United States
       Environmental Protection
 Office of Solid Waste
and Emergency Response
     (5104 A)
 Revised June 2007
  Emergency Isolation for Hazardous Material Fluid Transfer
 Systems - Applications and Limitations of Excess Flow Valves

The Environmental Protection Agency (EPA) is issuing this Alert as part of its ongoing
effort to protect human health and the environment by preventing chemical accidents.
We are striving to learn the causes and  contributing factors associated with chemical
accidents and to prevent their recurrence.  Major chemical accidents cannot be prevented
solely  through  regulatory requirements.  Rather, understanding the fundamental root
causes, widely disseminating the lessons  learned, and integrating these lessons learned
into safe operations are also required.  EPA publishes Alerts to increase awareness of
possible hazards.  It is important that facilities, State Emergency Response Commissions
(SERCs), Local Emergency Planning Committees (LEPCs), emergency responders,  and
others  review this information and consider whether  additional action is needed to
address the hazards.

While excess flow  valves  (EFV) are  in
extensive   service  and  have  prevented
numerous  pipe  or  hose  breaks  from
becoming  much more  serious incidents,
experience has shown that in some cases the
EFV did not perform as intended, usually
because  of misapplication.   Also, undue
reliance must not be placed on EFVs as the
sole  or  primary  protection  to  control
accidental chemical releases from  tanks  or

Excess flow  valves are protective devices
intended to prevent the uncontrolled release
of hazardous materials from  road,  rail and
marine transport vessels, stationary storage
vessels and distribution networks. EFVs are
designed to close when the flow rate through
them exceeds the expected range of normal
operation, for example due to a downstream
leak  or  valving  error that  provides   an
           unintended release path to the atmosphere.
           EFVs are intended to bring the release under
           control until the leaking element (e.g. hose
           or pipe) can be blocked in and positively
           isolated for corrective action.

           Industry incident experience, however, has
           shown that  under  certain  circumstances,
           EFVs can fail  to  provide  the  protection
           anticipated of them.  In fact, a number of
           significant releases  of hazardous materials
           have occurred from systems 'protected' by
           EFVs.    One  event investigated  by the
           National   Transportation   Safety   Board
           (NTSB) resulted in the deaths of three plant
           employees and the evacuation of 2,000
           nearby residents.   Concerned  that undue
           reliance might be placed  upon EFVs, the
           NTSB  recommended  in  its investigation
           report that EPA:

                 "Notify   all  facilities   that  are
                 required to submit risk management
                 plans    to   the    Environmental
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Emergency Isolation for Hazardous Material Fluid Transfer Systems -
Applications and Limitations of Excess Flow Valves
                             Revised June 2007
        Protection  Agency that tank  car
        excess flow valves cannot be relied
        upon to stop leaks that occur during
        tank  car  loading  and  unloading
        operations and that those companies
        that have included reliance on such
        valves  in  their risk  management
        plans  should  instead  identify  and
        implement other measures that  will
        stop  the  uncontrolled  release  of
        product  in  the event  of a transfer
        line failure during tank  car loading
        or unloading."

EPA  shares  the   NTSB's concerns  and
additionally recognizes that the use of EFVs
extends  beyond  tank  cars  and includes
loading and unloading operations associated
with tank trucks, marine barges, stationary
tankage  and piping  distribution networks.
This Hazard Alert is intended  to provide an
understanding of (1) how EFVs function, (2)
circumstances that can lead to their failure to
function as intended,  (3) important design
and  operational factors  for enhancing the
reliability of EFVs, and (4) alternate means
available for stopping uncontrolled releases.

Facilities  should  be  aware  of, and  give
proper  regard  to,  industry  best  practice
guidance  and regulatory requirements for
the use of EFVs.

When they are properly designed, installed,
and  maintained,  EFVs play  an important
role  in  comprehensive  accidental  release
prevention systems. It is not EPA's intent to
dissuade the regulated community from the
use  of EFVs  but,  rather,  to  provide
precautionary  guidance regarding their use
as a sole means of protection.


Provision should be included for blocking in
(isolating) hazardous material transfer lines
in addition to the protection provided by
EFVs. As in the following incidents, failure
to understand the limitations  of EFVs has
been a  contributing factor  in a number of
significant incidents where flow  restriction
prevented EFV closure.

8/2002  in Missouri -  A chlorine railcar
transfer  hose  ruptured,  releasing  48,000
pounds  of chlorine.  Hundreds of residents
were evacuated or  sheltered-in-place,  and
sixty-three local residents sought  medical
evaluation;  three  were  admitted   to  the
hospital.  The chlorine  also damaged  tree
leaves and  vegetation around the  facility.
The CSB determined  that an  excess  flow
valve internal to the chlorine railcar did not
close,  contributing to the severity of the
event.  As a result of such chlorine releases,
the CSB has issued a recommendation to the
Department  of Transportation  (DOT) to
expand   the   scope  of  DOT  regulatory
coverage  to   include   chlorine   railcar
unloading   operations   and   ensure   the
regulations  specifically  require  remotely
operated emergency isolation  devices  that
will quickly isolate a leak  in any of the
flexible hoses (or  piping components) used
to unload a chlorine railcar.

7/2001 in Michigan - A methyl  mercaptan
release occurred when a pipe attached  to a
fitting  on the unloading line of a railroad
tank  car fractured  and  separated.    Fire
damage  to  cargo transfer  hoses  on an
adjacent tank car also resulted in  the release
of chlorine gas. Neither of  the  two EFVs
closed to control  the  release.  Three plant
employees  were  killed  in  the resulting
explosion  and  several   employees were
injured.      Approximately   2,000  local
residents were evacuated from their homes
for 10 hours.  Failure of the  EFVs to close
contributed to the severity of the incident.
The NTSB  determined  that  the   facility
placed undue reliance on the tank car EFV
to close in the event of a  leak from the
transfer line.

4/1998   in  Iowa  -  A propane   release
occurred when a vehicle struck and severed
unprotected,  aboveground liquid  and vapor
lines serving  an   18,000-gallon  propane
storage   tank.   The  lines fed  vaporizers,
which  fueled heaters located in  barns  and
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Emergency Isolation for Hazardous Material Fluid Transfer Systems
Applications and Limitations of Excess Flow Valves
                            Revised June 2007
other farm structures. The liquid line, which
was  sharply reduced in pipe diameter, was
completely severed where it connected to a
manual shut-off valve  directly  beneath the
tank.    The release  ignited and the  tank
subsequently  exploded,  killing  two  fire
fighters and injuring seven other emergency
personnel.  A subsequent CSB investigation
determined  that the  flow  capacity of the
liquid  outlet piping system downstream of
the EFV was insufficient to allow the EFV
to close.

9/1999  in  North  Carolina - More  than
35,000  gallons  of propane were released
when  the   discharge  hose  on  an  LPG
transport  truck  separated  from  its  hose
coupling at the delivery end of the hose, and
none  of the safety systems on either the
truck or the receipt tank worked as intended
to stop the  release.  The  DOT determined
that  emergency  systems  such  as  EFVs do
not always function properly when a pump
is used to unload the protected vessel.  If a
release occurs downstream of the pump and
the EFV activation point is greater than the
pump capacity, the pump will function as a
regulator limiting  the  flow to below that
required to close the EFV.

Two common themes in these accidents are
that  flow  restrictions  prevented  the  flow
through an EFV from exceeding the shut-off
flow rate,  and emergency isolation block
valves  were  not  activated.  A  literature
review  revealed  a number  of  additional
incidents where the rates of discharge from
releases were insufficient to close the EFVs.

The literature also  shows, cases such as the
one below, where an EFV was not installed
but would have been beneficial:
children. The investigation report concluded
that the release was attributed to the plastic
feed line  being damaged by heat  from a
faulty splicing in a buried electrical service
cable located close to the natural gas line.
The natural gas feeder line was not equipped
with an excess flow valve.   Among the
findings it  was  concluded that "Had  an
excess flow valve been  installed in  the gas
line to the residence, the valve would have
closed  after  the  hole  in  the  pipeline
developed, and the explosion likely would
not have occurred."

Understanding the


Proper use of EFVs requires an
understanding of their capabilities and their

The  National  Fire Protection  Association
(NFPA)  defines  an  EFV  as a  "valve
designed to  close when  the liquid or vapor
passing through it exceeds a prescribed flow
rate" (NFPA 58). EFVs  are most commonly
used on the  liquid and vapor connections of
transport containers (e.g., rail cars and tank
trucks)  and on some   stationary tankage.
EFVs are often installed inside of the vessel
so that protection is provided  even if the
piping external  to the  vessel is damaged.
EFVs  are  also very commonly used in
natural  gas  distribution  lines  serving end-
users such  as  residential and  commercial
consumers. Figure 1 shows an EFV installed
in the  liquid unloading  line  on a chlorine
railcar.  In-line EFVs can also be installed in
external  piping systems  (e.g.,  to  protect
individual distribution lines).
7/1998 in Virginia - A natural gas release
occurred  in  the  underground  feed  line
serving  a newly constructed  residence  in
which  the occupants  had  moved-in  just
hours before.  The leaking gas entered the
basement where it found an ignition source
and exploded killing one of the new owners
and injuring the other parent and their two
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Emergency Isolation for Hazardous Material Fluid Transfer Systems -
Applications and Limitations of Excess Flow Valves
                            Revised June 2007
                                       from Car
                                                 against the seat, stopping the flow.  This
                                      Liquid Chlorine design permits the valve to be installed in
  Figure 1. EFV in Chlorine Railcar Liquid
               Outlet Line
EFVs are used with a variety of hazardous
chemicals,  of  which  chlorine,  liquefied
petroleum  gases (LPG), natural gas  and
anhydrous ammonia  are among the  most
common.   Consequently,    these    four
chemicals  are  used  as examples in  this
Hazard Alert.  Guidance for the application
of EFVs with regard to these four chemicals
is issued, respectively, by  the  Chlorine
Institute (CI), NFPA, and  the Compressed
Gas   Association  (CGA).     Regulatory
requirements for the usage  of  EFVs are
imposed  by  various  state  and  federal
agencies, including the  Occupational Safety
and Health Administration  (OSF£A) and the

Figures  2 and  3  illustrate two common
designs for EFVs.  The valve in Figure 2,
designed for use on a  chlorine rail car or
tank truck, contains  a  ball that is driven
upwards against a seat to stop the flow when
it exceeds the shut-off rate.  The design of
this type of EFV requires that  it be mounted
in the  vertical  orientation shown  in the
figure.  The valve shown in Figure 3 is used
in LPG and anhydrous ammonia service. A
spring normally holds the plug in the  open
position shown.  When the  flow through the
valve is high enough,  the plug is forced
                                                 any orientation.   It should be  noted that
                                                 EFVs permit flow  in both directions,  but
                                                 only    stop   flow    in    one   direction.
                                                 Consequently,   flow  direction   must  be
                                                 correctly considered in the installation of the
                                                 EFV.   In  both  figures,  the protected flow
                                                 direction  would be upwards  through  the
                                                       Normal Flow Position
                                                                         Flow Ctiecked Position
        Flow Dirictorv
Figure 2. EFV for Chlorine Service
Figure 3. EFV for Ammonia or LPG Services

The   potential   for    flow   restrictions
preventing the closure of the EFV is well
recognized by organizations  issuing good
practice guidance for the use of EFVs.  For
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Emergency Isolation for Hazardous Material Fluid Transfer Systems
Applications and Limitations of Excess Flow Valves
                            Revised June 2007
example, the CI  cautions that the EFV  is
principally a protection against an event that
damages the manual valve on the transport
container during transit and not a protection
against  damage  to  connected  loading or
unloading system piping.  The CI notes that
the EFV "may close if a catastrophic  leak
involving a broken connection occurs but it
is not designed to act as an emergency shut-
off device  during transfer."  CI guidance
does  not specify the  use  of  EFVs  on
stationary tankage, but recognizes that some
users choose to use EFVs in such a manner.
CI pamphlets addressing EFVs are identified
in the Information Resources section, below.

The installation  of  EFVs  in  stationary
tankage is  commonly used with LPG and
anhydrous ammonia.  NFPA, in its Liquefied
Petroleum Gas Code, specifies that,  where
EFVs are required, the "connections, or line,
leading  to or from  any individual opening
shall have  greater flow capacity than the
rated  flow  of  the   excess-flow  valve
protecting the opening."  CGA, in its Safety
Requirements for the Storage  and Handling
of  Anhydrous  Ammonia,  specifies  that
"piping, including valves and fittings in the
same flow path as the  excess flow  valve,
shall have a greater capacity than the rated
flow of the excess flow valve."

The National  Propane  Gas Association
(NPGA) notes a number of conditions which
could result in the failure of an  EFV to

•   Piping system restrictions such as pipe
    length, branches, reduction in pipe size,
    and  partially closed  shut-off  valve,
    could limit the flow  rate through the

•   The   size    of   break  or  damage
    downstream of the EFV is not  large
    enough to  allow a flow sufficient to
    close the valve.
•   The  system pressure  upstream of the
    EFV is not high  enough to produce a
    closing flow rate.

•   Foreign matter such as welding slag or a
    build up of process contaminants lodged
    in the EFV can prevent its closing.

•   The  piping break or  damage occurs
    upstream of an in-line EFV.

•   The  flow  through the EFV  is in the
    wrong direction.

•   The  EFV  has been  damaged,  or is
    otherwise not operable.

Recognizing the limitations inherent in the
design and application of EFVs, NPGA, CI,
NFPA, and CGA all recommend or require
the  use  of  some  secondary  means  of
preventing  uncontrolled releases in certain
high risk situations.

Controlling the Hazard

Careful analysis  is  required in order to
determine how much reliance can be placed
upon EFVs  ability to bring the rate of
release under control, and to identify any
necessary  and  appropriate  supplemental
controls for accidental releases.

System Design and Installation

System design  and installation issues must
be considered in evaluating the degree of
reliance  to  be   placed  on   an  EFV.
Considerations should include:

•   For the EFV to close, the failure in the
    downstream  piping   must  result  in
    enough  flow   to exceed  the   EFV
    activation   point.    Analyze  credible,
    catastrophic failures  at likely release
    points,   such  as  flexible  hoses  in
    unloading  systems, to determine if the
    flow   resistance   in  the  piping  both
    upstream and  downstream of the EFV
    might prevent the EFV from closing.
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Emergency Isolation for Hazardous Material Fluid Transfer Systems
Applications and Limitations of Excess Flow Valves
                             Revised June 2007
•   The  characteristics  of the  hazardous
    material have to be considered.  Release
    rate calculations must address the effect
    on flow rate of two-phase flow that will
    result upstream  of  the  release point
    when liquefied compressed  gases  flash
    to vapor as system pressure is released.

•   The  pressure  in  the  vessel  must  be
    adequate to produce the flow necessary
    to seat the EFV.  Consider the effects of
    low   vapor   pressure  liquids  and
    minimum credible winter temperatures.

•   The  type of  EFV specified must  be
    appropriate to the intended service, and
    any   necessary   constraints  on   the
    physical orientation of the valve must be

•   The  system  must be  installed in  strict
    accordance to design specifications.

•   The flow capacity of the EFV must be
    great  enough  to  avoid nuisance  flow
    stoppages caused by  normal variations
    in process flow rates,  but not so  high as
    to negate its protective function.

•   A piping system network with  smaller
    branch lines coming  off the main line
    will  need  separate   EFVs  to  control
    releases in these branch lines.

•   A  release that is not large  enough to
    activate  the  EFV  can still be  large
    enough to lead to serious consequences
    and  thus require  alternative   control

Operation and Maintenance Practices

Like any safety  device,  an EFV must  be
properly maintained  and  operated in order
for it  to provide its intended  protective
function.  There should be:

•   An    appropriate   inspection,   testing
    (including  verification of   flow  rate
    necessary to  activate the  EFV),  and
    preventive maintenance program for the
    EFV based  upon  past experience, the
    characteristics of  the process stream,
    and    standard    EFV    maintenance
    guidelines (e.g., CI Pamphlet 042, which
    may  provide  guidance  to  facilities
    handling other chemicals).

•   Operating procedures and  training to
    address the operation of the EFV and all
    supplemental controls.

•   Controls to manage system changes that
    might    otherwise   compromise   the
    function  of  the EFV.  (Management of

Determining the Need for Additional

Facilities,  absent any  applicable  industry
guidance or regulatory requirements, should
take a risk-based approach in evaluating the
need to supplement  EFVs  in controlling
accidental    releases.       Considerations,
addressing both the consequences and the
likelihood  of a  catastrophic release, would

•   The hazardous nature of the chemical
    involved, such as toxicity, flammability,
    and hazard to the environment.

•   The size  of potential releases, depending
    on  the  potential  for significant back-
    flow to  the  point  of release, size of
    inventory, and flow rates involved.

•   The likelihood of a release, depending
    on frequency of loading  and unloading
    operations and type of equipment used.
    A system containing flexible hoses or
    articulated (swivel-joint) piping may be
    more prone  to a release  than a system
    containing more robust rigid piping.

•   Local conditions such as the possibility
    of flooding,  mud or rock slides, wash-
    outs, sink holes and subsidence or other
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Emergency Isolation for Hazardous Material Fluid Transfer Systems
Applications and Limitations of Excess Flow Valves
                             Revised June 2007
    earth   movement  situations  warrant
    particular   attention   for   stationary

•   The  severity of  a credible  release on
    surrounding    populations,   workers,
    facilities, and the  environment.

Alternative/Additional Means for
Controlling Releases

Industry    guidance    and    regulatory
requirements  increasingly   recognize   the
prudence  of providing alternative means of
stopping  accidental   releases   in  certain
situations, either in place of or in addition to
EFVs.   Examples of approaches  used  in
industry include:

•   Remotely   isolating  leaking  transfer
    systems, with  particular emphasis on
    flexible hoses,  by bolting fail-safe  (air-
    to-open)  actuated   valves  on   the
    discharge side of railcar manual valves.

•   Shut-off protection  by quick  closing
    valves  that  can  be  controlled  from
    locations that would be accessible even
    in the event  of a release.

•   Emergency  shutoff valves equipped for
    remote  manual closure and automatic
    shutoff using thermal (fire)  actuation or
    chemical detection.  The  valve may be
    internal to the tank, in lieu of an EFV, or
    it may be installed external to the  tank
    as close as  practical to the tank  outlet,
    provided  there  is  an  internal  EFV.
    Emergency  shut-off systems should be
    thoroughly tested on a regular schedule
    to ensure  that they  will  operate  as
    intended when needed.

•   Commercially  available hoses  with a
    self closing  device at each end that will
    shut off flow  entering the  hose from
    either  direction  if the  hose is  pulled
    apart  or sheared  may be  considered as
    an  additional  measure  of  protection.
    Such  devices  will protect against hose
    failure, but not against leaks that occur
    upstream or down-stream of the hose.

The technologies,  systems,  and practices
cited above are meant only to be illustrative;
they do  not constitute a definitive list  of
options,  and  are not  meant  to establish
'requirements'     for     any     particular
application.  Additional details are provided
in the  references at the end  of this Alert.
References to regulatory requirements and
industry  best practices  are not intended  as
interpretations and users should consult the
referenced   documents   to     determine
applicability   to   their   own   particular

If it is determined that manual ("hand-on")
intervention   is   the   most   appropriate
approach to  responding to releases, a critical
analysis  should be made of issues such as:
the number  and location of isolation valves
relative  to  likely  points  of  release; the
properties of the released chemical and the
correspondingly required personal protective
equipment   (PPE);   personnel    staffing,
location   and  response  times;   and  the
adequacy of training provided to personnel
responding to a release.

What Needs To Be Done

EPA urges users of EFVs to evaluate their
applications to verify the operability of in-
place  controls and  to determine whether
additional   controls   are  warranted   to
minimize the  risk of release  of hazardous
materials. Industry experience  indicates that
sole reliance on EFVs to control accidental
releases  may not always be sufficient and
needs  to be  substantiated  by a thorough
engineering  and risk  evaluation.  In  most
cases   where  supplemental  controls  were
available  and clearly identified,  they  were
successfully  applied. Where  this has not
been the case, appropriate revisions should
be  made to  Risk  Management Program
elements  such  as  operating  procedures,
training,  and emergency response  plans.
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Emergency Isolation for Hazardous Material Fluid Transfer Systems
Applications and Limitations of Excess Flow Valves
                           Revised June 2007

Millions of EFVs are in service and each
year many properly-sized and correctly
installed EFVs operate as intended to greatly
mitigate the consequences of hazardous
material releases. Incident investigations
show that when the EFV was in place but
did not function as intended, it was usually
because either the valve was not correctly
sized and flow-rated or line restrictions or
low inlet pressure prevented sufficient flow
needed for valve closure. Mechanical
malfunction of the EFV is very rarely shown
to be a contributing factor.  Release rates
that are less than the EFV activation rate
represent a very serious situation. Natural
gas or city gas leaks downstream of the
regulator or meter fall into this category.
Alternate or additional means of release
prevention/mitigation should be installed for
high-risk situations and situations where
EFVs may not be effective.

Information Resources

References with information about the use
of EFVs and other methods for controlling
hazardous   releases  are  listed   below.
Regulations  potentially applicable  to EFVs
and  codes  and  standards  that  may  be
relevant are also included.

Statutes and Regulations

•  Clean  Air Act  Section  112(r)(l)  -
   General Duty
•  EPA's Risk Management Program  Rule
    [40 CFR 68]
•  OSF£A  Process  Safety  Management
   Standard [29 CFR 1910.119]
•  OSHA Standards:  29  CFR  1910.110,
   Storage  And  Handling Of Liquefied
   Petroleum Gases;  29  CFR  1910.111,
   Storage  and  Handling  of Anhydrous
   Ammonia; and  29   CFR   1926.153,
   Liquefied Petroleum Gas (LP-Gas)
•  DOT regulations [49 CFR 171-180]
Codes and Standards

•   The Chlorine Institute, Inc.: Pamphlet
    001,  Chlorine Manual; Pamphlet  042,
    Maintenance Instructions for  Chlorine
    Institute  Standard Excess Flow Valves;
    Pamphlet 049, Recommended Practice
   for Handling Bulk Highway Transports;
    Pamphlet  057,  Emergency  Shut-Off
    Systems for Bulk Transfer of Chlorine;
    Pamphlet 066, Recommended Practice
   for Handling Chlorine Tank Cars

•   The Compressed Gas Association,  Inc.:
    ANSI K61.1  (CGA G-2.1),  American
    National Standard Safety Requirements
   for  the   Storage  and  Handling  of
    Anhydrous Ammonia

•   The    National    Fire    Protection
    Association,  Inc.: NFPA 58, Liquefied
    Petroleum Gas Code

•   Freeman, R. A., and D.A. Shaw, "Sizing
    Excess Flow Valves," Plant/Operations
    Progress, Vol. 7, No. 3, July 1988

•   UK Health and Safety Executive:
    "Emergency Isolation,"
    http: //www .hse.gov .uk/hid/land/comah/1

Accident Histories

•   National Transportation Safety Board,
    Hazardous Materials Accident Report
    NTSB/HZM-02/01, "Hazardous
    Materials Release From Railroad Tank
    Car With Subsequent Fire at Riverview,
    Michigan, July 14,2001"

•   National  Transportation Safety Board,
    Pipeline  Accident Report, NTSB/PAR-
    01/01, "Natural Gas Explosion and Fire
    in South  Riding, Virginia July 7, 1998"

•   U.S.   Chemical   Safety  and  Hazard
    Investigation    Board,    Investigation
    Report No.   98-0071-1-1A,  "Propane
    Tank Explosion (2 Deaths, 7 Injuries),
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Emergency Isolation for Hazardous Material Fluid Transfer Systems
Applications and Limitations of Excess Flow Valves
                      Revised June 2007
   Herrig  Brothers Feather  Creek  Farm,
   Albert City, Iowa, April 9, 1998."

   U.S.  Chemical Safety   and  Hazard
   Investigation  Board:     Investigation
   Report No.  2002-04-I-MO,  "Chlorine
   Release     (66    Sought    Medical
   Evaluation),  DPC  Enterprises,  L.P.,
   Festus, Missouri, August 14, 2002."

   U.S.  Chemical Safety   and  Hazard
   Investigation Board:   Safety  Advisory
No.  2002-01-SA,  "Chlorine Transfer
Hose Failure"

U.S.   Chemical  Safety   and  Hazard
Investigation Board:   Safety  Bulletin
No.    2005-06-I-LA,    "Emergency
Shutdown   Systems   for   Chlorine
                         For More Information:

     Call the Superfund, TRI, EPCRA, Risk Management Program,
                         and Oil Information Center
                      (800) 424-9346 or (703) 412-9810
                   TDD (800) 553-7672 or (703) 412-3323
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                            Page 9