United States Office of Solid Waste May 1987
Environmental Protection and Emergency Response
Agency Washington DC 20460
" ——— . T '¦ —'
v>EPA Review of Interim
Emergency Report
Systems
Report to Congress
Section 305(b) Title III
Superfund Amendments
and Reauthorization Act of
1986
-------
EXECUTIVE SUMMARY
The U. S. Environmental Protection Agency (EPA) is submitting this interim
report to Congress in fulfillment of a requirement in Section 305(b) of Title
III of the Superfund Amendments and Reauthorization Act of 1986 (SARA).
Section 305(b) calls upon EPA to conduct a "review of emergency systems
for monitoring, detecting, and preventing releases of extremely hazardous
substances at representative domestic facilities that produce, use, or store"
these substances. The review is to yield findings regarding the status of
current technological capabilities not only to monitor, detect, and prevent
accidental releases, but also to provide timely alert to the public when
releases of extremely hazardous substances occur. Recommendations are
required on initiatives to support the development of new or improved
technologies or systems for monitoring, detecting, preventing, and providing
public alert of accidental releases. EPA's final report is to be submitted by
April 17, 1988.
This interim report to Congress, required under Section 305(b), first
explains the scope and approach of EPA's review of emergency systems and the
present status of the review. It then provides a preliminary overview, based
largely on previous research and studies, of the state of the art in available
technologies to monitor, detect, prevent, and provide public alert of
accidental releases. The following is a summary of this report's discussions
in these areas.
Review Approach and Status
EPA is conducting the Section 305(b) review of emergency systems by the
following steps:
• An examination of documentation on previous studies and
research to identify the state of the art in available
technologies.
• The selection of 20 chemicals from the SARA Section
302(a) list of "extremely hazardous substances" on which to
focus the review.
• A survey, using a written questionnaire, of a sample of
representative domestic facilities handling these chemicals
for two purposes: (1) to gather additional data on
available technologies and techniques; and (2) to determine
which technologies, operating procedures, and management
practices are being used, and why
• First-hand investigations by trained inspectors of a
limited number of the surveyed facilities to obtain
in-depth information on the technologies and practices
being used domestically, as well as to corroborate the
survey responses.
-------
At present, the examination of documentation on emergency systems is well
underway; preliminary findings are presented in this interim report. EPA has
selected 20 chemicals from the list of extremely hazardous substances and has
begun the process of identifying representative domestic facilities from which
to gather data. Consultations, to continue throughout the project, have been
initiated with states, industry, professional and trade associations, and
environmental interest groups to help steer the review. The survey of
selected facilities is scheduled to be conducted in July and August 1987,
followed by facility investigations in October and November 1987, enabling the
final report to be submitted to Congress by the April 17, 1988, statutory
deadline.
EPA is focusing its review on emergency systems directed towards sudden,
unanticipated, accidental releases -- the types of releases that can be
considered chemical emergencies -- rather than routine emissions to the
environment. Similarly, the review is focused on releases of significant
quantities of acutely toxic chemicals, i e., chemicals that can cause
significant adverse effects on human health and the environment with exposure
of brief duration. Releases to all environmental media are being addressed,
but the emphasis is on releases to air because of their potential severity and
immediacy. Section 305(b) calls for a review of technologies and devices for
monitoring, detecting, preventing, and providing public alert of accidental
releases. EPA considers proper operating procedures and management practices
to be essential to the effectiveness of technology and equipment in this
area. Moie broadly, EPA regards a management commitment to safety to be the
underpinning of any effective effort to prevent accidental chemical releases
Overview of Available Emergency Systems
The interim report to Congress presents separate overviews of technologies
and systems for (a) detection and monitoring, (b) prevention, and (c) public
alert.
Detection and monitoring systems. Operator observation appears to be the
principal method now used to detect leaks or catastrophic releases from
process equipment and storage areas Instrumentation in various
configurations may supplement observation, providing continuous surveillance
of a facility Detection instruments may be sensitive either to a specific
chemical compound or to a range of compounds defined by certain parameters.
Basically the same technologies are used to detect releases in process areas
and to monitor releases at the facility fence-line or perimeter before they can
enter the surrounding community. Some monitoring technologies, however, may
be portable or housed in a mobile van.
Prevention systems EPA understands "prevention systems" to include not
only any technology or procedure intended to prevent the loss of a chemical
from containment in the system m which it is manufactured, processed, used,
or stored, but also any technologies or procedures used to mitigate the spread
of a released chemical after it has escaped primary containment. There are a
variety of recognized analytical techniques to identify series of events that
could result in accidental releases. Technologies that can reduce the
-------
probability of the occurrence of such events, and resultant losses of primary
containment, may either be integral to the design and layout of a chemical
process line, or they may be added to technologies already m place. Examples
of the latter include back-up valves and control devices to measure
flow,pressure, temperature, and concentration. When upset conditions do
occur, flares, adsorbers, holding ponds, and similar technologies can be used
to contain, destroy, reduce the quantity of a chemical, or reduce its
potential hazards, before containment is lost. Barriers and vapor suppressant
foams are among the technologies available to mitigate the spread of a
released chemical before it can escape the facility perimeter.
Public alert systems. The Section 305(b) review is focusing on public
alert systems that can warn the surrounding community of an accidental release
at a facility, not just those to warn workers at the facility. All possible
communications links between a facility and the local community are being
taken into account. The purpose of a public alert and notification system is
not only to warn the community of an emergency,
-------
CONTENTS
Page
EXECUTIVE SUMMARY
1. INTRODUCTION 1
1.1 SARA Title III: Background 1
1 2 The Statutory Requirement for a Review of Emergency Systems ... 2
1.3 Organization of this Report .... 2
2. APPROACH AND STATUS 4
2.1 Scope 4
2.2 Goals 6
2.3 Overview of Approach and Status 7
2.<+ Selection of Representative Chemicals 8
2.5 Facility Selection 9
2.6 Data Acquisition 12
2.7 Schedule 13
3. OVERVIEW OF EMERGENCY SYSTEMS 14
3.1 Detection and Monitoring Systems 14
3.2 Prevention Systems 18
3.3 Public Alert Systems 26
Appendices
Glossary of Technical Terms
SARA Section 302(a) Extremely Hazardous Substances
-------
1. INTRODUCTION
This report presents the interim findings of the U S. Environmental
Protection Agency's (EPA) review of emergency systems for monitoring,
detecting, preventing, and alerting the public of releases to the environment
of extremely hazardous substances. EPA is submitting this report to Congress
in fulfillment of a requirement of Section 305(b) in Title III of the
Superfund Amendments and Reauthorization Act of 1986 (SARA). In this
introductory chapter, we explain briefly the purpose of SARA Title III,
summarize the specific requirements of Section 305(b), and describe the
organization of this report.
1.1 SARA TITLE III: BACKGROUND
Title III of SARA is entitled the "Emergency Planning and Community
Right-to-Know Act of 1986". The emergency planning provisions of Title III
require communities to prepare for the possibility of accidents at facilities
handling extremely hazardous substances. The "community right-to-know"
provisions require industry to share information with communities about toxic
chemicals present at a local facility. One of the driving factors behind this
legislation was a succession of disastrous accidents at chemical facilities.
The accidental release of methyl isocyanate m 1984 from a chemical plant
in Bhopal, India, created i cloud of toxic vapors that spread throughout the
surrounding community, leaving over 2,000 persons dead. This tragedy created
worldwide concern about the potential for accidents of similar magnitude
elsewhere. In the United States, the concern was intensified when a major
release of aldicarb oxime occurred not long afterwards from a chemical
facility in Institute, West Virginia, fortunately without loss of life These
incidents clearly demonstrated the potential for disaster as result of an
accidental release of chemicals that have become a part of modern life; they
also brought attention to the fact that releases of chemicals from the
facilities where they are manufactured, processed, used, or stored not only
can occur, but do occur commonly, even in this country.
The result was a new urgency in efforts to establish national programs to
address chemical emergencies The Administrator of EPA committed the Agency
to the prompt development of a program to foster planning and preparation
within communities for serious releases of extremely hazardous substances from
local chemical facilities. The result, EPA's Chemical Emergency Preparedness
Program, was launched nationally in November 1985. By October 1986, the local
planning encouraged on a voluntary basis by the Chemical Emergency
Preparedness Program was made mandatory by Congressional enactment of Title
III. To assist preparedness for chemical emergencies, and to enable
communities to recognize the potential hazards associated with local chemical
production or use, Congress included in Title III requirements for facilities
to report regularly the presence of hazardous chemicals on site, as well as
emissions of such chemicals to any environmental medium.
-------
1.2 THE STATUTORY REQUIREMENT FOR A REVIEW OF EMERGENCY SYSTEMS
Included as Section 305(b) of SARA is the requirement that EPA conduct a
"review of emergency systems for monitoring, detecting, and preventing
releases of extremely hazardous substances at representative domestic
facilities that produce, use, or store extremely hazardous substances." EPA
is required to report its interim findings to Congress by May 17, 1987, and to
issue a final report of findings and recommendations by April 17, 1988. This
document is the interim report to Congress required by Section 305(b).
Section 305(b) specifies that the report based on this review should
include findings regarding not only the status of current technological
capabilities to monitor, detect, and prevent releases, but also the status of
public emergency alert devices or systems for providing timely and effective
public warning of an accidental release. In addition, the technical and
economic feasibility of perimeter alert systems for detecting releases at
facilities must be addressed. Recommendations are required on (a) initiatives
to support the development of new or improved technologies or systems to
facilitate the monitoring, detection, and prevention of releases, as well as
(b) improving devices or systems for alerting the public in the event of an
accidental release.
The statutory requirement for this review acknowledges that the
prevention, monitoring, and detection of accidental releases must rely on the
technologies in place at facilities that produce, use, or store extremely
hazardous substances. It also suggests that the public may be alerted more
promptly and effectively when a release occurs if adequate public alert
devices or systems are installed. As explained in this report, EPA considers
management support and proper management practices essential for such
technologies to operate effectively. By providing information about current
technological capabilities at domestic facilities for preventing releases and
providing public alert, and about the ways in which these technological
capabilities are employed, this review serves as an important adjunct to the
emergency planning provisions of Title III
1.3 ORGANIZATION OF THIS REPORT
Following this introductory chapter, this report contains two chapters.
• Chapter 2: Approach and Status is a discussion of the
approach being taken to conduct the Section 305(b) review
and its present status. It describes the scope and goals
of the review, then discusses in some detail the procedures
EPA is following to select chemicals and domestic
facilities for study. It also explains the procedures
being used to collect information and the types of
information sought. This chapter concludes with a schedule
for completion of the review.
-------
-3-
• Chapter 3: Overview of Emergency Systems is an overview
of available and emerging technologies for monitoring,
detecting, preventing, and alerting the public to
accidental releases of extremely hazardous substances. The
information presented is preliminary and derived largely
from ongoing EPA reviews as well as related past studies,
symposia, and industry research.
A glossary defining the technical terms used in this report, and the list of
"extremely hazardous substances" under SARA Section 302(a), are provided as
appendices.
-------
-4-
2. APPROACH AND STATUS
This chapter explains the approach being taken to conduct the
Section 305(b) review of emergency systems and describes the present status of
the review. It begins with a discussion of the scope and goals of the
review. On this basis, it explains the general methods being used to collect
and analyze data and the progress of the review to date. Special attention is
then given to three aspects of the approach. (1) the selection of a limited
number of extremely hazardous substances as the focus of the review; (2) the
selection, for detailed investigation, of representative domestic facilities
handling these substances; and (3) the acquisition of data from those
facilities. The chapter concludes with a schedule for completing the review,
developing recommendations based on its findings, and preparing the final
report to Congress.
2.1 SCOPE
In defining the scope of its review of emergency systems, EPA has taken
care to address the full range of issues specified in SARA Section 305(b) and
to provide a sound basis for developing recommendations m the required
areas. At the same time, EPA has focused the review so that research on any
issue will be sufficiently thorough and detailed to yield informative findings.
Section 305(b) requires EPA to review emergency systems for monitoring,
detecting, and preventing releases of extremely hazardous substances.
"Extremely hazardous substances" are the specific chemicals on the list
referred to in SARA Section 302(a) and published in the Federal Register on
November 17, 1986 (51 FR 41570, as revised on April 22, 1987, 52 FR 13378).
The list, which can be revised, currently includes over 400 chemicals; it is
included in this report as an appendix.
In this report, the term "detection systems" refers primarily to
technologies for detecting leaks or catastrophic releases from process
equipment and storage areas. Basically the same technologies and techniques,
however, are used for detecting releases at the facility fenceline or
perimeter The term "monitoring systems" refers to the methodologies and
instrumentation used to perform sampling and analyses in a community
potentially affected by a release to determine whether, and to what extent,
the released chemical is present in the environment.
The term "prevention systems" refers broadly to any technology or
management practice that aids in preventing extremely hazardous substances
from entering the environment. Thus, prevention systems include not only
technologies or procedures that prevent the loss of a chemical from
containment in the system in which it is manufactured, processed, used, or
stored, but also any technologies or procedures that can be used to mitigate
the adverse effects of a loss of containment on human health or the
environment. Accordingly, the "prevention systems" EPA is reviewing include
hazard evaluation techniques, control and back-up systems in chemical
processes, and techniques for minimizing the dispersion or spread of a release
beyond facility boundaries
-------
-5-
The statute also requires a review of the status of public alert devices
or systems, which is understood to include any automatic technology or
communications links to warn adjacent communities of a significant release.
Section 305(b) states that "The Administrator [of EPA] may select
representative extremely hazardous substances from the substances on the list
referred to in section 302(a) [of SARA] for the purposes of this review." EPA
has chosen to focus the study on 20 listed chemicals selected as
representative not only of the full list of extremely hazardous substances,
but also of the types of chemicals most likely to be involved in significant
releases endangering human health and the environment. Section 2.3 of this
chapter describes the method by which EPA selected these chemicals.
EPA is focusing this review on sudden, unanticipated, accidental releases
-- the types of releases that can be considered emergencies -- rather than
routine emissions to the environment. Similarly, the review is focused on
releases that involve significant quantities of acutely toxic chemicals,
rather than chronically toxic chemicals. Chemicals are listed as "extremely
hazardous substances" under Section 302(a) because of their acute toxicity,
that is, their ability to cause significant adverse effects on human health
with brief exposure. The emergency systems on which this review focuses are
those able to monitor, detect, or prevent releases that could cause effects
from short-term exposures, rather than :hose systems intended primarily for
routine or low-level releases that would endanger human health and the
environment only over an extended period.
EPA is concentrating part of its investigation on a limited number of
facilities that produce, use, or store the 20 extremely hazardous substances
that have been selected. Only facilities handling one or more of these
20 substances will be investigated. These facilities and chemicals are
expected to represent the full range of emergency systems and hazards
associated with the handling of extremely hazardous substances. The
considerations that will be used to select facilities, and the methods by
which information on these facilities will be obtained, are described below.
The review will consider the prevention of releases to any environmental
medium -- air, land, surface water, ground water -- but the emphasis will be
on releases to air, which present the greatest potential for immediate and
widespread harm to human health and the environment. The release of a liquid
chemical at Bhopal, for example, quickly volatilized into a toxic cloud that
was blown into the surrounding community Because of their potential
severity, releases to air have been at the center of recent research on
chemical emergencies
With respect to public alert systems, EPA is concentrating on systems to
warn adjacent communities of an accidental release, rather than systems just
to alert workers within the facility's perimeter. The timely alert of the
local community to an accidental release, which can significantly minimize the
harm caused by the release, is a critical factor in the emergency planning and
preparedness activities mandated by Title III.
-------
-6-
One final aspect of the scope defined for this review deserves emphasis.
EPA considers management practices and operating procedures to be integral
components of the emergency systems and technological capabilities this review
is required to assess. The commitment of corporate and facility managers to
accident prevention is, in fact, the underpinning of effective accident
prevention. The installation of the most advanced technologies is an
ineffectual safeguard against accidents unless those technologies are properly
operated and maintained in a workplace where safety is explicitly valued.
Accordingly, this review is addressing management practices, operating
procedures, and human resources.
2.2 GOALS
The general goals of this review can be stated as a series of questions
that reflect the scope defined for this review (as explained above), the areas
in which findings must be obtained (as specified in Section 305(b)), and the
recommendations that must be based on these findings.
(1) What technologies are currently being used to monitor, detect,
prevent, and alert the public to accidental releases, and why? The review
will approach this question first by identifying the state of the art in
available and emerging technologies for monitoring, detecting, preventing, and
alerting the public to accidental releases. It will then determine the extent
to which these technologies are currently being used by industry, and the
reasons why industry has chosen to use certain technologies in certain
circumstances. The review will also address the effectiveness of the
technologies that are currently being used.
(2) What procedures are currently being used to monitor, detect, prevent,
and alert the public to accidental releases, and why? Such procedures include
operating procedures for technologies, analytical techniques for chemical
processes and chemical releases, and standards for chemical operations. What
procedures are available to be followed, and what is the state of the art in
this area? What procedures are currently being followed by industry, and in
which circumstances are specific procedures being used? Why are these
procedures being followed? How effective are they?
(3) What management practices are being used, and why? Where within an
organization are prevention and safety decisions made? These questions
require attention not only to the decision-making procedures used within
facilities and the level of resources dedicated to accident prevention, but
also to the management philosophy that pervades the operations of a facility
or an entire corporation.
(4) What are the relationships between facility characteristics,
emergency system characteristics, and system effectiveness? The review will
attempt to clarify relationships between factors such as the types of
chemicals being handled by a facility, the hazards posed by these chemicals,
the age of the facility, its size, the resources devoted to accident
prevention at the facility, the specific technologies or systems installed at
the facility, and the effectiveness of those systems. EPA will also consider
changes made and deficiencies rectified since the Bhopal disaster over two
years ago.
-------
-7-
In addressing these questions, EFA will consider both "intrinsic" and
"extrinsic" systems. Intrinsic systems can be designed into a facility and
are integral to its operations; extrinsic systems are added to a facility to
supplement technologies already in place. For example, one facility may rely
upon the designed layout of its process lines as a critical accident
prevention system, while another facility may rely upon piping guards
installed as a retrofit for the same purpose. Existing facilities may rely
more on the use of extrinsic systems to upgrade their prevention capabilities,
although they can also use an intrinsic approach by changing operating
conditions (e.g., temperature, pressure, process throughput). EPA is not
making any assumptions in this review about whether intrinsic or extrinsic
systems are inherently more effective, but will consider why one type of
system or the other is used.
2.3 OVERVIEW OF APPROACH AND STATUS
EPA's approach to conducting the review of emergency systems involves the
following steps:
• A review of previous research, studies, documentation,
and ongoing research to identify available technologies and
systems, as well as to determine the state of the art in
emergency systems.
• The selection of a limited number of extremely hazardous
substances on which to focus the review.
• The selection of a representative sample of domestic
facilities handling these substances from which to gather
additional data about available technologies and through
which to assess the status of current technological
capabilities, that is, to determine which of the available
technologies are being used, how, and why.
• A survey of the sample of domestic facilities and their
surrounding communities using a written questionnaire.
• In-depth investigations of a limited number of the
surveyed facilities and the surrounding communities,
conducted by trained inspectors, to assess first-hand how
technologies and systems are being used, as well as the
management practices followed at the facility.
• The analysis of the data obtained through the preceding
steps to generate the findings and recommendations required
by Section 305(b).
• The preparation of a final report to Congress.
There are separate discussions below of the critical steps in this
sequence: the selection of chemicals from the list of extremely hazardous
substances, the selection of representative domestic facilities, and the
acquisition of data from these facilities and adjacent communities by means of
a questionnaire and on-site investigations.
-------
-8-
To date, EPA has already initiated the literature review to identify
available technologies and systems. Chapter 3 of this interim report is an
overview of EPA's preliminary findings in this regard. EPA has also selected
20 chemicals from the list of extremely hazardous substances and conducted
initial research on the production and use of these chemicals in the United
States. The process of selecting facilities for the survey and investigations
has begun: relevant considerations have been identified so that suitable
facilities may be identified. The questionnaire EPA will use to conduct the
survey is now being developed. Section 2.7 below presents EPA's schedule for
the completion of the review.
Since the inception of this review, EPA has engaged in consultations with
a wide range of government agencies, as required by the statute, as well as
public interest groups and the general public. These consultations will
continue throughout the review. The review as a whole is being directed by a
workgroup with representatives from a wide range of EPA offices and from the
Federal Emergency Management Agency (FEMA). Periodically, representatives of
states, appropriate federal agencies, environmental groups, industry, trade,
and professional associations will have the opportunity to participate in
meetings to help steer the review State agencies will play a major role in
selecting facilities for the review. Community representatives will be
consulted in the investigations of representative domestic facilities. To
solicit comments from the general public, EPA held a public meeting on the
Section 305 emergency systems review in Washington on April 14, 1987. Expert
opinion on prevention alternatives and research needs was obtained from a
diversity of sources through an international prevention symponum held in
February 1987 under the joint auspices of EPA, the World Bank, and the
American Institute of Chemical Engineers.
2.4 SELECTION OF REPRESENTATIVE CHEMICALS
Congress stated that EPA could select chemicals from the list of extremely
hazardous substances under SARA Section 302(a) for the purposes of this
review. As noted, EPA has selected 20 chemicals from this list on which to
focus the review. The selection process was designed to yield a sample of
chemicals that would be representative not only of the full range of chemicals
listed as extremely hazardous substances, but also of the chemicals most
likely to be involved in significant accidental releases. Accordingly, the
emergency monitoring, detection, prevention, and public alert systems used by
facilities handling these chemicals should be representative of the emergency
systems used among those facilities that would be the sources of the most
significant accidental releases. By focusing on the handling of these
chemicals, EPA should be able to provide Congress with broadly based findings
regarding the current status of emergency technological capabilities.
The process by which EPA selected these 20 chemicals from the list of
extremely hazardous substances was as follows. First, the Agency identified
nine chemicals distinguished by their large production volumes, widely
recognized hazards, involvement in past plant and transportation accidents,
and generally recognized special handling procedures and controls. These
chemicals -- ammonia, chlorine, hydrocyanic acid, hydrogen fluoride, hydrogen
sulfide, methyl isocyanate, sulfur dioxide, and sulfur trioxide -- represent a
wide range of reactivity, flammability, and corrosivity hazards In addition,
a considerable amount of data is available on these chemicals.
-------
-9-
The remaining eleven chemicals were selected using a random number
generation technique from the list of extremely hazardous substances, with
certain guidelines. Because of differences in the manner in which gases,
liquids, and solids are handled in industrial settings, EPA wanted to ensure
that the random sample of eleven chemicals had the same proportion of
chemicals in each physical state as the full list of extremely hazardous
substances. Accordingly, one gas, six liquids, and four solids were chosen.
For liquids, the Agency also wanted to select chemicals that represented a
wide range of vapor pressures at 25°C because of the great differences in
chemical handling practices depending on volatility. Consequently, EPA
selected two liquids with high vapor pressure (> 100 mm Hg), two with
moderate vapor pressure (IS vapor pressure S 100 mm Hg) and two liquids
with relatively low vapor pressure (< 1 mm Hg).
The Agency evaluated each chemical selected in this manner with respect to
factors influencing the type of monitoring, detection, and prevention systems
likely to be employed in handling the chemical corrosivity, flammability, and
reactivity ratings; manufacturing, processing, and use volumes; number of
sites where the substance may be manufactured, processed, or used; physical
state and volatility; and information on past accidental releases. In
considering these factors, the Agency tried to ensure that a wide range of
industrial activities would be covered in the review. For example, a small,
batch processor of a chemical at ambient conditions may not have the same
prevention and monitoring techniques in place as a large continuous bulk
manufacturer of the same chemical at high temperatures and pressures, but both
manufacturers' varying techniques should be examined. EPA also wanted to be
sure that the review addressed only chemicals produced or handled in
sufficient volume to warrant review.
As a result of this review, one of the chemicals initially selected,
3-chloropropionitrile, was dropped because it is used only as a polymerization
intermediate (monomer), is produced in small quantities, and is used at only a
few sites in low volumes. Hydrazine, which meets the same physical property
criteria (liquid, medium vapor pressure) was selected as a replacement
Exhibit 2-1 identifies and characterizes the 20 chemicals comprising the
sample set for the review. It should be noted that this list may be revised
if warranted by new information as the review progresses.
2.5 FACILITY SELECTION
In consultation with state agencies, trade and professional associations,
and public interest groups, EPA is now m the process of identifying
facilities that manufacture, process, use, or store the 20 selected chemicals
in order to review emergency systems at representative domestic facilities, as
Section 305(b) requires. By examining the systems in place at domestic
facilities, EPA will be able to determine which of the technologies and
systems currently available are actually used today by industry, how these
systems are operated, and why they were chosen. It will be possible to
determine the extent to which the state of the art in emergency systems can be
-------
-10-
EXHIBIT 2-1
SAMPLE OF EXTREMELY HAZARDOUS SUBSTANCES FOR REVIEW
Vapor
TPQ
Chemical Name
Form
Pressure
(lbs)
Acrylonitrile
Liquid
High
10000
•^Ammonia
Gas
High
500
Benzenearsonic acid
Solid
Low
10
^Chlorine
Gas
High
100
Chloroacetic acid
Solid
Low
100
Furan
Liquid
High
500
^Hydrocyanic acid
Gas
High
100
Hydrazine
Liquid
Medium
1000
^Hydrogen fluoride
Gas
High
100
^Hydrogen sulfide
Gas
High
500
Mechlorethamine
Liquid
Low
10
Methiocarb
Sol id
Low
500
Methyl bromide
Gas
High
1000
*Methyl isocyanate
Liquid
High
500
*Phospene
Gas
High
10
Sodium azide
Solid
Low
500
"Sulfur dioxide
Gas
'Jigh
500
^Sulfur trioxide
Solid
High
100
Tetraethyltin
Liquid
Medium
100
Trichloroacetyl Chloride
Liquid
Low
500
Vapor pressure ranges: High = >100 torr
Medium = 1 < vp £100 torr
Low = <1 torr
TPQ = threshold planning quantity, the quantity of an extremely hazardous
substance present at a facility that will trigger the planning
requirements of SARA Section 302. The threshold planning quantities
listed above for solids apply when the substance is molten, a fine
powder, or in solution; otherwise the threshold planning quantity for
solids is 10,000 lbs.
* Denotes one of the nine chemicals selected because of high production
volumes, recognized hazards, involvement in past accidents, and recognized
need for special handling procedures.
-------
-11-
found among facilities that might be the sources of possibly severe chemical
accidents An investigation of representative facilities may also yield
additional information on the monitoring, detection, prevention, and public
alert systems currently available, and the state of the art in these systems.
As explained below, there will be first-hand investigations at some of the
facilities and communities in the sample but not others. The initial data
gathered from the full set of facilities and communities in the sample will be
used to select those where first-hand investigations will be conducted.
The following considerations are being taken into account to obtain a
broad but representative sample of facilities and communities:
CHEMICAL USAGE CHARACTERISTICS
• Utilization of the chemical: The type of production,
processing, use, or storage of the chemical, and the
quantity of the chemical handled at the facility (which
must exceed the threshold planning quantities established
under SARA Section 302).
FACILITY CHARACTERISTICS
• Size of chemical operations: The magnitude of the
operations at the facility, measure by throughput or output
volume.
• Size of physical plant: The physical size of the
facility, considering both structures and grounds.
• Number of employees at the facility.
• Age of the facility, the process line, and of any
modifications to the process line used for the chemical.
• Size of corporation: The size of the facility's parent
firm, based on annual sales and other standard measures.
• Release history: When, how, and why releases have
occurred at the facility, the substances released, the
quantities released, and the effects of the releases on
human health and the environment.
MANAGEMENT AND COMMUNICATION
• Loss-prevention and management: The type and extent of
loss-prevention efforts at the facility.
• Types and extent of community interaction: Participation
by the facility in the Chemical Manufacturers Association's
Community Awareness and Emergency Response (CAER) program,
-------
-12-
involvement in community planning under EPA's Chemical
Emergency Preparedness Program, or other indications of a
history of cooperation with community contingency planning
COMMUNITY CHARACTERISTICS
• Population of the community surrounding a chemical
facility.
• Geographic location: Where in the United States the
community is located. In addition, whether the location is
a state-designated priority area or an environmentally
sensitive area.
• Use of land adjacent to the facility: Urban or rural,
residential, commercial, agricultural, recreational, etc.
• Extent of community preparedness: Emergency planning and
response preparedness activities conducted to date in the
community. Public alert and notification systems used.
Response capabilities in the locality. The types and
extent of interaction with the facility for emergency
planning and response.
2.6 DATA ACQUISITION
Data for the Section 305 review is being collected in three ways. First,
EPA is examining previous studies and documentation in relevant areas.
Second, EPA will survey representative domestic facilities and communities by
means of a questionnaire soliciting written responses. Based on the returns,
EPA will then conduct on-site investigations of a limited number of facilities
As noted, the literature review is now well underway; it will continue
over the duration of the project. Chapter 3 of this report is an overview of
its preliminary findings on available and emerging technologies.
The survey will be used to obtain information on current technological
capabilities from a relatively large number of facilities. The questionnaire
for the survey, now being prepared, requests detailed information on major
unit processes and operations in use at the facility, including what potential
hazards exist, a description of relevant equipment and personnel, an
explanation of actual and potential release points, an inventory of the
quantities of extremely hazardous substances associated with facility
operations, and a description of equipment to prevent, detect, and monitor the
releases of extremely hazardous substances The questionnaire includes
questions regarding various types of practices to prevent and mitigate
accidental releases and potential hazards identified, as well as to detect any
releases that may occur: record-keeping and reporting practices, hazard
evaluation programs, plans for upgrading current prevention technologies and
procedures, the techniques available to model the dispersion of released
substances, spill control techniques and technologies, management organization
and practices relating to accident prevention, and operator training
-------
-13-
programs. Questions relating to public alert systems ask not only about
equipment and technologies, but also administrative practices, such as
evacuation plans and drills, concentrating on notification of the local
community. Both internal and external coinmunications are addressed, but EPA
is especially interested in obtaining information about the facility's
relationship with the surrounding community. Facilities will be asked to
describe current arrangements with local authorities regarding public alert
and evacuation procedures, joint training programs, and simulation exercises.
The adjacent community will receive a questionnaire regarding public alert
systems, emergency planning activities, and response capabilities.
This survey will provide a broad perspective on current technological
capabilities across industry. Chemical processes, operating procedures,
management practices, and prevention techniques, however, vary significantly
from facility to facility in ways that are very difficult to capture in
written responses to a questionnaire. Accordingly, EPA will conduct
first-hand investigations of a limited number of facilities to obtain in-depth
information. These facility investigations will ensure that the information
collected is objective and free of distortion.
Present plans are that each investigation will be conducted by a team of
inspectors trained to conduct rhis type of on-site inspection. An
investigation may require several days on site. A standard protocol will be
followed to permit uniformity in the investigations and in the interpretation
of their findings.
In order to submit the final report of findings and recommendations to
Congress by the required date of April 17, 1988, EPA will hold to the
following schedule for performing the remaining steps in the review.
2.7 SCHEDULE
May 1987:
Completion of development of
questionnaire
June 1987:
Facility selection; pretest of
questionnaire.
July - August 1987:
Survey of selected facilities.
September 1987:
Analysis of data from
questionnaire responses.
October - November 1987:
Facility investigations.
December 1987 -
February 1988:
Analysis of investigation
findings; development of
recommendations; preparation of
draft report.
March - April 1988:
Review and revision of report.
-------
-14-
3. OVERVIEW OF EMERGENCY SYSTEMS
This chapter provides an overview of available and emerging systems for
monitoring, detecting, preventing, and alerting the public to accidental
releases of extremely hazardous substances. The information presented is
preliminary and is derived largely from a review of documentation on ongoing
EPA prevention projects, industry research, symposia, and related past studies.
The chapter is organized as follows. Section 3.1 reviews available
detection and monitoring systems. Section 3.2 reviews prevention systems,
understood broadly (as explained in Chapter 2) to include hazard evaluation
procedures, technologies to prevent loss of containment, and techniques to
mitigate the spread of releases. Section 3.3 reviews systems and devices to
provide public alert of accidental releases to local communities.
3.1 DETECTION AND MONITORING SYSTEMS
This section describes in general terms the techniques currently used
within the chemical industry to detect and monitor releases of extremely
hazardous substances into either air or water. The section begins with a
discussion of the various types of detection systems, including both human-
and instrumentation-based systems. Then the n.ethods used to monitor the path
of the pollutant after it has crossed tht. plant's fenceline and entered the
community are described. The section concludes with a discussion of the
material to be included in the final report to Congress under Section 305(b).
3.1.1 Release Detection Systems
Detection systems are integral to a chemical facility's emergency response
capabilities. By using these systems, releases may be detected sufficiently
early to prevent catastrophic results. EPA's Section 305(b) review has
examined systems for detecting releases into air, surface water, and ground
water. For air releases, the review to date has focused on detection systems
used in process and storage areas. These systems are by and large the same as
those used at the facility property boundary (fenceline or perimeter), the
main difference being that more sensitive systems are usually employed at the
fenceline, because the distance from the release point to the fenceline
usually results in a high degree of dilution. Because there are no currently
available techniques to "knock down" or remove vapors from the air except in
confined spaces, once a toxic substance escapes its containment in a process
or storage area into the ambient air, most of it will be carried across the
downwind property boundary. Therefore, industry has emphasized the detection
of air releases in process areas before they have the opportunity to escape.
For releases into surface and ground water, perimeter systems are more
common. Water tends to exit a facility at specific points where sampling and
detection systems can conveniently monitor the concentrations of target
compounds. Current methods for monitoring in surface and ground water are
well developed and documented in many places, e.g., relevant federal
regulations, EPA guidance documents, and ASTM publications.
-------
-15-
There are four general types of techniques currently available for
detecting releases from process equipment: (1) operator observation,
(2) multi-detector systems, (3) fixed-detector/multi-sampling point systems,
and (4) remote sensing systems. Each is discussed separately in the following
subsections.
(1) Operator Observation. The primary method used by industry to detect
releases at chemical plants is observation by process operators and other
personnel. At many plants, personnel are required to conduct inspections on a
regular basis using inspection checklists. In some plants, these physical
inspections are augmented by video camera surveillance. Personnel can be
trained to look for abnormal conditions such as drippage, odors, and hissing
anywhere in the process, storage, and distribution systems. Alarms can be
strategically located and sound when a release occurs to initiate an
appropriate response.
The main advantage of relying upon operator observation for release
detection is that personnel are usually already present at the facility
performing other functions, and when attentive, may detect a release before it
becomes serious. The main disadvantage is that this detection system depends
on tne exposure of humans to the chemical. It also depends on human
capabilities and human performance of duties, which can fail Operator
observation continues to be the prime method of release detection in the
chemical industry, nonetheless, because for many chemicals the human senses
(smell, taste, sight) aie much more sensitive than any instrument now
available. For many hazardous chemicals, Occupational Safety ard Health
Administration (OSHA) regulations require that upon detection the employee don
protective equipment.
Desensitization of human responses, however, can occur with repeated
exposure In addition, for those chemicals that do not have an appreciable
odor or cause irritation prior to reaching concentrations of concern, an
instrumentation-based detection system is needed to prevent releases from
going undetected by workers before it is too late to initiate protective
action. In all cases, instrumentation-based detection systems should be
considered to reinforce operator observation.
(2) Multi-Detector Systems. This type of system involves the placement
of a number of real-time detectors at selected locations throughout a process
area. When one of the detectors senses that chemical concentrations have
exceeded a set level, an electrical signal triggers a visual or audio alarm to
initiate appropriate response Multi-detector detection systems are of two
types: general parameter devices (e g., hydrocarbon, flame ionization,
photo-ionization, and combustible gas detectors) or compound-specific (e.g ,
for hydrogen sulfide or phosgene) The most common type of multi-detector
systems are the general parameter devices. These respond to a wide variety of
chemical compounds and are used in areas where it is unlikely that any
compound other than those of concern will be present or released and interfere
with detection. Compound-specific devices produce electrical signals that are
directly related to the concentration of one compound and theoretically should
not respond to other chemicals. There can, however, be interfering compounds
that will either cause a response or inhibit the response of the device to the
-------
-16-
target compound. This type of detection system is therefore used only in
facilities where there is very little chance of encountering interfering
compounds.
Multi-detector systems provide "round-the-clock" detector availability to
supplement operator observation. One disadvantage is that the detectors must
come into physical contact with the chemical they are to detect.
Consequently, a relatively large number of detectors must be used to ensure
that the plume of released chemical does not slip over, under, or through the
array without contacting a detector. Another disadvantage is that many of
these detectors are relatively insensitive (i.e., have relatively high
detection limits) and therefore must be placed fairly close to the potential
release point, thus limiting the size of the area they can cover.
Additionally, these systems generally require constant maintenance and
calibration to ensure proper functioning. Despite these disadvantages, for
many processes involving extremely hazardous substances, multi-detector
systems are an important element m prompt detection of a release
(3) Fixed-Detector/Multi-Samplmg-Point Systems. This type of system
uses a single detector or analytical instrument. Samples from several process
points are pumped through tubing to the instrument and introduced m rotation
for analysis This type of system is usually used when an expensive or
complicated instrument or method of analysis is needed, such as gas
chromatography, fourler-transform infrared spectroscopy, or mass
spectrometry. The cost and complexity of the detection device make it
impractical to install a detector at each sampling point.
The sophisticated analytical instruments used in fixed-detector/
multi-sampling-point systems can be highly sensitive. It is possible, with
these systems, to achieve detection limits in the parts-per-billion range for
many organic chemicals in air. The trade-off for this enhanced sensitivity is
the loss of continuous monitoring. Because individual sample lines are
analyzed one at a time in rotation, each sampling point is only monitored
intermittently even though the instrument is operating continuously. Other
disadvantages are similar to those of multi-detector systems; in particular,
sampling points need to be arrayed properly to ensure that the released
chemical actually enters the sampling system In contrast to multi-detector
systems, however, sensitivity is such that a large area may be covered by one
system.
(4) Remote Sensing Systems. This type of system relies on a
fixed-station detector which receives optical signals from the released
substance. A detector is located within the potential release area and is
pointed at a light source (usually infrared or ultraviolet) also located
within the release area The detector measures the intensity of the light
source. When a release of a chemical occurs and a chemical plume crosses the
light beam, part of the light is absorbed or scattered by the molecules of the
chemical, diminishing the intensity of the light reaching the detector. An
electrical signal is sent from the detector, triggering an alarm. While a few
of these systems have been custom-designed for use in the detection of
volatile chemicals, most commercially available systems have been designed to
monitor dust levels at open pit mines and concrete plants.
-------
-17-
3.1.2 Monitoring Systems
Monitoring systems track the release of an extremely hazardous substance
after it has crossed the plant's fenceline and entered the communjty The
systems discussed below are used to monitor the plume formed by chemicals
released into air. Releases to surface and ground water, which pose
less-immediate threats to public health and the environment than releases to
air, are monitored by the use of long-established techniques, for example, the
analysis of samples taken periodically from wells or surface water bodies to
identify the presence of contaminants.
Monitoring of the atmospheric dispersion of a released chemical is used to
determine distances to which local residents must be evacuated or asked to
remain indoors when a release occurs. It is also used to determine when
concentrations have decreased sufficiently to allow re-entry to the area. The
purpose of community air monitoring is rarely to determine the direction of
the plume, because standard practice is to evacuate or remain indoors in all
directions from the source to guard against a shift m wind direction.
This section will provide general descriptions of both portable and field
laboratory instruments currently used for sampling and analyzing chemicals in
air. In addition, there is a brief description of the use of computer
simulation in tracing atmospheric releases
(1) Portable Monitoring Instruments. These are real-time direct-reading
instruments that can be easily carried and operated by one individual. They
are available as both general parameter and compound-specific detectors. The
general parameter instruments respond to any chemical that possesses a- certain
chemical or spectrometric property (e.g , photo-ionization, flame ionization,
thermal conductivity, infrared absorption catalytic oxidation).
Compound-specific monitoring instruments rely on properties such as surface
chemistry or electrochemistry, or the use of membrane separation technology or
calorimetric response. As with the compound-specific devices used m
multi-detector systems, there is a possibility for chemicals to interfere and
produce erroneous results from compound-specific monitoring instruments.
The advantages of these instruments lie m their portability and real-time
readout. They can be carried almost anywhere to provide instantaneous
estimates of chemical concentrations in air. Disadvantages derive from the
fact that they are limited in their sensitivity (e g., to concentrations such
as those in the OSHA/NIOSH Tolerance Limit Value Range). They may also be
difficult to calibrate They are nevertheless valuable tools for monitoring
the concentration of an extremely hazardous substance released into air.
(2) Field Laboratory Instruments. These are mobile laboratory units
transported by van or bus to the site of a release. These instruments can
produce accurate, precise data on the concentration in air of the target
chemicals in the sub-parts-per-million range. The analytical and detection
techniques used in field laboratory instruments include gas chromotography,
spectrochotometery, nitrogen and sulfur oxide monitoring, mass spectrometery,
and wet chemical methodology.
-------
-18-
The main advantage of field laboratory instruments is that they can
quickly provide accurate data using sophisticated analytical methodologies.
Their main disadvantage is that they are not widely available, must be
transported promptly to the accident site, and require calibration at the site.
(3) Computer Simulation of Plume Dispersion. Computer-based models may
be used to predict the dispersion of a plume of toxic chemical vapors
following a release. Many such models are now commercially available for use
on either personal computers or mainframes. The models vary from highly
site-specific automated systems to more generalized systems that may easily be
modified for use at a variety of locations Input requirements generally
include meteorological data such as wind speed and direction, spill size, and
dimensions of the container (or other characteristics to determine release
source and strength) Some systems include components that model the effects
of the surrounding terrain and buildings on dispersion. The choice of an
appropriate model for a given situation is highly individualized; advantages
and disadvantages must be evaluated in light of site-specific circumstances
The computer simulation of atmospheric dispersion is still relatively new
to the chemical industry, and as of yet, few models have been validated using
experimental data, especially for predicting short-term concentrations. There
is some debate over whether the models should be used without further
validation. Many chemical companies, both small and large, have decided to
use these models as part of their emergency response network, however, simply
because ho other method has been found for estimating distances of concern
from the point of release within the limited time available for response
These models may be used as training and planning tools in addition to
their use in emergency response. Many of the models have been designed
specifically for these additional uses, such as defining "vulnerable zones"
for potential release scenarios. Some even allow the user to save "planning
exercises" and use them in actual emergency situations if conditions are
similar, which can increase response time significantly. The main limitations
on the accuracy of computer simulations stem not from the models themselves,
but from the difficulty of obtaining accurate estimates for the input
parameters (i.e., real-time meteorological data, terrain data, and "source
strength estimates", that is, estimates of the rate at which the substance is
being released). In addition, the models, and the validation of their
results, may be costly.
3.2 PREVENTION SYSTEMS
This section describes in general terms the technologies and techniques
available to prevent or mitigate releases of extremely hazardous substances to
the environment. As explained in Chapter 2 of this report, EPA's Section 305
review is focusing on accidental releases rather than routine releases.
Exhibit 3-1 contrasts accidental and routine releases to clarify the focus of
the discussion that follows.
The technologies and techniques available to prevent or limit accidental
releases to any environmental medium (air, surface or ground water, land) may
be divided into four categories:
-------
-19-
(1) Hazard evaluation, that is, quantitative and qualitative techniques
for determining what series of events could result in an accidental release;
(2) Pre-release prevention, that is, intrinsic and extrinsic systems to
reduce the probability that the primary containment of a chemical in a process
line will be breached (often called "loss of containment");
(3) Pre-release protection, that is, control techniques such as flares,
scrubbers, or holding ponds to contain, destroy, or reduce the quantity of the
substance before it is subject to release; and
(4) Post-release mitigation, that is, measures that can be taken after a
release to the environment has occurred to limit the spread of the released
chemical and minimize damage to public health and the environment
3.2.1 Hazard Evaluation
Hazard evaluation, which is intended to determine what series of events
could result in an accidental release, is conducted by two types of
techniques: (a) hazard identification, and (b) hazard analysis. Hazard
identification techniques are usually qualitative. They involve surveying a
plant or process to identify potential equipment and procedure failures that
could result in an accidental release of an extremely hazardous substance.
Hazard identification techniques are also used to identify the consequences of
a release and opportunities to reduce Doth the probability of, and the
consequences of, a release.
The identification of potential problem areas using hazard identification
techniques is difficult because releases can be caused by any number of
circumstances, or by a series of interconnecting events each of which, by
itself, would not be enough to cause a failure leading to an accidental
release. Exhibit 3-2 illustrates some of the errors that may lead to a
chemical emergency. These errors include design, construction, operating and
human errors, as well as failures due to equipment or process upsets.
Hazard analysis techniques are often quantitative. They are used to
evaluate the probability that an event will occur and its potential severity.
To apply quantitative hazard analysis techniques, data are needed on the
actual causes of accidents, equipment failure rates, procedural errors, and
operational reliability. Judgment (and a certain amount of subjectivity) must
be involved in the absence of such data and in the interpretation of any
qualitative results.
There are a number of widely accepted techniques for hazard identification
and hazard analysis. Exhibit 3-3, a matrix developed by the Center for
Chemical Process Safety of the American Institute of Chemical Engineers, lists
the most common techniques and shows the applicability of these techniques in
a thorough hazard evaluation process.
-------
Exhibit 3-1
TYPES OF RELEASES
gp />,' MWMimmzMm WM i 1 ^ J-H iil
ROUTINE RELEASES
g 'immm. 1Us''if',''/' $%M s * *'
'/Accidental releases
- w.
PROCESS DISCHARGES
INTERMITTENT
INTERMITTENT
CATASTROPHIC
•
PLANNED
•
NOT SCHEDULED
• NOT SCHEDULED
FUGITIVE EMISSIONS
•
LIMITED
•
EXPECTED
• UNEXPECTED
NON-POINT-SOURCE
•
SCHEDULED
•
LIMITED
• MAJOR FAILURE
DISCHARGES
EXAMPLES:
EXAMPLES:
• UNCONTROLLABLE
~
STARTUP
~
TRANSIENT
EXAMPLES:
~
SHUTDOWN
~
UPSET
~ PROCESS FAILURE
~
MAINTENANCE
~
PRESSURE
~ CONTROL FAILURE
~
EQUIPMENT
OPENING
RELIEF
~ ARSON, VANDALISM
~ NATURAL DISASTER
-------
Exhibit 3-2
TYPES OF ERRORS LEADING TO HAZARDS
Inadequate Control
Inadequate Maintenance
Inadequate Inspection
Operaung Outside
Standard Limits
Wrong Materials
Improper Practices
Inadequate Supervision
Inadequate Specifications
Inadequate Supervision
Inadequate Hazard
Evaluation
• Inadequate Quali&cauons
• Inadequate Training
• Inadequate Operability
• Inadequate Emergency
Procedures
OPERATING
ERRORS
PROCESS
UPSETS
DESIGN
ERRORS
EQUIPMENT
FAILURE
HUMAN
ERRORS
CONSTRUCTION
ERRORS
-------
Exhibit 3-3
HAZARD EVALUATION PROCEDURES
Identify Deviations From
Good Practice
Identify Hazards
Estimate "Worst Case"
Consequences
Identify Opportunities to
Reduce Consequences
Identify Accident-Initiating
Events
Estimate Probabilities of
Initiating Events
Identify Opportunities to
Reduce Probabilities of
Initiating Events
Identify Accident Event
Sequences and Consequences
Estimate Probabilities
of Event Sequences
Estimate Magnitude of
Consequences of Event
Sequences
Identify Opportunities to
Reduce Probabilities and/or
Conseq. of Event Sequences
Quantitative Hazard
Evaluation
Hazard Evaluation Procedures
Event Case Human
Tree Consequence Error
Analysis Analysis Analysis
Process/
System Safety
Checklists Review
Relative Preliminary
Ranking Hazard
Dow & Mond Analysis
Hazard
and
"What If" Operability
Method Study
Failure
Modes
Effects and Fault
Criticality Tree
Analysis Analysis
3 Provides Context Only
Primary Purpose
Secondary Purpose Primary Purpose for Previously Recognized Hazards
Source: The Center for Chemical Plant Safety, American Institute of Chemical Engineers. Guidelines for Hazard F.valualion Procedures
Prepared by Battelle Columbus Division. New York, New York, 1985.
-------
3.2.2 Pre-Release Prevention Systems
The purpose of pre-release prevention, or loss prevention, is to reduce
the probability that the primary containment of a chemical will be breached.
Pre-release prevention technologies may either be intrinsic -- integral to the
design of a facility or process line -- or extrinsic -- supplemental to
process technologies already in place. Redundancy and back-up systems are
central to pre-release prevention technologies. In addition to technologies,
however, pre-release prevention depends on safe operating procedures. It also
involves safety reviews during the planning and design of the facility, as
well as of plant operations and maintenance, followed by modifications to
plant design or operating procedures to rectify any deficiencies. Management
commitment to following safe operating procedures, to installing
state-of-the-art loss prevention technologies, and to making whatever changes
are needed to improve the safety of the facility is critical to the success of
pre-release prevention efforts
The following discussions address pre-release prevention in (a) process
design, (b) physical plant design, (c) siting, and (d) procedures and
practices. The hazard evaluation techniques discussed above are used to help
identify the controls needed to address potential hazards in each of these
areas.
(a) Process Design. The inherent hazards of chemicals used in a process
are regulated through the use of control systems, such as flow, pressure,
temperature, And concentration measurement devices. These controls are used
to govern and monitor reaction rates. They can be incorporated into the
original design of the process line or may be added to existing facilities.
Reaction rates are usually one of the major considerations in process
design, especially for reactions that are exothermic, that is, chemical
reaction in which heat is liberated. If the heat is not removed or not
allowed to escape, temperature will rise, causing an increase in the reaction
rate. This could lead to an upset condition, i.e., a run-away reaction, an
increase in pressure, discharges from relief systems, rupture of equipment,
and possibly explosions releasing hazardous chemicals. The operational
difficulty of controlling the process increases with its complexity.
Process design changes that may serve to prevent containment losses from
occurring include substitution of less hazardous chemicals, reduction of the
severity of process conditions (i.e., temperature and pressure), reduction of
process complexity, and improved operation and safety procedures and training.
(b) Physical Plant Design. Pre-release prevention can be taken into
account in plant design and layout. It is a factor in engineering
specifications for structures, barriers, foundations, piping, process
machinery, and instrumentation. An important safety requirement in the design
of the physical plant is the "quantity distance". This is the distance
between areas where explosive or reactive chemicals are located (i.e., process
and storage areas), as well as between these areas and population centers.
-------
-24-
There are a number of widely accepted codes, standards, and
recommendations that provide minimum safety standards for equipment design,
procedures, and systems Technical and trade organizations, federal agencies
such as OSHA, testing standards and safety groups, insuring associations, and
professional societies have all developed codes and standards for facilities
handling hazardous chemicals. An example relating to quantity distances is
the Oil Insurance Association's general recommendation for spacing in
petrochemical plants.
(c) Siting Considerations relevant to pre-release prevention in the
siting of a facility include the meteorology of the area, its topography,
proximity to ground water and drinking water sources, and proximity to
population centers. Also relevant is the accessibility of maintenance and
emergency response teams. Attention to safety in siting is especially
important when highly toxic chemicals are used or manufactured in significant
volumes. A facility that was originally well-sited may lose its margin of
safety if development subsequently encroaches on the site.
(d) Procedures and Practices. Management sets the tone, direction, and
quality of operations at a facility handling extremely hazardous substances.
It is management's responsibility to ensure that the appropriate systems and
procedures are developed and followed. Management must also ensure that the
possibility of human error is addressed through tra.ning of operators in
standard and emergency procedures, fire and explosion protection, maintenance,
and safety reviews. Thus, management procedures and practices are
indispensable components of pre-release prevention
3.2.3 Pre-Re lease Protection
Pre-release protection systems are intended to contain, destroy, or reduce
the quantity of the extremely hazardous substance before it can be released to
the environment. Pre-release protection technologies include flares,
scrubbers, adsorbers, holding ponds, dikes, and double liners Each of these
measures either destroys the chemical, reduces the quantity of the chemical,
or contains the chemical, providing additional time to conduct remedial
efforts or treat the chemical before it is released into the environment
These measures can be applied only when the released chemical is in
confinement, when it can be transported into properly sized control systems,
or when circumstances allow remedial action to be taken. For example, a
containment building can temporarily confine a chemical so that it can be
vented through a scrubber or sent to a diversion pond for future treatment.
Pre-release protection measures applicable to potential releases to
surface and ground water from storage tanks include maintaining back-up pumps
or secondary structures to remove or contain discharging liquids, possibly
followed by the treatment (e.g., detoxification) of the substance. For waste
storage and disposal units such as landfills, surface impoundments, and waste
piles, where the releases primarily of concern are to surface or ground water,
such pre-release protection measures include double liners with a leachate
collection system between the liners. In these systems, liquids that leak
through the primary liner are conveyed by the leachate collection layer to a
sump, where they are then pumped to a treatment unit.
-------
-25-
When applying any control measure for pre-release protection, it is
necessary to ensure that a more serious problem will not be created through
secondary hazards. For example, the connection of relief valves to an
existing header leading to a flare might be the most expedient method to
eliminate discharges to the environment; however, it could lead to an
uncontrolled reaction or an explosive condition caused by contamination
through poorly seated relief valves.
3.2.4 Post-Release Mitigation
Post-release mitigation measures are used when a loss of containment has
occurred, but while the extremely hazardous substance is still within the
facility perimeter. They serve to reduce the possibility of the substance
migrating off-site. Usually they reduce the quantity or concentration of the
substance to which people would be exposed. Included are temporary partial
constraining measures, water sprays, foam, permanent physical barriers, and
dispersion
For example, post-release mitigation actions following a chlorine spill
might first involve covering the spilled chlorine immediately with plastic and
venting the fumes under the cover to a scrubber The liquid chlorine would
then be pumped to a tank for treatment and disposal. If the substance
released was liquid hydrogen flucride, post-release mitigation might involve
spreading soda ash or a strong soda ash solution on the hydrogen fluoride to
act as a neutrallzer and prevent the further release of tox_c vapors.
Foams can be effective vapor suppressants and are commonly used to prevent
rapid evaporation from liquid spills Depending on the chemical and the
circumstances of a release, a water spray or water curtain may also be used to
absorb vapors (e g , ammonia vapors) and provide a physical barrier to
down-wind dispersion. Various factors contribute to the effectiveness of the
post-release mitigation measures, including the environmental medium to which
the release occurs, the physical state of the substance (gaseous, liquid, or
solid), and ambient conditions (e.g , wind speed, weather conditions)
Post-release mitigation measures for releases to surface water include the
construction of filter fences and dams in contaminated streams, or the removal
and disposal of contaminated soil Post-release mitigation measures for
releases to ground water are intended to prevent the migration of contaminants
beyond the facility boundary. Impermeable boundaries such as slurry walls,
chemical grouts, or sheet piling can be used to divert ground water flow or
prevent the migration of contaminated ground water. Well and pump systems are
used to remove ground water for treatment and subsequent re-inject ion.
Subsurface drains can be used to intercept contaminated ground water. An
alternative to these approaches is in situ treatment, in which a chemical or
biological reactant is introduced to interact with the plume of contaminated
ground water.
-------
-26-
3.3 PUBLIC ALERT SYSTEMS
As explained in Chapter 2 above, the Section 305(b) review is focusing on
public alert systems that can warn the surrounding community of an accidental
release at a chemical facility, not just systems to warn workers at the
facility. The community to be alerted, when an accidental release of an
extremely hazardous substances occurs, consists of everyone potentially
exposed to the chemical. Timely warning to the local community of a release
is essential to minimizing its impact.
The purpose of a public alert system is not only to warn the community of
the emergency, but also to provide specific instructions for self-protection.
Public alert systems generally rely upon two separate and distinct components,
namely, alert and notification. The alert component is designed to attract
the attention of the public. Sirens, horns, and public address systems are
all examples of alert systems. The notification component of a public alert
system is the information delivery mechanism used to communicate instructions
to the population considered to be at risk Examples include the Emergency
Broadcast System, television stations, and annunciators Only those
mechanisms which are capable of reaching a high percentage of the public in a
quick and simple manner are considered acceptable for notification.
It is the responsibility of both public officials and industry to protect
the members of the community against the hazards associated with accidental
releases of extremely hazardous substances. in the event that a release is
detected, plant or facility managers have the responsibility to contact the
pre-designated public officials who can activate the appropriate public alert
and notification system This requires coordination and planning prior to an
actual release. In general, an effective public alert and notification system
for chemical emergencies requires the cooperative efforts of both industry
management and local officials in the design and routine testing of the system
to ensure that the information concerning an emergency release is quickly
relayed from plant managers to public officials. In addition, public
education programs are required to ensure that the public is informed of the
significance of the various alert and notification systems.
3.3.1 Alert Methods
Audible warning devices are the most commonly used devices for alerting
the public of an emergency situation. Some examples of devices currently
being used in the chemical industry include sirens, bells, horns, whistles,
and pubic address announcements. These are typically designed to produce and
emit sound energy at frequencies between 300 and 3,000 mHz and at amplitudes
below the threshold of pain (130 dB) but at least 10 decibels above average
ambient noise levels at the location of the population at risk. The primary
"alert" tone or frequency of the device must not mimic any other popular sound
within the intended alert area; tones with frequencies closely related to
sounds or noise generally found in the area are to be avoided.
Outdoor sirens are one of the most commonly used systems for accomplishing
wide-area alerting. A variety of siren tones are available, but experience
-------
-27-
has shown that the broad use of different tones for different purposes has not
been particularly effective Even with extensive public awareness programs, a
large portion of the public is not able to clearly recognize different tones
and does not remember what the different tones signify. Sirens are also
available with public address capabilities. Public address capabilities have
been used in locations where immediate recognition and specific responses must
be affected
3.3.2 Notification Methods
Notification methods include the use of commercial broadcast radio
stations as a part of the Emergency Broadcast System and combinations of the
broadcast radio system, television stations, cable television systems, and
other mechanisms such as the National Oceanic and Atmospheric Administration
radio system.
A fully reliable Emergency Broadcast System requires the utilization of
state-of-the-art communications equipment, extensive training of broadcast
personnel, and frequent drills and tests of the system.
3.3.3 Combined Alert and Notification Methods
Thore are also devices available that accomplish the functions of both
alert and notification. The three most common devices are alert radio
receivers (tone and voice), telephone alert/notification systems (tone and
voice), and interruption of programming on television systems.
Alert radio receivers are designed to be silent until activated by a radio
signal Once a signal is received, a loud alerting signal precedes the
emergency instructions. These devices are generally used either in sparsely
populated areas where siren coverage is impractical or as a redundant system
for schools, hospitals, nursing homes, and other locations of special
populations.
A telephone alert/notification system allows for emergency management
officials to ring all of the residential and commercial telephones in a
particular area simultaneously and then to deliver emergency instructions. In
this way, the system can be used as a notification method for emergency
response personnel and as an alert/notification system for the general
population in large area.
Another type-of telephone alert/notification system employs a personal
computer as an automatic dialer. This system can be programmed to dial
numbers sequentially and then play recorded instructions. As with alert radio
receivers, telephone alert/notification systems are most effective as a
redundant method of alert/notification for special facilities or population
groups.
An additional technology which is rapidly emerging in this country (and
which has already had very good success in Germany) is the Public Information
Notification System (PINS). PINS utilizes a subcarrier of the standard FM
-------
-28-
radio channel to provide an alert signal and emergency information Among the
PINS equipment now available for public use are decoders that are located in
automobile radios and can automatically tune into the channel with the
emergency information. These decoders are becoming more readily available in
the U S but will not be installed in significant numbers of private vehicles
for several years
3.3.4 Public Education
The aforementioned methods of alert and notification are relied upon to
attract the attention of the public and provide citizens with invaluable
information on precautions to take in an emergency situation. This sometimes
requires that the public be aware of what each step in the process or signal
signifies. That is, the public must know in some cases that when "alerted",
they are to seek information from a second source, for example, the Emergency
Broadcast System or one of its components.
Informing the public about how to react in an emergency is a vital element
of emergency planning. Consequently, preparing understandable instructions
for the public on how they will be notified and on what steps they should
follow in the event of an emergency is an important part of preparedness for a
chemical emergency. Preparation of educational materials requires preparers
to analyze their target population and develop a site-specific style. The
focus, content, jnd organization of emergency documents is of paramount
importance in creating documents that succeed in the communicating critical
information to the public.
3.3.5 System Operation
In order for a public alert/notification system to serve effectively the
purpose for which it was designed, the procedural aspects of its operation
must be carefully understood. The question of who activates the system must
be decided on a facility-by-facility basis. Each individual facility and its
adjacent community have unique characteristics that must be considered. The
type and size of the local government (or the lack of local government
structure), the density of the surrounding population, the proximity of the
population to the facility, the nearest 24-hour local government facility, are
all factors to be considered
Generally, it is the function of facility management to advise local
government officials during an emergency situation and to provide necessary
information and recommendations of protective actions to the public. If,
however, the site is located in an unincorporated area with a nearby
residential population, it may be necessary to reach an agreement which will
allow facility personnel to activate all aspects of the public
alert/notification system pending the arrival of public officials.
It should be noted that the activation of a public alert/notification
system involves the careful coordination of a number of elements If, for
instance, the protective action communicated to the public is to evacuate,
-------
-29-
then mass care centers must be opened and manned, transportation provided,
institutions and special populations assisted, and state and federal officials
notified. The question is not simply who will activate the pubic
alert/notification system, but who must be involved immediately to make the
system work This requires coordination between local police, fire, and
government officials and industry. This coordination can result only from
advance planning for a chemical emergency.
-------
-30-
APPENDIX: GLOSSARY
Monitoring and Detection Systems: (a) Technologies ranging from process
instrumentation and in-plant detection devices to perimeter alert devices for
anticipating emergency or upset conditions, identifying constituent chemicals
in releases, providing data on the chemical composition of releases, and
determining concentrations of chemicals in releases; and (b) Modeling
technologies for determining the magnitude and direction of hazards posed by
releases.
Routine Release: A process emission, such as atmospheric venting, designed
into a process or operation to maintain operational control.
Accidental Release: An unexpected discharge or emission of a substance into
the environment, possibly involving a fire or explosion, resulting from
operational errors, improper maintenance, or equipment failure in the course
of an industrial activity.
Extremely Hazardous Substances: Substances appearing on the list referred
to in Section 302(a) of SARA and published in the Federal Register on November
17, 1986 (51 FR 41570, as revised on April 22, 1987, 52 FR 13378). The list
is composed of acutely toxic chemicals that might pose an immediate hazard to
a ci.mmunity upon release
Hazard Evaluation Procedures: Qualitative and quantitative procedures for
determining what failures or series of events could result in accidental
releases of extremely hazardous substances and their probability of
occurrence. These procedures include hazard identification and hazard
analysis procedures.
Hazard Identification Procedures: Qualitative techniques and procedures
used to survey a plant or process to identify what equipment and procedure
failures or series of events could result in an accidental release of an
extremely hazardous substance.
Hazard Analysis Procedures: Quantitative techniques and procedures used to
evaluate the probability that events presenting hazards will occur and the
probability of the severity of various consequences. Such quantitative data
as estimated probabilities must be interpreted qualitatively during hazard
analysis.
Prevention Systems: Any technology or management practice that aids in
preventing extremely hazardous substances from being accidentally released to
the environment. "Prevention" refers to avoidance of an accident or a loss of
containment situation, as well as mitigation of the possible off-site
migration of the extremely hazardous substance. Thus, prevention systems
include hazard evaluation procedures, pre-release prevention systems including
-------
-31-
control and back-up systems that help to prevent loss of containment,
pre-release protection systems that include specific technologies for
destroying or reducing the quantity of the chemical prior to its release to
the environment, and post-release mitigation systems that help to minimize the
adverse consequences of a loss of containment. Prevention systems apply to
designed release points, such as pressure relief valves, as well as unplanned
releases from explosions, valve leaks, or pipe ruptures.
Pre-Release Prevention Systems: Systems and procedures designed to reduce
the probability that the primary containment of an extremely hazardous
substance will be breached. Pre-release prevention includes numerous
activities dealing with the plant siting/layout, process design, operations,
and maintenance of the facility Control systems and redundant or back-up
systems are major components of systems designed to prevent a -e'^ase
Pre-Release Protection Systems: Specific pre-release control techniques
(flares, scrubbers, and adsorbers) that either contain, destroy, or reduce the
quantity of the extremely hazardous substance prior to its release to the
environment.
Post-Release Mitigation Systems: Systems and techniques applied to an
extremely hazardous substance after loss of containment has occurred, but
while the substance is still within the plant boundaries, to reduce the
oossibility of the substance migrating off-site Examples are foams and water
sprays
Public Alert Systems: Equipment, technologies, and methods, such as sirens,
the Emergency Broadcast System, and telephone alert/notification systems for
providing timely and effective public warning of an accidental release of an
extremely hazardous substance, as well as for informing the public of
precautionary measures
-------
Federal Register / Vol. 52. No 77 / Wednesday, April 22, 1987 / Rules and Regulations 13397
The List of Extremely Hazardous Substances and their Threshold Planning Quantities
[Alphabetical Order]
CAS Na
Chemical name
Notes
75-06-5
Acetone Cyanohydnn
1752-30-3
Acetone Thiosemicartiaade ¦ ¦
e
107-02-8
Acrolein
79-06-1
Acrylamide
d. 1
107-13-1
Acrylonitnle
d, I
814-66-8
Acrytyl Chlonde
e. h
1*.1-69-3
Adiponitnle
e, 1
116-06-3
Aldicarto
c
309-00-2
Aldnn
d
107-16-6
Altyl Alcoto1
107-11-9
Allylamine
e
20859-73-8
Aluminum Phosphide
b
54-62-6
Ammoptenn
e
78-53-5
Amiton
e
3734-97-2
Amiton Oxalate
e
7664-41-7
Ammonia
1
16919-56-7
Ammonium Chloroplatinate
a. e
300-62-9
Amphetamine
e
62-53-3
Aniline
d. 1
88-06-1
Aniline. 2,4 6-Tnme!hyl-
e
7783-70-2
Antimony Pentafluonde
e
1397-94-0
Antimycin A
c e
66-68-4
ANTU
1303-28-2
Arsenic Pentoxide
d
1327-53-3
Arse nous Onde
d. h
7784-34-1
Arsenous Trie Monde
t*
7784-42-1
Arsme
e
2642-71-9
Azmphos-Ethyl
e
86-50-0
Annphos-Methyl
1405-87-4
Bacitracin
a, e
98-87-3
Benzal Chloride
d
98-16-8
Benzertamine, 3-CTnfluofomethyt)-
e
100-14-1
Benzeoe, 1-(Cfiloromethyt)-4-Nitro-
e
98-05-S
Setuenearsonic Acid - ¦
e
98-09-9
Benzenesulfonyl Chlonde
a
3615-21-2
Benamdaiole, 4.5-OcNoro-2-{Tnfluoromethyf)-
e. 9
98-07-7
Benzotnchtonde
d
100-44-7
Benzyl Chlonde
d
140-29-4
Benzyl Cyanide
e. h
Reportable
quantity*
(pounds)
Threshold
planning quantity
(pounds)
10
5.000
100
100
1
100
1
1
1
100
s.Oi
100
5,000
5,000
5 000
5.000
100
100
1
-------
13388 Federal Register / Vol. 52. No. 77 / Wednesday, April 22, 1S87 / Rules and Regulations
Appendix A —The List of Extremely Hazardous Substances and thew Threshold Planmno Quantities—Continued
[AfphabebcaJ Order]
Reportable
Thies/icud
CAS No
Chemical name
Notes
quantity*
planning quantity
(pounds)
(pounds)
15271-41-7
BcycJo(2-2 1]Heptane-2-Cait>oriitnle. 5Ch(oro-6-((((Methyi«mino)C»tory()Oxy)lmino)-,
e
1
500/10,000
(Is-<1 -alpha 2-beta 4-alpha. 5-alpha. 6€))-
534-07-6
Bis(Chloromethyl) Ketone -
e
1
10/10000
4044-65-9
Bitoscanate _ —
e
1
500/10000
10294-34-5
Boron Tncftonde
e
1
500
7637-07-2
Boron Tnfluende . . .
e
1
500
353-42-4
Boron Tnfluonde Compound W#h Methyl Ether (11)
e
1
1,000
28772-56-7
Bromadiolona _ . _
e
1
100/10,000
7726-95-6
Bromine _ ... .. „ . ..
e 1
1
500
106-99-0
Butadiene .. - . — — -
& «
1
10.000
109-19-3
Butyl Isovalerate . _ - - .
a.«
1
10,000
111-34-2
Butyl Wiyl Ether
a,e
1
10,000
1306-19-0
Cadmium Onde - ¦ -. ¦
e
1
100/10,000
2223-93-0
Cadmium Stearate ... . _
c, e
1
1,000/10.000
7778-44-1
CaJaum Arsenate— ...
d
1,000
500/10,000
8001-35-2
CamphecNor. . — - — -
d
1
500/10.000
56-25-7
f~fl«tharvflr>
e
1
100/10,000
51-63-2
Carbachol Chloride - ... . .
e
1
500/10,000
26419-73-8
Ca)tmmlr A^ f.("}(^inlan.7.yl)UatfeylanA)Ammn).
•
1
100/10.000
1563-66-2
Carbofuren.. .
to
10/10.000
75-15-0
Carbon Dwulfldo -
I
100
10,000
766-19-6
CerbophenotNon — — -
e
1
500
2244-16-8
Carvone _ ...
a. e
1
10.000
57-74-9
CMordane..
d
1
1,000
470-90-fl
Chlortenvmfos— ,,,. .
e
1
500
7782-50-5
Chlonna _
10
100
24934-8 J -A
Chlormephos
e
1
500
999-61-5
Chtofmequat Chloride ._ - .
e, h
1
100/10,000
107-2Q-0
Chloroacetaldehyde
a
1,000
10,000
79-11-6
Chforoacetlc Add _ .
e
1
100/10,000
107-07-3
Chtowethanol .... —
e
1
500
627-11-2
Chloroethyi Chloroformate
e
1
1,000
67-60-3
CMomfarm . — -
d, 1
5,000
10.000
542-68-1
rhinmnwrthyl emat
d, h
1
100
107-30-2
Oitommntflyf Matty Fth»
c, d
1
100
3691-35-6
rwi'ur^rfiaajiwt*
e
1
100/10.000
1982-47-4
PMnmnvnn
e
1
500/10,000
21023-23-8
e, b
1
500
10025-73-7
Ctrmwki OiWrto
e
1
1/10,000
7440-48-4
Cobalt _
a, e
1
10,000
62207-76-5
Cobalt, ((2.2'-(1 ,2-Ethanedtyfbta (NJtrilomethy6dyneJ)Ba(6-FhJorophenolalo)M2-)-
e
1
100/10,000
KN'.O.a)-..
10210-68-1
rotMll Carhmyl
e, h
1
10/10,000
64-66-8
Coiet»one . . „ _ _
e, h
1
10/10,000
117-52-2
Coimafuryl .. . _ .... _ ..
fce
1
10.000
56-72-4
Coumaphoa ... _ ... ...
10
100/10X100
5836-29-3
Coumatetratyl — . _ _ . _. ..
e
1
500/10,000
95-48-7
Cresol. o- .... ._
d
1.000
1.000/10.000
535-69-7
Cnmidme _ _
•
1
100/10,000
4170-30-3
OotonakJetiyde ... .
100
1,000
123-73-9
Crotonaldehyde. (E>- .. - .... _ . ... -
100
1.000
506-68-3
Cyanogen Bromide .
1,000
500/10.000
506-78-5
Cyanogen Iodide - - -... -
t
1
1.000/10,000
2636-25-2
Cyanophoe ._
e
1
1.000
675-14-8
Cyanuric Fluoride . _ _ ...
e
1
too
66-61-9
Cydobexirmd® - .. —
e
1
100/10,000
108-91-6
rycWmnyliifTiina
e. 1
1
10.000
287-92-3
Cydopemarw. .
a, e
1
10,000
S33-03-4
C 1 Baae Green 1
a. e
1
10,000
17702-41-8
rWalnrann^)
e
1
500/10.000
eoes-46-3
namctfln
e
1
500
919-66-8
n
-------
Federal Register / Vol. 52, No. 77 / Wednetday. Aprri 22. 1887 / Rn'cs and Regulation* 1PM
Appendix a.—The List of Extremely Hazardous Substances amo man Threshold Plannmg Guamtihes—Contnued
[Alphabetical Outer)
Reportable
Threshold
CAS No
Chemical name
Notes
quantity"
pUmng«ua*%
(pounds)
(pounds)
149-74-6
Dichloromethytphenylsiisne. _ .
e
1
1.000
82-73-7
OcMorvos . _ —
10
i.eoo
141-66-2
Dwotophos ... ._
e
1
too
1464-53-5
Die(»oxybulane _ ....
d
1
500
814-49-3
Dietiyt Chlorophoapate - - _ —
e, h
1
500
1642-54-2
^W>*iyt«uhamaTe _.. _ .
a,e
1
10.000
71-63-6
Digrtoan .
c. e
t
<00/10.000
2238-07-5
Dtglyodyl Ether ... _ — .... _
e
1
1,900
20830-75-5
Dtgoxm... . _ -. _ _
e, h
1
10/10400
115-26—4
PimAfn*
e
1
500
60-51-5
Dimethoate ... . _ .._ "...
to
900/10400
2524-03-0
Dimethyl Phosphorochlondo&noate __ _ ._
e
1
90S
131-11-3
Dimethyl Phthalate - - .. _ _
a
&JX)Q
10,900
77-7&-1
Dimethyl Sulfate . .
d
t
500
75-19-3
Dimethyl Sulfide _ . _ ... — ._ .
e
1
100
75-78-S
Ometfryldichtorgsiiane. . -
e, h
i
900
57-14-7
Dimethythydrazme
d
t
1,000
99-96-9
Dimctftyl-p-PhenytOTedianime
e
i
14/10,000
644-64-4
Omptfan
s
900/10,060
534-5^-1
Dwtrocresol.. — ._ _
10
10/10400
88-35-7
1A>0
>00/10400
1420-07-1
Dmotert) _ _ _ _ —
0
1
500/10400
117-94-0
Dioctyl Phthalate ....
a
5,900
10,000
78-34-2
Dioxathton„ _ _ ... — _
e
1
500
646-06-0
Dioxotane .. _. . .. _,
«.e
1
10.000
62-66-6
Diptacmone
e
1
10/10.000
152-16-0
Dtphosphoranwde. Octamettoyt- .
100
100
298-04-4
Oisiifoton _ ._
1
500
514-73-8
Dittnazamne Iodide. . . -
e
1
500/10,000
541-53-7
Oithebniret . . . . .
100
100/10400
316-42-7
Emetine. OihydrocN ride _ . _
e. h
1
1/10400
115-29-7
Endofulian . . . _ _.. . .
1
10/10,000
2778-04-3
EnHntrV-.-
e
1
500S10400
72-20-8
Fryfnn , r
1
900/10.000
106-89-8
Eptchlorohydrf. _. . . ...
d. 1
1,000
1,000
2104-64-5
EPN _ . _
e
1
100/10400
50-14-6
Ergocalcrferol ... _
c, e
1
1,000/10,000
379-79-3
Ergotamine Tartrate _. _ _ .
e
1
900/10400
1622-32-8
Ethanesulfonyl Chloride, 2-Chk)fO- . .
e
1
500
10140-87-1
Ethanol, 1-2-[>chto»o-, Aceute ._
e
1
1,000
563-12-2
Ethion - . _ . _
10
1,000
13194-48-4
Ethaprophos ... . _ _ „ _
e
1
1,000
538-07-8
Ethylt*s(2-ChoroetHyl)Amine . _
e, h
1
500
371-62-0
Ethylene Fluorohydnn
c e.
h
1
10
75-21-8
Ethylene Oxide _ . _
n
d.i
1
1.000
107-15-3
Ethylenediamine _ .
5.000
10,000
151-56-4
Ethyleneimine _
d
1
500
2235-25-6
Elhylmercunc Phosphate . - . -
a. e
1
10,000
542-90-5
Ethyllhiocyanate - - _
e
1
10,000
22224-92-6
Fenamiphos
o
1
10/10 000
122-14-5
Fenrtrothion . _
e
1
500
115-90-2
Fensullothion _ . _
e, h
1
500
4301-50-2
Fluenetil
e
1
100/10.000
7782-41-4
Fluorine
k
10
500
640-19-7
Fluoroacetamide
1
100
100/10400
144-49-0
Fluoroacetic Acid _
e
1
10/10.000
359-06-8
Fluo'oacetyi Chloride
c e
10
51-21-8
Fiuoiouracil
e
1
500/10 000
944-22-9
Fonolos
e
1
500
50-00-0
Formaldehyde
di
1.000 500
107-16-4
Formaldehyde Cyaaonydnn .
e h
1
1,000
23422-53-9
Fcmetanaie Hydrochloride
e h
t
500/10.000
2540-82-1
Formothion
e
1
100
17^02-57-7
Formparanate
e
1
100/10,000
?1546-3C-3
Foslhiilan
e
1
500
-------
13400 Federal Register / Vol. 52. No. 77 / Wednesday. April 22, 1987 / Rules and Regulations
Appendix A —The List of Extremely Hazardous Substances and their Threshold Planning Quantities—Continued
[Alphabetical Order]
CAS No.
Chemical name
Notes
Reportable
quantity*
(pounds)
Threshold
planning quantity
(pounds)
3878-19-1
Fubendazole
Q
1
100/10,000
110-00-9
Furan ..
100
500
13450-90-3
Gal Sum Trichloride
e
1
500/10,000
77-47-4
Hexachtorocydopentadiene
1
100
1335-87-1
Hexachtoronaphthalene
a,e
1
10.000
4835-11-4
Hexamethylenediamine, N.N'-Dbutyt- .
e
t
500
302-01-2
Hydrazine ..
d
1
1.000
74-90-8
Hydrocyanic Acid -
10
100
7647-01-0
Hydrogen Chloride (Gas Only)
«. 1
1
500
7664-39-3
Hydrogen Fluoride
100
100
7722-84-1
Hydrogen Peroxide (Cone >52%)
o, 1
1
1,000
7783-07-6
Hydrogen Selemde ...
e
1
10
7783-06-4
Hydrogen Sulfide .. .
,,,
l
100
500
123-31-9
Hydroqunone
I
1
500/10,000
53-86-1
Indomethaon
....... . ...
a.e
1
10.000
10025-97-6
Indium Tetrachloride
... .. ....... .. .
a, 6
1
10,000
13463-40-6
Iron, Pentacartonyt-
.
e
1
100
297-78-9
Isobenzan.
....
e
1
100/10.000
76-62-0
Isobvtyronrtrde -
e. h
1
1,000
102-36-3
Isocyanc And, 3,4-OcMoraphenyl Ester
0
1
500/10,000
465-73-6
Isodm
. .
1
100/10.000
55-91-4
Isofluorphate
c
100
100
4098-71-8
Isophorone Onsocyanate _ ..
b, e
1
100
108-23-6
Uopopyi CNorotormate
e
1
1,000
82 5-55-6
Isopropyi Formate ...
, „ ...
e
1
500
119-38-0
Isoproptymethytpyrazotyt Donethylcarbafnate
e
t
500
78-97-7
Lactonrtnle
...
6
1
1.000
21609-90-6
Leptophoa — _
e
1
500/10,000
541-25-3
Lewisite . ..
.. . ..
c, e,
1
10
58-89-9
Lindane _
d
1
1,000/10,000
7560-67-6
Lithium Hydride.
b. e
1
100
109-77-3
Malonoretrfle
1.000
500/10,000
12108-13-3
Manganese, Tricafborryi Methytcydopentactenyl
... N. ... ...
e, h
1
100
5t-75-2
MecMorethamne
..
c, e
1
10
950-10-7
Mephosfolan
... . .. ....
e
1
500
1600-27-7
Mercuric Acetate
e
1
500/10,000
7487-94-7
Mercuric CMonde
e
1
500/10,000
21908-63-2
Mercuric Oxide
e
1
500/10,000
108-67-6
Meeltytene
a. e
1
10,000
10476-95-6
Methacrotan Diacetate ...
e
1
1,000
760-93-0
MethaoryHc Anhydride
,
e
1
500
126-98-7
MathacrytonitiUe .
h
1
500
920-46-7
Methaaytoyl CMonde - .. - —
e
1
100
30674-60-7
Methacrytoyloxyethyl Isocyanate
e. h
1
100
10265-92-6
Methaimdoptos
. ~ ....
.. „ .... . ..
e
1
100/10.000
558-25-8
Methanesutfonyl Fluoride ....
e
1
1,000
B50-37-6
Methriaihon
,,
e
1
500/10.000
2032-65-7
Methtocarb.
..
10
500/10.000
16752-77-5
Methomyt
„
.
h
100
500/10,000
151-36-2
Methoxyetfiytmercuric Acetate..
. .. ... ....
e
1
500/10,000
80-63-7
Methyl 2-CNoroaciylate
..... .
e
1
500
74-63-9
Methyl Bromide
I
1.000
1.000
79-22-1
Methyl Chlorolormate
d.h
1,000
500
624-92-0
Methyl Disulfide
.
,1>M
e
1
100
60-34-4
Methyl Hydrazine
10
500
624-83-9
Methyl laocyanate
f
1
500
556-61-6
Methyl tsothocyanate
b,e
1
500
74-93-1
Methyl Mercaptan
..... ...
100
500
3735-23-7
Methyl Pfienfcapton
0
1
500
676-97-1
Methyl PtKMphonfc Ochloride
b, e
1
100
556 64 9
Methyl TNocyanate.
. .. ..
a
1
10.000
76-94-4
Methyl Vinyl Ketone
((M.„
e
1
10
502-39-6
Methyknercunc Dicynjwrtdo..
e
1
500/10.000
75-79-6
MethyttricMorosdane
. ....
e,h
1
500
1129-41-5
Metoicsto _..
e
1
100/10.000
7786-34-7
Mevinptios. _
- -
10
500
-------
Fedecal Relator / Vol. 52, Mo. 77 / Wednesday, April 22, 1987 / Rules and Regulations 19401
Appendix A.—The List of Extremely Hazardous Substances amo thejr Threshold Planning Quantttes—Continued
[AlplwtekeaKMarl
CAS No.
Chemical name
Notes
Reportable
quantity*
(pounds)
Threshold
planning quantty
(pounds)
315-18-4
Mexacarbate _
1.000
500/10,000
60-07-7
Mitomycin C .
d
1
500/10000
6923-22-4
Monocrotophos ... .... ...
e
1
10/10000
2763-96-4
Musamol .. .
a. h
1,000
10,000
505-60-2
Mustard Gas . _ . .. . _ _
e, h
1
500
7440-02-0
Nickel
a. d
1
10,000
13483-39-3
Nickel Cartwnyl_ .
d
1
1
54-11-5
Nicotine .....
c
100
TOO
65-30-5
Nicotine Sulfate ....
e
1
100/10000
7697-37-2
NitncAcid . _ . . ...
1,000
1.000
10102-43-9
Nitnc Oxide .... _ ...
c
10
too
98-95-3
Nitrobenzene ...... ... _
1
1,000
10,000
1122-60-7
Nitrocydohexane ... ... .....
e
1
soo
10102-44-0
Nitrogen Otonrte ....
to
too
62-75-9
Nitrosodimethytarrune ... _ .. ......
d. h
1
1,000
991-42-4
Noftoormide - ...
•
1
100/10,000
0
Organortiodtum Complex (PMN-82-147)
e
1
10/10.000
65-86-1
Orotic Acid . _ . .
a. e
1
10,900
20816-12-0
OsnMum Tetroxide- - . . . . .
a
1.000
10.000
690-60-4
Ouabain. _ . .....
c. •
1
too/10,000
23135-22-0
Oxamyl ...
•
1
100/10,000
76-71-7
Oxetane, 3,3-BtsPhenyt) Ester
e
1
500
50782-69-9
Phosphonothioic Acid Methyl-. S-(2-(Bis(1-Methylethyl)Amino)Elhy1 O-Ethyt Ester
e
1
100
2665-30-7
Phosphorothioic Acid. Methyl-. 0-(4-Nitrophenyl) O-Phenyl Ester
•
1
500
3254-63-5
Phosphoric Acid Dmelhyl 4-(Methylthio) Phenyl Ester _. . _. _ _
e
1
500
2587-90-8 ; Phosphorothioic Acid. O.O-Dimethyl-S-12-Methylthio) Ethyl Ester
c. e.
1
500
7723-14-0
Phosphorus _ ...
9
b. h
1
100
10025-87-3
Phosphorus Oxychloride . _
d
1,000
500
10026-13-8
Phosphorus Pentactilonde
b. e
1
500
1314-5&-3
Phosphorus Pentoxide _ _ ...
b. •
1
10
7719-12-2
Phosphorus Tnchloride _
1 000
1,000
64-80-0
Phyitoqumone
a. •
1
10,000
57-47-6
Physosugmine - - — - .
e
1
100M 0 000
57-64-7
Physosligmine, Salicylate (1 1) ... _
e
1
lOO'lOOOO
124-87-8
PicrotOJin ... ....
e
1
500/10,000
-------
13402 Federal Register / Vol. 52. No. 77 / Wednesday, April 22, 1987 / Rules and Regulations
Appendix A.—The List of Extremely Hazardous Substances and their Threshold Planning Quantities—Continued
[Alphabetical Order)
Reportable
Threshold
CAS No
Chemical name
Notes
quantity*
planning quantity
(pounds)
(pounds)
110-89-4
Pipendine
e
1
1.000
5281-13-0
Piprotal
e
1
100/10.000
23505-41-1
Pinmtf os-Ethyl .......
e
1
1.000
10025-65-7
Platlnous Chloride ....... . _
a, e
1
10.000
13454-96-1
Platinum Tetrachloride
a. e
1
10,000
10124-50-2
Potassium Arsenite ...
d
1.000
500/10.000
151-50-8
Potassium Cyamda _ ... _
b
10
100
506-61-8
Potassium Silver Cyanide . .....
b
1
500
2831-37-0
Promecarb
e. h
1
500/10.000
106-96-7
Propargyl Bromide
e
1
10
57-57-8
Propioiartone, Beta- -
e
1
500
107-12-0
Propionrtnle ....... ...
10
500
542-76-7
Proptonrtnte, 3-Chtoro- -
1,000
1.000
70-69-8
Proptophenone, 4-Amino- ...
«.9
e
1
100/10,000
109-61-5
Propyl Chkxoformate
1
500
1331-17-5
Propylene Glycol, Ally) Ether .
a, e
1
10.000
75-56-9
Propylene Oxide -
1
100
10.000
75-65-8
Propyteneunme
d
1
10.000
2275-18-6
Prolhoate - —
e
1
100/10,000
95-63-6
Pseudocumene
a e
1
10,000
129-00-0
Pyrene — _
c
5,000
1,000/10,000
140-76-1
Pyridine, 2-Methy»-5-Viny»-
e
1
500
504-24-6
Pyridne, 4-A/rtno-
h
1,000
500/10,000
1124-33-0
Pyridne,4-Nltro-, 1-Oxide . _...
e
1
500/10,000
53558-25-1
Pynminil._
e, h
1
100/10,000
10049-07-7
Rhodium Trichlonde _
a. e
1
10,000
14187-18-1
Saleomine
6
1
500/10,000
107-44-6
Sartn
e, h
1
10
7783-00-8
SeieriouaAod
10
1,000/10,000
7791-23-3
Seterman Oxychtorlde
e
1
500
563-41-7
^ II 1 m m a ^ J - It ^h I 1 I * ¦
MfnCMwW nyarocmonoe
e
1
1,000/10,000
3037-72-7
Sdane, (4-Aminobutyt)Diethoxymethy1- _
e
1
1,000
128-5&-3
Sodkim Anthraqunone-1-Sulfonate— . _
a, e
1
10.000
7831-89-2
Sodum Arsenate ...
d
1,000
1,000/10.000
7784-48-8
Sodium Arsenite ... -
d
1,000
500/10,000
26628-22-8
Sodium Adde (Na(N3))
b
1,000
500
124-65-2
Sodium Cacodytate
•
1
100/10,000
143-33-9
So<8um Cyanide (Na(CN» .
b
10
100
62-74-8
Sodium Ruoroacetate _
10
10/10,000
131-52-2
Sodium Pentachlorophenate
e
1
100/10,000
13410-01-0
Sodium Selenate _
e
1
100/10,000
10102-18-8
Socfium Setenrte _ .. .
h
100
100/10,000
10102-20-2
Snrtam Tnlhntn
e
1
500/10,000
900-95-6
Stannane, Acetoxytrtphenyt-
e. fl
1
500/10,000
57-24-9
Strychnne .. ..
c
10
100/10,000
60-41-0
Strychrane, Sulfate
e
1
100/10,000
3689-24-5
Sulfotep
100
500
3569-57-1
Sulfoxide, 3-Chloropropyl Octyt
e
1
500
7446-09-5
Sulfur Dioxide
e,
1
500
7783-60-0
Sulfur Tetrafluoride
e
1
100
7446-11-9
Sutfur Trioxide .._. _
b, e
1
100
7664-93-9
Sulfur Aod ,, . .
1,000
1,000
77-61-6
Tabun... „ . _ . ..
c,«.
1
10
13494-60-0
Teltunum .
n
e
1
500/10,000
7783-60-1
Tetlurtum Hexafluoride
a, k
1
100
107-49-3
TEPP
10
100
13071-79-0
TnrtjvfM
e, h
1
100
78-00-2
Tetraethytlead
c. d
10
100
597-64-8
TatraathyMn
c, e
1
100
75-74-1
Tetrametttyflead -
c, e, 1
1
100
509-14-8
TetranHromethane
10
500
1314-32-6
TTiaIScOxide..- .. .
a
100
10,000
10031-59-1
Thallium Sulfate _
h
100
100/10.000
6833-73-9
ThaJtous Carbonate.
c, h
100
100/10,000
7791-12-0
Thalloua Chloride
c, h
100
100/10.000
-------
Federal Register / Vol. 52, No. 77 / Wednesday, April 22, 1987 / Rules and Regulations 13403
Appendix A —The List of Extremely Hazardous Susstances and their Thresholo Planning Quantities—Continued
[Alphabetical Order]
CAS No
Reportable
Threshold
Chemical name
Notes
quantity*
planning quantity
(pounds)
(pounds)
2757-18-8
Thallous Malonate ... _
c. e,
t.
1
100/10,000
7446-18-6
Thallous Sulfate
n
100
100/10.000
2231-57-4
Thtocarbaade _
e
1
1.000/10,000
21564-17-0
Thiocyantc Acid, 2-(Benzothiazolytthio)Methyl Ester
a, e
1
10,000
39196-18-4
Thiofanox - .
100
100/10,000
640-15-3
Thiometon
a. e
1
10,000
297-97-2
Thionazin _ _ . _
100
500
106-98-5
Ttuophenol ... _ _
100
500
79-19^
Thiosemicarbazide
100
100/10.000
5344-62-1
Thiourea, (2-Chlorophenyl)- .. . . . . . _
100
100/10,000
614-78-8
Thiourea, (2-Methylphenyl .. .. ...
e
1
500/10,000
7550-45-0
Titanoxn Tetrachloride .
e
1
100
584-64-9
Toluene 2,4-Dusocyanate
100
500
91-08-7
Toluene 2.6-Ottsocyanate ._ .. _.
100
100
110-57-6
Trans-1,4-Oichlorotxrtene__ .......
e
1
500
1031-47-8
Triaiwphos _ _ . - - . .
e
1
500/10,000
24017-47-8
Triazofo# .. -
e
1
500
76-02-8
TrirhVjrofimty ftilnnrto
e
1
500
115-21-9
Tnchloroethylsilane ...._.
e, h
1
500
327-98-0
Tnchloronate ... ..
e, k
1
500
96-13-5
Trichlorophenytsilane . . .
e, h
1
500
52-66-6
Trtchlorophon... _ —
a
100
10.000
1556-25-4
Tnchloro(Chloromethyl)Silane ._. . ... ... ._.
e
1
100
27137-85-5
Trichlorochlorophenyl)Silane _. _
e
1
500
996-30-1
Tnethoxystlane . . ~
e
1
500
75-77-4
Tnmethylchlorosilane .......
e
1
1,000
824-11-3
Tnmethylolpropane Phosphite .„ . .... .. ._.
e, h
1
100/10,000
1066-45-1
Tnmethylttn Chlonde
e
1
500/10.000
639-58-7
Triphenyltin Chlonde _..
e
1
500/10,000
555-77-1
Trts(2-Chloroethyl) Amine .._ ...
e, h
1
100
2001-95-6
Valtnomyan„
c, e
1
1,000/10,000
1314-62-1
Vanadium Pentoxide - _ ..... _ —
1.000
100/10,000
108-05-4
Vinyl Acetate Monomer _ .. _.
d, 1
5,000
1,000
3048-64-4
Vinylnorbomene .
a, e
1
10,000
81-61-2
Warfarin
100
500/10,000
129-06-6
Warfarin Sodium .. ....
e, h
1
100/10,000
28347-13-9
Xyfytene Dlchlonde __ _. ... _ ......
e
1
100/10,000
58270-08-9
Zinc, Dlchtoro(4,4-Dimettiyl-5((((Methytamino) Caitoonyl)Oxy)lmino)Pentanenitnle)-,(T-4>-
e
t
100
100/10,000
1314-64-7
2nc Phosphide._ __ . —
b
500
'Only the statutory or final RQ « shown. For more information, see 40 CFR Table 302 4
Notes
a This chemical does not meet acute toxicity cntena. Its TPQ is set at 10,000 pounds.
b Tha material is a reactive solid. The TPQ does not default to 10,000 pounds for non-powder, non-molten, non-solution form,
c The calculated TPQ changed after technical review as described In the technical support document
d Indcates that the RQ is subject to change when the assessment of potential carcinogenicity and/or other toxicity is completed,
e Statutory reportable quantity for purposes of notification under SARA sect 304
------- |