Systems
Expertise N/A
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Name and Tide
Affiliacion
Area of Responsibility
Expertise
Name and Tide
Affiliacion
Area of Responsibility
Expertise
Name and Ticle
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Steve Mason, Title III Coordinator
EPA Region VI
Health and Safety
Communications
Fend.ol Chiles, AARP
EPA Region VI
Chemical Systems Process
N/A
Curtis Franklin, TAT
Ecology and Environment, Inc
Health and Safety
N/A
Gary Dry, TAT
Ecology and Environment, Inc
Spill Prevention, Control and
Countermeasure Coordination
N/A
Follow-Up Activities:
By the Facility:
T.I is in the process of implementing a TELOS Air Composite
Monitor to serve as a real-time, early warning system for incident
prevention.
The facility has designated an individual as the Site Emergency
Preparedness Coordinator.
Thirty-three key managers and supervisors at the facility
completed the Dupont Safety Management Training for Operations
Managers, and are establishing an internal safety review function
for each building complex. [further information required]
The facility has begun to provide Safety and Environmental
training to T.I. contractors.
The facility has decided to pursue a HAZOP fault tree or failure
mode analysis at the building complex level for the most
manageable approach to chemical accident prevention Failure mode
analysis of the MCT operation resulted in extensive upgrade of the
safety controls of the MCT furnaces and process exhaust system
T.I is planning to complete a new facility to provide offices and
a training area for the facility's Hazardous Materials Response
Team (HAZMAT) in June, 1990
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• T.I. has established an on-line computer-based emergency
communications listing of key response personnel for each major
building
• T.I is outfitting a forty-eight foot tandem trailer to serve as a
mobile HAZMAT command and communications center equipped with a
computer and modem link with T.I 's on-line chemical database of
Material Safety Data Sheets
By the Regional Office:
• N/A
By State and Local Authorities:
• N/A
Regional Contact:
Steve Mason
(214) 655-2277
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Phillips 66 Company Woods Cross
Petroleum Refinery
Facility Location:
West Bountiful, Utah, Region VIII
Date(s) Audit Conducted:
May 2-4, 1989
Description of Facility:
Location:
SIC Codes(s):
Products manufactured,
produced, or distributed:
Proximity to
sensitive populations:
Suburban area norch of Sale Lake City,
Utah
SIC 2911 - Petroleum refining
Leaded and unleaded gasoline, jet fuel.
fuel oils, propane and asphalts
The five mile radius of the plant includes
the town of West Bountiful, Bountiful.
North Salt Lake City, Woods Cross, and
Centreville The plant is bounded by
residential developments to the north and
by light industrial and residential planes
on the south.
Reason for Facility Selection:
ARIP Reports:
The facility uses several hazardous
chemicals which present the risk of an
airborne release with off-site
consequences. The hydrogen fluoride (HF)
alkylation unit experienced a release in
October 1988 because of operator error
The release was stopped and no injuries
occurred.
10/18/88 release of hydrogen fluoride
(questionnaire completed 4/7/89)
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Focus of Audit:
Hazardous Substance(s)
Examined: Hydrogen Fluoride (HF)
Sulfuric Acid
Chlorine
Sodium Hydroxide
Hydrochloric Acid
Cresylic Acid
Chromic Acid
Physical Area(s) Examined at the Facility
Storage and Handling
• Storage Systems
Crude oil and refined product storage are located outside of the
refinery process area, primarily along the south of the plant, where the
storage tanks are located, and to the east, where the chemicals are
blended. [need to determine description]
Process Area(s')
HF is used as a catalyst in the alkylation unit. Alkylation is a
reaction employed to maximize the octane content of refinery products
through the selective reaction of olefins, typically isobutylene and
propylene, with isobutane to form higher molecular weight isoparaffins
The end product, termed alkylate, is a high octane branched paraffin
(isoparaffin) such as isoheptane and isooctane
The HF used in the alkylation unit is recycled in the continuous process
with make-up HF addition from a feed tank adjacent to the
accumulator/settler. The capacity of the HF feed tank is approximately
75,600 pounds while the accumulator/settler system circulates
approximately 130,000 pounds of HF
Feedstocks to the alkylation unit are both passed through a desiccant to
minimize water introduction into the process. Corrosion becomes a
significant operating problem at water levels approaching 5 percent in
the HF recycle stream. To guard against corrosion, process equipment
such as reactor feed line, acid soluble oil drum, relief neutralizer,
acid rerun tower, and heat exchanger tubes bundles that are exposed to
HF and water are either fabricated from Monel steel or are Monel clad.
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Summary of Audit Findings and Recommendations:
Conclusions.
Process Information
• The scorm water tank and tank #104 were not diked
• At present, the loading/unloading operators work individually and
check with each other every four hours at night A radio system
to improve communication with these operators is presently on
order
• Management has undertaken a significant capital expenditure within
the last five years to design and construct a new wastewater
treatment system
Chemical Accident Prevention
• Contractors receive safety training including an initial safety
orientation, four-hour respirator training, first-aid training,
monthly safety meetings, and annual training on the facility's
hazard communication and fire protection programs
• The facility has organized a team of personnel, including
personnel from the engineering, operations, maintenance, and
safety departments as well as management, to evaluate hazards
The team meets monthly to discuss safety issues and to consider
possible changes to the facility's design, construction and
standard operating procedures.
• The refinery's safety department has allocated resources to
coordinate all safety training, worker safety monitoring, health
monitoring, safe work practices, hot tap system, confined space
entry system, safe work permit system, hot work permit, and
lock/tag out procedure.
Facility Emergency Preparedness and Planning Activities
• The facility's monitoring system is not capable of early release
detection. An example of a missed release at the facility was the
February, 1989, release of a water/oil mixture from an undiked
tank that was not detected by facility personnel until the mixture
had run off-site
Accidental Release Investigation
• The facility maintains files documenting releases and near misses
and implements a thorough review procedure following a release
However, the file did not provide evidence of in-depth
investigations of the near-misses or the reportable releases
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Community and Faci.li.cy Emergency Response Planning
• The facility does not have a representative on the LEPC and has
had no contact with this group
• The emergency plan includes coordination with local authorities
and with other refineries in the area. In the event of an
emergency, the refinery is equipped with a recently installed
radio alert system. The fire station has the frequency of the
signal and can monitor it The system is used in addition to the
emergency fire horn during working hours.
• Response to fire or other emergency at night depends on the off-
site calls received by the facility for the fire brigade Since
the explosion hazard of a refinery is always present, it is
possible to lose the phone system Neither the local police or
the local fire department have a list of key refinery personnel co
be contacted by radio in the event of an emergency situation where
the phone system is not available for use.
Public Alert and Notification Procedures
• Communication and alert procedures utilized to alert the
surrounding community in the event of a serious release need to be
improved.
Recommendations:
Process Information
• The facility should expedite plans to dike the storm water tank
and tank 104 where a water/oil spill occurred in February, 1989
• Until the new system is installed, a buddy system or a system of
30 minute checks among personnel should be implemented for the
loading/unloading operators
• The facility should investigate implementing an efficient release
monitoring system capable of early release detection. As an
example, a February, 1989 water/oil release was not detected until
it had run off-site.
Chemical Accident Prevention
• The facility should investigate an expansion of the contractor
safety training to include additional training tailored to that
contractor's work assignment and the chemicals/hazards unique to
that assignment.
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Community and Facilicy Emergency Response Planning Activities
• The police or the fire department should have a list of key
refinery personnel, so that they could be notified by radio in a
situation where that phone system is lost
• The facility should ensure that it is represented on the LEPC.
Public Alert and Notification Procedures
• The facility should investigate the possibility of improving the
communication and the alert procedures utilized to alert the
surrounding community in the event of a serious release
Audit Team Member Composition:
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Rick Horner
EPA - Headquarters
N/A
Chemical Engineering
Tien Nguyen
EPA - Region VIII
N/A
Chemical Engineering
Don Shosky
EPA - Region VIII
N/A
N/A
Edwin Coker, Technical Assistance Team
Environment & Ecology
N/A
N/A
Mark Dahm, Technical Assistance Team
Environment & Ecology
N/A
N/A
Follow-up Activities:
By the Facility:
Public alert and notification procedures did exist, denoting
emergency contacts and phone numbers, at the time of the audit.
The existing procedures are also being updated and expanded as
part of the LEPC effort.
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• The dike around cank 104 was partially removed at the time of the
audit due to maintenance activities. The storm water dike was
completed June 1, 1989
• The facility has tried one emergency alert horn since the audit
and found it to be unsatisfactory. Another is on order
Additionally, the facility has scheduled a "mock" drill by the end
of 1989
By the Regional Office:
• N/A
By State and Local Authorities:
• N/A
Regional Contact:
Due Nguyen
(303) 293-1876
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Facility Location-
Chevron Chemical Company
Rock Springs, Wyoming, Region VIII
Date(s) Audit Conducted:
June 13 - June 15, 1989
Description of Facility:
SIC Codes(s):
Location:
Products manufactured
produced, or distributed:
Proximity to
sensitive populations:
SIC 2874 - Phosphatic fertilizers
Remote area directly south of State
Highway 430 in southwestern Wyoming
Approximately five miles southeast of the
town of Rock Springs
Granular phosphate fertilizer and a
concentrated 68% phosphoric acid (Super
Green Acid).
Four communities would be vulnerable to a
chemical release. Rock Springs is five
miles northwest of the facility and has a
population of 22,000 people. Arrowhead
Springs, which consists of approximately
twelve families, is three miles southwest
of the plant. Rock Springs airport is
located five miles northeast of the
facility. Canyon Trailer Court community
is located four miles west of the plant on
State Highway 430
Reason for Facility Selection:
ARIP Reports:
The facility was selected due to the
occurrence of six hazardous substance
releases at the facility between 1986 and
1989.
3/17/88 release of sulfuric acid
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Focus of Audit:
Hazardous Substance(s)
Examined:
Phosphoric Acid
Sulfuric Acid
Sulfur
Sulfur Dioxide
Anhydrous Ammonia
Chlorine
Monoammonium Phosphate
NOPCO 8050 Defoamer
De Foamer 913-BL
Diammonium Phosphate
Diesel Fuel, No. 2 Grade
Physical Area(s) Examined at the Facility:
Storage and Handling
• Storage Systems
• Shipping/Receiving
• Material Transfer
Phosphoric acid is stored primarily in the clarification and storage
tank farm adjacent to the phosphoric acid plant. This area is
concreted, curbed, and serviced by a drain collection system. Sulfuric
acid is stored in a separate tank farm east of the absorption towers
building. The facility has six horizontal anhydrous ammonia bullet-cype
storage tanks with a capacity of 874 tons each. The bullet-type tanks
are equipped with pressure relief valves and are protected by concrete
barriers
Sulfur is delivered to the plant in a molten form in rail cars
Anhydrous ammonia is transported by rail in liquefied form.
Molten sulphur is pumped from the sulphur pit to the reactor in the
sulphuric acid plant. The acid is later pumped across the plant to the
north end for reaction with the phosphate rock slurry
Process Area(3)
Phosphoric Acid Production. A phosphate rock slurry, pumped to the
plant via a pipeline from Chevron's phosphate mine in Vernal Utah, is
reacted isothermally with sulfuric acid. The reactor effluent is
filtered to produce a dilute phosphoric acid (28 percent) and a solid
byproduct, gypsum. The gypsum byproduct is slurried and pumped to the
gypsum disposal pond. The dilute phosphoric acid (28 percent) is
concentrated by evaporators to a 52 percent phosphoric acid. The 52
percent phosphoric acid is also concentrated by evaporation and filtered
to 68 percent phosphoric acid (Super Green Acid) The Super Green Acid
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is both sold co end users and reacted with ammonia co produce one of
several granulated phosphate fertilizer products
Sulfuric Acid Production. Concentrated sulfuric acid is produced ac the
facility in a process oxidizing molten sulfur in a furnace to produce
sulfur dioxide A series of catalytic reactors are utilized to convert
sulfur dioxide to sulfur trioxide. Sulfur trioxide is absorbed in
aqueous solutions to produce sulfuric acid
Summary of Audit Findings and Recommendations:
Conclusions:
Process Information
• The sulfuric acid plant and associated product storage present the
hazards of both liquid and vapor cloud exposures in the event of a
failure
• Several of the reportable releases involved a failure of pumps and
piping
• Critical valves have redundant components
• The concrete barriers surrounding the ammonia storage bullets have
been found out of position.
• Air is monitored for sulfur dioxide, gaseous fluoride, particulate
fluoride, and total particulates There is a continuous sulfur
dioxide monitor on the sulphuric acid plant
• There is no detection system or drainage dike in the ammonia
storage area in case of a spill or leak.
Chemical Accident Prevention
• Internal procedures have been developed, safety equipment and
training is provided, and communication networks are established
with the outlying communities.
• Chevron has not instituted a hazards analysis procedure at this
facility. This analysis requires a team of experts to evaluate
the consequences of an unexpected event, such as a chemical
release.
• It was noted that not all workers were wearing steel-toed boots,
and contact lenses were being worn at the facility. Chevron
stated that OSHA indicated that these practices were acceptable
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• Chevron utilizes an equipment inspection program to track
equipment failures However, there is not a comprehensive method
for routine inspections for all of the process components
Facility Emergency Preparedness and Planning Activities
• The facility's current emergency response plan includes general
emergency procedures and explicit instructions for responding to
sulfuric acid, sodium chromate and anhydrous ammonia releases
However, the plan lacks specific emergency response procedures for
other hazardous materials used at the plant (i.e , phosphoric
acid) At the present time, the emergency response plan is being
revised.
• Chevron's safety and fire protection representative created four
emergency response simulations including a sulphuric acid burning
a person, an ammonia leak, asphyxiation, and a fire at a waste oil
storage drum However, only two exercises have been conducted
since the inception of the emergency exercise program in 1987
Chevron's goal is to implement these simulations on a monthly
basis at the facility
Recommendations:
Process Information
• It may be beneficial to conduct a study of the causes of the large
number of small releases associated with pumps and piping. A
number of reportable releases occurred because of piping and pump
failures at the plant.
• The storage and handling of anhydrous ammonia is recognized as the
greatest hazard present at the facility in terms of off site
implications from a spill or leak The installation of an ammonia
monitoring system in the ammonia storage area should be considered
since none exists at this time. In addition, if safety barricades
surrounding the tanks were maintained and kept in proper position,
it may prevent a vehicle from shearing off a valve/port.
Chemical Accident Prevention
• Routine inspections of all equipment should be considered, and the
more critical components should be inspected at more frequent
intervals. Mechanical failure has been a source of releases in
the past.
• Other areas to be addressed to help in the prevention of chemical
accidents might include a safety shoes policy and contact lens
policy, in order to comply with OSHA standards and prevent
injuries.
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Accidental Release Incidenc Investigation
• The facility should document "near miss" releases
Facility Emergency Preparedness and Planning Activities
• Since tested safety procedures may help to prevent or mitigate a
dangerous situation, emergency response simulation exercises
should be conducted on a regular basis Additional procedures for
dealing with specific hazardous substances (i e phosphoric acid)
would also be beneficial.
• The contingency plan should be updated in the areas of management
structure to ensure proper communication is maintained between
operators.
Audit Team Member Composition:
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Tien Nguyen, Team Leader
US EPA/Region VIII
N/A
N/A
Jim Knoy
US EPA
N/A
N/A
Mark Dahm, Technical Assistant Team
Ecology & Environment
N/A
N/A
Henry Schmelzer, Technical Assistant Team
Ecology & Environment
N/A
N/A
Melissa Haines, Technical Assistant Team
Ecology & Environment
N/A
N/A
Jack Zimmerman
SCEMA/LEPC
N/A
N/A
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Name and Title Judy Valentine
Affiliation SCEMA/LEPC
Area of Responsibility N"/A
Expertise N/A
Follow-up Activities-
By the Facility:
• N/A
By the Regional Office:
• N/A
By State and Local Authorities:
• N/A
Regional Contact:
Due Nguyen
(303) 293-1867
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
The Western Forge Corporation
Facility Location:
Colorado Springs, Colorado, Region VIII
Date(s) Audit Conducted:
August 15-17, 1989
Description of Facility:
Location:
SIC Codes(s):
Products manufactured,
produced, or distributed:
Proximity to
sensitive populations:
Northern edge of Colorado Springs, in
central Colorado
SIC 3423 - Iron and steel foundries
Screwdriver blades, chisels, punches,
adjustable wrenches, and pliers
The facility is located about 4 miles from
the nearest hospital and high school, 3
miles from the nearest elementary school
and one mile from the Colorado Technical
School.
Reason for Facility Selection:
ARIF Reports:
The insulator of the heating/cooling line
ruptured and sprayed water into the
stripping tank which contained a sodium
cyanide and nickel solution. The added
amount of water caused the tank to
overflow onto the floor and, subsequently,
out the door. A portion of the spill left
the facility and contaminated an area
approximately forty inches wide and twenty
feet long. The contaminated area was
excavated and back-filled.
None prior to audit.
Focus of Audit:
Hazardous Substance(s)
Examined:
Perchloroethylene
Acetone
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Butyl Acetate
Mechylene Chloride
Xylene
Toluene
Sulfuric Acid
Hydrochloric Acid
Nitric Acid
Methyl Ethyl Ketone
Physical Area(s) Examined at the Facility:
Storage and Handling
• Storage Systems
• Material Transfer
Western Forge stores hazardous chemicals in three areas underground
storage tanks, the central storage area, and process storage areas
Acetone and acetate are stored in underground storage tanks -- acetone
in a 2,000 gallon tank and acetate in a 100 gallon tank Both tanks
-have cathodic protection, overfill collection, inventory control, and
monitoring wells. Most of the other hazardous materials are stored in
the five sections of the central storage area, access to which is
controlled.
The first section holds flammable raw materials These include about
six drums of perchloroethylene, methylene chloride, toluene, and methyl
ethyl ketone. The second section contains material to be recycled,
specifically waste acetone and acetate from the plastics department
The third section contains hazardous waste, primarily from the pliers
department -- mixtures of toluene, methyl ethyl ketone, methylene
chloride, still bottoms from the vapor degreaser, and waste ethylene
glycol. The fourth section holds new empty drums and non-hazardous
waste (spent Plastisol). The fifth section contains empty drums
Process operators use two small pumps to transfer acetone and acetate
from the underground storage tanks to the vapor polish machine While
these pumps are operating, a blue flashing light in the process area
indicates that they are in use.
Process Area(s)
The facility processes raw steel into screwdriver blades, chisels,
punches, adjustable wrenches, and pliers. The facility uses a nickel-
chromium plating on some screwdrivers and pliers; the remaining tools
are either treated with a black oxide coating or given a machined
finish. The facility also makes plastic screwdriver handles
Western Forge plans to discontinue plating operations in the near
future. Until then, the tools to be plated are all processed in a
similar manner The process begins with a heated alkaline soap cleaner
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tank followed by a heated. 20 percent hydrochloric acid water bath
After two water rinse tanks, the tools proceed through an acidic
cleaner, two water rinse tanks, and another heated, 20 percent
hydrochloric acid and water bath.
Tools are sent through three water rinse tanks and a heated nickel
plating tank before being sent through a nickel plating dragout bath,
heated water rinse, and another heated water rinse before proceeding to
the heated chromic acid tank. After chrome plating, the tools are
rinsed in a series of three counterflow water baths before entering r.;o
rinse tanks. The final tank contains deionized water The heated dip
tanks are vented to a scrubbing system located on the roof of the
building. The temperature of each solution is continuously measured and
observed by the process operators
The racks used to carry the tools through the plating bath are stripped
in an adjacent sequence of stripping tanks. The first rank is heated
and contains a mixture of water and nitric acid, and is followed by a
water spray rinse. The racks are then sent through another heated
acidic strip tank, a water spray rinse, a heated alkaline strip tank,
and a final water spray rinse before drying. Off-specification tools
are also stripped on a nearby parts stripping line As a result of a
sodium cyanide solution spill, Western Forge discontinued use of the
sodium cyanide bath for this stripping operation and now uses an amine-
based solution of unknown composition
For some products, Western Forge provides a black oxide finish instead
of a plated finish. This coating is applied in a series of four tanks
The tools are sent through an alkaline soap solution, superheated
caustic bath, water soluble rust preventative, and final water rinse
The waste water treatment system collects effluents from all of the
production areas, except the plating department. The effluent is
collected in a large sump before being sent to a neutralizing tank In
addition to neutralization, the effluent is treated to reduce any
hexavalent chromium to trivalent chromium.
After neutralization and chromium reduction, the effluent is processed
through a lamella (used to settle solid material) before proceeding to
the final tank. Solid material is collected through the use of a filter
press and the filter cake, containing metal hydroxides, is a hazardous
material. After the final tank, the plant effluent is discharged
directly into an open square hole in the building floor that empties
directly to the City of Colorado Springs waste water treatment plant
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Summary of Audit Findings and Recommendations
Conclusions:
Chemical Hazards
• Material Safety Data Sheets are located in notebooks in various
locations in the facility The MSDS for sulfuric acid was missing
from the plating department MSDS notebooks and. in general, the
notebooks were not in any specific order.
• Hazardous chemical usage in the pliers department is limited co
four areas in which the chemicals are either used to prepare
pliers for coating or to remove defective coatings
Process Information
• Currently all storage containers are outside and exposed directly
to sunlight and precipitation. Several rusting drums were noticed
during the audit Exposure of full liquid containers to the heat
of direct sunlight may cause the contents to expand and be
released through the bungs or weaker (rusted) areas
• The drum storage areas are diked but this area also collects
precipitation This area is also served with a drainage cut to
remove precipitation. Spilled materials can exit the storage area
through this hole in the dike
• Hazardous waste manifests required under RCRA have been compiled
into binders and appear to be in order.
• Hazardous materials (hydrochloric acid, nitric acid, and sulfuric
acid) are stored in the plating department in plastic-lined, 55
'• gallons drums on a diked concrete pad.
• Hazardous materials (toluene, methylene chloride, xylene. and
methyl ethyl ketone) are also stored in the pliers department.
• Excess vapors around the vapor polish machine are vented from the
floor by an exhaust fan. The fan is connected to an automatic
shutoff system that will stop the conveyor in case of vent failure
and activate a red light in the process area to begin flashing.
Chemical Accident Prevention
• It is apparent from the scope of the training program presently
under development that management is taking measures to improve
the safety environment at the facility.
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The faci.li.cy Environmental and Safety Department, consisting of
two professionals, is responsible for safety and release
prevention Corporate assistance is provided by the corporate
Health, Safety, and Environmental Affairs Department
New employees receive an eight-hour training and orientation
course which includes a video presentation on hazard communication
and hazardous materials
The plant has two training managers and is developing a new
training program, focusing on both general health and safety
training and specific job skill training. Current employees will
be required to attend this training program.
The facility has developed a health, safety, and environmental
(HSE) program to provide a safe and environmentally responsible
workplace for all employees. The program was created as a result
of an internal safety review brought about by rising workmen's
compensation costs
The plant HSE committee conducts facility inspections, offers
recommendations, and oversees their implementation. The committee
meets monthly to discuss HSE program status, achievements, and
plans, review new health and safety recommendations, and discuss
lost time accidents, spills, and near misses
The HSE program requires HSE coordinators to be selected from each
operating area and shift, trained, and responsible for HSE issues
within their area The program also provides the coordinators
with inspection tour checklists and accident reports
The plating process and rack stripping areas are surrounded by a
trench system that collects tank overflow, rinsate, and spills
The trench system effluent is collected in a sump and pumped to
the wastewater treatment system.
Both the pH and the chromium are monitored by instrumentation
located on a nearby control panel. If either step in the waste
water treatment process is not working properly, an audio alarm
will sound to notify the process operator. When this situation
occurs late at night, or on a weekend, the alarm notifies the
security guard who is instructed to notify the plant management
The plating equipment is maintained on a regular basis. The
plating baths are cleaned monthly and the rinsate is collected in
the trench system. Once every six months, the whole system is
shut down and is cleaned, inspected, and repaired, if necessary
It was not determined if the vapor polish machine or the vapor
degreaser receive regular maintenance.
206
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• There is an operation and maintenance procedure manual for was re
water treatment. However, the employees appear to acquire their
skills through on-the-job training.
• Western Forge does not conduct regular hazard evaluations of its
production processes.
• Employees in the plating, pliers, and plastics departments appear
to acquire their skills through on-the-job training -- the
auditors did not review any SOPs for these departments
• Employees are required to wear steel-toed shoes and safety glasses
in any production area. Employees handling hazardous chemicals
are also required to wear a face shield, rubber gloves, and a
chemically-resistant apron. Employees were observed following the
rule for personal protective equipment.
Accidental Release Incident Investigation
• Western Forge has experience a significant release of hazardous
chemicals in each of the previous three years. According to the
HSE program, near misses must also be reported and investigated.
• The HSE program identifies the individuals responsible for
investigating accidents and outlines the required steps that the
investigating team should take in evaluating the situation It
also places the responsibility for implementing any corrective
action in the hands of the Environmental and Safety Specialise
• Western Forge has not determined vulnerability zones for potential
off-site impacts of accidental releases. There is some potential
for surface spills of liquids that could flow off-site
Facility Emergency Preparedness and Planning Activities
• The Western Forge contingency plan is revised annually, and is
distributed co facility management personnel as well as the El
Paso County LEPC, the local fire department, the local HazMat
unit, and the local hospital.
• The plan as revised in August 1989 discusses the minimization of
hazards to human health or the environment from fires, explosions,
or any unplanned sudden release of hazardous chemicals to air,
soil, or surface water.
• The plan includes a description of the facility, hazardous waste
streams, and hazardous waste storage and inspection procedures.
emergency equipment and alarm systems; spill response equipment
and location; spill control and countermeasures coordinators,
emergency response and notification procedures, evacuation plan,
and emergency telephone listing.
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The company does have safety equipment and spill cleanup equipment
scored near the plating operations where most spills are likely co
occur The spill materials storage cabinet was noted to he
lacking some of the items called for in the contingency plan;
although additional supplies are located at the facility, during
the spill event, a worker must rely on what is available in the
cabinet to respond to the spill
. Tvvex coveralls were placed in the spill materials storage
cabinets, but the company did not seem to be aware that these
coveralls do not provide protection against high concentration
acids SCBA gear located near the plating operation was extremely
dirty and a face mask hose was crimped
Personal splash protection gear is also stored in individual
storage lockers and appears to be accessible
The company is not equipped to handle large spills, but relies on
the nearby Colorado Springs HazMat unit to respond
Community and Facility Emergency Response Planning Activities
A facility representative serves on the LEPC and Tier II lists and
section 313 reports have been submitted as required
The local fire department and hazmat unit make regular inspections
of the facility to identify fire code violations and to assess
hazards
Recommendations:
Chemical Hazards
The plant should post required protective clothing requirements,
for handling hazardous chemicals at the storage and handling
locations.
The MSDS notebooks located at offices throughout the facility
should be updated.
Process Information
Since all storage containers are outside, Western Forge may wish
to construct a carport-like structure to keep full containers in
the shade and under protection from precipitation.
Western Forge should consider the relocation of flammable chemical
and material drums stored inside the buildings.
The plant should segregate flammable raw materials'from other
solvents in the plating and pliers departments.
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• The plane should monitor the acetone level against the Permissible
Exposure Level (PEL) inside the vapor polish room of the Plastics
Department
Chemical Accident Prevention
• Standard Operating Procedure manuals relating to the various
process operations should be developed
• The pliers and plastics departments should develop SOPs for their
employees and ensure the procedures are understood and followed
• The facility should installed diking around the smallest dip tank
in the pliers department, the four floor drains in the plastics
department, and the plant effluent discharge floor drain These
measures will help to prevent uncontrolled releases to floor
drains emptying to the city wastewater treatment system
• Western Forge should consider installing an automatic shutoff
system on the pumps used to fill the vapor polish machine in the
plastics department in order to prevent overflow during filling.
• The plant should install diking around the vapor polish machine to
prevent spills as a result of an overflow during filling
• The facility should install an automatic shutoff on the wastewater
treatment process, or a properly sized surge tank prior to
effluent discharge, to prevent uncontrolled releases to the city
wastewater treatment plant in the event of a neutralization or
chromium reduction process upset
• The plant should consider the placement of curbing within the
plating building to contain a worst-case process vessel failure.
• Western Forge should conduct regular testing of the wastewater
treatment alarm system.
• Western Forge should conduct regular hazard evaluations of
chemical storage, handling, and processing at the facility.
• The plant should develop a schedule of inspection and maintenance
for the wastewater treatment equipment, since one does not exist
Accidental Release Incident Investigation
• The plant should consider reporting and investigating all near
miss accidents as indicated'in the HSE program manual.
• The facility should revise the HSE program definition of a near
miss to state, ".... would have resulted in a lost time injury,
hospital or doctor case, or uncontrolled release of a hazardous
substance to the environment "
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Facility Emergency Preparedness and Planning Activities
• Western Forge should revise the facility contingency plan to
include appropriate notification procedures to the National
Response Center, the US Coast Guard, and EPA Region VIII
Audit Team Member Composition.
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Tien Nguyen
EPA Region VIII
Team Coordinator
Chemical Engineer
Jim Knoy
EPA Region VIII
Team Member
Senior OSC
Mark Dahm, TAT
Team Member
N/A
N/A
Henry Schmelzer, TAT
N/A
N/A
N/A
Lew French, HQ TAT
N/A
N/A
N/A
Bill Ragsdale
El Paso County,
N/A
N/A
CO, LEPC
Follow-up Activities:
By the Facility:
Western Forge will discontinue plating pliers as of August 1989,
and will substitute a machine finish. The facility also plans to
discontinue the plating of punches and chisels In general,
Western Forge plans to stop plating completely in the near future
depending upon consumer acceptance of the substituted finishes
Western Forge is installing a new set of black oxide baths to
replace the existing line in its coating operations.
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» The Hazard Communication program for new employees is being
revised to address each operations department. The new program
will be a 2 to 3 hour segment of employee orientation and Western
Forge expects to ultimately train 20 to 30 employees each month
• Western Forge will retrain all of its current employees with an
eight hour course presented by a local consulting firm in the fall
of 1989 This course will re-emphasize health, safety, and
environmental issues to Western employees
• Western Forge has begun development of a comprehensive employee
training program to develop production set-up teams, increase
employee flexibility, reduce workmen's compensation costs, improve
the workplace safety environment, and lower employee turnover.
• Safety SOPs are being developed for the employee training program.
By the Regional Office:
• N/A
By State and Local Authorities:
• N/A
Regional Contact:
Due Nguyen
(303) 293-1876
211
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Koppers Industries, Denver Wood Produces
Plane
Facility Location:
Denver, Adams Councy, Colorado, Region
VIII
Date(s) Audit Conducted:
March 27, 1990
Description of the Facility:
Location:
SIC Code(s).
Products manufactured,
produced, or distributed:
Proximity to sensitive
populations:
The plane is on a 60-acre sice located
outside che Denver Cicy limics, Councy of
Adams, Colorado
SIC 2491 - Wood preserving
Treacmenc and preservation of wood
produces
The plane is locaced in an area which has
light
industry, recail businesses, and few
residences within 1/2 mile of north of che
plant.
Reason for Facility Selection:
ARIP Reports:
Eight accidental releases of creosoce/oil
had been reporced Co che NRC during che
last cwo years.
1/18/89, 3/3/89, 3/30/89, 4/5/89, and
6/8/89 releases of creosoce (quescionnaire
for all five releases completed 10/9/89)
Focus of Audit:
Hazardous Substances
Examined:
Creosoce
Wolmanac (CCA)
Slurry Oil
Sulfuric Acid
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Physical Area(s) Examined at the Facility
Storage and Handling
• Storage Systems
• Material Transfer
Four 100.000 gallon storage tanks at the facility contain creosote and
slurry oil A 5,950 gallon storage tank is used for storage of 50
percent Wolmanac solution and is contained by a concrete storage dike
Both creosote and slurry oil are received twice a month by railcar The
creosote must be heated to 170 degrees prior to pumping out of the tank
car due to its high viscosity and precipitated sludge at ambient
temperature The total time required for heating the creosote LS
eighteen hours, an additional 3 hours is necessary for transfer into a
storage tank. The heating process is always coordinated by a
supervisor The Wolmanac solution is delivered by truck and is pumped
directly from the truck into the tank upon delivery. The truck driver
is solely responsible for supervising this process All transfer
activities are performed during the day shift so that in the event of a
leak or spill it will be detected and addressed quickly
Process Area(s)
Wood is treated with either a creosote/oil solution or Wolmanac (CCA)
A proper blend of creosote and oil is mixed to create the wood treating
solution: the contents of the mixture depend on the type of wood product
being treated Wood treating is performed in one of three steel
cylinders, 6-7 feet in diameter and 133 feet long (two cylinders are for
creosote treating, one is for CCA treating). Each cylinder can hold
approximately 2,000 cubic feet of wood and 25,000 gallons of treating
solution.
Creosote treatment is performed at 200°F and 100 psi. After treating
the wood, solution from the steel tank is removed into a blowdown tank.
excess solution is vacuumed out of the treatment tank. Creosote is
separated from the blowdown solution for reuse using a slanted
horizontal creosote separator; excess water is removed from the
separated creosote by boiling the solution in a creosote dehydrator
Waste water resulting from the removal of creosote from the blowdown
solution is treated so that the creosote/oil concentration is 15 ppm,
making it acceptable for disposal to the sanitary sewage system
For Wolmanac (CCA) treatment , the Wolmanac solution is blended with
Dricon and water prior to treating the wood. The wood treating is then
performed in the steel tank at ambient temperature and 100 psi. The
remaining waste solution is then removed into a blowdown tank, and CCA
is removed for reuse
213
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Summary of Audit Findings and Recommendations:
Conclusions:
Chemical Hazards
• An industrial hygiene study was conducted by Koppers in 1982 to
measure the exposure levels experienced by personnel at wood
preserving plants in comparison to OSHA Permissible Exposure
Limits (PELs) The study's final report, "Occupational Health
Experience in the Wood Preserving Industry" by Charles W
Flickinger, Manager, Industrial Hygiene, Koppers Company, and
Alonzo W. Lawrence, Ph D., Vice President, Science and Technology,
Koppers Company, is not available to Koppers plant personnel
• There is no ongoing medical surveillance program to monitor
workers at Koppers, as it was eliminated due to budget
constraints
• Safety glasses are not required to be worn by operators, in spite
of the proximity of high pressure steam lines and hazardous
chemicals near work areas at the facility.
• There are no eye wash stations at any locations within the Koppers
facility where workers might come into contact with hazardous
chemicals These include the floe house, where sulfuric acid is
used, and the water treatment building, where sodium hydroxide is
used
Process Information
• Small leaks from valves and flanges going to and from the four
100,000 gallon creosote/slurry oil storage tanks were observed
• No ground cables are used near the storage tanks to guard against
static buildup, and no lightning rods are present in the storage
tank area to dissipate lightning strikes.
• There is currently no system to prevent accidental collisions with
railcars during the offloading of creosote into storage tanks
• Process piping, pumps, valves, and equipment are not labelled at
the facility.
• No routine air monitoring is currently performed at the site
Chemical Accident Prevention
• Procedures to deal with upset and unsafe conditions, such as in
the event of a power or utility failure at the facility, have not
been written
-------
• Although a prevencative maintenance checklist is kept in the
facilLty control room, it LS not an integral part of plant
operations. The facility does not have a maintenance department,
relying upon supervisors to ensure chat proper maintenance of the
equipment is performed. During repairs, improper installation of
equipment, such as steam valves and product lines, has occurred as
a result. Further, there is no centralized system for record
keeping of any repairs at the facility.
• Based on the audit team's review of the facility's records, it
appears that Koppers has devoted little attention to hazard
evaluation and modelling.
• The spill containment structures around the wood treating tanks
were not constructed of impervious materials.
• According to a SARA Title III section 313 report for 1988, 1,865
pounds of creosote dripped to land at the Koppers facility
Currently, Koppers has no method for reducing the drippage of
creosote and CCA from wood after it has been treated
Accidental Release Incident Investigation
• Koppers reported five accidental spills of creosote/oil during
1989 which were in excess of one pound The NRC, LEPC, and the
Colorado Department of Health were notified of all of these
releases, and written incident reports were sent to the LEPC and
the SERC
Facility Emergency Preparedness and Planning Activities
• Although Koppers provides training on emergency response for all
upper level personnel, there are no simulation exercises that
would help test all facility personnel on preparedness in the
event of an accidental release.
• Although an evacuation plan is provided at the end of the spill
response plan, the attached map does not extend to show the
evacuation routes and alternatives.
• Personal Protective Equipment (PPE) needed to respond to an
emergency is centrally located in the yard house. However, the
PPE located on the second floor of the facility is not in a
location conducive for a rapid response. Also, proper cartridges
for acid vapors were not present at the facility, and only one
pair of neoprene boots was found to be available.
Community and Facility Emergency Response Planning
• The emergency response plan was last submitted to the local police
and fire departments and hospital in March 1987.
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• The fire department was requested to conduct an inspection of a
new wood treating installation at the facility that was expected
to be completed in June 1990
• Koppers has submitted information under SARA Title III sections
301 - 303 (Emergency Planning) and sections 311 - 312 (Hazardous
Chemical Reporting). Koppers has also sent copies of the Toxic
Chemical Release Inventory Reporting Form, as required by SARA
Title III section 313, to the U.S EPA and the Colorado Department
of Health.
Public Alert and Notification Procedures
• There are currently no provisions in Koppers1 contingency plan for
public notification or media interaction in the event of an
emergency release. The local Police and Fire Departments would be
responsible for making decisions pertaining to public evacuations
in the event of an emergency.
Recommendations:
Chemical Hazards
• Koppers should make the results of the 1982 industrial hygiene
study readily accessible to plant personnel.
• The medical surveillance program should be reinstated, in order co
expand the cross-section of workers in the industrial hygiene
study and statistically increase the validity of the results
This is because the original study only focused on a limited group
of workers in certain job classifications at wood preserving
plants
Process Information
• Koppers should place both ground cables and lightning rods on and
near all of its storage tanks to prevent an accident due to
lightning.
• Derailers should be installed to prevent collisions with railcars
• A current piping and instrument diagram (P & ID), along with
physical labelling of all process piping, pumps, valves, and
equipment at the Koppers facility, should be developed This will
assist in training, maintenance, and plant safety.
• The facility should develop a system to monitor air quality at the
plant.
216
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Chemical Accident Prevention
• Procedures co deal with upset and unsafe conditions at the
facility should be written
• Koppers should increase the priority given to preventative
maintenance and should develop a centralized organization to
improve record keeping.
• Routine maintenance, including tightening flange bolts, should be
increased in frequency in order to reduce the occurrence of leaks
• Koppers should conduct a comprehensive hazard evaluation or "what
if" study to familiarize plant personnel with the potential
consequences of an accident at the facility
• Spill containment structures near the wood treating tanks and the
creosote and oil tanks should be improved. Specifically, these
structures should be constructed of impervious materials
• Koppers should investigate methods for reducing creosote and CCA
drippage from treated wood
Facility Emergency Preparedness and Planning Activities
• The evacuation plan s"hould contain a more detailed map which
highlights all possible evacuation routes in the event of an
emergency situation.
• Koppers should be better prepared for small incidents that may
occur at its facility Specifically: PPE should be relocated on
the second floor in a location conducive for a rapid response in
case of an emergency; proper cartridges for acid vapors should be
provided; and, more neoprene boots should be made available for
emergency use.
• Koppers should require that all personnel working in wood
processing area wear safety glasses.
• Eye wash stations should be installed at various plant locations,
including the floe house and the water treatment building.
Community and Facility Emergency Response Planning Activities
• Koppers should develop a "table top" exercise in coordination with
the LEPC to assist both the facility and the local fire department
in emergency preparedness. All plant personnel should be required
to participate in this exercise
217
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In the evenc of any future accidental releases requiring
notification under SARA Title III, Koppers should notify che NRC,
SERC, and LEPC, and should send incident reports to the SERC,
LEPC, and the local Fire Department.
Public Alert and Notification Procedures
• Provisions should be made in Koppers1 contingency plan for public
notification or media interaction in the event of an emergency
Audit Team Member Composition:
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation-
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Due Nguyen, Team Leader
EPA - Region VIII
N/A
N/A
Jim Knoy, Deputy Team Leader
EPA - Region VIII
N/A
Jerry Goedert, Technical Assistance Team
Ecology and Environment, Inc.
N/A
N/A
Edwin Coker, Technical Assistance Team
Ecology and Environment, Inc.
N/A
N/A
Rosalie DuKart, LEPC/Chair
Adams County
N/A
N/A
Jim Younger, LEPC
North Washington Fire Protection
District/Battalion Chief
N/A
N/A
Follow-up Activities:
By the Facility:
Eye wash stations have since been installed at the floe house and
water treatment building.
218
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By the Regional Office:
• EPA requests that six month progress reports be supplied to EPA
detailing activities undertaken in response to the
recommendations
By State and Local Authorities:
• The Adams County LEPC recently conducted a "table top" exercise
with Koppers personnel and other nearby facilities
Regional Contact:
Due Nguyen
(303) 293-1867
219
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name.
Amoco Production Company Elk Basin Gas
Plant
Facility Location
Powell, Wyoming, Region VIII
Date(s) Audit Conducted:
May 15-17, 1990
Description of Facility:
Location:
SIC Code(s)•
Products manufactured,
produced, or distributed:
Proximity to
sensitive populations:
Sixteen miles northwest of Powell, and
about 50 miles ease of Yellowstone
National Park in northern Wyoming
SIC 131 - Crude petroleum and natural gas
Natural gas
Nearest residence is 10 miles away.
Reason for Facility Selection:
ARIP Reports:
After the installation of a "zero release"
system, fifteen releases of sulfur dioxide
or hydrogen sulfide occurred.
None prior to audit
Focus of Audit:
Hazardous Substance(s)
Examined:
Methane (CH4)
Hydrogen Sulfide (H2S)
Sulfur Dioxide (S02)
Sulfur (S)
Physical Area(s) Examined at the Facility:
Storage and Handling
• Storage Systems
• Shipping/Receiving
• Material Transfer
220
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Produce scorage at the plane is comprised of moLcen suLfur and chree
separace natural gas liquids - propane, butane, and natural gasoline
Sulfur and natural gas liquid storage are at opposite ends of the plant
in spherical tanks.
Sulfur. A trucking contractor hauls molten sulfur to Powell, where it
is transferred to railcar. Two loads of 48,000 pounds each are hauled
daily.
Natural Gas and Liquids (NGL) Procedures for NGL loading are similar
to sulfur loading. However, there are several companies loading the
three types of NGL, and one company loading mixed NGL which is separated
at the plant.
Transfer pumps and piping are used in the process and for product
transfer to trucks. Although process vessels are labeled, pipes are
not
Process Area(s)
• Natural Gas Separation
• Natural Gas Liquids (NGL) Separation
• Sulfur Production
• Tail Gas Processing
• Waste Water Treatment
Natural Gas Separation The inlet natural gas is collected
continuously, and enters the plant at 0 5 psig pressure It is
compressed to 170 psig, H2S and C02 are removed in an amine contractor,
it is compressed again to 510 psig, NGL is removed with a lean oil
absorber; final H2S removal; and water is removed with a glycol
contractor.
Natural Gas Liquids (NGL) Separation. NGL are easily separated from
absorption oil since the boiling point of NGL is much lower
Distillation columns are used for this separation and also to separate
propane, butane, and natural gasoline from the feed gas. Caustic potash
contactors are used to neutralize the acid content of the NGL. Each of
these produces is stored in bullet tanks
Sulfur Production. The Elk Basin plant utilizes a two-stage modified
Glaus process to convert 93-95 percent of the H2S to elemental sulfur.
Although current pollution standards require greater than 95 percent
conversion, a grandfather clause exempts older plants from this
requirement. A series of converters and condensers achieve about 95
percent sulfur recovery Water steam is released from the H2S reaction
221
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Tail Gas Processing The unreacced gas effluent of che sulfur plane
feeds into this process, which makes zero emission possible. The gas is
heated to 600 degrees Fahrenheit and sent to a reactor containing cobalt
molybdenum, which converts S02 back to H2S The exit gas is cooled and
compressed and flows into the three injection wells
Waste Water Treatment. The absorber oil system collects in an
explosion-proof sewer system which drains to a concrete pit northeast of
the yard. Oil is skimmed and placed in tanks or reprocessed Caustic
wash water is retained in an evaporation pit and is neutralized with
acid.
Summary of Audit Findings and Recommendations:
Conclusions:
Process Information
• A cause for unplanned plant shutdown that occurred at the facility
was attributed to a loss of electricity, which is generated at the
plant.
• The current control room does not have automatic shutoffs The
plan for a future automated control room also does not include
full automatic shutoffs.
• Loading and unloading areas have no markers to alert vehicle
drivers A driver's ability to judge distance from pipes and
railguards may be impaired in winter weather.
• Sulfur dioxide monitors are portable, and are not permanently in
place around the facility
• Process vessels are labeled, but pipes are not
• New chemical truck drivers are trained by plant personnel on
proper loading procedures. Loading is done only during daylight
hours.
Chemical Accident Prevention
• The SOP, although currently under review, has not been updated in
over ten years.
• Training classes outside the facility are provided for operators
and maintenance personnel. Selection of training is based upon
supervisor suggestion and employee interest.
222
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• There is no formal new operator training program in place at the
facility The new employees have been trained by the more
experienced personnel or immediate supervisor and the SOP is noc
used as a guideline for training
• Startup and shutdown procedures are included in the SOP, but there
is not a checklist for routine operation.
• Each maintenance shift has a measurement technician who is trained
to repair instruments. Although pressure relief valves and
emergency shut down (ESD) valves are supposed to be removed and
tested annually, records for this were incomplete.
• Minor process changes are made informally through discussions with
the plant engineer, process, and maintenance foremen, and
operators
• Workorder Forms are used as a system for operators and foremen to
have maintenance performed
• The production foreman prioritizes workorders on a daily basis
However, the work orders are not used as a means to schedule
preventative or predictive maintenance.
• Shift changes have 15 minute overlaps where foremen provide
information and discuss important events with operators for each
area.
• Rotation of one operator to a different shift occurs annually co
improve inter-shift communications
Accidental Release Incident Investigation
• Near miss reporting is available at the facility but usually
refers to personnel injury An accidental release could happen in
the same near miss involving an injury. The near miss reports are
discussed at the monthly safety meetings and circulated to other
field and plant offices in the region.
Facility Emergency Preparedness and Planning Activities
• Modeling of releases to the air has not been performed at this
plant.
• As directed by the Regional office, emergency drills are conducted
quarterly
• The Elk Basin plant has equipped H2S detection, combustible gas
detection, and fire detection alarm systems to warn the operators
of malfunction
223
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• The facility has an Emergency Response Plan The primary
considerations include personal safety, protection of company
property, and protection of the environment
• The facility's lack of backup power could leave nighttime
emergency mitigation without light.
• The facility has no fire brigade for responding to on-site
emergencies.
Community and Facility Emergency Response Planning Activities
• In over 10 years, no incident has required community response
• The Elk Basin Plant has a good relationship with the Park County
LEPC and facility compliance with SARA Title III regulations has
been consistent.
• While the facility complies with notification requirements, it has
not coordinated with community officials in simulating an
emergency response.
Recommendations:
Process Information
• Improvements are needed in the facility's ability to respond co
in-plant electrical outages. To have emergency lighting at night.
a system using available city electricity should be designed as an
effective backup.
• With a new automation control room installed in the future.
automatic shutoffs need to be considered and designed into the
process to protect the plant from losses or equipment damage If
operators will be relying on automatic control, manual shutoff may
be delayed.
• Railguards with fluorescent tape should be installed on piping.
posts, and fence at all loading and unloading areas.
• Real time sulfur dioxide monitors should be installed to help in
identifying and limiting employee exposure.
• Valves, piping, and equipment should be permanently labeled
according to SOP for easy operation in emergency situations,
training, and winter conditions
Chemical Accident Prevention
• The SOP should become a working document. Annual review by
operators, safety, environmental, and management groups should
224
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occur. Enforcement of the SOP should occur or it should be
amended until LC is enforceable. Discrepancies from operator to
operator can lead to serious problems
• SOPs should be used as a training guide and a formal training
program developed for new employees to prevent the possibility of
unsafe practices being passed on from the veteran employees to the
new employees during on-the-job training. Although the low
turnover rate has put little pressure on having a training
program, dependence on this could be risky
• Checklists should be developed to track routine process
activities.
• Although it is likely that the required relief and ESD valve
testing was performed, documentation should be improved to verify
that it has been done
• Maintenance records should be organized to provide for trend
analysis
• A formal system of identifying and conducting process and
equipment modifications should be devised to document all changes
and ensure that the facility's safety and environmental groups
review all proposed changes.
Facility Emergency Preparedness and Planning Activities
• If an emergency should happen during the night, emergency backup
lighting system in the plant is likely to be necessary in order to
respond to the emergency. Therefore, city power should be used as
a backup power source
• ,A fire brigade should be formed. Facility employees in this fire
brigade should be trained and equipped for fighting sulfur pit
fires, H2S fires, fuel oil fires, etc. The fire brigade personnel
should consist of facility employees and be coordinated with local
fire department personnel who are familiar with various operations
and equipment in the plant.
Community and Facility Emergency Response Planning Activities
• The facility personnel should coordinate with Park County LEPC,
Powell Fire Department, and other local agencies to develop a
table top exercise for emergency preparedness.
• The facility should invite the local fire department to the
facility to be familiarized with the processes for emergency
situations
225
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Audit Team Member Composition:
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Due Nguyen, Team Leader
EPA Region VIII
N/A
Chemical Engineering
Jerry Goedert, Lead Technical Reviewer
TAT/Ecology & Environment
N/A
Chemical Engineering
Randy Perils, Technical Reviewer
TAT/Ecology & Environment
N/A
Chemistry
Scott Matthews, Technical Reviewer
TAT/Ecology & Environment
N/A
N/A
Duane Sharp, Co-Chairman
Cody LEPC
N/A
N/A
Follow-up Activities:
By the Facility:
• The facility has installed an automatic switch-over from on-site
to city electricity.
By the Regional Office:
• N/A
By State and Local Authorities:
N/A
Regional Contact:
Due Nguyen
303-293-1867
226
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name
Nunes Cooling, Inc.
Facility Location.
Salinas, California, Region IX
Date(s) Audit Conducted:
May 12 and 13, 1989
Description of Facility:
Location:
SIC Code(s):
Products manufactured,
produced, or distributed:
Proximity to any
sensitive populations:
Light industrial area in the southern part
of Salinas, CA.
SIC 0723 - Agricultural production and
shipping
Refrigerating produce grown at Nunes, Inc
farms.
Estimated vulnerable zone surrounding the
facility of 1.9 miles in radius
Reason for Facility Selection:
ARIP Reports:
The facility was chosen because of a
release of an anhydrous ammonia plume from
a cooling shed. A pipe flex-joint failed
when pressure from trapped ammonia gas in
the pipe increased as the gas warmed,
resulting in the release of approximately
2,000 pounds of ammonia gas. The release
was the result of an operator error
Twelve civilians received hospital
treatment as a result of exposure to the
ammonia vapor.
11/22/88 release of ammonia (questionnaire
completed 6/1/89).
Focus of Audit:
Hazardous Substances
Examined:
Anhydrous ammonia
227
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Physical Area(s) Examined at the Facility
Storage and Handling
• Storage Systems
An ammonia refrigeration system is used at the facility. The ammonia
refrigeration system is constructed of carbon steel that is not
passivated. Ammonia liquid is distributed through the system by piping
which is connected by stainless steel flex joints Pressure
differentials range from 33 psi to 180 psi within the system.
Process Area(s)
• Ammonia refrigeration system to cool produce for storage
There are two systems in use at the facility The first is a vapor
compressor system using fan coil units (evaporators) in the chilling
rooms Heat is abstracted from the air surrounding the system by the
conversion of ammonia from its liquid state to a vapor This vapor
compressor system causes the ammonia refrigerant to absorb heat at low
temperatures by vaporization and to give up heat elsewhere at higher
temperatures by condensation. The second is a vacuum retort system
which reduces the pressure in the vessels using vacuum pumps The coils
then attract water vapor from the produce and cool the produce by
evaporation.
Summary of Audit Findings and Recommendations
Conclusions:
Chemical Accident Prevention
• An estimated vulnerability zone with a distance of 1 9 miles in
radius surrounding the facility has been calculated. While this
represents the beginnings of a general risk assessment, it is not
a complete assessment until sensitive populations that might be
affected by an ammonia release are identified and addressed in the
planning process.
• The Nunes Cooling Safety Manager stated that he devoted
approximately five percent of his total workweek to safety related
activities.
• A formalized safety training program does not exist at Nunes
Cooling
• Nunes Cooling management has established a system of standard
operating procedures for the operation of its facility Operation
of the cooling system is taken care of by management level
personnel. Since the release incident at the facility occurred
228
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when all managemenc level personnel were away from the facility,
Nunes modified their standard operating procedures after che
release occurred to provide that at least one management Level
individual is either on or available to the facility during all
times of operation.
• Nunes Cooling does not have any eyewash stations or safety showers
located in close proximity to chemicals in order to mitigate
exposure to employees.
• Nunes Cooling lacks an integrated system of detection devices and
alarms for notification of an emergency situation.
• In order to mitigate the potential for another ammonia release due
co trapped liquid within the cooling system, Nunes Cooling has,
drilled a one-eighth inch diameter hole through the check in each
check valve that could potentially trap ammonia liquid
• Prior to plant start-up, all equipment and instrumentation is
checked in order to prevent shut-downs from occurring, major
repairs are scheduled for the winter season when the plant is not
in operation. However, the existing instrumentation on the
refrigeration system is of the minimum extent required for proper
operational use only.
• The refrigeration cooling systems at the facility were in good
working order with no evidence of corrosion or leaking However,
the refrigeration units have no pre-release protection equipment
which would capture, neutralize, or destroy a toxic chemical
before it is released into the environment. Bypass and surge
systems are utilized to minimize accident potential
Accidental Release Incident Investigation
• Formal procedures to investigate a release and incorporate the
results into safety practices have not been defined.
Facility Emergency Preparedness and Planning Activities
• Nunes Cooling's facility emergency response plan refers to
specific locations of evacuation routes and emergency response
equipment, but these locations are not visibly posted on maps
• Nunes Cooling's facility emergency response plan provides
information about emergency notification procedures, but these
procedures are not exercised regularly by employees.
• There is no formalized training for the Business Emergency Action
Team on the emergency procedures, use of emergency equipment, and
other emergency requirements
229
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• The alarms and intercoms between the administration office and the
cooling plant are not interconnected
Community and Facility Emergency Response Planning Activities
• When responding to the ammonia release at Nunes Cooling, the
Salinas Fire Department declined to accept a suggestion from Nunes
personnel that the fire department apply a water fog spray to the
ammonia vapor release cloud This suggestion was based upon the
recommendation shown on the Material Safety Data Sheet (MSDS)
supplied to Nunes Cooling by their ammonia supplier While this
MSDS had been senc to the City of Salinas, it had not been
effectively disseminated throughout the fire department
• Nunes Cooling has not coordinated with the community with regard
to preparedness planning and is not represented on the LEPC In
addition, no public notification and alert procedures have been
established.
• According to the SERC and LEPC, Nunes Cooling has not resubmitted
Section 312 chemical inventory forms, as required under SARA Title
III, to the SERC. LEPC, and the Salinas Fire Department Nunes is
not presently providing notification under Section 302 to the
State and LEPC about extremely hazardous substances (EHSs) that
are being handled in amounts in excess of their threshold planning
quantities (TPQ).
Public Alert and Notification Procedures
• No public notification and alert procedures have been established
Recommendat ions
Process Information
• It is suggested that a fully integrated system of detection
devices and alarms be investigated by Nunes Cooling and considered
for installation at its facility.
Chemical Accident Prevention
• While Nunes Cooling has calculated their vulnerability zone as
part of a general risk assessment, a vulnerability analysis based
on an earthquake scenario should also be performed.
• Although a full-time safety officer is not necessary at Nunes
Cooling, at least two man-hours per week of the Safety Manager's
time should be devoted to safety-related functions
• A formalized safety program should be instigated as part of
employee training, as such a program is presently not in effect
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Accidental Release Incident Investigation
• Nunes Cooling needs to define formal procedures for investigating
an accidental release and incorporating the results into safety
practices
Facility Emergency Preparedness and Planning Activities
• An evacuation plan detailing escape routes, internal emergency
notification procedures, and location of safety equipment should
be posted in a visible location These plans and procedures
should be exercised on a regular basis to assure employee
familiarity
• The facility emergency response plan should be revised as follows
(1) the current plan in effect is dated 31 December 1986 and
should be revised every two years, (2) since only one person is
listed as the facility emergency contact, alternates should be
named, (3) members of the Business Emergency Action Team should be
named specifically, and (4) the Plan should detail evacuation
routes and locations of emergency response equipment on maps
• Formalized training of the Business Emergency Action Team should
be instigated to familiarize these individuals with personal
protection equipment, emergency response procedures, and to ensure
compliance with the worker protection standards listed in 29 CFR
Part 1910.120
• The alarms and intercoms between the administration office and rhe
cooling plant should be interconnected and tested periodically
• Eyewash stations and safety showers should be installed in close
proximity to chemicals
Community and Facility Emergency Response Planning Activities
• Nunes Cooling should, either directly through their trade
association or through their Chamber of Commerce, coordinate more
closely with the City of Salinas to ensure that copies of the MSDS
sheets for ammonia and other relevant chemicals are brought to the
attention of city officials and are effectively disseminated
throughout the fire department.
• SARA Title III compliance is incomplete. Two specific items need
to be addressed: (1) Section 312 chemical inventory forms (Tier
I) must be resubmitted annually to the SERC, LEPC, and the local
fire department with jurisdiction over the facility; and (2)
Section 302 notification must be made to the State and LEPC by
facilities that handle extremely hazardous substances (EHSs) in
excess of the threshold planning quantity (TPQ).
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• Nunes Cooling should expand its SARA Tide. Ill activities beyond
the scope of the response plan by. coordinating with the
community with regard to preparedness planning, and being
represented on the LEPC.
Public Alert and Notification Procedures
• Nunes Cooling should establish defined public notification and
alert procedures
Audit Team Member Composition:
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation:
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Richard Horner, Audit Team Leader
EPA Headquarters
N/A
Chemical engineering
Evelyn Wachtel, Deputy Team Leader
EPA - Region IX
N/A
N/A
William Blank, AARP
EPA - Region IX
N/A
Engineering and construction experience in
petro-chemical facilities and electrical
generating stations
Nancy Parson, Technical Assistance Team
Ecology and Environment
N/A
N/A
Follow-up Activities
By the Facility:
• N/A
By the Regional Office:
• N/A
By State and Local Authorities:
• N/A
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Regional Contact:
William Blank
233
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Eticam
Facility Location-
Fernley, NV, Region IX
Date(s) Audit Conducted:
August 16-17, 1989
Description of Facility
Location:
SIC Codes(s):
Products manufactured,
produced, or distributed:
Proximity to
sensitive populations:
The facility is located 30 miles ease of
Reno, NV and southeast of the town of
Fernley, NV.
SIC 495 - Sanitary services.
The company processes liquid and solid
hazardous and non-hazardous wastes to
reclaim the metal content.
The nearest buildings are industrial and
within 200 yards of the plant to the
southwest. The immediate area is flat,
desert ground Across the road and 500
yards to the east, a golf course was under
construction. Future plans included a
housing project that was to be built
around the golf course, but development
has not yet begun.
Reason for Facility Selection:
ARIP Reports:
During a Compliance Evaluation Inspection
conducted December 14-16, 1988, the Nevada
Division of Emergency Management noted
that Eticam logs showed a release of
nitrogen oxides on November 23, 1989. The
release occurred as a result of the
addition of too much reducing agent to a
waste mixture containing nitric acid.
Eticam reported a release of nitric oxide
and nitric dioxide, each greater than 10
pounds.
11/23/88 nitrogen dioxide release
(questionnaire completed 7/7/89) .
234
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Focus of Audit
Hazardous Substance(s)
Examined: Nitric oxide
Nitric dioxide
Physical Area(s) Examined at the Facility:
Storage and Handling
• Storage Systems
• Shipping/Receiving
• Material Transfer
A single 35,000 square foot building houses the offices, laboratory,
loading dock (truck bay), tank storage area, reactor room, dewacering
room, metal recovery room, scrubber system, and evaporator/crystallizer
of inorganic salts. The tank storage room contains 28 Polyethylene and
PVC tanks ranging in size from 12-24 ft high to 6-8 ft in diameter. The
tanks are connected by PVC piping to the truck bay Groups of tanks
containing the various waste classes are separated by 5-7 ft berms.
Crystallized mixed salt is stored in 55 gallon steel drums in the
exterior storage area. In another section of the exterior storage area
drums house metal-containing sludge awaiting shipment to the smelter
These drums are stored in an open, bermed, asphalted area draining to a
runoff collection sump. The drums are stacked two high on pallets,
sometimes with the second tier separated from the first with wood
There is an aisle between each row for inspection.
Delivery tanker trucks are required to enter the unloading bay once the
contents of the truck are cleared by the laboratory on-site. Unloading
is accomplished by gravity flow to storage tanks assigned to various
waste streams using 4 inch reinforced hose with cam lock connectors
The facility is permitted for bulk shipments ranging from tank truck
lots to individual drums of waste. The facility received 171,300
gallons of waste for treatment.
Process Area(s)
• Laboratory
• Reactor Room
• Dewatering Room
• Metal Recovery Room
• Crystallizer Area
Laboratory. The company has a laboratory for the analysis of metal
content of the various incoming wastes and for the precipitated products
they sell for smeltering. Samples of waste from delivery trucks are
analyzed to verify that the material conforms with the contract
235
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agreement in terms of the guaranteed metal content and solution
components
Reactor Room. The reactor room contains three 7,000 gallon tanks and a
control panel. The laboratory determines which processing chemicals
should be introduced into the waste stream. Chemicals are introduced
into the reactor tanks by hand or regulated by computer After the
reaction is complete, the material is transferred to a settling tank for
collection of precipitated metals.
Dewatering Room. The aqueous liquor from the settling tanks is
withdrawn and cleaned for either reuse or release. The precipitate is
then pressed free of most remaining liquid in filter presses. Ammonia
is sometimes released in detectible amounts during this process The
sludge from this process is sealed in 55 gallon steel drums for shipment
to smelters.
Metal Recovery Room. This room is mainly used for storage but there are
plans for additional processing steps.
Crystallizer Area. A portion of the product of the facility is
crystallized mixed salt. Treated effluent is evaporated to near dryness
and the salt content allowed to crystallize for potential use as a
fertilizer. A gas-fired steam plant that is housed in an outside truck
trailer is used for heating the effluent.
Summary of Audit Findings and Recommendations:
Conclusions:
Process Information
• The plant and surrounding grounds are fenced (chain link)
completely with two gates at the north front for access to tanker
trucks hauling the hazardous waste to be processed.
• The laboratory, truck bay, and reactor room are adjacent, allowing
for expeditious flow of material and personnel from area to area
• Material Safety Data Sheets (MSDS) records are duplicated and made
available to all employees in three different areas of the plant
• The company is changing processes to treat other forms of chemical
wastes, so their lists of hazardous substances may be outdated
• Materials are stored on the catwalks in the reactor room causing
obstructions.
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• Cyanide containing solutions are kepc separated from all other
solutions to avoid acidification which could result in an
uncontrolled release of HCN
• Both cyanide and acid solutions are present in che truck bay, and
hoses used to unload these materials from che trucks into storage
tanks are interchanged.
• No waste is unloaded into the facility storage tanks until cleared
by the laboratory
• Labelling for the laboratory samples for analysis did not provide
information for identifying the sample Past inspections by the
State of Nevada also identified this problem.
• During unloading of tanker trucks, a 4 inch reinforced hose is
used and the truck is rinsed
• In the draining of the truck tank, the hoses are raised over the
operators' heads in order to drain the entire contents into the
facility holding tank
• It was observed that rain water accumulated from the storm the
previous day was dripping into the tank storage area and the sump
beneath was filled with a green liquid.
• The loading dock in the metal recovery room has a number of gas
cylinders that did not have any support.
• The temperature in the reactor room is monitored by an operator
reading a visual gage. The gage has alarm contacts to alert
operators when the reactor design temperatures are being
approached.
Chemical Accident Prevention
• While the company encourages employee feedback regarding
operations, safety, and training, there appears to be no formal
mechanism for that feedback.
• The operating procedures regarding the chemical analysis in the
laboratory and the actual processing may have been the cause of
the NC^ release. The release occurred as a result of the addition
of too much reducing agent to a waste mixture.
Training of personnel is done by both experienced staff and hired
certified trainers. Training sessions have included waste
treatment procedures and associated hazards, protective clothing,
and respiratory protection methods.
Operator training has been improved, but there are no provisions
for refresher courses in operation, safety, or other training
237
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> Exhaust vents in the reactor room are equipped to detect releases
of HCN, H2S, and S02 at levels of at least 50 ppm. The
ventilation system automatically shuts down upon detection.
Detection of NOX is more difficult and has not yet been used at
the facility.
• The central emergency control panel in the laboratory has very
small identification labels that are not easily read.
• No hazards analysis or modeling for worst case scenarios have been
done by the company.
• A screening dispersion model is used to assess the potential
impact from reportable releases.
• An all-encompassing modelling study and risk assessment is in
progress under contract with the Desert Research Institute
• A process hazards evaluation committee and an in-plant Safety
Committee have been established at the facility, however, there
are no provisions in the facility contingency plan for hazard
analysis to be performed.
• The unloading dock in the truck bay is equipped with sloping
floors and spill collection areas.
• Tanks in the tank storage room are contained in a 20 foot,
concrete-lined, sunken room that is capable of holding the
contents of all the tanks should all rupture at once The floor
contained sealed sumps for collecting spills.
• In order to prevent the escape of NOX or other contaminants, the
ventilation system for the reactor room is shut down during a
release, allowing all the air in the room to be processed by the
scrubber system.
Facility Emergency Preparedness and Planning Activities
• Eticam's contingency plan is dated August of 1988, and includes a
May 1, 1989 amendment.
• Operators were observed wearing splash suits, boots, and hardhats
with face shields during the unloading of the trucks.
• Emergency communication within the plant occurs via telephone and
a loud speaker system.
• The eye-wash stations in the laboratory were hand-held and not
easily identified.
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• A new alarm system was installed in che spring of 1989 and it
employs cyanide and hydrogen sulfide dececcors When che siren
sounds all personnel are required co evacuate Co che "windward"
side of che building
• Alchough che company indicaced chac emergency exercises had been
held incernally and with local emergency people, che facilicy's
contingency plan makes no provisions for chese exercises.
• The concingency plan does noc incorporace a sice and floor plan co
identify existing hazards. Sensitive surrounding populacions are
also noc identified in che plan.
• Emergency equipment such as respiracors and SCBA are not cesced
regularly by the facility
Community and Facility Emergency Response Planning Accivicies
• The emergency concingency plan of che facilicy does noc indicace
how che company should inceracc with the public in the case of an
emergency.
• The facility has made no provision co coordinate wich che
community in responding to spills that may occur locally during
transport co the facility.
Public Alert and Notification Procedures
• In the case of a release, a signal is sent to an off-sice
monitoring company who in turn contacts local response agencies
and the facility personnel on call.
Recommendations:
Process Information
• An effort should be made by che facility to update chemical
inventories and MSDSs on a regular basis.
• Pre-printed and color-coded labels should be used in the
laboratory to better identify waste samples.
• Catwalks should be kept clear to improve safe mobility
• In the unloading of tanker trucks, operators should not have co
raise the drainage hose above their heads in order co completely
drain the truck. Hose connections could be lowered or the trucks
could be elevated.
239
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• AC this time, hoses used for che unloading of cyanide and acid
solutions are interchanged. It is recommended that a specific
hose be dedicated for each activity
• The temperature sensors in the reactor vessels should be updated
to include both audible and visual gauges. Only visual gauges are
employed at this time.
Chemical Accident Prevention
• The facility should institute a formal means of obtaining employee
feedback regarding operations, safety, and training
• Provisions should be made for refresher courses in the areas of
operations and general safety
• Considering the potential for major releases at the facility, some
form of hazard analysis or modeling for worst case scenarios
should be instituted by the facility.
• The labels on the central emergency control panel in the
laboratory should be enlarged so they can be easily read
• The facility should continue to research the availability of NOX
detectors for their release prevention system.
Facility Emergency Preparedness and Planning Activities
• The facility should incorporate regular emergency exercises into
their contingency plan.
• The emergency contingency plan should have a site and floor plan
to identify existing hazards.
• Operator training could be improved in the area of protective
equipment. More information on the use and care of the equipment
would be beneficial in order to prevent an accident.
• Regular testing of emergency and safety equipment should be
performed in order to ensure that the equipment is in proper
working order.
Community and Facility Emergency Response Planning Activities
• The company should consider working with the local emergency
responders in the community to establish an emergency response
plan to deal with spills which may occur during local transport of
waste materials. The facility has the expertise and materials
that would be necessary in neutralizing a spill.
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The emergency contingency plan of the facility should make
provisions for the facility to interact with the community in the
case of an accident
Audit Team Member Composition:
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Edward Snyder, Team Leader
U.S Environmental Protection Agency
Chemical hazards and processes
Environmental Specialist
William Davis, Lead Technical Reviewer
U.S. Environmental Protection Agency/AARP
Chemical hazards and processes
Biochemist with professional experience in
chemistry and toxicology
William Blank, Supporting Technical
Reviewer
U S. Environmental Protection Agency/AARP
Chemical processes and site assessment
Civil Engineering
Follow-up Activities:
By the Facility:
• The company plans to build stairs in the tank storage room for
safer access.
• The company is determining the need to incorporate NOX sensors in
their alarm system.
By the Regional Office:
• N/A
By State and Local Authorities:
• N/A
Regional Contact:
William Blank
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
All Pure Chemical Company
Facility Location:
Kalama, Washington, Region X
Date(s) Audit Conducted:
July 27, 1989
Description of Facility:
Location:
SIC Code(s)-
Products manufactured,
produced, or distributed:
Proximity to
sensitive populations:
1/2 mile northwest of Cicy of Kalama
SIC 2812 - Alkalies and chlorine
Bleach (Sodium Hypochlorite) for swimming
pools.
The plant is located within 1/2 mile of
the City of Kalama, population 1,223 Two
schools, police, fire, city hall, and
community center facilities are located
within the city The port of Kalama Mth
15 employees, lies directly to the souch
and is within 1 mile Directly across the
Columbia river to the west is the Trojan
Nuclear Plant at Rainier, Oregon
Reason for Facility Selection:
300 pounds of chlorine gas were released
at the facility on April 28, 1989. The
release was caused by an employee error
during a chlorine transfer process
Liquid chlorine was being transferred from
a railcar to a one ton tank when, due co
an employee opening a wrong valve, liquid
chlorine entered the bleach tank through
the one ton tank off-gas line resulting in
a chlorine gas release.
ARIP Reports:
None prior to audit
242
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Focus of Audit:
Hazardous Substance(s)
Examined: Chlorine
Sodium Hypochlorite
Sodium Hydroxide
Physical Area(s) Examined at the Facility:
Storage and Handling
• Storage Systems
• Shipping/Receiving
The concentrated sodium hydroxide (caustic soda) is stored in an above-
ground 10,000 gallon mild steel tank located outside at the north end of
the All Pure building The dilute caustic soda is stored in the same
vessels in which it is diluted
Chlorine is shipped into the facility by railcars and occasionally by
truck The chlorine is transported directly from the railcars to ton-
tanks
Process Area(s)
To produce bleach, the caustic soda is diluted from 50 to 14 percent and
then reacted with chlorine to produce sodium hypochlorite (bleach),
sodium chloride, and water Both the caustic soda dilution and bleach
production reactions are exothermic and unstable
The reaction takes place in an open-top stirred tank reactor located
inside the All Pure building The 50 percent caustic soda is diluted in
three other similar tanks The reactor is filled with dilute caustic
soda and chlorine at a rate controlled by the operator, until the
temperature within the reactor reaches 80-84 degrees fahrenheit.
Summary of Audit Findings and Recommendations:
Conclusions:
Process Information
• The process design lacked process diagrams and associated design
calculations such as mass balance and heat exchanger sizing
calculations
• There was no process control instrumentation, reactors of similar
size had varying heat exchange capacities, and the piping was made
out of mild steel schedule 40
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• After the April 1989 release, a valve was installed in the liquid
chlorine feed line from the railcars to the reactors The valve
is actuated by a relay connected to reactor temperature
indicators Other reactor feed lines (i.e., caustic soda, "gas-
off" lines from the cylinder and ton-tank filling areas) were noc
integrated into the system.
Chemical Accident Prevention
• All Pure has an informal policy that all process vessels be
emptied and visually inspected once a year. There is no policy
regarding routine inspection or preventative maintenance.
• Employees perform most process modifications such as design,
fabrication, and installment, unless there is a considerable
expense associated with the proposed modifications. Modifications
costing in excess of $300 (approximately) are authorized by
headquarters
• The safety officer conducts monthly safety/accident prevention
meetings mandatory for all employees. The meetings provide safety
information provided by corporate headquarters, contents of
release or near miss reports, and general information gathered by
the safety officer No agenda for these meetings was provided in
the packet of training documents
• A review of records disclosed training records for only 19 of 51
employees; no records documented safety or accident prevention
training of management, supervisory or clerical staff. While the
available materials document training for specific areas related
to chemical processes, it did not cover training in first aid,
accident prevention, or OSHA-WISHA [Washington Industrial Safety
and Health Administration] regulations
• All Pure conducts a hazard evaluation on an annual basis. The
evaluation is limited in scope to a safety review and audit of the
previous twelve month period. While no area is specifically
targeted, corporate headquarters does indicate areas of special
interest to be addressed by the hazard evaluation. The evaluation
is conducted by the safety officer and the engineering officer
They do noc have any documented expertise in the evaluation field
but have many years of experience. All Pure documents and
forwards the result of the hazard evaluation to corporate
headquarters for remedial action where necessary.
Accidental Release Incident Investigation
• Accidental releases and near misses are reported to the corporate
safety officer. These reports are then reviewed by corporate
headquarters which sometimes sends recommendations back to the
facility. The reports are also discussed at the monthly safety
meeting.
244
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• Investigation of releases and near misses is conducted by the All
Pure Manager or the Assistant Manager and the Supervisor on duty
at the time of the incident.
Facility Emergency Preparedness and Planning Activities
• All Pure Chemical Company upgraded its contingency, preparedness
and prevention plan in May 1989 The entire plan is not made
available to employees. As employees advance through different
segments of training, or are assigned as responders, they are
acquainted with those segments pertinent to their new area of
responsibility. The plan was compiled by combining sections from
other facilities' contingency, preparedness and prevention plans
The auditors found that it lacks cohesiveness, and is consequently
difficult to comprehend
• The facility maintains an in-house alarm system to warn employees
when an emergency occurs The facility relies upon the 911 system
and local emergency responders for off-site notification All
Pure does not maintain a horn or other audible alarm system within
the city, but it does maintain the current phone numbers of the
schools and the Chamber of Commerce
Community and Facility Emergency Response Planning Activities
• The plant is active in the local CAER group and participates in a
yearly training exercise with the first responders group from the
immediate area. Kalama Police and Fire, and other interested
neighboring companies Although records show that All Pure '.-as an
active participant in the LEPC, it was not represented during
1988 According to management, All Pure was not notified of the
1988 meetings
Recommendations:
Process Information
• Management should ensure that process diagrams and associated
design calculations are accessible. This measure would ensure a
ready source available for reference for the maintenance
personnel.
• The facility should standardize the heat exchange capacities of
reactors of similar size and install process control
instrumentation.
• The facility should integrate all reactor feed lines such as the
caustic soda lines from the cylinder and the one ton tank within
the temperature indicators This measure would alert operators to
the cause of rhe malfunction in case the reactor overheats
245
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• The facility should assess che compatibility of the construction
materials and process conditions Mild steel schedule 40 may be
corroded by chlorine byproducts
• The facility should develop an inspection and maintenance program
Such a program would reduce the likelihood of releases caused by
worn out equipment.
• Management should provide professional hazard analysis training to
those charged with that responsibility. The facility should also
engage an outside professional agency to conduct hazard analysis
on a 3 year schedule.
• Ongoing training for all employees should be conducted through a
series of standard operating procedures and checklists specific co
each employee's assignment.
• All Pure should obtain a hazard evaluation process using industry
established and accepted methodologies and techniques from the
Chemical Manufacturers Association. The corporate safety officer,
utilizing accepted industry procedures, could then perform a more
comprehensive hazard analysis.
Facility Emergency Preparedness and Planning Activities
• The contingency, preparedness, and prevention plan should be
reviewed and rewritten with more emphasis toward those persons who
are going to have to read, understand, and place into operation
its mandates. An employee or a professional industrial writer
should prepare a draft which the response employees can exercise
to evaluate its effectiveness as a planning and response tool A
copy of the plan should be made available and reviewed with all
new hires.
Community and Facility Emergency Response Planning Activities
• Management should ensure that it is represented on the LEPC and
that it is notified of all meetings.
Audit Team Member Composition:
Name and Title Patrick Lowery
Affiliation EPA - Region X
Area of Responsibility Team Leader
Expertise Business Administration
Name and Title Gordon Goff
Affiliation EPA - Region X
Area of Responsibility Emergency Planning
Expertise Emergency Planning
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Name and Title Tom Ashley, Technical Assistance Team
Affiliation Ecology & Environment
Area of Responsibility Process Safety and Release Mitigation
Preparedness
Expertise Chemical Engineering
Name and Title Rick Spangenberg, LEPC
Affiliation Cowlitz County
Area of Responsibility Observer
Expertise Engineering
Follow-up Activities:
By the Facility:
• N/A
By the Regional Office:
N/A
By State and Local Authorities:
• N/A
Regional Contact:
Patrick J Lowery, EPA, Region X
(206) 442-4349
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CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Facility Location:
McWhorcer, Inc.
Portland, Oregon, Region X
Date(s) Audit Conducted.
September 12-15, 1989
Description of Facility:
Location:
SIC Code(s):
Products manufactured,
produced, or distributed:
Proximity to
sensitive populations:
Northwest industrial area of the City of
Portland, approximately 2 miles north o£
the Downtown/Municipal areas
SIC 2821 - Plastics materials, synthetic
resins, and non-vulcanizable
elastomers.
SIC 2851 - Paints, varnishes, lacquers.
enamels, and allied products.
20 million pounds of water and oil-based
resins annually, also alkyd, polyester.
copolymer, latex, acrylic solution
varnish and blended products.
The facility is close to both residential
and commercial areas. It is located 2
miles from downtown Portland. The site is
near groundwater and the sewer system.
Reason for Facility Selection:
A release occurred on July 2, 1986, of 400
to 500 gallons of partially polymerized
resin containing hazardous materials.
Some of the resin entered public waters.
Gaseous components formed a "vapor cloud"
which spread extensively into industrial
and residential areas of Portland. The
spill required a fire department response
and an extensive cleanup of the storm
sewer. Several local residents developed
eye irritation, dizziness, and respiratory
disorders and the Oregon Department of
Environmental Quality received
approximately 600 odor complaints.
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ARIP Reports: None prior co audic
Focus of Audit
Hazardous Substance(s)
Examined: Ethyl Acrylate
Maleic Anhydride
Physical Area(s) Examined at the Facility.
Storage and Handling
• Storage Systems
• Shipping/Receiving
Raw materials such as alcohol and glycol, as well as dirty solvents and
waste products are stored in drums. The majority of the liquid-
containing drums are stored outdoors throughout the facility This
system is designed to maximize space between drums and helps prevent the
formation of an ignitable atmosphere or a severe fire inside a building
Liquid raw materials are stored in underground storage tanks (USTs) ,
above-ground storage tanks, and drums. The USTs contain the plant's
styrene monomer and solvents such as xylene and toluene.
Organic peroxides, used as catalysts, are stored in a specially designed
concrete building located at the south end of the property,
approximately 100 feet from the reactor building. The peroxides are
stored in the dark on concrete benches and the building is kept cool by
spraying water onto the tin roof.
Indoor tanks are used as temporary storage in the manufacturing process
Hot liquids from the Y- and the Z-kettles are routed to tanks in the
reactor building where they are allowed to cool. These tanks are purged
with nitrogen to prevent the ignition of vapors generated by the hot
liquids. Once the liquids have cooled sufficiently, they are routed to
thinning tanks where the viscosity is adjusted by the addition of
appropriate solvents. The thinning tanks are located in a covered area
between the reactor building and the stack room. From the thinning
tanks, the finished product is transferred to its final storage
destination.
Manufactured products are stored in tanks arranged in two bermed tank
farms The tanks are warmed by steam, agitated and insulated to reduce
viscosity, and equipped with highly visible level indicators.
Hazardous materials are unloaded from tank trucks. Unloading of tank
cars takes place on the rail siding just outside of the north end of the
facility.
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Process Areafs^
Alkalyde, polyester, copolymer, latex, acrylic solution, varnish and
blended products are made at the site. Oil base products are made using
endothermic reactions in a 3,000-gallon direct fired reactor called the
Y-kettle and the stack area consisting of 3 stalls for small ^00- and
500-gallon kettles. The water based products such as acrylic resins and
latexes, are produced as a result of exothermic reactions in a 2,000-
gallon reactor called the Z-kettle.
Two thinning tanks are connected to the reactors to allow for blending
and solvent dilution of resins manufactured in the Y- and Z-kettles
The Y- and Z-kettles as well as the thinning tanks are equipped with
rupture disks which are designed to fail if the pressure is above a
certain limit Three additional thinning tanks serve the portable
kettles. Typically, only products from the Y-kettle and stack kettles
are routed to the thinning tanks.
A gas-fired furnace is located directly beneath the Y-kettle to provide
the necessary heat for the endothermic reactions. The Y-kettle is
capable of being vented to the atmosphere, either directly from the
reflux condenser, or through a venturi scrubber. Vapors from the
reactor charging operations may be directed to an afterburner The
afterburner combusts vapors collected from the dome of the reactor and
directs combustion gases to the combustion air intake of the furnace
The destruction efficiency of volatile organic carbon is approximately
98%
The venturi scrubber is a two-stage, recirculating alkaline liquor
system which is effective in removing acids, anhydrides, acrylates,
aldehydes, and other base soluble materials. Scrubber efficiency for
these compounds is estimated at 90%. The scrubber also removes small
quantities of toluene and xylene, provided the scrubber liquid has not
become saturated with these materials.
\
Summary of Audit Findings and Recommendations:
Conclusions:
Process Information
• Leaky valves and pipes, standing liquids, unmarked drums, various
types of debris, and general disorder were present throughout the
facility.
• The top of a drum storage area is within several feet of the
pipelines which transport flammable liquids between the
underground storage tanks within the plant. .
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Chemical Accident Prevention
. Covered storage areas, including the indoor storage areas, do not
have necessary secondary containment such as raised doorways,
berms, or drainage systems. These areas include the thinning
area, tank #80, the shipping room, and the boiler room. No
containment mechanisms were available in the stack room Liquids
spilled in these storage areas could pose a significant hazard
even if they are eventually trapped by the facility's drainage
system. Without berms, spilled liquids could spread over a wide
area and could contact an ignition source or an incompatible
material.
• There are few alarms associated with the kettles which would alert
operators, especially those out of the reactor room, of an
impending air release If vapors do exit a kettle via a rupture
disk, downstream equipment will not adequately control an air
release. Rupture disk catch tanks for the Y- and Z-kettles are
vented directly to the atmosphere and rupture disk lines from the
thinning tanks are directed to the roof
• There is no preventative maintenance schedule or calibration
program established for instrumentation. Many of the gauges on
the Y-kettle were covered with grime and extremely difficult to
read. The nitrogen flow meter to the Y-kettle catch tank was also
very difficult to read and was not operational at the time of the
audit.
• While the standard operating procedures (SOP) for the Y-Kettle
were made available to the audit team, it was apparent that
written SOPs for many of the other processes were not available or
non-existent.
• Following the spill in 1986, the company has installed a new storm
drainage system. Over 99 percent of the facility was paved with
concrete in a manner that controlled the flow of liquid wastes
inward from the facility's boundaries and towards the storm water
drains. A culvert routed these wastes to a spill containment
system, equipped with baffle-type oil/water separators.
• Although he had not been notified of his assignment as the plant
training manager, the plant supervisor had taken the initiative co
assemble a training program. A review of training records
disclosed that no scheduled training has taken place since early
1988. This may be due to a transitional phase in the delegation
of responsibility caused by the recent acquisition of the plant by
the Valspar Corporation.
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Accidental Release Incident Investigation
• At present, there are no written procedures for the investigation
of accidents, incidents, accidental releases or near misses
Actual releases are investigated by the plant manager and/or
Supervisor, near misses are not. Within this framework a small,
non-injury, non-reportable release could be passed over with
little or no investigation of follow-up even though it had the
potential for a major disaster.
Facility Emergency Preparedness and Planning Activities:
• The McWhorter emergency response plan appears to address most
contingencies. The McWhorter facility has adopted the Valspar
Corporation's Safety Policies and Procedures Guide and is in the
process of making it site specific to the Portland operation. The
standard corporate safety guide contains 10 chapters which
include
Statement of Safety Policy
Corporate Safety Program Requirements
Corporate Safety Measures .
Written Program Requirements
Written Program Procedures
Employee Training and Testing
Occupational Health Programs
Reporting Requirements
Engineering Practices.
• The facility has a monitored electronic security system providing
both fire and intrusion coverage. It is monitored by an off-site
vendor, ADT Alarm Co., on a 24-hour, 7-day basis. Coverage
afforded by this system is limited to the office/laboratory area
A chain link fence with a razor wire top guard provides perimeter
security. It was mentioned while on site, the fence is a
potential threat to worker safety when workers are stacking
products along the fence line. Some thought has been given to the
removal of the razor wire in the areas where the pallets are
stacked.
Community and Facility Emergency Response Planning Activities
• The facility has not undertaken simulation releases to test
company and local emergency preparedness capabilities.
• McWhorter has several sets of on-site plans to work from should a
disaster occur. Unfortunately, there are no off-site emergency
plans for the surrounding communities immediately available should
the release leave the site through airborne or waterborne
channels. There are no schematics displaying waste and water
conduits leaving the facility available for reference.
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Recommendations:
Facility Background Information
• Due to the limited coverage of the electronic security system and
to the facility's past history of intrusions, management should
request a physical security survey by a private security firm or
the Portland Police Bureau. Removal of the razor wire, while
reducing worker apprehension, will increase site vulnerability to
the criminal or disgruntled employee type intruder. Management
should consider installing an different type of perimeter
security.
Process Information
• A facility wide clean-up and maintenance upgrade should be
undertaken, particularly for monitoring instruments
• Covered and indoor storage areas such as the thinning area, the
shipping room, and the boiler room should be equipped with
secondary containment mechanisms.
• The facility should examine the feasibility of modifying plant
operations to allow for additional spacing between stored
chemicals in order to comply with NFPA codes.
• Vent gases should be routed from the rupture disk catch tank
through a scrubber system before being discharged to the
atmosphere.
Chemical Accident Prevention
• The facility should have SOPs for all processes, not just for the
Y-kettle. They should be available at all times for reference by
both managers and employees.
Accidental Release Incident Investigation
• The facility should investigate and maintain records of accidents,
incidents, accidental releases and near misses. Maintaining
records of near misses may allow for the early detection of a
potential safety hazard before a release occurs.
Facility Emergency Preparedness and Planning Activities
• The emergency response plan should be reviewed. The facility
should consider having maps available, detailing the adjacent
communities. It should have schematics displaying underground
manmade and natural water conduits, out to 1 mile from McWhortev.
for local emergency planners and responders.
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Community and Faci.li.cy Emergency Response Planning Activities
• Emergency drills and exercises should be scheduled within the next
six months to test knowledge, understanding, and implementation of
emergency control procedures. It is recommended that drills be
held no less than once per year and that the public officials and
organizations involved in the emergency response be invited to
participate.
• The facility should initiate an evaluation of communication
capability and needs. It should also designate an on- site media
manager equipped with the knowledge and expertise to handle all
local media concerns.
• The facility should conduct a simulation exercise of a release.
This type of exercise could be besc handled through a cooperative
effort with the local LEPC or CAER members
Public Alert and Notification Procedures
• McWhorter, Inc. should work through the local CAER group towards
devising and implementing a local alarm system that would provide
some form of notification to the neighborhood should a release
occur. A release of major magnitude, involving a large segment of
the city, should be handled through the LEPC.
Audit Team Member Composition:
Name and Title Gordon Goff
Affiliation EPA - Region X
Area of Responsibility Team Leader
Expertise Emergency Planning
Name and Title Pat Lowery
Affiliation EPA - Region X
Area of Responsibility Emergency Preparedness and Safety Training
Expertise
Name and Title John Davis, AARP
Affiliation EPA - Region X
Area of Responsibility Chemical Processes
Expertise Compliance Inspector
Name and Title Tom Ashley, TAT
Affiliation Environment & Ecology
Area of Responsibility Process Operations
Expertise Chemical Engineer
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Name and Ticle Noah Myers, TAT
Affiliacion Environment & Ecology
Area of Responsibility Process Safety
Expertise Chemical Engineering
Name and Title Dennis Walthall
Affiliation Oregon Fire Marshall
Area of Responsibility Observer
Expertise Chemical Industrial Hygiene
Name and Title Bob Albers
Affiliation Oregon Fire Marshall
Area of Responsibility Observer
Expertise Occupational Safety
Follow-up Activities:
By the Facility:
• N/A
By the Regional Office:
• N/A
By State and Local Authorities:
N/A
Regional Contact:
Patrick J Lowery
(206) 442-4349
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